Opinion for the court filed by Circuit Judge MIKVA.
[516]*516Dissenting opinion, in which Circuit Judges MacKINNON, ROBB and WILKEY join, filed by Circuit Judge TAMM.
Dissenting opinion filed by Circuit Judge MacKINNON.
MIKVA, Circuit Judge:
This case presents a narrow question concerning the relative authority of the Secretary of the Interior and the states in the administration of the Surface Mining Control and Reclamation Act of 1977 (Surface Mining Act, or Act), 30 U.S.C. §§ 1201-1328 (Supp. I 1977). The United States District Court for the District of Columbia held that the Act gives the Secretary rulemaking power to prescribe minimum information requirements for permit applications submitted to state regulatory agencies. We conclude that the Act does give the Secretary this authority, and accordingly affirm the judgment of the district court.
I. THE ISSUE PRESENTED
The Surface Mining Act embodies Congress’ recognition that “the expansion of coal mining to meet the Nation’s energy needs makes even more urgent the establishment of appropriate standards to minimize damage to the environment and to productivity of the soil and to protect the health and safety of the public.” Act § 101(d).1 After an initial period of direct regulation by the Secretary, the Act contemplates a continuing partnership between the states and the federal government, with the Secretary providing oversight, advice, and back-up authority, and the states bearing the major responsibility for implementation of the Act. The crucial step in accomplishing this transition is a state’s submission of its proposed regulatory program to the Secretary for his approval. The Secretary may only approve the state program if he finds it capable of carrying out the exacting provisions of the Act, and consistent with his own regulations. Act § 503(a).
Whether regulation is under federal authority or an approved state program, persons wishing to engage in surface mining must obtain a permit from the regulatory authority. Act § 506(a). Permits may not be granted unless the applicant successfully carries the burden of establishing full compliance with the applicable program, and the applicant must submit detailed information from which the regulatory authority and interested citizens may judge compliance. Act §§ 510(b), 507(b). Section 507(b) lists a large number of items which, “among other things,” a permit application must contain.
The Secretary’s regulations for the permanent regulatory program, issued in March 1979, include rules concerning the content of acceptable state program submissions. See 44 Fed.Reg. 14,902, 15,312 (1979) (codified at 30 C.F.R. pts. 700-890 (1979)). These regulations specify minimum information that a state must require in a permit application, information which extends beyond the explicit information requirements detailed in the Act itself. See 30 C.F.R. pts. 778-784 (1979).
Various interested persons filed actions in the United States District Court for the District of Columbia, challenging the permanent regulations.2 Appellant attacked the Secretary’s information requirements in sweeping terms, denying that the Secretary possessed any power to promulgate regulations on that subject. Appellant also criticized numerous individual regulations as, for various reasons, beyond the scope of the Secretary’s authority. In February 1980, [517]*517the district court reached a decision on some of the many issues presented in the cases consolidated before it. The court concluded that “the structure of the Act, the general grants of rulemaking authority, and section 501(b) support the Secretary’s power” to issue regulations requiring the states to demand more information than the statute itself requires. In re Permanent Surface Mining Regulation Litigation, Civ.No. 79-1144, mem. op. at 31 (D.D.C. Feb. 26, 1980). The district court entered a final judgment in accordance with rule 54(b) of the Federal Rules of Civil Procedure on that portion of its decision dealing with the Secretary’s rulemaking power so that Peabody Coal Company could appeal that determination without delay. On July 10,1980, a panel of this court reversed the judgment of the district court. Upon the Secretary’s petition, we granted rehearing en banc and vacated the panel decision.
