U.S. EPA RAP Liaison
Niagara Frontier Program Manager
US EPA Region 2
290 Broadway (24th floor)
New York, NY 10007-1866
State RAP Contacts
New York State Department of Environmental Conservation
Albany, NY 12233-3508
Region 9 Water Manager
New York State Department of Environmental Conservation
270 Michigan Avenue
Buffalo, NY 14203-2999
Environmental Program Specialist
New York State Department of Environmental Conservation
270 Michigan Avenue
Buffalo, NY 14203-2999
Niagara River Remedial Advisory Committee
William M. Murray, Esq.
Chairman, Niagara River Remedial Advisory Committee
Erie County Department of Environment and Planning
Edward A. Rath County Office Building
95 Franklin Street
Niagara Fall, NY 14202
- Atlantic States Legal Foundation
- Cities of Niagara Falls and Buffalo
- Finger Lakes-Lake Ontario Watershed Protection Alliance (FL-LOWPA)
- Great Lakes Research Consortium
- Great Lakes United
- Lake Ontario Lakewide Management Plan (LaMP)
- Lake Ontario Sportfishing Promotional Council
- New York State Canal Corporation
- New York State Department of Environmental Conservation
- New York State Department of Health
- Niagara County
- Niagara County and New York State Health Departments
- Niagara County Department of Promotion and Tourism
- Niagara County Soil and Water Conservation District
- Niagara County Water Quality Advisory Committee
- Niagara River Remedial Advisory Committee
- New York Sea Grant Extension
- Sierra Club
- State University of New York (SUNY)
- Upstate Freshwater Institute
- U.S. EPA – Great Lakes National Program Office
- U.S. EPA, Region 2 -
New York City
- AOC Area of Concern
- BUI Beneficial Use Impairment
- CMP/EIS Chemical Management Plan or Environmental Impact Statement
- GLNPO Great Lakes National Program Office
- RAP Remedial Action Plan
- Beneficial Use Impairments
- Delisting Targets
- RAP Development and Status
- Significant RAP Milestones
- RAP Implementation
- RAP-Related Publications
- Community Involvement
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The Niagara River Area of Concern (AOC) is located in Erie and Niagara counties in western New York. This AOC extends from Smokes Creek near the southern end of the Buffalo Harbor, north to the mouth of the Niagara River at Lake Ontario. Past municipal and industrial discharges and waste disposal sites have been a source of contaminants to the Niagara River. A long history of development has also changed the original shoreline along much of the river, affecting fish and wildlife habitat. Habitat degradation and the survival of aquatic life in the AOC have been impaired by toxic chemicals such as PCBs, mirex, chlordane, dioxin, dibenzofuran, hexachlorocyclo-hexane, PAHs, and pesticides. Fish migration from Lake Ontario has an influence on the Niagara River community as does the related affects of invasive species. Metals and cyanides in the sediment prevent open lake disposal of bottom sediments dredged from the river. Sources and loadings of pollutant causing use impairments in the Niagara River include these sediments as well as inactive hazardous waste sites, combined sewer overflows, and other point and nonpoint sources. Contamination originating from discharges within Lake Erie's watershed contributes to effects in the Niagara River and Lake Ontario. These sources and river shoreline practices both contribute to the identification of use impairments for which remedial action is being taken to restore and protect beneficial uses.
Beneficial Use Impairments
- Restrictions on fish and wildlife consumption
- Fish tumors or other deformities
- Degradation of benthos
- Restriction on dredging activities
- Loss of fish and wildlife habitat
In addition two beneficial uses need further assessment to determined their status:
- Degradation of fish and wildlife populations (further assessment needed)
- Bird or animal deformities or reproduction problems (further assessment needed)
The Remedial Action Plan (RAP) identifies five use impairments based on the fourteen possible International Joint Commission (IJC) impairments. Two other beneficial uses have been evaluated as unknown and will require further investigation to determine the extent of their impairment. This group of indicators was established by IJC based on the Great Lakes Water Quality Agreement between the United States and Canada. The major impairment is restrictions on fish and wildlife consumption, primarily due to PCB and dioxin contamination. Mirex and chlordane also are chemicals of concern contributing to the fish consumption restriction. These restrictions are part of a lakewide fish advisory for Lake Ontario. Niagara River benthos is also listed as degraded, likely due to the presence of contaminated sediment "hotspots" at certain tributary and nearshore areas. Contaminated sediment has also caused a restriction on open lake disposal of dredged material from the Niagara River. In the upper Niagara River, fish tumors have been reported and the loss of fish and wildlife habitat due to human activities has been dramatic. The extent of degradation of fish and wildlife populations, and the presence of bird or animal deformities or reproductive problems will require further investigations.
