2001-12-11_PERMIT FILE - C1981010A (7)

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© ing and in [erpreting such data. The system should rely instead on the most • efficient and dependable indicator of success. Such a reclamation index would provide objective evidence of success or failure. There is no need to subject every reclaimed site to in-depth statistical analyses of multiple parameters if a single parameter can reasonably provide the basis of a valid conclusion. It is nearly inconceivable to Chink of a range survey without production measurements. What we need [o accomplish, however, is not a range survey, nor is it a research project to include detailed and theoretical analyses. For the purpose of demonstrating revegetation success or failure, evaluations of herbaceous cover, shrub and tree density, and composition by cover and density are technically adequate and are compatible with both the Federal and Colorado statutes. The current regulatory approaches to testing for revegetation success are far too theoretical and result in making the problems even more complex. The determination of species diversity should rely on tested and well defined concepts. Plan[ composition by cover is a parameter Chat has been used for years and which allows an interpretation of the desirability of the i• ` contributing species. The Colorado Mined Land Reclamation Division regulations as proposed in December, 1979, included an evaluation of diversity using composition. The proposed regulations stated: "In order to demonstrate [hat the species diversity and seasonal variety of the vegetation on the reclaimed area meet the requirements of 4.14.8, the operator shall provide the Division with information on the herbaceous species composition of both [he reclaimed area and the undisturbed vegetation. Species composition may be calculated in terms of either rela- tive productivity or frequency. These parameters shall be mea- sured separately for each species contributing five percent (5%) Y -11- ~i t:-,, 2 'i9fl2 •., .. -,-