An illustration or two will suffice to demonstrate the absolute character of appellant’s claim. Section 522(e)(5) of the Act forbids new surface coal mining operations “within three hundred feet from any occupied dwelling, unless waived by the owner thereof.” The explicit information requirements of the Act, however, do not mandate that a permit application include any information from which it can be ascertained whether such owners have consented to the proposed operations. The Secretary’s regulations require the operator to submit evidence of such consent with the permit application. 30 C.F.R. § 778.16(c) (1979). Congress also directed the Secretary to promulgate “regulations directed toward the surface effects of underground coal mining operations,” Act § 516(a), and to make such modifications in the requirements of the Act “as are necessary to accommodate the distinct difference between surface and underground coal mining,” Act § 516(d). Understandably, the explicit information provisions of the Act do not anticipate all of the Secretary’s modifications. See, e. g., 30 C.F.R. § 784.14(d) (1979). Yet appellant denies that the Secretary has the power to issue any regulations requiring permit applications to include information that may be necessary to ensure compliance with section 522(e)(5) or the Secretary’s modifications under section 516, unless that information is already demanded explicitly by the Act. Appellant insists that only the states have the power to increase the information requirements of the Act.
Our inquiry is narrow. We are called upon to determine only whether the Secretary has rulemaking authority to require that permit applicants submit any items of information beyond those enumerated in the Act.3 The partial summary judgment we review does not extend to the question whether the regulations actually promulgated by the Secretary are permissible exercises of that authority. Challenges to individual regulations are being separately adjudicated in the court below, with varying results.4 Appellant insists both in [518]*518briefs and in oral argument to this court that the Secretary has no power to prescribe information requirements for permit applications.5
We have, therefore, no occasion to assess the Secretary’s justifications for individual regulations. We neither approve nor disapprove any regulation, and our decision today in no way forecloses subsequent timely challenges to those regulations, either here or in the court below.
II. THE ROLES OF THE STATES AND THE SECRETARY IN ADMINISTERING THE SURFACE MINING ACT
Congress chose a special kind of regulatory structure for the Surface Mining Act, in which the federal government shares administrative responsibility with the states. Rather than reposing all decisionmaking power with the Secretary of the Interior, Congress afforded the states an opportunity to propose regulatory programs of their own, conforming to the requirements of the Act and to regulations promulgated by the Secretary.6 Under a state program, the state makes decisions applying the national requirements of the Act to the particular local conditions of the state. The Secretary is initially to decide whether the proposed state program is capable of carrying out the provisions of the Act, but is not directly involved in local decisionmaking after the program has been approved.
The essence of appellant’s arguments against the Secretary’s claimed rulemaking power is that it does violence to the special allocation of decisionmaking power effected by the statute’s structure. Because the state has the “primary governmental responsibility” under an approved state program, Act § 101(f), appellant urges that the Secretary has no power to decide what information the state should have before it makes its decisions.
The Secretary responds that this argument exaggerates the independence of the state’s role in administering an approved [519]*519program and slights the Secretary’s responsibilities in approving and overseeing such a program. Appellant, according to the Secretary, would place an unjustified limitation on his approval role by denying his right to ask the states to seek more information in the permit application than explicitly required by the statute.
A. The State’s Role in Administering an Approved State Program
In an approved and properly enforced state program, the state has the primary responsibility for achieving the purposes of the Act. First, the state is the sole issuer of permits. In performing this centrally important duty, the state regulatory authority decides who will mine in what areas, how long they may conduct mining operations, and under what conditions the operations will take place. See Act §§ 506, 510. It decides whether a permittee’s techniques for avoiding environmental degradation are sufficient and whether the proposed reclamation plan is acceptable. Act § 510(b). The state sets the amount of the bond to be posted by the operator, and inspects the mine to determine compliance. Act §§ 509, 517. When permit conditions are violated, the state is charged with imposing appropriate penalties. Act § 518(i).
Finally, it is with an approved state law and with state regulations consistent with the Secretary’s that surface mine operators must comply. See Act § 503(a), 518(i). Administrative and judicial appeals of permit decisions are matters of state jurisdiction in which the Secretary plays no role. Act § 514.7
As long as the state properly enforces its approved program, it is the exclusive “on the scene” regulatory authority.8 It is, essentially, the entity that applies the general standards of the Act to the particular geographical and geological circumstances of the state. Congress cited the flexibility achieved in this allocation of regulatory functions as its reason for leaving “primary governmental responsibility” with the states. Act § 101(f).
