Montana's Natural Resource Damage Program should not fund the "Restoring Native Plant Diversity" proposal

[Background: The State of Montana has won nearly 300 million dollars in a legal settlement with Arco-British Petroleum for damages to natural resources in the upper Clark Fork River basin of western Montana. Montana's Natural Resource Damage Program funds proposals for projects that replace or restore resources in the affected area. This is a copy of a comment I submitted to the NRD Program on what I believe is a project that should not be funded.]

To: Members of the Upper Clark Fork River Basin Remediation & Restoration Advisory Council

Carol Fox, Restoration Program Chief, Montana Natural Resource Damage Program

RE: Comments on the “Restoring Native Plant Diversity Project,” a project submitted by Dr. Richard Douglass of Montana Tech, Butte Montana

I strongly disagree with the NRDP staff recommendation to fund the “Restoring Native Plant Diversity in the UCFRB” for more than $800,000. While planting flowers on the Butte Hill might make it a prettier place, this project is a poor use of limited NRD funds.
• The better part of a million dollars would be better spent on priorities such as removing tailings that pollute Silver Bow Creek, putting a thicker soil cap on Butte’s “reclaimed” mine dumps, or simply buying plants for restoration;
• The Native Plant project uses highly uncertain and very experimental methods that make it a big gamble; and
• The project management skills and experience of the Native Plant project team appear to be woefully inadequate for successful completion of a project of this scope.

I realize this is a rather long document, but when $800,000 is at stake, I think it is worth deep consideration.

Introduction: My Background

Please consider my experience when evaluating this letter of comment. I was a charter member of the Advisory Council, serving two terms as Governor Racicot’s appointee. During my tenure, I was especially active in promoting the council’s educational mission. As a Science & Technology Studies scholar, I have spent nearly 30 years critically evaluating policy-related issues such as environmental restoration.

Since moving to Walkerville (on the hill above Butte) nearly 20 years ago, I have spent thousands of hours on every aspect of Superfund remedy and restoration in the UCFRB—including non-paid volunteer work for the Advisory Council, EPA “TAG” groups, Trout Unlimited, and the Clark Fork Watershed Education Program. This includes a “boots on the ground” approach. I have floated Silver Bow Creek and the Clark Fork River, hiked all over the Butte Hill and its mine dumps, and toured every Superfund site from Butte to Missoula.
As a member of the Advisory Council, I took seriously Chairman Jim Flynn’s concern that there is far too little money to fund every pie-in-the-sky project that comes along. NRD funds must be spent cautiously and strategically.

The Native Plant Project is a Big Gamble

Because of my close association with Butte and Montana Tech, it pains me to criticize this project. Rick Douglass is a good small mammal biologist. And, after all, I like seeing “pork” come to my town and institution as much as the next person. Even a pork barrel project, however, should have reasonably certain outcomes. But this is a bad project and a waste of money.

This project is a big gamble and raises significant questions:
• What are the ecological outcomes of this project?
• How is it that flowering plants (forbs) are superior to grasses for mine waste restoration?
• Will forbs result in more birds and mammals on the Butte Hill?
• Will there be measurably less sediment or polluted run-off from the Butte Hill to Silver Bow Creek?
• Is a production-scale greenhouse reasonably effective at Tech’s high elevation, and what will it require as a subsidy in terms of heating, lighting, and temperature control?
These questions should have been stated as measurable outcomes in the proposal. Instead, the proposal reads like a request for research support, and not as a demonstration of proven techniques with reasonably certain outcomes.

