Annex 1
Paul Horvatin – U.S. EPA
Great Lakes National Program
Office
General Points
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No formal EPA Position at this time.
Any changes would require extensive
binational consultation.
Recent analysis of Annex 1.
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BEC discussion held.
Updating Annex 1 was a lower priority than
implementing other aspects of Agreement.
Numbers only meaningful in a context – i.e.
methods, avg. times, extent of monitoring,
enforcement, placement in permits.
Observations for
Consideration and Reaction
Little impact on domestic programs.
 Outdated scientific rationale.
 New programs adopted (by both
countries) have superceded Annex 1objs.
 New Annex 1 could be relevant and
useful. Potential uses:
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TMDLs, SOLEC Indicators and Reporting,
Progress on GLBTS, and ongoing monitoring.
Keeping Annex 1 Current
Updating is immense effort, new
science quickly makes out-of-date.
 Could make Annex action/process
oriented. Require binational
discussions on levels of toxic
substances in Great Lakes.
 Not objectives, but “Action Levels”.
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Action Level Options
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Continually updated: adopt by reference most
stringent standards of Fed., State, or Prov.
agency, incl. emerging issues.
Expand to other media-based objectives
(sediment, tissue, etc.)
Would not force a single “right” objective.
Keep existing specific objectives, no
“backsliding”.
If exceeded, triggers binational consultation.
Action could be taken action via GLWQA-BEC,
GLBTS, POPs, CEC forum(s) and result in
additional monitoring activities.
Existing U.S. Programs
Regulatory program and compliance
monitoring, enforcement is real.
 GLI will be foundation for EPA position
on Annex 1:
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Required by Law.
Years of rule-making, court challenges.
Incredible investment.
Suggestions
Consultation on “Action Level” approach.
 Compile relative standards for Annex 1
process every (?) years, based on current
standards and monitoring data.
 Report on activities, accountable to public,
based on current science.
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