B. The Secretary’s Role in Approving and Overseeing a State Program
Once the state has assumed all these functions, the Secretary’s role is primarily one of oversight. The statute requires occasional federal on-site inspections “to evaluate the administration of approved State programs.” Act § 517(a). Interested persons may also report suspected violations of the Act or of state-imposed permit conditions to the Secretary, and if he has reason to believe the allegations he must notify the state regulatory authority. Act § 521(a). If the state fails to take appropriate action, the Secretary is to order a federal inspection of the mine site. Id. Violations that threaten imminent environmental harm are to be halted by a cessation order from the Secretary. Act § 521(aX2).
The Secretary’s oversight function is shared in part by the public, which is given the right to sue in federal court, to compel compliance with the state program and its permits. Act § 520. Both the Secretary and the public have access to a large body of information, including nonconfidential permit application information, to facilitate this enforcement role. Act §§ 507(e), 517(f); see 30 C.F.R. § 840.14 (1979).
The Secretary’s ultimate power over lax state enforcement is set out in section 521(b) of the Act. When the Secretary determines that violations result from a state’s lack of intent or capability to enforce the state program, he is to enforce permit conditions directly, and to take over the entire permit-issuing process himself.
[520]*520Direct intervention by the Secretary in the operation of state regulatory programs is clearly intended as an extraordinary remedy. See H.R.Rep.No. 218, 95th Cong., 1st Sess. 129 (1977), reprinted in [1977] U.S. Code Cong. & Ad. News 593, 661. The Secretary’s primary means of guaranteeing effective state programs lies in his approval function at the beginning of the process.
A state wishing to take over regulatory responsibility for administering the Act w.ithin its borders must submit a proposed state program to the Secretary for his approval. Act § 503. The Secretary may only approve a program if he determines that the state “has the capability of carrying out the provisions of this Act and meeting its purposes.” Act § 503(a). The proposed state program must include “a State law which provides for the effective implementatio[n], maintenance, and enforcement of a permit system,” Act § 503(a)(4), and “rules and regulations consistent with regulations issued by the Secretary pursuant to this Act,” Act § 503(a)(7). The Secretary is required to hold a public hearing, to solicit the views of other federal agencies, and to obtain the written concurrence of the Environmental Protection Agency with respect to certain aspects of the state program. Act § 503(b).
C. Congressional Intent and the Tradition of State Regulation
A major premise of appellant’s argument is that Congress deliberately minimized the federal role in administration of the Act out of deference to state prerogatives. Appellant denies that the statute is based primarily on environmental concerns, and insists that an “even more fundamental purpose of the Act ... is to preserve the federal structure of our nation and to leave with the states primary responsibility for this land-use regulation.”9 Congress’ special solicitude for the states’ traditional role in controlling local land use, appellant claims, prevented Congress from delegating to the Secretary authority to dictate permit information requirements to the states.
Our own examination of the Act and its legislative history reveals a very different congressional assessment of the tradition of state surface mining regulation. The legislative history contains significant expressions of congressional dissatisfaction with state mining regulation practices:
[Djespite claims from some quarters that state reclamation laws have improved so significantly that Federal mining standards are no longer needed, the hearing record abounds with evidence that this is simply not the case. For a variety of reasons, including the reluctance of the State to impose stringent controls on its own industry, serious abuses continue.
H.R.Rep.No. 218, 95th Cong., 1st Sess. 58 (1977), reprinted in [1977] U.S.Code Cong. & Ad. News 593, 596. Congress preferred to leave primary governmental responsibility with the states “because of the diversity in terrain, climate, biologic, chemical, and other physical conditions in areas subject to mining operations,” Act § 101(f), but skepticism about the states’ willingness to implement the federal program justified the Secretary’s continuing oversight role.
While it is confident that the delegation of primary regulatory authority to the States will result in adequate State enforcement, the committee is also of the belief that a limited Federal oversight role as well as increased opportunity for citizens to participate in the enforcement program are necessary to assure that the old patterns of minimal enforcement are not repeated.