The technical feasibility of/likelihood of success for the Native Plant project is very low:

• The project proposes developing “forb sods.” This is not a recognized or proven concept for establishing flowering plants under wild, untended conditions. Forb sods are a proven, albeit extremely expensive and high maintenance, technique for turf grasses and for wildflowers under carefully tended yard/garden conditions.
• Even in a yard or garden – ideal conditions with high maintenance – survival of forbs planted using sod mats can be very low.
• Mine waste soils pose a huge challenge for establishing any sort of vegetation, let alone wildflowers. What evidence is there that flowers will grow on mine waste?
• The project proposes using tissue culture (i.e. cloning). Cloning wildflowers is extremely difficult, uncertain, cost- and labor-intensive. According to the literature: “[Tissue culture] is not without its problems. First of all, it takes a great deal of research and experience to determine the best ratio of different hormones and other factors to get a particular species to respond well. The time and equipment needed to run a lab make them prohibitive for even most nurseries… Characteristics such as variegation, which are often genetically unstable to begin with, can be lost in culture.” William Culina, Growing and Propagating Wildflowers (Houghton Mifflin, 2000): 244.
• The project proposes collecting seed from wildflowers. This is difficult at best, especially at the volumes needed for this project.
• Successfully propagating wildflower seeds is highly uncertain. The literature emphasizes this serious problem: “Significant results of a seeding project can take 3 to 5 years; perennial grass and forb seed often lies dormant in the soil until climate conditions are appropriate for germination.” Kim Goodwin and Roger Sheley, “Revegetation Guidelines for Western Montana: Considering Invasive Weeds” (Missoula County Weed District, 2003): 46.
• The proposal does not seem to acknowledge the build-up of herbicide on mine waste soils that have been reclaimed and revegetated with grasses, such as those that dominate the Butte Hill. What will the effect of these residual herbicides be upon the proposed establishment of forbs? Again, this is a well-known problem: “Unnecessary broadcast herbicide treatments will injure or permanently damage a remnant or remaining native forb component. If entirely removed, this critical feature is impossibly difficult and expensive to reestablish.” Kim Goodwin and Roger Sheley, “Revegetation Guidelines for Western Montana: Considering Invasive Weeds” (Missoula County Weed District, 2003): 7.
• The notion of “weed resistant forbs” has been well studied from the point of view of established forb communities. This project, however, proposes investigating whether forbs can invade established weed communities, and whether forbs can out-compete weeds under restoration conditions. Are there previous studies of this phenomenon, or is this a fundamentally new and highly experimental research area?
• What functional influence, if any, is conferred by species diversity? This is highly uncertain, and perhaps a matter of faith and not science. If you believe in it, then it's obviously good. Alternatively, the functional implications of species diversity, if any, are unknown. Do we need this plant diversity? Can we afford it? One plant revegetation expert summed it up this way: “Everyone would agree that 6 adapted species are better than 2 or 3. The trouble is finding 4 or 5 well-adapted species, not several not-so-well-adapted species, in which case a few better adapted species would be superior.”
• In my brief review of the literature, it is clear that tree and shrub diversity confers significant ecosystem benefits to animals and birds. The benefits of adding flowers to grasses, however, are very low.

The economics of the Native Plant project do not measure up:

• Even if successful, this project would restore just 3 acres at a cost of more than $250,000 per acre.
• Assume this project succeeds and could be scaled up to the thousands of acres needing restoration in the Clark Fork. Flowers (forbs) must be planted densely to matter. With 43,560 square feet in an acre, if you plant one every 4 square feet, that's 11,000 plants per acre. At $2 for each one planted that's $22,000 for one small element of revegetation on a single acre. How many survive is another matter, but if you seed for the basic objectives of erosion control, forage, habitat, and aesthetics, competition will take its toll assuming a grassland soil (a good soil—our revegetation sites are poor, mine waste soils). Even on rocky sites where forbs might do better than grasses and stress tolerance replaces competition in organizing plant communities, the transplanting itself is difficult and expensive, and there will be high mortality in the establishment phase.
• The Project Team should well appreciate this fact, since it has already placed forb mats in un-watered areas where they failed.
• The original proposal called for nearly a half-million dollars in “Contracted Services.” In reviewing the budget, it seemed unclear exactly how that $456,956 for “Contracted Services” was to be allocated and spent.
• Funding includes three years at approximately $54,000 per year (including benefits) for a greenhouse technician. Is this primarily a greenhouse plant propagation project or a mine waste restoration project? Is this a full-time position for the project, or is this just a partial salary for a technician that allocates considerable time to other projects?
• $800,000 would buy a lot of flowers from commercial greenhouses to plant the Butte Hill. Is this project an expensive and wasteful duplication of existing services?
• Is it feasible and cost-effective to operate a production greenhouse at Montana Tech’s elevation of approximately 6,000 feet above sea level? The heating and lighting costs will be exorbitant.

