President Orders Agencies to Repeal Two Rules for Each New Regulation

February 13, 2017

An executive order issued by the President requires that, unless prohibited by law, whenever an executive department or agency (agency) publicly proposes for notice and comment or otherwise promulgates a new regulation, it shall identify at least two existing regulations to be repealed. For details on the implications of the executive order, see this Q&A.

Several environmental groups have sued the Trump administration to block the order signed by President Trump. Public Citizen, the Natural Resources Defense Council (NRDC), and the Communications Workers of America represented by Earthjustice are asking the court to issue a declaration that the order cannot be lawfully implemented and bar the agencies from implementing the order. The order requires new rules to have a net cost of $0 this fiscal year, without taking into account the value of the benefits of public protections.

The suit, filed in the U.S. District Court for the District of Columbia, names as defendants the president, the acting director of the Office of Management and Budget (OMB), and the current or acting secretaries and directors of more than a dozen executive departments and agencies. The complaint alleges that the agencies cannot lawfully comply with the president’s order because doing so would violate the statutes under which the agencies operate and the Administrative Procedure Act.

“When presidents overreach, it is up to the courts to remind them no one is above the law and hold them to the U.S. Constitution,” said Earthjustice attorney Patti Goldman. “This is one of those times.”

"No one thinking sensibly about how to set rules for health, safety, the environment and the economy would ever adopt the Trump Executive Order approach—unless their only goal was to confer enormous benefits on big business,” Public Citizen President Robert Weissman said. “If implemented, the order would result in lasting damage to our government’s ability to save lives, protect our environment, police Wall Street, keep consumers safe, and fight discrimination. By irrationally directing agencies to consider costs but not benefits of new rules, it would fundamentally change our government’s role from one of protecting the public to protecting corporate profits.”

“President Trump’s order would deny Americans the basic protections they rightly expect,” said NRDC President Rhea Suh. “New efforts to stop pollution don’t automatically make old ones unnecessary. When you make policy by tweet, it yields irrational rules. This order imposes a false choice between clean air, clean water, safe food and other environmental safeguards.”

CWA President Chris Shelton said, “It is unbelievable that the Trump administration is demanding that workers trade off one set of job health and safety protections in order to get protection from another equally dangerous condition. This order means that the asbestos workplace standard, for example, could be discarded in order to adopt safeguards for nurses from infectious diseases in their workplaces. This violates the mission of the Occupational Safety and Health Administration to protect workers’ safety and health. It also violates common sense.”

A draft 2016 report to Congress from the White House OMB estimates that the annual benefits from all major regulations over the past 10 years for which agencies monetized both benefits and costs were between $269 billion and $872 billion, while the costs were between $74 billion and $110 billion, in 2014 dollars. OMB’s 2005 report to Congress estimated that major rules from the previous 10 years provided annual benefits of $69.6 billion to $276.8 billion, while costing between $34.8 billion and $39.4 billion.

New Sulfur Dioxide Emission Rules in Ohio

Ohio EPA has adopted amended, new, and rescinded sulfur dioxide air emission rules in the Ohio Administrative Code (OAC) Chapter 3745-18. The rules set limits, testing, and recordkeeping requirements for emissions of sulfur dioxide from sources in the state of Ohio. The new rules were issued on Monday, February 6, 2017, and will become effective on Thursday, February 16, 2017.

Elevated Levels of PFCs Found Near New Hampshire Business

The New Hampshire Department of Environmental Services (NHDES) recently announced that test results of a residential drinking water well in Rochester, New Hampshire showed elevated concentrations of perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). Testing of residential wells near the Lydall Performance Materials, Inc. (Lydall), Rochester facility, was initiated by NHDES when results of one groundwater well (not used for drinking water) and three samples from lagoons and/or effluent from the facility, obtained during a permit renewal inspection, showed elevated levels of PFCs.

The New Hampshire Ambient Groundwater Quality Standard (AGQS) is 70 parts per trillion (ppt) for PFOA, PFOS, and for PFOA and PFOS combined. The test results for the impacted property showed 88 ppt of PFOA and 140 ppt of PFOS, a combined 228 ppt. Samples collected from the Lydall facility exhibited a combined concentration (PFOA and PFOS) of 443 ppt to 860 ppt. Test results of nine additional drinking water and monitoring wells in the area exhibited combined concentrations of 2.6 ppt to 24 ppt, which are below New Hampshire’s AGQS.