H.R.Rep.No. 218, 95th Cong., 1st Sess. 129 (1977), reprinted in [1977] U.S.Code Cong. & Ad.News 593, 661.
Congress announced its willingness, “wherever necessary, [to] exercise the full reach of Federal constitutional powers to insure the protection of the public interest through effective control of surface coal mining operations.” Act § 102(m). Nationwide standards were “essential in order to insure that competition in interstate commerce among sellers of coal produced in [521]*521different States will not be used to undermine the ability of the several States to improve and maintain adequate standards on coal mining operations within their borders.” Act § 101(g).10 Congress’ concern about the states’ ability to withstand economic temptation extended to the very area of permit information with which we are dealing:
Experience has shown that without a thorough and comprehensive data base presented with the permit application, and absent analysis and review both by the agency and by other affected parties based upon adequate data, th[i]s judgment has often traditionally reflected the economic interest in expanding a State’s mining industry. Valid environmental factors tend to receive short shrift.
H.R.Rep.No. 218, 95th Cong., 1st Sess. 91 (1977), reprinted in [1977] U.S.Code Cong. & Ad.News 593, 627.
Thus, the legislative history of the Act, the declarations of congressional purpose it contains, and the allocation of authority it creates between the Secretary and the states confirm that Congress was not interested in perpetuating the existing tradition of state mining regulation, and that Congress saw the need for both federal standards and federal oversight to guarantee an effective change. Congress did, not withhold powers that the Secretary might require in his efforts to safeguard federal interests.11
III. THE SOURCE OF THE SECRETARY’S RULEMAKING POWER
The Secretary identifies two grants of rulemaking power in the Act as the source of his authority to promulgate regulations expanding the list of information required to be submitted in permit applications. The first of these provisions is a general rule-making grant typical of statutes that, like the Act, delegate extensive responsibilities to administrative agencies.12 It provides [522]*522that the Secretary shall “publish and promulgate such rules and regulations as may be necessary to carry out the purposes and provisions of this Act,” Act § 201(c)(2). The second source is a more specific rule-making grant, tied to the provisions of title V of the Act, in which the permit provisions are found. It requires the Secretary to
promulgate and publish in the Federal Register regulations covering a permanent regulatory procedure for surface coal mining and reclamation operations performance standards based on and conforming to the provisions of title V and establishing procedures and requirements for preparation, submission, and approval of State programs and development, and implementation of Federal programs under the title.
Act § 501(b) (emphasis added).13
A. The Secretary's Interpretation
The Secretary has cited sections 201(c) and 501(b) of the Act as authority for his rulemaking, and has viewed them as empowering him to expand the permit information requirements beyond those specified in the Act. As Congress recognized, “[t]he informational and environmental requirements of this [Act] are its most vital provisions.” S.Rep.No.128, 95th Cong., 1st Sess. 53 (1977). The importance of an adequate data base to state decisionmaking, federal supervision, and citizen oversight makes the state program’s information-gathering provisions crucial to the success of the Act. The Secretary has concluded that the explicit information provisions included in the Act should be supplemented to guarantee its effective implementation. As the interpretation favored by the agency responsible for administering the Act, this conclusion is entitled to some deference. See Miller v. Youakim, 440 U.S. 125, 145 n.25, 99 S.Ct. 957, 969 n.25, 59 L.Ed.2d 194 (1979). Absent a contrary indication in the statute, we should accept the Secretary’s judgment, for it is not
a reasonable canon of interpretation [to assume] that the draftsmen of acts delegating agency powers, as a practical and realistic matter, can or do include specific consideration of every evil sought to be corrected. . . . [This] is precisely one of the reasons why regulatory agencies . . . are created, for it is the fond hope of their authors that they bring to their work the expert’s familiarity with industry conditions which members of the delegating legislatures cannot be expected to possess.
American Trucking Ass’ns v. United States, 344 U.S. 298, 309-10, 73 S.Ct. 307, 314, 97 L.Ed. 337 (1953).
