[APWG] Performance Standards for non-riparian reveg/weed management

[Craig Dremann - Redwood City Seed Company]

Dear Wayne and All,

Thanks for your email.  Non-Riparian Weed management or Ecological
Restoration Performance Standards.

SINCE NON-RIPARIAN lands cover probably 95% or more of the land in the
arid West, and maybe 80-90% elsewhere, that it is a very important topic
to discuss.

Having a project a few hours away,  like along I-505 in the Sacramento
Valley, allows a person to periodically view performance standards for a
government sponsored non-riparian project at
http://www.ecoseeds.com/road.test.html

Yesterday, while driving to the California State Gray Lodge wildlife
viewing area at the Butte Sinks and the rice fields along Highway 45 to
see the 1.2 million migrating birds that my wife and I saw, (mostly snow
geese and ducks right now), I measured both sides of the I-505 project,
and both the West and the East side test plots, that after ten years, has
stabilized at 28% native plant cover, and 72% weed cover.

There are perhaps at least several reasons for that:

1) NOT ENOUGH SMALL SCALE TEST PLOTS. Not enough small scale test plots
were planted, to get the 99.5% native cover before the whole two acres was
planted over and over again.  Small scale test plots were done early on,
but they all collapsed into weed patches, and more small scale plots were
not done until the 99.5% native cover could be achieved first.

2.) SKIPPING SMALL TEST PLOT SUCCESSES. When the small scale test plots
failed, the project was converted to the usual plan for non-riparian
areas, which is to use the whole project area as one huge test plot, and
keep replanting that whole area after each failure, every year or two.

3.) SEEDS NOT BROADCAST SOWN. The seeds were sowing in error by drill
seeding, instead of broadcast seeding, and you can still see the rows,
with big spaces between the plants for the weeds to grow.  Plus not enough
seed per acre was sown.

4.) NO OTHER ECOSYSTEM SPECIES SOWN. Only native grasses were sown over
the last decade, and none of the other ecosystem recipe families were
sown, like the poppy family, or the Indian paintbrush family, or the
miner’s lettuce family, or the native clovers, etc.  It is like baking a
cake with only flour, with nothing added for flavoring or to make it rise
or no egg added to hold together.

5.) NO LICENSE WAS GOING TO BE PAID. The idea of the project, was to
invent the successful weed management or ecological restoration techniques
for the I-505 project on the fly, and for free, without Caltrans paying
for a license for the best technologies that was invented.

Caltrans spent $450,000 and a decade on those two acres, with the idea
that whatever restoration or weed management technologies were invented to
get 99.5% weed-free roadsides established by planting local native plants,
that Caltrans could use that technology without paying any licensing fees
per project, on any of their other 55,000 miles of freeway roadsides that
need the same treatment.

Obviously, a ten year performance time period is way too long,  and five
failed attempts for the whole project is not good, and only 28% native
plant cover, and still with 72% weed cover, is a very poor and expensive
performance standard for $225,000 per acre?

KEEP ALL FAILURES,  SMALL SCALE AND CHEAP.  If you are going to fail, and
you ARE going to fail if you are doing a new project in a particular spot
for the first time, it is best to have cheap failures on small scale, with
very small insitu or exsitu test plots failing, and not use the whole
project over a decade, as one big test plot.

For example, some of my exsitu test plots this winter for the 42,000 acre
Riverside County Krat habitat soil, I had failures in some of the pots,
but it was very easy to correct those mistakes in little 4 inch plastic
pots, than if the whole 42,000 acres was planted wrong, and you had to go
back though and make the corrections quickly on 65 square miles?

WHAT ARE YOUR PERFORMANCE STANDARDS? This is why all of the government
agencies that are reading these posts, that will ever sign off on any
non-riparian restoration projects in the future on their lands, should set
up small scale test plots this year.  You absolutely need to test out what
you  are recommending for mitigation for your lands, and see if those
plans with those particular native species at those sowing rates, really
are going to work, at the end of the day.

Any weed management projects or any non-riparian ecological restoration
projects, like pipelines, power lines, oil and gas pads, $42 million
dollar Endangered species habitats in Riverside County, etc., ---Any weed
management or restoration plans need to be pre-tested on a small scale,
and be able to achieve high quality standards, within a few years, for a
reasonable cost per acre.

Once you get close to 95% native cover, you will be able to see quickly,
whether or not you need to get closer to the 99.5% standard that I am
suggesting.

SPEED AND LOWERING COSTS. And once you get to the 95-99.5% stable native
plant cover, then the next challenge will be to increase the speed and
lowering the costs.

As for speed to get to the 95-99.5% native cover, since the I-505 project
has taken a decade to get a stable 28% native cover, so it might take 30
years total to get to 95-99.5%?

30 years is beyond the working life for any agency person who will sign
off on the project, so that time span is totally unreasonable.    Plus if
we multiply the costs so far for the first decade, then the 30 year total
could be over $600,000 per acre?  The maximum time frame needs to be, the
working lifetime of one agency person, which would be 20 years or less, to
get to 95-99.5% native cover for a project.

Also speed is very important for contract law considerations, because most
State contract laws do not allow for projects to drag on for several
years, in order for a contract to perform.

Performances longer than a year or two actually may be illegal under your
State’s or the Federal government’s contract performance laws.  Therefore
you may have to set up annual performance standards in your mitigation,
bond, or restoration contracts, in order to comply with State or Federal
contract laws.

LEGALLY ACCEPTABLE CONTRACT PERFORMANCE  STANDARDS. That is why I am
suggesting 100% weed abatement within the first 12-24  months, and get
that weed-free objective covered as the first part of the project and
contract.  Then 95-99.5% native cover within the next 12-24 months.

LOWERING COSTS PER ACRE. Once you have the 95-99.5% native cover and the
speed issue and the State or Federal contract law issues covered, then you
can start working on the per acre costs.

As you can see from the I-505 project, even setting the price as high as 
$225,000 per acre, there was no economic incentive to either make them
work, or any negative incentive if they failed, because the technologies
that were going to result from the project were going to be given away
instead of licensed by Caltrans.

OFFER TO PAY FOR A LICENSE FOR SUCCESS. By offering to license any
successful weed management or restoration technologies as a separate
contract item, you are offering an economic incentive for success and
there is also an incentive for you not to be offered sketchy technologies
that do not work quickly and efficiently, because there will be no future
licensing fees paid.

Sincerely,  Craig Dremann  (650) 325-7333