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

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Conclusions ~• Some basic logic should be stated to use as guidelines for the formulation of criteria to evaluate revegetation success. First, we have to work within Che current state of our technology. Poorly defined and controversial techni- cal concepts such as diversity or usable producCion cannot be resolved by regu- lation. Secondly, we must accept certain physical restraints on our abilities to obtain large quantifies of data within short enough periods of time for it to be comparable. Thirdly, the best solution is almost always a simple one. Complex solutions become difficult or impossible to apply and generally spawn more complexities. Fourthly, we should be seeking efficient and sound indica- tors of revegetation success. There is no need to analyze multiple parameters that result in redundant :onclusions of success or failure. The tests to be applied only need to compare certain key vegetation expressions to the chosen standards. The concept of using indices of reclamation success is valid and does not presume we can collect and interpret data beyond the state of [he art. A great deal of "free thinking" is needed to conceptualize new ways of evaluating revegetation success. It may be that for areas where a change from premining conditions is desirable, a concept of best available technology could be applied. The revegetation standard could be established for a particular project over time, paying attention to use of the best available reclamation technology for the region and the results obtained. It should be emphasized that the existing proposed procedures for testing success of revegetation are still theoretical and unproven. Civen the fact that most coal mine operators are unlikely to be testing for revegetation suc- cess for several more years, it would be prudent to be more cautious about defining the precise mechanics of testing. The various concepts for ~•~ -14- ;~0 9 '19f7. .,