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success standards can be developed without the use of reference areas with the exception of <br />dryland pasture. Baseline sampling during the 1987 field season reconfirmed the great <br />variation in management objectives of individuals and the highly diverse nature of the soils, <br />geology, and ground and surface water regimes. In many cases the management plans of <br />operators (both within and adjacent to the study area) changed weekly. This occurred even on <br />lands where Peabody had a reasonable level of control. Crop rotations or pasture and hayland <br />renovation could easily eliminate or change the nature of a reference area at the time of bond <br />release evaluations. Personal management objectives and methods are highly variable for the <br />various landowners or lessees. Irrigation water management, fertilization programs (if any), <br />harvest period, hay /pasture management, cropping, and grazing management were different <br />for nearly all landowners contacted. The end result of the above is a situation of no <br />guarantees. Guarantees of long term and somewhat consistent management are a critical <br />element that must be reasonably assured when using reference areas. Therefore, Peabody <br />has developed alternate reclamation standards as allowed for under 4.15.7(d) of the <br />Regulations. These standards are discussed in Section 2.05.4(2)(e), Revegetation. <br />For the 1999 vegetation baseline studies, sampling procedures were used that corresponded <br />with those agreed upon in the 1987 permit for sampling sagebrush, irrigated pasture, irrigated <br />hay, and swale/ drainage. In addition, three other plant communities occur in the proposed <br />permit expansion boundary but are outside the area of disturbance. These areas were agreed <br />to be described in a qualitative narrative. These communities are the flood plain of Tuttle draw, <br />a small area of deciduous trees fed by irrigation water on a north facing mesa side slope of the <br />Martin Property and a small area of Pinon and Juniper on a north facing mesa side slope of <br />WFC property. <br />Table 2.04.10 -3A summarizes sampling parameters and intensities for the various types in <br />1987. Table 2.04.10 -313 summarizes sampling parameters and intensities for the various <br />types in 1999. Details of sampling methods are provided following this summary. Data <br />Sampling Summary results are in Attachment 2.04.10 -3 Sampling Data Summary. <br />August 2013 (PR 08) 2.04.10 -11 <br />