Action Item: Recommendations of the Great Lakes Commission Implementation of the Great Lakes Restoration Initiative

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Introduction

President Obama has proposed a multi-year Great Lakes Restoration Initiative designed to address the most pressing environmental issues facing the Great Lakes. The Initiative will be led by the U.S. Environmental Protection Agency (U.S. EPA) and coordinated with other federal agencies through the Interagency Task Force.

Successful implementation of the Initiative will depend on close coordination with many stakeholders, especially state agencies. The Initiative builds on the framework and recommendations established in 2005 in the Great Lakes Regional Collaboration Strategy to Restore and Protect the Great Lakes (GLRC). Through the leadership of the Great Lakes governors, states were key to the development of the GLRC and since then have consistently called for increased federal support for its implementation.

In July 2009 U.S. EPA released a draft Great Lakes Multi-Year Restoration Action Plan Outline to guide implementation of the Great Lakes Restoration Initiative (GLRI) over a five-year timeframe (FY 2010-2014). The document identified five focus areas for the Initiative, including toxic substances and Areas of Concern; invasive species; near-shore health and nonpoint source pollution; habitat and wildlife protection and restoration; and accountability, monitoring, evaluation, communication and partnerships. The President’s FY 2010 budget requests $475 million for the GLRI, which will be distributed by U.S. EPA through both its own programs and those of other federal agencies. A substantial portion of the funding will be administered to nonfederal partners via grants, cooperative agreements and contracts.

In July and August U.S. EPA convened a series of meetings across the Great Lakes basin to review the GLRI and secure feedback on the draft Action Plan Outline. Separate meetings were held in each state for the public and state agencies, and regional conference calls were held for Great Lakes tribes and cities. The Great Lakes Commission assisted U.S. EPA in convening the meetings and summarizing comments submitted.

The meetings demonstrated the high level of enthusiasm and support among states for the proposed Initiative. At the meetings, states were able to engage in detailed discussions with EPA as planning for GLRI implementation unfolds. States presented many of their restoration priorities and identified many of the challenges and opportunities they anticipate. The meetings were well attended by senior managers from multiple agencies in each state. States submitted detailed written comments outlining their priorities and recommendations. The vast majority of comments from the states and other stakeholders were supportive and constructive, reflecting the unprecedented degree of enthusiasm over the prospect of substantially advancing the restoration and protection of the Great Lakes.

Great Lakes Restoration and the Role of the States

The eight Great Lakes states have a unique and leading role to play in implementation of the GLRI. The Great Lakes governors began the process of developing the regional restoration plan by articulating nine priorities around which to focus such a program. The governors, together with the Great Lakes Commission and many other partners, have advocated persistently with Congress and the Executive Branch for leadership in developing and funding a Great Lakes restoration program. The framework for this program was developed under the Great Lakes Regional Collaboration, a year-long planning process under which the states, federal agencies, cities, tribes and nongovernmental organizations united to craft a consensus-based strategy for restoring the Great Lakes. The Great Lakes Regional Collaboration was guided by the governors’ priorities and the states were key leaders – and prime contributors – to the final 2005 Great Lakes Regional Collaboration Strategy to Restore and Protect the Great Lakes. As such, the states are key “owners” of the restoration strategy.

Since release of the strategy the states have worked to implement recommendations and address the serious environmental problems facing the Great Lakes. Many of the states have developed state-specific restoration plans designed to “step down” the regional restoration plan to address specific problems within their jurisdiction. Despite severe fiscal constraints facing the region, substantial investments are being made to restore and protect the Great Lakes. Finally, and perhaps most significant, the states united in establishing an historic regional Compact to ensure that the quantity and quality of Great Lakes water are managed for the well-being of future generations.

The Great Lakes states will be on the “front line” in implementing the GLRI. Cooperation and close coordination between EPA and other federal agencies and states is paramount. The states understand the priorities of local governments and stakeholders and are best positioned to coordinated local activities. More than any other level of government, the states have the technical understanding of the problems facing the lakes; the regulatory and programmatic tools to address them; and the skilled and committed staff needed to carry out the restoration effort. Finally, the states – through their citizens and their political leaders – understand the profound role the lakes play in driving their economies and their way of life and, thus, the imperative to restore and protect them for future generations.

Recommendations for Implementing the Great Lakes Restoration Initiative

The Great Lakes Commission offers the following recommendations on behalf of its member states for implementing the GLRI and maximizing its effectiveness. These recommendations represent a consensus-based synthesis of feedback provided to EPA by the eight Great Lakes states this summer and reflect additional views arising during ongoing preparation.

As stewards of the lakes and long-time advocates for their restoration and protection, the states bear substantial responsibility for ensuring that restoration funding is spent wisely and achieves the desired outcomes. The states, together with their federal, local, tribal, and nongovernmental partners, share the accountability for the success of this substantial investment in the region.

1. Recognize the unique role of the states as key partners in implementing the GLRI
   
   It is essential that EPA and its partner federal agencies recognize that states have specific priorities for Great Lakes restoration and protection, including priorities articulated in state-specific restoration plans. The states are already heavily engaged in implementing existing plans developed through state wildlife action plans, the North American Wetlands Conservation Act, the Great Lakes Fishery Commission, Remedial Action Plans for Areas of Concern, and others. The states are in the best position to identify specific places that should be afforded the highest priority for implementation. States are in the best position to coordinate activities of local governments and stakeholders within their borders.