The Remedial Action Plan that effectively combines the Stage 1 and Stage 2 RAP elements was completed September 1994. A RAP Status Report update was published June 2000. The RAP addresses use impairments, sources, existing remediation programs, and recommends future remedial strategies.
For further information on Niagara River BUIs, see the RAP documents listed in Significant RAP Milestones.
Delisting targets are being developed for Great Lakes Areas of Concern. In New York State, Remedial Advisory Committees for the six AOCs have been working on defining specific delisting criteria for each of the beneficial use indicators. For the Niagara RAP, these delisting targets are summarized below and are applied as initial endpoints for the AOC. A working set of endpoints and criteria have been drafted for the Niagara River RAP.
- Fish Consumption* - removal of lakewide fish consumption advisory (human)
- Fish Tumors* - no abnormal high tumor incidence or deformities
- Benthos* - community integrity substantially similar to reference
- Dredging* - no Army Corps of Engineers (USACE) restrictions
- Fish Habitat* - no restricted use of habitat from flow or contamination
- Fish Populations - substantially similar to reference community (Lake Ontario)
- Birds or Animals – no abnormal high deformities incidence or reproduction prob.
* Indicators defined as impaired for the Niagara River AOC; two others involve further assessment.
RAP Development and Status
NYSDEC applied a phased approach to development of RAPs for its six AOCs. In 1989, a group of interested citizens was appointed by New York State Department of Environmental Conservation (NYSDEC) as the Niagara River Action Committee to help develop the RAP. The committee comprised 26 environmental, industrial, sports people, academic, community and local government representatives. Committee representatives and NYSDEC staff created an Executive Committee that directed RAP development. The Executive Committee established RAP goals, mapped out a workplan, defined responsibilities and reviewed draft sections of the RAP. The RAP was completed in 1993 and published final in 1994; it addresses problems, sources, existing remediation programs and recommends remedial strategies. Tracking progress in implementation of the RAP has three components: plan review/update; periodic status reports with workplans for planned activities; and public participation, primarily through an advisory committee. NYSDEC has appointed a twelve-member Remedial Advisory Committee (RAC) representing government officials, public and economic interest groups and private citizens to advise and assist NYSDEC in implementing the RAP.
Members from each of the binational jurisdictions (Canada and United States) have laid the groundwork to collaborate on AOC objectives. This was accomplished through the Remedial Advisory Committees in earlier development stages of the RAP. In May 2004, a binational meeting was held to discuss next steps for the St. Lawrence River, another binational AOC. The following binational needs were identified: 1) understanding the status of each RAP; 2) reviewing delisting criteria status; 3) identifying monitoring and next step; and, 4) identifying opportunities for collaboration in delisting efforts. All of these would also apply to the Niagara River, and a similar binational meeting on this AOC is forthcoming.
The International Joint Commission completed a Status Assessment Report for the entire AOC in June 2002. Certain implementation activities were identified as successes for the RAP process. Challenges for the binational process as well as next step recommendations were also identified for the AOC in the Status Assessment Report. There are differences yet common points identified by the advisory committees in their assessment of impairments.
As next step activities in RAP implementation, the committees are to collaborate on sharing information and making progress in resolving the use impairment indicators. A review of the guidelines for operating an advisory committee can be useful in establishing ground rules for moving ahead while considering all points of view. Sharing information and data in implementing the strategies will be a key to making progress. The jurisdictions can agreed to work together to make incremental progress in addressing each of the beneficial use indicators.
Significant RAP MilestonesSince 1989, the development and implementation of the Niagara River Remedial Action Plan has resulted in a number of milestones being achieved:
- 2007: Niagara River Toxics Management Plan - progress report and work plan completed.
- 2006: AOC workshop conducted to update and identify next steps for the RAP and AOC.
- 2004: Niagara River Greenway Commission established.
- 2003: Western New York RAP workshop was held.
- 2002: Niagara River AOC Status Assessmentcompleted.