Deference to the administering agency is particularly appropriate when a complex regulatory statute emerges from a process of difficult legislative gestation. The Surface Mining Act was the result of a protracted effort, dating back to the Ninetieth Congress, and including presidential veto of bills passed by the Ninety-third and Ninety-fourth Congresses.14 From such a process of compromise and adjustment, a [523]*523symmetrical statute containing explicit answers to every question of administrative implementation is unlikely to emerge.
Appellant would insist that deference is due, not to the Secretary, but to the individual state regulatory agencies that bear primary responsibility for enforcement of the Act. Appellant views this “primary” responsibility as paramount and final responsibility. Our examination of the Secretary’s approval and oversight roles convinces us that this argument misconstrues the statute. Once a state program has been approved, the state regulatory agency plays the major role, with its greater manpower and familiarity with local conditions. It exercises front-line supervision, and the Secretary will not intervene unless its discretion is abused. But ultimate responsibility for guaranteeing effective state enforcement of uniform nationwide minimum standards lies with the Secretary, and his duty to disapprove proposed state programs that he considers ineffective may not be obstructed by a policy of judicial deference to the state agencies proposing those programs. This is particularly true when it comes to seeking the information from the permittees on which his oversight will be based.
B. Interpretation of the Rulemaking Provisions
Appellant argues that the sections of the Act on which the Secretary relies for his rulemaking powers confer no substantive authority at all, and must instead be interpreted as routine housekeeping and procedural provisions. We disagree.
Section 201(c)(2) of the Act empowers the Secretary to “publish and promulgate such rules and regulations as may be necessary to carry out the purposes and provisions of this Act.” Appellant urges that the Secretary’s interpretation of section 201(c)(2) would give him unlimited power to enact rules, destroying the intended structure of the Act by drowning the states in a sea of irrelevant and time-consuming regulations. But as this court observed of the Clean Air Act’s similar rulemaking grant,15 “[sjuch a provision does not provide the Administrator with carte blanche authority to promulgate any rules, on any matter relating to the . .. Act, in any manner that the Administrator wishes.” Citizens to Save Spencer County v. E.P.A., 600 F.2d 844, 873 (D.C.Cir.1979). The Secretary’s regulations must not be arbitrary, capricious, or inconsistent with the Act, and section 526(a)(1) of the Act provides for review of the individual regulations on that basis in the district court. Appellant is participating in that process in the district court, and nothing we decide today forecloses appellant’s challenges to individual regulations.
Appellant’s other argument against the Secretary’s interpretation of section 201(c)(2) is a quantitative one. Because the Act contains, in addition to section 201(c)(2), twenty-one specific grants of rulemaking power, appellant maintains, either those specific grants or section 201(c)(2)’s general grant must be redundant — and the 21:1 ratio in favor of the specific grants demonstrates that it is the interpretation of section 201(c)(2) that is erroneous. Rather than conferring general rulemaking power, in appellant’s view, that section merely empowers the Secretary to engage in “routine housekeeping,” such as setting up rules for distribution of government funds, and allocating authority among his employees. Appellant urges as a proposition of administrative law that the existence of specific grants must eviscerate a general grant of rulemaking power. That proposition cannot be squared with recent Supreme Court decisions relying on general rulemaking grants to uphold rulemaking authority despite the presence of specific grants in the statutes scrutinized. See, e. g., E.I. du Pont de Nemours & Co. v. Train, 430 U.S. 112, [524]*524132, 97 S.Ct. 965, 976, 51 L.Ed.2d 204 (1977) (general rulemaking grant in § 501 of Federal Water Pollution Control Act, 33 U.S.C. § 1361 (1976), supports issuance of categorical effluent limitations under § 301, 33 U.S.C. § 1311 (1976), despite explicit specific rulemaking grants in, e. g., §§ 303, 304, 306, and 307, 33 U.S.C. §§ 1313, 1314, 1316, 1317 (1976)); Mourning v. Family Publications Service, Inc., 411 U.S. 356, 93 S.Ct. 1652, 36 L.Ed.2d 318 (1973) (general rulemaking grant in § 105 of the Truth in Lending Act, 15 U.S.C. § 1604 (1976), supports prophylactic “Four Installment Rule,” despite explicit specific rulemaking grants in, e. g., §§ 123, 125, 126, and 127, 15 U.S.C. §§ 1633, 1635, 1636, 1637 (1976)).
