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3. It appears MCM would like to utilize a technical standard that is currently used at the adjacent Trapper <br />Mine (C-1981-010) to evaluate revegetation success at the Utah Tract in terms of vegetation cover and <br />productivity. This request is in accordance with Rule 4.15.7(2)(d)(v). Based on this rule, such standards <br />must be derived from statistically adequate samples collected over a period of several years. Given this, <br />the justification for using the proposed success standard should be included in the permit application <br />package. The Trapper Mine Permit section 4.4, specifically pages 4-101 to 4-111 discusses how these <br />standards were developed from historic data from 1979 through 1985. Please include a copy of these <br />pages as a separate exhibit or attachment to the permit and cite this information on proposed revised <br />page 2.05-35 and or 2.05-35.1. <br />a. MCM RESPONSE: <br />i. MCM has revised the Williams Fork Mine PAP to include a new Exhibit to reflect the <br />technical standards derived by Trapper Mine, Exhibit 14a. Page 2.05-35.1 has been <br />revised to reflect a reference of the technical standards to Exhibit 14a, this page has <br />been included in this Adequacy Response No. 1, along with a new table of contents. <br />Please update all volumes of the approved PAP with the new table of contents and <br />insert Exhibit 14A after Exhibit 14. <br />4. Proposed revised page 2.05-35 for the Utah Tract explains what statistical equation will be used if the <br />vegetation success standard is less than 90% of the standard. The proposed equation is cited to be from <br />page 22 of the DMG Vegetation Guidelines. The "Sk" variable used to calculate the standard error of <br />the mean is proposed to be (s/04n). This variable should be (s/4n) in accordance with Rule <br />4.15.11(2)(b) and in accordance with the Division's "Guidelines Regarding Selected Coal Mine Bond <br />Release Issues " dated April 18, 1995. Please revise the equation to match what is required by Rule <br />4.15.11(2)(b). <br />a. MCM RESPONSE: <br />i. Page 2.05-35 has been revised in accordance to Rule 4.15.11(2)(b). This page has been <br />included in this Adequacy response No. 1. <br />Sincerely, <br />Miranda Blomquist <br />Engineering Technician - Environmental <br />Moffat County Mining, LLC <br />mblomquist@peabodyenergy.com <br />Page 2 of 2 <br />