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Peabody Sage Creek Mine SL -3 Phase 111 Bond Release Request July 2014 would not be as affected. The previously discussed determination method for arriving at a reasonable allowable first hit herbaceous cover value for the mountain brush reference area addresses this and provides a technically valid resolution. The sagebrush reference area, without the structural characteristics of the mountain brush, does not have this issue and first hit herbaceous cover sample adequacy with reasonable sample sizes is attainable. Calculation of 90 percent of the cover performance standard determined from 2010 and 2011 sampling is demonstrated below based on the following reference area data that is weight averaged. The weighting contribution is mountain brush 83% and sagebrush 17 %. 2010 Cover Success Evaluation 2010 Mountain Brush Reference Area allowable first hit herbaceous cover 12.8 x 2 = 25.6% 2010 Sagebrush Reference Area allowable first hit herbaceous cover 44.7 x 2 = 89.4% 90 percent of the Cover Standard = 0.90 [0.83(25.6) + 0.17(89.4] = 32.8% The 2010 Phase III bond release BRB PSCM -1 sampling at thirty (30) random locations resulted in an allowable first hit herbaceous cover value of 54.9% which exceeds the 90 percent cover standard value of 32.8 %. 2011 Cover Success Evaluation 2011 Mountain Brush Reference Area allowable first hit herbaceous cover 20.95 x 2 = 41.9% 2011 Sagebrush Reference Area allowable first hit herbaceous cover 44.4 x 2 = 88.8% 90 percent of the Cover Standard = 0.90 [0.83(41.9) + 0.17(88.8] = 44.9% The 2011 Phase III bond release BRB PSCM -1 sampling at thirty (30) random locations resulted in an allowable first hit herbaceous cover value of 55.8% which exceeds the 90 percent cover standard value of 44.9 %. Production. The PSCM herbaceous production standard and success evaluation is based on a weight averaged value (based on the two primary premine vegetation type contributions to total 10