The Secretary also relies on section 501(b) of the Act as support for his authority. This section directs the Secretary to promulgate regulations “establishing procedures and requirements for preparation, submission, and approval of State programs.” Appellant insists that the evident meaning of this section is that the Secretary may set out “mechanical and procedural provisions” governing formal aspects of the submission and approval process. Appellant’s Supplemental Brief on Rehearing En Banc at 28.
We recognize that the language of section 501(b) is not entirely lucid, but the Secretary’s reading is a reasonable one, and is supported by the use of similar language in another provision of the Act. Section 405 deals with state submission of plans for reclamation of abandoned mines, and requires the Secretary to
promulgate and publish in the Federal Register regulations covering implementation of an abandoned mine reclamation program incorporating the provisions of title IV and establishing procedures and requirements for p[re]paration, submission, and approval of State programs consisting of the plan and annual submissions of projects.
Act § 405(a) (emphasis added). Section 405(d) instructs the Secretary to turn over exclusive responsibility for reclamation programs to the states if they submit an acceptable program. The Secretary is to “monitor the progress and quality of the program,” Act § 405(i), and he
shall withdraw such approval and authorization if he determines upon the basis of information provided under this section that the State program is not in compliance with the procedures, guidelines, and requirements established under subsection 405(a).
Act § 405(d) (emphasis added). This continuing duty to withdraw approval of noncomplying state programs provides the Secretary’s only power to revoke the state’s authorization to administer the reclamation program. It would be unreasonable to assume that this severe sanction was intended to be invoked when the Secretary realizes that in approving the program initially he had overlooked a procedural defect, but not when experience demonstrates that the state is conducting an inadequate program. The clear implication of the language of section 405(d) is that the Secretary has authority under section 405(a) to establish procedures and requirements that have substantive content beyond the specification of procedural formalities for submission of state programs. It is therefore quite reasonable to read the identical language in section 501(b) as granting equally substantive powers.
Appellant offers only one argument in favor of its own reading of section 501(b). This is a variant of the reductio ad absurdum suggested in connection with section 201(c)(2). Appellant urges that if the Secretary does have rulemaking authority in the area of program approval, he can dictate every detail of the states’ programs, and thereby destroy their role in flexible implementation of the Act. But as we have pointed out earlier, the power to issue regulations is not the power to issue any regulations. The Secretary has no more carte blanche under section 501(b) than he has under section 201(c)(2).
Appellant’s misconception of the role of section 501(b) is based on a more fundamental misunderstanding. Appellant has argued in its briefs and at oral argument that [525]*525even if the Secretary may withhold approval of a state program because its permit information requirements fail to include necessary items not explicitly required by the Act, he may not advise the states of his additional requirements by regulation. Instead, he must proceed by adjudication on a case-by-case basis. Appellant’s view cannot be reconciled with a significant body of case law favoring the use of rulemaking where agencies have adjudicatory power over the subject and at least some rulemaking authority.
In National Petroleum Refiners Ass’n v. F.T.C., 482 F.2d 672 (D.C.Cir.1973), cert. denied, 415 U.S. 951, 94 S.Ct. 1475, 39 L.Ed.2d 567 (1974), this court upheld the power of the FTC to issue substantive rules governing its adjudications. Examining a line of cases including United States v. Storer Broadcasting Co., 351 U.S. 192, 76 S.Ct. 763, 100 L.Ed. 1081 (1956), and National Broadcasting Co. v. United States, 319 U.S. 190, 63 S.Ct. 997, 87 L.Ed. 1344 (1943), the court recognized an “obvious judicial willingness to permit substantive rulemaking to undercut the primacy of adjudication in the development of agency policy.” 482 F.2d at 679. The court praised the agency’s use of rulemaking as a method for announcing new norms of conduct:
[Tjhere is little question that the availability of substantive rule-making gives any agency a valuable resource-saving flexibility in carrying out its task of regulating parties subject to its statutory mandate. More than merely expediting the agency’s job, use of substantive rule-making is increasingly felt to yield significant benefits to those the agency regulates. Increasingly, courts are recognizing that use of rule-making to make innovations in agency policy may actually be fairer to regulated parties than total reliance on case-by-case adjudication.
