Public Comments Open on Upper Clark Fork Strategic Plan

Read the Strategic Plan button
May 17, 2023

The State of Montana’s Superfund cleanup of legacy mining pollution from the upper Clark Fork River corridor – between Warm Springs Creek and Garrison – has been underway for 13 years. In that time, the State has removed metals-laced soils from roughly 14 of the project’s 47 river miles and is now coming to terms with two facts: 1) the now-clean sections cost more money to remediate than expected; and 2) going forward, the current approach will exhaust the available funds and leave many river miles, and acres of floodplain, unremediated.

To address the situation, the State of Montana revisited and updated past analyses, refined its guidelines, and developed a new approach that agencies hope will bring cleanup activities on all the remaining phases into line with budget realities. Before finalizing and implementing this strategic plan, the State wants to hear from you.

Does the plan deliver the best possible outcome for the river and the people, fish, and wildlife it sustains?

Talking Points for Public Comment

The plan is currently open for public comment until May 21. Read on for some of CFC’s talking points you should feel free to adapt, then  email your comments to the Montana Natural Resource Damage Program.

HUMAN HEALTH: We appreciate that cleanup of Arrowstone Park – a popular public park in Deer Lodge – has been bumped up as a priority on the cleanup timeline. In that vein, we would like the plan to expedite cleanup on other reaches and river access points that see high-use and are exposing people unknowingly to dangerous toxins. Furthermore, we would like to see “protecting human health” highlighted as an explicit goal in the new plan.

STREAMBANK DESIGN: We are excited that the State is promoting streambank designs and treatments that promote ecological function and fish habitat. For example, the recent use of large wood for bank construction is an improvement over previous designs that relied heavily on engineered coir logs (see photos below). Incorporating new data into cleanup as research is completed is key and we encourage the State to implement an adaptive management approach in practice.














RIVER FUNCTION: We would like to see river function fully integrated into the plan as a component of the design process. A fully restored, ecologically functioning river system requires connected and diverse suites of aquatic habitats. Actions that encourage floodplain connectivity and promote off-channel and instream habitat development are the foundations of system resilience.

FUNDING: This new plan is based on the recognition that currently available funds are insufficient for maintaining the waste-removal approach of the prior cleanup phases. As a result, the plan proposes to stretch the settlement dollars to Garrison by leaving more waste in place along the way, where it will sit exposed to Montana’s dynamic climate. Another approach that doesn’t cut corners on protecting human health and restoring fish and wildlife habitat would be to maintain the remediation goals of previous mainstem cleanup phases and collect additional funding – through “the round robin” provision – that can be made available if money runs out.

BOTTOMLINE: This is a once in a lifetime opportunity to do a big one right for the river and the people, fish, and wildlife it sustains. The State’s strategic plan should set the tone for scaling the funding to match the public’s aspirations for the river.

Send Public Comments Now

It’s crucial that the State hears the community’s concerns before May 21. Please provide comments for the Montana Natural Resource Damage Program via e-mail at The subject line must contain “CFROU Strategic Plan Comments.”

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