Since the initial test results, NHDES, Lydall and the City of Rochester have been working cooperatively on the ongoing investigation to determine the source of the PFCs. In the interim, Lydall is providing bottled water to the impacted residence. If Lydall is determined to be the source of the groundwater contamination, Lydall will work with the property owner and the city of Rochester to extend public water to the property.

Rochester residents with drinking water wells near the Lydall facility that would like to have their well tested for PFCs are encouraged to submit a request form located on the following website: http://www.des.nh.gov/organization/commissioner/pfoa.htm (NHDES will contact well owners if they are in the investigation area). For more information, please call Jim Martin, NHDES at (603) 271-3710.

New Report Makes Strong Business Case for Using Safer Chemicals in Products and Supply Chains

Chemicals are all around us, present in the products we use every day. The demand for increased transparency on chemicals up and down the supply chain is growing—we need to understand how and with what chemicals we are interacting. Consumers, retailers, and brands all want to know more, driving companies to disclose information about the hazardous chemicals in their products and to make safer choices.

Now a new report, The Business Case for Knowing Chemicals in Products and Supply Chains, highlights the benefits to companies when they invest in an "Active Strategy" for chemicals management, one in which they proactively manage the chemicals in their products and supply chains to stay ahead of regulatory and market demands.

The United Nations Environment Programme (UNEP) report, prepared in collaboration with the environmental NGO Clean Production Action, was released at the Strategic Approach to International Chemicals Management (SAICM) Open-ended Working Group's meeting in Geneva, Switzerland.

The report speaks directly to the emerging chemicals policy issue of Chemicals in Products, which will be discussed in-depth at the SAICM meeting, along with five other emerging policy issues of high priority to the international chemicals policy community. "A thorough understanding of which chemicals are present in products we use on a daily basis, and any hazards they bring with them, is the first critical step to reducing the risk to these hazards," said Fatoumata Keita-Ouane, Head of UNEP's Chemicals Branch. "This business case report underlines how companies that actively seek and act upon this information generate long-term value for themselves, their shareholders, the public and the planet."

"The fact that chemicals are the foundation of everything around us presents significant management challenges for the vast majority of businesses that do not know the chemicals in their products or supply chains, do not understand the hazards of those chemicals, and do not know the availability of safer alternatives," said Dr Mark Rossi, Chair & Founder of BizNGO and Co-Director at Clean Production Action. "As the new report details, this massive gap in information leaves companies and communities at risk."

The report compares companies with differing chemicals management strategies, concluding that those with Active Strategies reduce their risk to damaging chemicals "surprises" and generate long-term value through increased sales, enhanced brand reputation, and well-managed supply chains.

The report demonstrates how companies with "Passive Strategies" can face big fines, loss of market share and value, and tarnished reputations if an unknown "hidden liability" of hazardous chemicals in their products comes to public light. The report notes that over a three-year period Walmart, Target, Walgreen Co., CVS Pharmacy, and Costco Warehouse paid a total of US $138 million in fines because of chemicals of concern found in their products.

Product recall costs can also be significant: Sony's recall of its PlayStation in 2011 due to illegally high cadmium levels cost the company more than US $150 million in lost sales and product reformulation costs; Mattel's recall of more than nine million toys in 2007 due to lead in their paint cost the company US $110 million in recall expenses and its stock price tumbled 18%; and RC2 Corporations 2007 recall of toy trains, also due to lead paint, cost US $48 million and halved its stock price.

The marketplace is also swift to punish: in China in 2009, tens of thousands of consumers stopped buying, and thousands of stores stopped selling, Johnson & Johnson's baby products after formaldehyde and 1,4-dioxane were found in some of these products in the United States. Johnson & Johnson saw its market share in China for baby products decline by almost 10%.

Conversely, the report says, proactive businesses that adopt an Active Strategy reap the rewards of their efforts: they avoid fines and product recalls, are well-prepared for new government regulations and respond quickly to ever-growing market demands to know and control the chemicals in their products.