The Project Team appears to lack the experience and expertise to make this project successful:

• This project hinges on a large new greenhouse, but there is as yet no greenhouse in sight. The project team’s leader received approximately $300,000 more than a year ago for a greenhouse. The original design proved inadequate under external review by knowledgeable experts. The greenhouse had to be redesigned. Since then, the greenhouse has missed one start date after another. The Project Team let an entire growing season slip past without accomplishing its goal. The greenhouse project is now allegedly $100,000 over budget and no construction has begun.
• Receiving funding for projects such as the greenhouse is admirable, but the Project Team must follow through in a responsible, timely manner. The greenhouse project, if done competently, could lead to future funding and lay down a track record. But no NRD funds should be allocated until the Project Team demonstrates a clear ability to follow through on projects.
• Montana Tech’s old greenhouse has been allowed to slip into a state of abysmal disrepair. Temporary greenhouses could have been erected but were not. The Native Plant project proposal clearly stated that “some aspects of the project are already underway…” How is this occurring without a greenhouse? What, exactly, has “been underway?”
• The Project Lead – the key person on the project – is a small mammal biologist with no experience in mine waste revegetation.
• Other project team members also lack effective experience in mine waste revegetation. An experienced revegetation expert, in commenting on this project, stated “It’s amateur hour, at best.”
• The key person and other project members appear to have no credible experience (i.e. publications) with tissue culture of wildflowers.
• NRDP worked closely with the USDA Bridger Plant Materials Center and had good success with revegetating mine waste with several grass species in addition to forbs such as fuzzytongue penstemon and common snowberry. There seems to be no acknowledgement of this prior work in the project proposal.
• The project team seems to lack awareness of earlier efforts to establish forbs on herbicide sprayed sites. Cf. James S. Jacobs, Susan R. Winslow, and Monica Pokorny (2007), “The effect of five pre-emergence herbicides on emergence and establishment of four native wildflowers,” Native Plants Journal 8: 224-231. This or similar prior work is not described in the project proposal.
• The project team has allegedly overstated the commitment of partners such as Butte-Silver Bow government to subsidize this project with watering and other high-maintenance activities. What, exactly, is local government willing to do in order to subsidize and support this project?

Conclusion: Start Small, Demonstrate Results, then Go For It

While I understand that the NRDP staff and Butte want an assured source of greenhouse plants for revegetation, it’s not worth the gamble for more than $800,000 of precious and limited NRD funds. The NRD fund is not a goose that lays golden eggs. When the money is gone, it’s gone forever. You don’t write a high-stakes gambler a blank check.

The problems with this proposal run far deeper than I have documented here. For example, if you take time to read the entire proposal, it appears to be two separate and disjointed requests for money—one from Montana Tech and one from UM- Missoula. If this is the case, then each entity should apply separately.

This project does pose an intriguing possibility that might someday be realized. But why rush into a million dollar project without laying a solid foundation?

If this project is funded in the current cycle, then the scope of work should be clearly focused, the amount of money greatly reduced, and annual measurable goals established to insure good fiscal management.

Better yet, the project team should apply for one or more Project Development Grants. This would give them the time and experience to develop the experimental methods and expertise to tackle a larger and more ambitious project. Though this project might look like a pig in a poke today, it could well prove to be achievable if the project team is willing to be patient, demonstrate competence, and take the long view.

I appreciate the work of the many volunteers on the Advisory Council and the dedication of the professional staff at NRD. Thank you for this opportunity to submit public comment.