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					         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.
       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 Outdated scientific rationale.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  countries) have superceded Annex 1objs.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:
       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  science quickly makes out-of-date.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”.
            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.
           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.
               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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