The examples are striking:

Coastwide Laboratories, a division of Staples, designed and invested in a new product line—The Sustainable Earth brand—based on safer chemicals. This became a primary driver of Coastwide Laboratories' sales and market share growth in the early 2000s. "We seek to offer our customer's products that are inherently safer for human and environmental health and that address environmental impacts throughout their lifecycle. Listening and responding to our customers has clearly paid off over the years," said Roger McFadden, Vice President and Senior Scientist at Staples. "With increasing regulatory changes and a growing awareness about how chemicals impact health, avoiding harmful chemicals in consumer products is no longer an ideological nice-to-have, but a must-have moving forward. This new report reveals information and evidence that can be valuable to any business."
Shaw Industries' investment in safe chemicals for carpet backings netted the company substantial benefits. Shaw replaced its polyvinyl chloride carpet backing with a safer alternative, reducing weight by 40%, and quickly captured market attention—production capacity tripled in 2000 and by the end of 2002, sales of its EcoWorx products exceeded those of its PVC-backed carpets. "Shaw has had a long-standing holistic approach to sustainability. "Our aim is that every chemical, every material, every process, and every action is designed for a better future," said Paul Murray, Vice President of Sustainability and Environmental Affairs at Shaw. "The Cradle to Cradle Certified TM Product Standard guides our focus on chemical and material health, material reutilization, energy, water, and social fairness. This requires continued investment in innovation, but the long-term rewards are reaped not only in profits, but also in regard to people and the planet."
Seagate Technology PLC, a manufacturer of data storage devices, put in place a chemicals information management database which tracks the chemicals that go into its products. This means that each time a new chemical of concern is noted, staff simply search the company's database to see if it is present in its products. This enables the company to respond to new substance restrictions with existing resources, avoid the "saw-tooth effect" (where the costs of data collection vary widely, as the company responds to unpredictable new requests for data), and gives Seagate a better understanding of both the chemistry of its products and its suppliers' performance. "By requiring full disclosure from suppliers and maintaining a comprehensive database, Seagate is positioned to quickly respond not only to new regulations, but also to customers' product sustainability and environmental data requirements," said Brian Martin, Product Environmental Compliance Director at Seagate Technologies. "Given the benefits from design through sales, once more businesses are aware of the implications of full supply chain chemicals management, it should quickly become the status quo."

The report notes that many sectors—apparel, footwear, outdoor industry, automotive, electronics, cleaning, personal care, building, and retail—have leaders advocating and building active chemicals management strategies, and the necessary complementing information systems. But progress is not uniform, and many sectors do not have sufficient systems in place to enable reliable exchange of the chemical content information that is needed to meet current and future regulatory and customer demands.

"Transforming corporate cultures to the Active Strategy is itself a significant challenge," the report says. "The demands from consumers as well as the continual increase in regulatory requirements help foster that interest, but creating the organizational will power to absorb upfront costs—for uncertain future risks is often a difficult case to make."

"The pathways to knowing chemicals in products/supply chains and using safer substitutes are clearly established. Innovators and early adopters are already on this path—the question is how rapidly other businesses—begin to implement Active strategies for managing chemicals in products."

Spilled Mercury Found in Minnesota Dumpster

The New Ulm Public Safety Department and Minnesota Pollution Control Agency (MPCA) responded to a mercury spill reported February 7 in the 100 block of North Garden Street in southern Minnesota city. The agencies believe there is no risk to the public at this time. They asked the public to avoid this area as response crews clean up the spill and check surrounding structures for mercury that may have been tracked or spread.

A local waste hauler noticed the mercury spill in a dumpster and alerted authorities. Mercury is a silvery, liquid metal at room temperature, but like water, mercury can evaporate and become airborne. Its vapors are dangerous to inhale because they are toxic to the human nervous system. Cold temperatures are preventing the mercury outside from vaporizing. Indoors, a significant amount of mercury vapor can build up at room temperature so it is important to clean up any traces. Mercury requires special cleanup because sweeping or vacuuming it can actually increase the risks.

Authorities believe a property owner removed about two gallons of mercury from their garage, disposing of it in the trash. About one gallon spilled in the dumpster. Authorities believe the mercury is isolated to the dumpster, alley and garbage truck where the mercury was found.

Crews are using special equipment to clean up the mercury and will dispose of it appropriately.

The MPCA responds to about 10 mercury spills a year on average. If people suspect they have mercury or other potentially hazardous materials, they should call their local Household Hazardous Waste program. Statewide, these programs collect about 100 lb of mercury a year.

