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2018-12-12_REVISION - M2018016 (7)
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2018-12-12_REVISION - M2018016 (7)
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Last modified
12/27/2024 7:10:03 AM
Creation date
12/12/2018 2:16:33 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M2018016
IBM Index Class Name
Revision
Doc Date
12/12/2018
Doc Name Note
Impact Economic Assessment
Doc Name
Objection
From
Emily S. Andrews, Ph.D.
To
DRMS
Type & Sequence
AM1
Email Name
PSH
Media Type
D
Archive
No
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' rangeland proposal includes descriptive information on re-vegetation, site drainage, <br /> g P P P g � g • <br /> ' and weed control. The proposal indicates that the reclamation efforts will be <br /> successful when sufficient vegetation is established and sufficient to prevent erosion <br /> and noxious weeds are not present'in significant quantities'. The final details of <br /> ' this proposal would form the agreement with DMG for the reclamation bond. <br /> Environmental science literature, however, is less sanguine than the DMRM about <br /> ' the potential for successful rehabilitation. Environmental scientists believe there <br /> are significant risks in any environmental rehabilitation strategy. While we know <br /> more about rehabilitating our environment than gold and silver miners did in the <br /> ' nineteenth and twentieth centuries, mistakes we are paying for still, rehabilitation <br /> remains a risky and expensive undertaking. <br /> ' The risks to imperfect rehabilitation for the proposed gravel pit are great given the <br /> possibility of unintended consequences. According to a key review article by <br /> Hildebrand, Watts and Randal, "Perspective: The Myths of Restoration Ecology" in <br /> ' Ecology and Science: <br /> "Many government policies concerning development and extractive resource <br /> ' use already assume the ability to mitigate ecosystem damage through the <br /> restoration of degraded land or creation of new habitats. However, many <br /> restorations are not successful either in structure (Lockwood and Pimm <br /> ' 1999) or function (Kentula 1996, Zedler and Callaway 1999) when compared <br /> with reference ecosystems.1184 <br /> ' Several problems and myths are addressed.85 One overarching issue raised is the <br /> inability to recognize and address uncertainty. This is consistent with the emphasis <br /> ' in this report on the role of risk in gravel pit operations. In addition, the article <br /> stresses that ecological restoration is trying to accomplish in a matter of years what takes <br /> decades or centuries under natural conditions. <br /> The first myth addresses the idea that ecosystems develop in a predictable fashion <br /> toward a specified, static, end point or climax. Most landscapes are a mosaic of <br /> ' different vegetation types and identifying a single state is not realistic for most <br /> systems. The second myth addresses the idea that the ecosystem process follows a <br /> repeatable trajectory. Uncertainty is implicitly ignored. Failure to accept <br /> ' uncertainty and the dynamic nature of ecological environments can lead to the traps <br /> of the previous myth. The third myth assumes that there is a need to demonstrate <br /> the rapid recovery of disturbed lands in order to have insurance or mitigation <br /> ' performance bonds returned quickly.As most restorations include plantings to get <br /> the ball rolling and stabilize the terrain, it is logical to try to advance the process, <br /> and this is why the practice is so common. Even when successful, certain ecological <br />' 84htt s: www.ecolo andsociet .or vo110 issl art19 ?fbclid=IwAR052Bil6WIS3WLSt <br /> P // gY Y g/ � � / <br />' 48HUkokLT5ReBSUQ7voy5I0nELfLhljXSylm58B5QY <br /> 85 See article referenced for an extensive bibliography of research studies. <br /> 29 <br /> 1 <br />
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