2015-04-29_PERMIT FILE - C1981008A (7)

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4.0 Vegetation Baseline Sampling Methods The presence of specific vegetation types and communities resulting from intensive agricultural land use and irrigation dictated unique approaches to vegetation baseline sampling within the study area at the proposed New Horizon 2 Mine. Surface mining operations normally occur on native rangelands in the Western U.S., and only rarely involve agricultural lands. General discussions on sampling methodologies and intensities, as well as vegetation type delineations, were carried out with representatives of the Office of Mined Land Reclamation (OMLR) beginning in February 1987. A letter to the OMLR on June 15, 1987 detailed Peabody Coal Company's (Peabody) proposed sampling program for the New Horizon 2 study area. Included in the letter were approximate acreages for the various vegetation or agriculture types and accompanying detailed descriptions of the types and the natural and manmade conditions controlling their expression on the landscape. Sampling parameters and intensity were also proposed in the letter. The OMLR response to this proposal was received on August 11, 1987 and specified concurrence for the sampling techniques proposed for the Irrigated Hayland Type, Irrigated Cropland Type, and the Farmstead, Facilities, Orchards, etc. Questions were raised as to why all parameters (i.e., production, cover, woody plant density) were not sampled for the Irrigated Pasture Type, as well as concern for a lack of adequate sampling intensity in the Swale/Drainage and Rangelands Types. On August 20, 1987 Peabody responded to the OMLR's comments and concerns and provided clarification on several items. Peabody agreed to increase sampling intensity in the Swale/Drainage Type and provided a discussion supporting justification for using ocular cover estimates versus point -intercept cover measurements in the type. Justification for a sampling intensity of 30 samples in the Rangeland Type was also provided in the August 20 letter. It was also brought to the OMLR's attention that the cropland areas within the study area were not going to be cropped during the 1987 growing season. On September 3, 1987 the OMLR responded to Peabody's August 20 correspondence, concurring with the requested sampling intensity in the Rangeland type and the change in cover sampling methodology for the Swale/Drainage Type. Based on the OMLR's comments on the Irrigated Pasture, Peabody completed sampling for all parameters in the type. The issue of reference areas was addressed in both Peabody's and the OMLR's correspondence. It was Peabody's opinion and is WFC's opinion that adequate reclamation success standards can be developed without the use of reference areas with the exception of February 2015 (TR -66) 2.04.10-10