For spills of mercury or other suspected hazardous materials, call the Minnesota Duty Officer at 800-422-0798 or 651-649-5451, which is staffed 24 hours a day 7 days a week. The Duty Officer will connect residents and companies with someone who can advise on dealing with the spill.

Check your kitchen, bathroom and garage for mercury thermometers, blood pressure cuffs, fluorescent bulbs or other mercury-containing devices, and bring them to household hazardous waste programs for disposal. Take extra care not to break anything by putting mercury-containing devices inside a sealable plastic container.

It is unlawful to place mercury or mercury-containing devices in ordinary household garbage. Call your county's solid waste officer for the location and hours of the household hazardous waste site nearest you.

EMD Millipore Fined $385,000 for Clean Water Act Violations

Under the terms of a Consent Decree lodged in federal court, EMD Millipore Corp. of Jaffrey, N.H., will upgrade its on-site wastewater treatment system to comply with the terms of the company's industrial wastewater discharge permit and prevent pretreatment violations of the federal Clean Water Act (CWA). The company will also pay a civil penalty of $385,000 for alleged violations of the CWA.

EMD Millipore operates an industrial manufacturing facility in Jaffrey, New Hampshire, that produces water filtration devices. The facility operates an on-site wastewater treatment system that introduces wastewaters into the Jaffrey publicly owned treatment works (POTW) through a dedicated pipe. The facility's wastewaters contain pollutants including ammonia, total suspended solids, hydrogen ion concentration (pH), and oxygen demanding pollutants such as biochemical oxygen demand. The settlement resolves numerous allegations of Clean Water Act pretreatment violations, including pass through and interference violations at the Jaffrey POTW.

The Consent Decree requires EMD Millipore to upgrade the facility's wastewater treatment system to achieve compliance with the federal pretreatment regulations and the facility's industrial wastewater discharge permit. The company must also comply with certain interim wastewater management requirements. Finally, EMD Millipore must provide annual training to individuals at the facility who are responsible for CWA compliance and perform wastewater sampling and analysis, and submit quarterly reports to EPA, to ensure compliance with the Consent Decree and the CWA.

The Consent Decree is the result of a federal enforcement action brought by the U.S. Department of Justice, on behalf of the EPA.

Pitman Farms Fined $242,980 After Ammonia Release

The EPA recently announced a settlement with Pitman Farms, Inc., for violations of federal chemical safety and reporting requirements following three ammonia releases at its poultry processing facility located in Sanger, California. Pitman Farms, which sells poultry from its Sanger facility under the brand name Mary’s Free Range Chicken, will pay a $242,980 civil penalty and perform two local environmental projects valued at nearly $200,000.

EPA’s action is a result of its November 2014 inspection that uncovered violations of the federal Clean Air Act’s Risk Management Program, designed to prevent the accidental release of extremely hazardous substances to the air. The inspection was prompted by a release of 2,700 lb of anhydrous ammonia at the facility in September 2014 that led to the hospitalization of 15 employees. Additional smaller releases of anhydrous ammonia occurred in May 2016 and July 2016. Each of those incidents resulted in the medical treatment of 4 employees.

“Companies using hazardous chemicals must take steps to ensure the safety of nearby residents and their workers,” said Alexis Strauss, EPA’s Acting Regional Administrator for the Pacific Southwest. “We appreciate Pitman Farms’ recent efforts to install new refrigeration equipment to reduce the chance of ammonia releases.”

During its inspection, EPA found that Pitman Farms violated the Risk Management Program regulations by failing to:

Provide training to employees to assure they understand and adhere to the operating procedures
Ensure that employees were properly fitted for personal protective equipment
Perform annual inspections and tests of the ammonia refrigeration system, and correct deficiencies in equipment in a timely manner
Promptly address all recommendations made in its Incident Investigation Report after the September 2014 release of anhydrous ammonia at the facility
Document that all ammonia process equipment complied with industry standards, such as labeling ammonia refrigeration system pipes

EPA inspectors also found that the company failed to immediately notify the National Response Center and the California Office of Emergency Services as soon as it knew of the releases in September 2014 and July 2016, in violation of the federal Comprehensive Environmental Response, Compensation, and Liability Act and Emergency Planning and Community Right-to-Know Act.

