Roger Soocier: While it may not be practical to use material which has been in spoil 

 banks for a great amount of time for wetlands creation, spoil banks can be degraded 

 even though the material may have experienced a 50 percent volume reduction. This 

 reduces the effects of the spoil banks themselves, including accelerated subsidence 

 in the immediate area, and blockage of surface drainage and overland flow. 



Murray Hebert: I hear many complaints from permit applicants that requirements are 

 overly broad and restrictive and, in many cases, counterproductive. 



John Woodard: As a large land owner, my company is usually able to work out such 

 problems. Smaller land owners and independent operators may have more problems 

 because they lack areas in which to mitigate or the resources to accomplish 

 mitigation. As environmental concerns increase it has become a more difficult 

 process to obtain permits, but we have been generally successful if we modify the 

 project to obtain the permit. 



Michael Lyons: I do not think regulatory programs have been overly restrictive. Often 

 Federal agencies suggest that the feasibility of directional drilling or backfilling 

 should be studied but do not absolutely require either. If these would be absolutely 

 required, it may be overly restrictive. Backfilling, for example, may be effective In 

 some areas and not others. 



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