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Annex 1

Annex 1. Paul Horvatin – U.S. EPA Great Lakes National Program Office. General Points. No formal EPA Position at this time. Any changes would require extensive binational consultation. Recent analysis of Annex 1. BEC discussion held.

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Annex 1

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  1. Annex 1 Paul Horvatin – U.S. EPA Great Lakes National Program Office

  2. General Points • No formal EPA Position at this time. • Any changes would require extensive binational consultation. • Recent analysis of Annex 1. • 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.

  3. 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 • Outdated scientific rationale. • New programs adopted (by both countries) have superceded Annex 1objs.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: • TMDLs, SOLEC Indicators and Reporting, Progress on GLBTS, and ongoing monitoring.

  4. Keeping Annex 1 Current • Updating is immense effort, new science quickly makes out-of-date.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”.

  5. Action Level Options • 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.

  6. Existing U.S. Programs • Regulatory program and compliance monitoring, enforcement is real. • GLI will be foundation for EPA position on Annex 1: • Required by Law. • Years of rule-making, court challenges. • Incredible investment.

  7. 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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