Under the settlement, Pitman Farms will spend $194,950 on environmental projects to support emergency planning and preparedness efforts in the Sanger area and larger Fresno County communities. The company will purchase and donate emergency response equipment to the Fresno County Hazmat Emergency Response Team and the City of Fresno Fire Department, to assist them in responding to hazardous materials incidents. In addition, the company will upgrade its facility by installing centralized safety controls to provide rapid detection and control of anhydrous ammonia releases. Pitman Farms has also installed a new state-of-the-art ammonia refrigeration system and filed a revised risk management plan for the new system, which became operational in August 2016.

The Clean Air Act’s Risk Management Program requires facility plans that include hazard assessments detailing the potential effects of an accidental release and a prevention program that includes safety precautions and maintenance, monitoring, and employee training measures. When properly implemented, risk management plans help prevent chemical releases and minimize their potential impacts at facilities that store large amounts of hazardous substances or flammable chemicals. Facilities are required to update and resubmit their risk management plans at least once every five years. These plans are used by EPA and other emergency responders to assess chemical risks to nearby communities and prepare for emergency responses.

Oregon Landowner Violated Clean Water Act

This spring, Martin Nygaard and Nygaard Land, LLC, will embark on a major wetland restoration effort, covering 72 acres of a formerly wooded property owned and cleared by Mr. Nygaard, east of Airport Lane and west of Highway 101 in Warrenton, Oregon. Work was originally scheduled for last fall, but heavy Autumn rains pushed the restoration activities back until spring. Work at the site will involve heavy equipment working in the fragile wetland habitat to remove culverts and other structures, while also restoring filled tidal channels.

The project is part of a federal Clean Water Act settlement between the EPA, Mr. Nygaard and Nygaard Land, LLC, to resolve clean water act discharge violations on the property. The alleged violations include discharging dredged or fill material into wetlands and other waters of the United States without an Army Corps of Engineers Clean Water Act Section 404 permit.

While a large portion of the site will be left to recover naturally, active re-vegetation will occur on just over 2 acres, including restoring an additional ½ acre of tidal channels that run through the site. Along with agreeing to perform the restoration project and doing the streambank repairs, Mr. Nygaard will pay a $62,924 penalty.

The site’s wetlands and tidal channels are connected to the Lewis and Clark River, which flows into Youngs Bay, then into the Columbia River, and ultimately into the Pacific Ocean. The river is home to bottom-feeding sturgeon, which is a popular sport fish in the area. It is also home to an extensive salmon repopulation program. The river also supports runs of wild steelhead and cutthroat trout. Each of these species depends on cold, clean, oxygen-rich water to survive and use tidal channels and wetlands for feeding and rearing their young.

This is not the first time Mr. Nygaard and his companies have experienced regulatory transactions with both state (Oregon Department of Lands) and federal (Army Corps of Engineers) authorities. The state and Corps elected to refer this case to the EPA based on multiple past violations by the Nygaard family’s companies, including wetland fills near their stockyard in Hammond (OR) in 2009 and on a Seaside (OR) property in 2007.

Wetlands are important features in the Oregon landscape that provide many benefits for people, fish, and wildlife. These include: Protecting and improving water quality, providing fish and wildlife habitat, storing floodwaters, and maintaining surface water flow during hot, dry summers.

MPCA Reaches Settlement with Hibbing Aircraft Refinisher on Air-Quality Violations

The Minnesota Pollution Control Agency (MPCA) has signed an agreement with Midwest Aircraft Refinishing of Hibbing, Minn. resolving air-quality violations. The company agreed to correct the violations and will pay a $25,000 civil penalty.

The violations stem from the company’s failure to get a required air quality permit from the MPCA before starting up a paint line for aircraft and aircraft parts in 2010. It did not apply for the proper permit until August, 2016; the MPCA is now processing that application.

MPCA permits are designed to protect human health and the environment by limiting pollution emissions and discharges from facilities. When companies operate without the required permits, the resulting pollution can be harmful to people and the environment.

In addition to applying for the permit, the company also agreed to submit all required notifications and compliance reports within 90 days of the agreement’s signing (January 9, 2017), and to operate under the pollution-control requirements of its permit.

Chinese Air Pollution Linked To Respiratory And Cardiovascular Deaths

In the largest epidemiological study conducted in the developing world, researchers found that as exposures to fine particulate air pollution in 272 Chinese cities increase, so do deaths from cardiovascular and respiratory diseases.