Id. at 681. This approbation may also be seen in a large body of cases that have rejected claims that a given agency may operate only on a case-by-case basis, and have likewise rejected crabbed interpretations of those agencies’ rulemaking powers. See, e. g., E.I. du Pont de Nemours & Co. v. Train, 430 U.S. 112, 126-35, 97 S.Ct. 965, 974-78, 51 L.Ed.2d 204 (1977) (national effluent limitations permissibly imposed by regulation on state-issued permits under § 301 of the Clean Water Act); Weinberger v. Hynson, Westcott & Dunning, Inc., 412 U.S. 609, 619-21, 93 S.Ct. 2469, 2478-79, 37 L.Ed.2d 207 (1973) (Food and Drug Administration may deny efficacy hearings to manufacturers who have not undertaken adequate clinical investigations conforming to regulations); cf. Permian Basin Area Rate Cases, 390 U.S. 747, 774-77, 88 S.Ct. 1344, 1363-65, 20 L.Ed.2d 312 (1968) (area rates rather than individual natural gas rates may be set by Federal Power Commission).
The rationale of National Petroleum and kindred cases lends additional strength to our conclusion that both sections 201(c)(2) and 501(b) of the Surface Mining Act authorize the Secretary to issue rules governing approval of state programs. Appellant’s arguments in favor of a trivializing construction of these provisions are wholly without merit. The only remaining question is whether some other evidence demonstrates that Congress intended to exclude from the Secretary’s authority the power to require permit information that he determines to be necessary to an effective program.
C. “Common Sense” and Exhaustion
Appellant’s most significant argument against the Secretary’s rulemaking power is the claim that, even if the Secretary has some authority to promulgate criteria for the approval of state programs, the explicit permit application provisions of the Act were intended as the exclusive federal list of necessary data. Appellant deduces this limit on the Secretary’s power from two premises — a “common sense” rule of regulatory authority, and the exhaustive length and detail of the explicit statutory provisions.
Appellant insists that granting the Secretary the power to expand the permit information requirements would defy com[526]*526mon sense: “The Congress cannot reasonably be supposed to have created an administrative structure so bizarre that the agency which has the exclusive power to decide the issues is powerless to determine the information which it needs to reach that decision.” Appellant’s Supplemental Brief on Rehearing En Banc at 24. Because the state regulatory authority has the power, not subject to federal review, to make permit-issuing decisions, the state must have the power to specify the information that applicants submit.
Of course, the superficial appeal of this “common sense” argument is somewhat undercut when we recognize that the Secretary has only purported to promulgate minimum information requirements, and has not sought to limit the state’s ability to require further data from applicants. And appellant must admit that the Act itself grossly violates this maxim: subsection 507(b) alone contains seventeen numbered paragraphs specifying information that the state regulatory authority must require.
The conclusive answer to appellant’s “common sense” argument, however, is that even if individual state permit decisions are unreviewable, the state’s overall performance in administering the Act is not. Congress believed that guaranteeing effective state enforcement required the vigilance of both the Secretary and the public, and so provided that permit applications, as well as inspection reports, must be available to the public. Act §§ 507(e), 517(f). Since the Secretary must use the information submitted with permit applications in evaluating the continuing compliance of the state permit process with the Act, there is nothing “bizarre” about allowing the Secretary to tell the states that they need more information to meet their responsibilities.
Appellant next argues that sections 507 and 508 of the Act are carefully devised, limited exceptions to the “common sense” rule, and that they were clearly intended to exhaust federal intervention into the information-gathering process. But the Act itself and its legislative history do not demonstrate such an intent.