2. Provide a mechanism for states to participate in establishing priorities and managing the GLRI
   
   The states should be involved in defining annual priorities, establishing goals and objectives in the multi-year action plan, reviewing results of reporting and monitoring, recommending changes and adapting to evolving needs as the GLRI moves forward. Focused consultation, building on this summer’s series of meetings, is imperative and should be instituted on an ongoing basis to assess progress being made under the GLRI, address obstacles and adopt new approaches. This should occur both at a high level with senior agency managers to guide the overall collaborative effort and at a topic-specific level to manage restoration efforts in key areas (e.g., habitat restoration). EPA and its partner federal agencies should work with the states to determine if exiting institutional structures can be adapted for this purpose, or if new or revised approaches are needed. At a minimum, the existing structure under EPA’s leadership with the Interagency Task Force s should be adapted to better engage the states and provide mechanisms for interaction with other stakeholders.


3. Establish large, “bundled” approaches to administering grants under the GLRI
   
   Consolidating multiple projects into large, “bundled” grants will enable the states to more efficiently administer the GLRI program within their jurisdiction. States urge EPA and its federal partners to develop mechanisms to bundle large grants that cut across the five focus areas of the GLRI. This approach will minimize administrative work, allow states to focus on their highest priorities, and ensure visible results. This will also improve transparency and accountability while coordinating GLRI efforts with state restoration plans and topic-specific plans. This will also enable the states to package projects for critical watersheds and geographic areas to maximize environmental outcomes.


4. Increase coordination among federal agencies to consolidate funding and reduce the administrative burden on grantees
   
   Differing application, reporting and administrative requirements among federal agency grant programs will pose a heavy administrative burden on states and other entities implementing restoration efforts under the GLRI. To the maximum extent possible, the federal “family” should coordinate, pool resources and consolidate duplicative funding opportunities. Federal agencies are urged to coordinate the timing of calls for proposals, and develop consistent approaches for applying for and administering grants across various federal agencies and programs.


5. Provide funds for administrative support
   
   States across the nation are experiencing unprecedented fiscal constraints that have resulted in reduced staffing and other challenges. Thus, to ensure adequate state engagement in and administration of restoration efforts under the GLRI, federal agencies should allow reasonable administrative costs to be included in funding proposals.


6. Establish and support a coordinated, efficient, streamlined reporting and accounting system
   
   States recognize and embrace the importance of accountability and transparency, but recognize that there could be excessive administrative costs to execute these responsibilities. EPA and its partner federal agencies should work with the states to develop and implement an accountability system that is based on transparency, common sense and minimization of transaction costs.
   
   Reporting and accountability should be recognized as an essential element of all of the focus areas, and not separate requirement. A common, region-wide reporting system will reduce transaction costs for grant recipients and improve transparency, accountability and adaptive management. Providing funding to states and other grantees to assist with project tracking, coordination, public outreach, and progress reporting is essential for ensuring transparency, collecting feedback to effectively manage the GLRI over time, and building support for additional funding. Reporting requirements should be simplified to collect necessary information and to track progress without detracting from efficient project implementation. Results should be reported in a manner that is transparent and that allows for sharing of data with the public.


7. Utilize existing plans and strategies to guide restoration efforts under the GLRI
   
   Substantial effort has been invested in developing plans, including both statewide restoration plans as well as plans focused on specific geographic areas or topics. As much as possible, these plans should be utilized to guide restoration efforts. EPA and other federal agencies should avoid spending GLRI funds on new plans or studies, except where these are needed to accurately target restoration activities, provide technical guidance, engineering specifications or similar information critical to the effective allocation of funding.


8. Use the states to coordinate projects and avoid duplication of efforts
   
   EPA and other federal agencies should develop a management mechanism to avoid duplication of efforts and support for projects that may conflict or compete with state priorities. With an unprecedented level of funding being administered by up to 16 federal agencies – and often through multiple programs in each agency – there is significant risk of duplication and competition among different levels of government and with nongovernmental entities. It is imperative that all parties collaborate on restoration efforts within watersheds and the states are best positioned to facilitate this coordination.


9. Reduce or eliminate match requirements
   
   A key challenge for the Great Lakes states, as well as other partners, is providing matching funds for federal restoration programs. This is an especially severe challenge during these times of fiscal crisis, budget deficits, staff reductions and hiring freezes. Awarding grants to projects that can produce the highest level of nonfederal funding could have the effect of favoring areas of greater wealth rather than areas with the most significant environmental needs, benefits or potential returns. Federal agencies should exercise maximum flexibility in reducing or eliminating requirements for nonfederal matching funds, counting in-kind or other contributions, and helping organizations identify resources and approaches to meet match requirements.


10. Support additional research to inform and guide restoration efforts
    
    The GLRI should support research that can ensure more effective restoration actions over time. While restoration efforts should be initiated immediately with a bias toward on-the-ground actions, additional research is important to prepare for implementation in future years, and will lead to more cost-effective restoration and sustained productivity.