The researchers reported their results in "Fine Particulate Air Pollution and Daily Mortality: A Nationwide Analysis in 272 Chinese Cities," published online ahead of print in the American Thoracic Society's American Journal of Respiratory and Critical Care Medicine.

"Fine particulate [PM2.5] air pollution is one of the key public health concerns in developing countries including China, but the epidemiological evidence about its health effects is scarce," said senior study author Maigeng Zhou, PhD, deputy director of the National Center for Chronic and Non-communicable Disease Control and Prevention, Chinese Center for Disease Control and Prevention. "A new monitoring network allowed us to conduct a nationwide study to evaluate short-term associations between PM2.5 and daily cause-specific mortality in China."

The researchers found:

The average annual exposure to PM2.5 in the Chinese cities was 56 micrograms per cubic meter (μg/m³) —well above the World Health Organization air quality guidelines of 10 μg/m³.
Each 10 μg/m³ increase in air pollution was associated with a 0.22% increase in mortality from all non-accident related causes.
Each 10 μg/m³ increase in air pollution was associated with a 0.29% increase in all respiratory mortality and a 0.38% increase in chronic obstructive pulmonary disease (COPD) mortality.
Mortality was significantly higher among people age 75 and older and among people with lower levels of education.
The association between PM2.5 levels and mortality was stronger in cities with higher average annual temperatures.

The researchers speculate that differences in educational attainment may result in environmental health inequalities and access to health care that affects mortality. In warmer cities, the authors hypothesize residents may spend more time outdoors and open windows, increasing their exposure to PM2.5.

The researchers said their study suggests a weaker association between increases in PM2.5 and mortality than studies conducted in Europe and North America. They suggest a number of possible explanations for this difference, including that in most Chinese cities there was a plateauing of mortality at the highest levels of pollution and the components of PM2.5 pollution in China may be less toxic than the components in Europe and North America. Crustal dust from arid lands and construction make up more PM2.5 pollution in China than it does in Europe and North America.

In 2013 China began introducing PM2.5 monitoring in urban areas. The current study analyzed available data between 2013–15. For nearly half the cities in the study, there was only one year of PM2.5 data available, and the authors note that a limitation of their study is that it does not look at the cumulative effect of PM2.5 over many years.

"Our findings may be helpful to formulate public health policies and ambient air quality standards in developing countries to reduce the disease burden associated with PM2.5 air pollution," said study co-author Haidong Kan, MD, professor of public health at Fudan University in China. "Further massive investigations, especially looking at the long-term effect studies, are needed to confirm our results and to identify the most toxic components of PM2.5 in China."

New Framework to Reduce Nutrients in Lake Erie Basin

The State of Ohio has released the framework that is being used to reduce phosphorus entering Lake Erie under the Western Basin of Lake Erie Collaborative Agreement, which was signed in June 2015 by Ohio Lt. Governor Mary Taylor, Michigan, and Ontario with a goal of reducing phosphorus loading to Lake Erie by 20% by 2020 and 40% by 2025.

This framework gives Ohio a jump start on U.S. EPA’s and Environment and Climate Change Canada’s deadline to develop a state Domestic Action Plan required under the binational Great Lakes Water Quality Agreement by February 2018.

Action items being implemented focus on prioritizing and assessing watersheds within the western Lake Erie basin; furthering the use of nutrient best management practices in agriculture and at point-source discharges; identifying and fixing failing home septic systems; and improving the coordination of programs and funds being spent in the basin. Since 2011, the State of Ohio has invested more than $2 billion in Ohio’s portion of the Lake Erie Basin for both point source and nonpoint source nutrient reduction and drinking water treatment.

The Ohio Lake Erie Commission will be coordinating the implementation of the framework with Ohio EPA, Ohio Department of Agriculture (ODA), Ohio Department of Health (ODH) and Ohio Department of Natural Resources (ODNR). Each agency will be accountable for implementing their respective areas of authority included in the framework to meet the overall 40% reduction.

The adaptive management process is central to the long-term implementation of the framework. This means that water quality monitoring, sampling and nutrient management practices are being developed, evaluated and adjusted as circumstances change in order to meet the goals of the Collaborative. Verification that implemented programs are working to reduce nutrients from entering the lake will be key over time as the state moves towards its goal.

The framework was developed with input from various stakeholder groups and state agencies and is available at epa.ohio.gov/Portals/33/documents/WLEBCollaborative.pdf and on the respective state agency websites.