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Peabody Sage Creek Mining <br />Page 3 <br />June 22, 2016 <br />a. Four leks were monitored and the number of males observed at <br />each lek was reported. <br />2. Golden Eagle Nests: <br />a. The report indicates that three of the original six Golden Eagle <br />nest sites are believed to be destroyed as a result of natural <br />causes and the remaining three sites were inactive during 2015. <br />viii. A 2015 Rill and Gully and Surface Maintenance map with submitted with the <br />2015 ARR. This information was reviewed and appears consistent with the <br />Division's 2015 inspection reports regarding required maintenance. <br />Acreage Accounting <br />• The 2015 ARR form and page 1 of the repot document indicate the cumulative total acres <br />disturbed is 1,844.00 acres. Based on the Division's instructions from the 2014 ARR, this <br />acreage should be the sum of the acreage disturbed from the Seneca II mine within the PSCM <br />permit area (1766.36 acres) and the total newly disturbed acres (9.6 acres), minus the Phase III <br />bond release acreage (68.79 acres from SL2 and 1026 acres from SU approved for the PSCM). <br />Thus the cumulative total acres disturbed at the site should have been reported to be 681.17 acres <br />(1,766.36 + 9.6 — 68.79 -1026 = 681.17). Please submit a revised ARR form with the correct <br />cumulative total acres disturbed listed. <br />• PSCM reports that 146.4 acres have been re -disturbed according to the ARR form, however page <br />1 of the report document indicates these acres are former Seneca 11 mine acres that had been <br />approved for Phase III bond release that were approved to be re -disturbed under the PSCM <br />permit. The purpose of the annual reclamation report form is to document actual on the ground <br />disturbance and reclamation, not to report on what acres are approved to be disturbed. Given this, <br />based on the review of previous ARR's the number of acres that have been re -disturbed at the site <br />was reported at 58.2 acers. Please review the number of acres of re -disturbance that had <br />occurred through 2015 and report the actual number of acres that have been re -disturbed. <br />• PSCM reported that a cumulative 68.8 acres have been newly disturbed at the site on the ARR <br />form, however page 1 of the report document indicates that PSCM has been given approval to <br />disturb 68.8 acres. It should be noted that PSCM has been approved to create only 67 acres of <br />new disturbance. Similar to the item above, for the ARR, the cumulative total newly disturbed <br />acres should be the actual on the ground acres that have been newly disturbed though 2015. <br />Based on previous ARR's and the fact that no new disturbance has been reported to have <br />occurred over the last few years, the newly disturbed area should only be 9.6 acres. Please <br />review the number of acres of new disturbance that had occurred through 2015 and report <br />the actual number of acres that have been newly disturbed. <br />• PSCM reports that 1,628.8 acres has been backfilled and graded, topsoiled and seeded. It is <br />unclear how this number was derived. Please explain how this acreage number was <br />determined. <br />• Portions of the SU and SU Phase I and II bond release acreage from the Seneca 11 mine are <br />within the area shown to be disturbed for the PSCM operation. According to previous ARR's, <br />58.2 acres have been re -disturbed of formally Seneca 11 mine acres. If any of the currently <br />reported acres that had obtained Phase I and 11 bond release have been redisturbed, the number of <br />