- 2000: Niagara River Remedial Action Plan Status Report completed.
- 1994: Final Niagara River RAP and summary documents published.
The 1994 RAP document presents a remedial strategy that includes a variety of remedial measures: stream water quality monitoring, contaminated bottom sediment assessment and action determination, inactive hazardous waste site remediation, point and nonpoint source discharge evaluation, combined sewer overflow assessment, remedial measure implementation monitoring and fish and wildlife beneficial use restoration and habitat protection.
A number of Niagara River initiatives are ongoing which have been and continue to be of assistance to RAP implementation. These initiatives establish a strong foundation for the implementation of RAP related activities.
Niagara River Toxics Management Plan
In the late 1980s mutual concern over the Niagara River’s high levels of toxic chemicals resulted in a decision by four Canadian and US environmental agencies to enter into a landmark agreement to work cooperatively to reduce toxic inputs to the River. In February 1987, Environment Canada (EC), U.S. EPA, the Ontario Ministry of the Environment (MOE) and NYSDEC, "the Four Parties", signed the Niagara River Declaration of Intent (DOI), to adopt and implement a toxics reduction plan.
The Niagara River Toxics Management Plan (NRTMP) was the plan designed to achieve these reductions. In it, eighteen priority pollutants were targeted for reduction, with a 50% reduction in point and nonpoint sources of ten of these toxic chemicals called for by 1996. In 1996, the Four Parties re-affirmed their commitment to the NRTMP in a Letter of Support that called for continued reductions of toxic pollutants to achieve ambient water quality that will protect human health, aquatic life, and wildlife, and while doing so, improve and protect water quality in Lake Ontario as well. In addition to source trackdown and remediation, reporting and public involvement are parts of the implementation process. A Niagara River Toxics Management Plan progress report and workplan is produced annually.
Niagara County Water Quality Advisory Committee
The Niagara County Water Quality Strategy was prepared by the Niagara County Water Quality Advisory Committee. The committee works to coordinate efforts to improve water quality in the county, especially through the development and implementation of a strategy to control nonpoint source water pollution. The Water Quality Advisory Committee (WQAC) plans to concentrate on nonpoint source water pollution problems. Nonpoint sources are seen as a threat or potential threat to water quality in all of the county's major watersheds. Sources of nonpoint pollution include: agricultural and related runoff (fertilizers and pesticides), sedimentation from erosion, septic system failure and other runoff from sources such as road salt, leaking underground storage tanks and other chemical containers.
Strawberry Island Habitat Restoration Project
Strawberry Island, which is located near the southern tip of Grand Island, became endangered as a result of gravel dredging and the erosive forces of the Niagara River's strong currents. The crescent-shaped island once totaled more than 200 acres, but now consists of five acres. This project includes the restoration of three acres of wetland habitat along the eastern and western arms of the island and the installation of approximately 2,300 feet of rip-rap break-wall to protect the island from wind and wave damage. Submerged sills will hold wetland soil in place and nearly 5,000 yards of wetland soil will be transported from the Buckhorn Island Marsh State Park restoration project and placed at Strawberry Island. In addition, more than 5,200 erosion-resistant plants will be placed on the island to help protect the soil.
Niagara River Greenway Commission
Although not a direct activity of the RAP, the Niagara River Greenway Commission's goals and mission will benefit the AOC and RAP objectives. This commission was established in late 2004 as a cooperative regional organization to work with participating state agencies, organizations and residents in order to implement linear system of parks and conservation areas along the NR riverfront, to be known as the Niagara River Greenway. The Greenway will redefine the Niagara riverfront by increasing landside access to the river; creating complementary access to the greenway from the river; augmenting economic revitalization efforts and celebrating the region’s industrial heritage in Niagara and Erie Counties.
Recent Progress and Achievements
Following are some activity highlights relative to RAP progress and achievements. Seven environmental program areas are used to describe progress. Concurrent with the RAP process, many NYSDEC environmental program activities are in place and progressing as part of State environmental protection laws and policies, and therefore are being implemented independent of any formal RAP coordination. The RAP strategies do, however, make use of all resource commitments to restore beneficial uses since a key to successful restoration and protection of the AOC is securing implementation commitments to achieve RAP objectives.
