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A. 33: F) No. (see response to Question B which discusses the difference between 

 EPA-approved State water quality standards and Federally promulgated water qual- 

 ity standards) Federal agencies cannot selectively refuse to comply with portions of 

 a standard due to cost, but must comply with the entire standard, whether State or 

 federally promulgated. 



Q. 34: What thoughts do you have on the Great Lakes Sediment Control Act of 

 1993? 



A. 34: In general, EPA supports the goals and objectives of the Great Lakes Sedi- 

 ment Control Act (GLSCA). Many of the activities mandated by the proposed 

 GLSCA are already underway in response to mandates of the National Environmen- 

 tal Policy Act (NEPA) and Section 404 of the Federal Water Pollution Control Act 

 (FWPCA), and through less formal mechanisms. As such, the GLSCA complements 

 the direction and goals of our Great Lakes programs. However, the Agency is con- 

 cerned that the mandates of the GLSCA will require extensive resources which the 

 Act does not provide, and will in many cases, require timeframes beyond those spec- 

 ified. In particular, those mandates concerning the development of sediment dispos- 

 al guidance and the management of confined disposal facilities on the Great Lakes 

 cannot realistically be completed by the December 31, 1994, deadline imposed by the 

 GLSCA. In addition, while we consider existing confined disposal facilities to be 

 worthy of the tj^e of attention outlined in the bill, we also believe that they pose 

 much less of a risk to the environment then the large amount of unconfined con- 

 taminated sediments that are currently in place in the Great Lakes system. If the 

 impact of the bill is to divert limited resources from in place contaminated sediment 

 remediation to confined disposal facility certification, the Great Lakes environment 

 will suffer. 



EPA is not opposed to concurrence authority on matters of sediment manage- 

 ment, but wishes to note that the Corps of Engineers currently seeks EPA input and 

 concurrence on most such matters in the Great Lakes. In addition, the imposition of 

 EPA concurrence authority for sediment management matters in the Great Lakes 

 Basin, but not for such matters in other waters of the United States, may lead to 

 significant variations in the government's response to such matters. 



We wish to note one area of potential confusion in the GLSCA. Subsection 2(A) of 

 Section (n) Sediment Load Reduction, implies that the Administrator of EPA shall 

 award grants to achieve such reductions under authority of Section 319 of the 

 FWPCA. However, Subsection 4(A) of Section (n) implies that the Secretary of the 

 Army will award such grants with EPA concurrence. Only EPA is authorized to 

 award Section 319 grants. 



Q. 35: What are your views on the Great Lakes Federal Effectiveness Act which 

 would create a Great Lakes Research Council to coordinate research among Fed- 

 eral agencies? 



A. 35: Research into the ecological processes of the Great Lakes is critical to both 

 our understanding of the Great Lakes and to our efforts to protect and restore these 

 unique resources. However, EPA does not believe that the establishment of an addi- 

 tional committee under the auspices of the International Joint Commission will 

 ensure the promotion of an ecosystem approach among the responsible Federal 

 agencies. Rather, the Agency believes such a committee to be unnecessary. Scarce 

 public resources can be better spent through directed research programs supporting 

 ongoing U.S. regulatory efforts. 



Q. 36: A) How would you organize and what priority would you give to geo- 

 graphically-targeted programs? 



A. 36: A) Over the years, EPA has focused its efforts on technology-based control 

 programs. While EPA has achieved a high level of success in controlling pollutants 

 to waterbodies through this traditional technology-based approach, it has become 

 apparent that other risks to ecosystems and human health exist which may be 

 better addressed through geographically targeted efforts. Geographically-targeted 

 programs, such as EPA's Great Water Body programs in the Great Lakes, Ofiesa- 

 peaJke Bay and the Gulf of Mexico; the National Estuary program; and smsdler scale 

 Clean Lakes; Near Coastal Waters, and other watershed projects have been very 

 successful at refocussing attention on water resources in need of protection or resto- 

 ration and tailoring solutions to these remaining needs. Often the larger-scale ef- 

 forts have involved several Regions and States, requiring a cooperative team effort 

 to their management. Experience-to-date suggests that these efforts, as well as 

 ground water protection, should be managed from the "most local level" embracing 

 an ecosystem protection approach, i.e., the Regions if Regional in scope, or State if 

 intrastate. Experience has also taught us that there must be a clear lead or chair- 

 person and staff support for these efforts. Based on our success with geographically- 

 targeted efforts and our need to move to a more holistic approach to ecosystem pro- 



