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Vegetation Baseline History. Initial vegetation studies were conducted on and adjacent to • <br />the permit area during 1974. These studies consisted of preparing a vegetation map, <br />sampling line-intercept cover transects in each major vegetation type, and preparing a <br />species list. <br />In 1978, Peabody Coal Company (Peabody) initiated further environmental studies for a <br />permit to mine. The vegetation sampling program was designed in late 1978. At this time, <br />no permanent state program had been developed by the Colorado Mined Land Reclamation <br />Division (CMLRD) and the final rules of the Office of Surface Mining (OSM) were under <br />development. As a result, the baseline sampling program was designed to follow Wyoming <br />Department of Environmental Quality Guideline 2 which was the most comprehensive set of <br />guidelines available at the time. <br />Following discussions with CMLRD and OSM during 1979 (R. Funsten, D. Kimball, 8. Stark), <br />quantitative sampling was conducted in all vegetation types within the planned mine <br />disturbance area and associated reference areas by Environmental Research and Technology, <br />Inc. (ERT). The haul road corridor was mapped, but not sampled pending a more precise • <br />road alignment. <br />In 1980, Peabody initiated additional vegetation studies to provide information on the <br />tie-across haul road corridor, and to update existing mine area baseline data by sampling <br />shrub density. The sampling program was designed to meet the then Proposed Colorado Mined <br />Land Regulations as well as expected changes required for the Final Rules and Regulations. <br />In 1982, Peabody personnel sampled minor areas of the gre asewood community along the <br />tie-across haul road and collected additional species information for the permit area to <br />be mined and the haul road. In addition, field reconnaissance was performed to correct <br />and update the accompanying vegetation maps as well as prepare the 1/2-mile Adjacent <br />Vegetation Study Area Map (originally Exhibit 13-5). The 1/2-mile Adjacent Vegetation <br />Study Area is now included on Exhibit 10-1, Premi Wing Vegetation Types and Sample Location <br />Map. <br />On November 29, 1982, Peabody submitted an application to mine to the CMLRD. As a part of <br />its review, CMLRD determined that portions of the vegetation baseline studies were <br />deficient, as spelled out in a deficiency letter dated December 8, 1982, After • <br />conversation s between Peabody and CMLRD, as summarized in a letter from Dan Matthews to <br />2 <br />