Hazardous Waste Site Remediation (Land-Based)
Under the Four Parties agreement among Canadian and US agencies, reducing toxic chemical inputs to the Niagara River, primarily by hazardous waste site remediation, is being successfully implemented. Twenty-six New York State sites were identified as responsible for over 99% of the pollutant load on the U.S. side of the basin. Remedial measures have been completed at 21 of the sites, with site plans including long-term operation and monitoring. The remaining sites are under active remediation or design phases. The U.S. EPA estimates that site remediation to date has reduced the potential inputs into the River by approximately 94%. A listing of inactive hazardous waste sites and the status of their remedial progress is provided in the 2008 report entitled "Reduction of Toxics Loadings to the Niagara River from Hazardous Waste Sites in the Unites States".
Contaminated River Sediments
The U.S. EPA and NYSDEC have overseen the remediation of embayment sediments along the Niagara River. Contaminated sediments in embayment areas have been identified as sources of impairments in the river. Three embayment locations, the mouth of the Pettit Flume, 102nd Street embayment and the mouth of Gill Creek have been remediated. However, monitoring and determinations of further remedial activities are needed. To date, over 90,000 cubic yards have been dredged in the Niagara River with up to 200,000 cubic yards removed from tributaries. The U.S. EPA is developing a proposed management strategy which is expected to include sediment criteria that would allow decisions to be made relative to the likely environmental impacts of contaminated sediments. NYSDEC currently uses a 1994 guidance document. Sediment data indicate the presence of a wide variety of organic and inorganic contaminants in sediments from the Buffalo Harbor, the Black Rock Canal, the Bird Island-Riverside nearshore area, the Tonawanda Channel nearshore area, the Wheatfield-Upper River nearshore area and the Lower Niagara River nearshore area. Analyses of core samples from the sediment bar at the mouth of the Niagara River show a significant decrease in contaminants over the past twenty years.
Point Source Discharge Control
NYSDEC has developed an Environmental Benefit Permit Strategy to assist in establishing priority for renewal modifications of point source discharge permits based on the identification of environmental/water quality benefits. A significant reduction in the mass of contaminants discharged within the drainage basin by area industries has been achieved by the installation of improved wastewater treatment systems, the implementation of best management practices, the ongoing discharge permit monitoring and renewal process, hazardous waste site remediation activities and the implementation of pollution prevention measures.
In the early 1990s, EPA and DEC required the City of Niagara Falls to treat all of the Fall Street Tunnel flow during dry weather. This was a significant source of toxic contamination to the Niagara River. As a result of corrective action, flow of up to 10 mgd from the Tunnel is being diverted to the City of Niagara Falls wastewater treatment plant to preclude dry weather discharges and to reduce wet weather overflows. In addition, recent grouting undertaken by the City has reduced daily dry weather flow in the tunnel. Overall, as a result of these management actions, both the frequency and volume of wet weather overflows from the Fall Street Tunnel have been significantly reduced.
Nonpoint Source Pollution Control
Excessive nutrients (phosphorus) and sedimentation (erosion) from agriculture activities as well as toxics from stormwater runoff contribute to nonpoint source pollution problems in the Niagara River drainage basin. County Water Quality Management Strategies have been developed to address nonpoint source pollution in the watershed. Implementation of these County Water Quality Management Strategies and related Best Management Practices (BMPs), including improvements to stormwater management, is recommended and is progressing. Various funding programs (grants) now support and are available to assist in the implementation of nonpoint source pollution control efforts. NYSDEC's Division of Water has developed nine guidance document sections for the Management Practices Catalogue for Nonpoint Source Pollution Prevention and Water Quality Protection in New York State.
Fish and Wildlife Assessments/Actions
Several of the Niagara River AOC use impairments are based on the status of fish and wildlife conditions and considerations. Available fish and wildlife investigative information has been reported (Skinner 1989). A fish pathology study is needed as well as investigative studies concerning deformity and fish and wildlife populations.
Health and Environmental Assessments/Actions
Maintaining current and useful contaminated fish consumption advisory information serves to reduce exposure of user groups. NYSDEC in conjunction with NYSDOH has prepared updated fish consumption advisory pamphlets to assist with public outreach and education. The implementation of this fish consumption advisory at the local level and the research necessary to monitor long-term trends in regard to the advisory will be continued.