We have already observed in passing that, although appellant refers to sections 507 and 508 as the only information requirements of the Act, other scattered sections in title V also demand information from permit applicants. See note 3 supra. This technical observation is relevant here, because it tends to rebut the suggestion that sections 507 and 508 comprise a compact, meticulous listing of all the information that Congress considered essential for permit decisionmaking. The addition of other information requirements in scattered sections suggests ad hoc responses to perceived needs for data rather than an integrated effort to produce a comprehensive list.16
The House Committee report contains a more plausible explanation of the function sections 507 and 508 were intended to serve. After discussing the need for a “thorough and comprehensive data base” in language we have already quoted, the report continues: “To meet this problem the bill delineates in detail the type of information required in permit applications in sections 507 and 508 and the criteria for assessing the merits of the application in section 510.” H.R.Rep.No.218, 95th Cong., 1st Sess. 91 (1977), reprinted in [1977] U.S.Code Cong. & Ad.News 593, 622 (emphasis added). Because of the importance of information to a proper decision by the regulatory authority and to effective oversight by the Secretary, Congress included a detailed list of the type of information that would have to be at the state’s disposal. Such a list is not necessarily exhaustive, and does not necessarily rep[527]*527resent Congress’ judgment that the states should be free to decide for themselves whether to seek any other information.
The Act itself contains a persuasive counterexample to the suggestion that detailed enumerations must be exhaustive. Section 515 spells out the Act’s central environmental performance standards. Counting the pages in Statutes at Large, we find that section 515 is roughly twice the length of sections 507 and 508 combined. Section 515(b) alone contains twenty-five numbered paragraphs containing directives as specific as “[to] refrain from the construction of roads or other access ways up a stream bed or drainage channel or in such proximity to such channel so as to seriously alter the normal flow of water,” Act § 515(b)(18). Yet the legislative history makes absolutely clear the expectation that the Secretary would flesh out these requirements in his regulations:
The committee believes that it has struck a balance between legislation which merely frames performance standards in terms of general objectives and standards which are cast in terms more detailed than those generally found in regulatory legislation. In choosing a middle path, the committee is mindful of the past failures on the State level and thus bases its approval of H.R. 2 on the expectation that Federal regulations promulgated under the act will fully implement the environmental performance standards. Obviously, the mere reproduction of the statutory environmental performance standards in the regulations would be inadequate.
H.R.Rep.No.218, 95th Cong., 1st Sess. 85 (1977), reprinted in [1977] U.S.Code Cong. & Ad.News 593, 622. Although the legislative history does not contain a similar exhortation regarding permit applications, we cannot conclude that the mere length or specificity of portions of sections 507 and 508 manifests a desire to exclude the Secretary’s rulemaking powers from their domain.
The Act contains numerous generally phrased and specifically detailed limitations on the freedom of surface mine owners to operate as they please. Some of these limitations are reflected in the permit application provisions, and some are not; the legislative history does not enlighten us as to the reasons for Congress’ selectivity. Appellant would have us rule that the statutory list is exhaustive, and that the Secretary never has the power to supplement that list when he concludes that further information is needed for the proper administration of the Act. We find that sections 507 and 508 represent a diligent and comprehensive congressional effort to guide the Secretary with respect to the type of information a permit application should require. Appellant has not demonstrated a congressional intent to make these provisions an exclusive federal list.
IV. CONCLUSION
The Surface Mining Control and Reclamation Act of 1977 enacts a national plan to alleviate the harmful effects of surface mining. Because of past failures on the state level, the Act provides for national standards relating to environmental performance, and federal oversight of the state programs applying those standards to local geographic conditions. Before the Secretary may approve a state program, he must conclude that the program is sufficient to carry out the purposes of the Act.
We hold that the Act does grant the Secretary rulemaking power enabling him to specify by regulation criteria necessary for his approval of a proposed state program. We hold that the Act’s explicit listings of information required of permit applicants are not exhaustive, and do not preclude the Secretary from requiring the states to secure additional information needed to ensure compliance with the Act. This question concerning the existence of the Secretary’s authority is the only question decided and appellant is free to continue to contest the specific regulations in the district court. The judgment of the district court is
Affirmed.