2013-10-15_PERMIT FILE - C1982057A (2)

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Sampling Intensity. Sampling intensity will be sufficient to demonstrate sample adequacy following statistically valid approaches in accordance with Rule 4.15.11. The minimum number of samples to be collected shall be in accordance with the selected statistically valid approach. Sampling locations will be established through the use of random point selection unless an allocation of random samples in reclamation sub units or a systematic distribution of samples is more appropriate as approved by the regulatory authority. A sampling point is that location in the study area where the production, cover, or woody plant density measurements are collected. Extended Reference Area Approach An extended reference area approach will be used for assessing successful revegetation for the parameters of cover and production at both the II -W and II -W South Extension areas. Woody plant density and species diversity success criteria will be based on technical performance standards. As discussed later in this section, seasonal variety as a success parameter is not applicable because of the cool season vegetation dominance in the native areas. In addition, premining data for the wetter phase of the mesic drainage type (Dry Creek area in II -W; Hubberson Gulch in the II -W South Extension area) will be used as success standards for this minor type (in terms of areal extent). The proposed revegetation plan for this mesic drainage type should also be kept in mind when considering revegetation success criteria. In March 1985, the Division issued Peabody Coal Company a set of adequacy comments based on the review of the Seneca II -W permit application. Included was a comment regarding the then proposed two -acre reference areas and their comparability to the permit area. In May 1985, as part of a Peabody response package, the extended reference area approach was proposed to alleviate the concerns of the Division. The approach and response were approved as part of the August 5, 1985 Decision and Findings of Compliance document for the Seneca II -W Mine permit. The Seneca II -W permit was signed on December 31, 1985. In response to Peabody's Permit Revision 1 (PR 1) to the Seneca II -W permit, the Division issued a Preliminary Adequacy Review letter on March 11, 1991, which, in part, required documentation of the comparability of the extended reference area to the mine affected area. Peabody responded to this requirement as part of an April 26, 1991 response package to the Division's Adequacy Review letter. The response, prepared as a demonstration of extended reference area and mine affect area comparability, was approved by the Division in the June 3, • 1991 second adequacy review letter to Peabody. Appendix 22 -2 contains the information, which supports the above - referenced demonstration. Tab 10, Vegetation, and in particular, TR -65 43 Revised 9/09