Investigations and Monitoring Activities
The results of various investigations and monitoring activities will be instrumental toward resolving the Niagara River AOC use impairments. Stream monitoring and monitoring associated with planned remediation projects will contribute to the re-assessment of use impairment indicators. Water quality is determined by comparing the concentrations of pollutants in the water column (water collected without disturbing bottom sediments) with numerical standards and guidance values (concentrations above which desired uses are likely to be impaired).
In accordance with the Niagara River Toxics Management Plan and the four-party Declaration of Intent (1987), Canada, the United States, New York State and the Province of Ontario have developed an upstream/downstream water quality monitoring program involving the collection of water and suspended solids samples at the head (Fort Erie) and the mouth (Niagara-on-the-Lake) of the Niagara River. The purpose of the program is to estimate input loadings of specific metals and organic chemicals to the Niagara River from Lake Erie and output loadings to Lake Ontario. State-of-the-art sampling and analytical methods capable of quantifying the presence of chemicals at very low concentrations are being used. Water quality samples are collected weekly by Environment Canada at the two stations. Statistical methods are applied to give annual mean concentrations of each chemical at both ends of the river.
Current projects and outlook
Implementation of the Niagara River RAP is a continuous process that will include periodic updates and improvements as knowledge of the use impairments, sources and the effectiveness of remedial actions increases. Remedial actions are to be evaluated and coordinated as to the impacts on restoration of beneficial uses. Within the AOC and watershed, the priorities include addressing the fish consumption advisories, completing the site remedial measures, conducting monitoring and investigation activities, and re- assessing the status of beneficial uses. When necessary, contaminant trackdown may be used. Restoring and maintaining an improved quality of life in the ecosystem of the Niagara River and its watershed is the overall goal. In addressing the binational AOC, NYSDEC has taken the lead in coordinating the RAP activities for the New York state portion. Likewise Canadian jurisdictions are taking the lead for the RAP concerning the Ontario side of the river. Some progress has been made in collaboration activities.
Niagara River Comprehensive Watershed Study Proposal
Congress is considering funding an Energy and Water Bill that includes a US Army Corps of Engineers Buffalo District proposal entitled the "Niagara River Comprehensive Watershed Study". The Buffalo Niagara Riverkeeper has worked hard to have this study implemented and believes that revitalization of the Niagara River, its watershed and shoreline are important for the area. To accomplish full restoration, the Buffalo/Niagara region must have a healthy community with accessible waterfront to fully realize the region’s tourism and marine business potential. Even more, the river system itself must be restored for the Niagara Region to capture the benefits of Great Lakes waters.
Many toxic levels in the Niagara River waters have been dramatically reduced; however beneficial use impairments remain due to historic contamination and habitat destruction. A comprehensive watershed study is needed to 1) synthesize environmental data, 2) determine goals for restoration of the ecosystem with measurable endpoints, 3) establish an implementation strategy, and 4) obtain Great Lakes restoration funding.
- 2008: Reduction of Toxics Loadings to the Niagara River From Hazardous Waste Sites in the United States, U.S. EPA and NYSDEC
- 2007: Niagara River Toxics Management Plan Progress Report and Work Plan
- 2006-2007: Health Advisories: Chemicals in Sportfish and Game , New York State Department of Health (NYSDOH).
- 2004: 30 Year Trends in Water Quality of Rivers and Stream in NYS, NYSDEC.
- The Great Lakes Research Review : This is a publication jointly produced by the Great Lakes Program of the University at Buffalo, the Great Lakes Research Consortium, and the New York Sea Grant Institute. The publication provides an outlet for information concerning important research being undertaken in the Great Lakes, particularly but not exclusively by researchers affiliated with the New York Great Lakes Research Consortium and its member institutions. It is designed to fill a gap between newsletter-type information and articles that are suited for technical journals. For more information contact: Great Lakes Program at SUNY Buffalo, 207 Jarvis Hall, Buffalo, NY 14260, 716-645-2088, or the Great Lakes Research Consortium at SUNY College of ESF, 24 Bray Hall, Syracuse, NY 13210, 315-470-6816.
The following historical documents may also be available from one of the AOC contacts
- NYSDEC. Trends in Water Quality of Selected Rivers in New York State. August 1995. pg. 21-29.
- NYSDEC. Technical Guidance for Screening Contaminated Sediments. July 1994. Division of Fish & Wildlife, Division of Marine Resources. 36 pp.
- NYSDEC. 1993. Pollution Prevention Guidance for Local Governments.
- NYSDEC. 1992. Reducing the impacts of stormwater runoff from new development. 178 pages.
- S.J. Jackling and R.W. Karcher. August, 1994. Identification of and changes in chemical contaminant levels in young-of-the-year from New York's Great Lakes Basin: 1992. Tech. Report 94-4 (BEP), NYSDEC, Albany, NY. 44 pp.
- NYSDEC. 1993. Priority Water Problem List: summary and county listing documents.
- NYSDEC. 1992. New York State 25-Year Plan for the Great Lakes.
- Longabucco, P. 1991. Controlling agricultural nonpoint source water pollution in New York State: a guide to the selection of best management practices to improve and protect water quality. NYSDEC, Albany, N.Y. 169 pp.
- NYSDEC. 1990. Nonpoint Source Management Program
- Categorization Committee NYSDEC. 1990. Categorization of Toxic Substances in the Niagara River. Niagara River Secretariat.
- Skinner, L.C. 1989. Chemical contaminants in Young of the Year Fish from New York’s Great Lakes Basin 1984 through 1987. NYSDEC .43 pp.
- Black, J.J. 1988. Fish Tumors as known Field Effects of Contaminants. Toxic Contamination in Large Lakes, Vol I Chronic Effects of Toxics. Lewis Pub. Ca
- Declaration of Intent (DOI). 1987. The Niagara River Declaration of Intent. Environment Canada, the United States Environmental Protection Agency II, Ontario Ministry of the Environment and the New York State Department of Environmental Conservation, February 4, 1987.
- McMahon, J. 1987. Comparison of 1981-82 and 1985-86 Toxic Substance Discharges to the Niagara River. NYSDEC.
- Litten, S. 1987. Niagara River Area Sediments. NYSDEC.
- Simpson, K.W. 1982. Macroinvertebrate Study of the Niagara River – 1982.New York State Department of Health.
- NYSDEC. Management Practices Catalogue for nonpoint source pollution prevention and water quality protection in New York State: a nine section document of best management practice categories.
- The brochure entitled, RAPs in Action, was developed to augment the message of the New York state RAP Display. The brochure provides more detailed information on remedial activities that are being implemented to restore and to protect beneficial uses in New York State's RAP Areas of Concern.
- A promotional brochure entitled, Getting the Word Out, was also developed to provide a description of public outreach and educational materials (audiovisuals, brochures, fact sheets, etc.) produced by and/or for the RAPs or the Lake Ontario Lakewide Management Plan (LaMP).
Over the years, the Niagara River Remedial Advisory Committee (RAC) conducted monthly, and later quarterly, meetings on RAP implementation. At the Western New York 2003 RAP workshop, stakeholders shared information on activities affecting the Niagara region. Active participants have been focusing attention on the Buffalo River RAP implementation. A 2006 Niagara River RAP workshop was conducted to identify next steps for the Area of Concern. The Advisory Committee consists of a diverse and multi-stakeholder representation with the task of identifying needed studies and remedial actions, seeking implementation, and then affecting these activities in the watershed and AOC. Reporting on progress and communicating this information to the public has been an objective of the committee. Recent efforts in the Niagara RAP have focused on the implementation of the NRTMP and hazardous waste site remediation to address the use impairments and realizing that pollutant source clean up is being accomplished.
Regular meetings of the RAC were conducted as part of the development of the RAP. Implementation and documentation of RAP-related activities are coordinated through a continuing public participation process. Stakeholders need to be informed of remedial activities and progress and steps have been taken to include a continued outreach effort in the development and implementation of remedial measures. Presentation of study and remedial activity results are part of this public participation process. At times, field trips are organized to learn more about the specifics of a remedial activity and to respond to committee members’ interests as necessary.
It is important to provide a periodic status report of the Niagara River AOC to maintain and increase public awareness about the restoration and protection activities and needs of this important geographic area. The last RAP Status Report was published in June 2000; the NRTMP Progress Report is produced every three years, with a brief newsletter-style report issued in the intervening years. A promotional brochure and RAP display are other examples of outreach activities that have been incorporated into the public participation activities involving Great Lakes program activities. The RAC will continue to provide advice and consultation and foster interest in implementation of remedial measures that benefit the AOC.