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2020-11-24_REVISION - C1994082
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2020-11-24_REVISION - C1994082
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Last modified
12/1/2020 10:49:19 AM
Creation date
12/1/2020 10:43:19 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1994082
IBM Index Class Name
Revision
Doc Date
11/24/2020
Doc Name
Adequacy Review Response
From
Peabody- Twentymile Coal, LLC
To
DRMS
Type & Sequence
SL8
Email Name
RAR
JLE
Media Type
D
Archive
No
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Greater than 30 samples were taken in the bond release area to allow for hypothesis testing using <br />the reverse null hypothesis. Sample adequacy based on all -hit values was calculated for the bond <br />release area and achieved for each of the reference areas. <br />BRB-2a Cover <br />Calculation of the 90 percent of the cover standard for the 2016 sampling is demonstrated below. <br />Cover standard derivation: <br />Aspen Reference Area Allowable All -Hit Herbaceous Cover' = 74.6% <br />Mountain Brush Reference Area Allowable All -Hit Herbaceous Cover' = 44.9% <br />Sagebrush Reference Area Allowable All -Hit Herbaceous Cover' = 36.4% <br />Steep Mountain Brush Reference Area Allowable All -Hit Herbaceous Cover' = 28.2% <br />'Herbaceous cover adjusted by subtracting noxious weeds and annual/biennial plant cover in excess of <br />10% of the remainder <br />90% of the ERA area weighted Cover Standard <br />0.90*[0.244(74.6%) +0.489(44.9%) +0.24(36.4%) +0.027(28.2%)] = 44.7% <br />The mean allowable all -hit herbaceous vegetation cover sampled in 2016 BRB-2a was 48.4%, <br />exceeding 44.7%, which is 90% of the area -weighted cover performance standard (see also <br />Figure B-la, Table B-1). This direct comparison of reclaimed area mean to standard is allowed <br />under DRMS rules (CDMG 2005 revised rule, 4.15.11 (2)(a)) when sample adequacy has been <br />demonstrated for the reclaimed and reference areas. Thus for 2016, successful revegetation with <br />respect to allowable all -hit herbaceous cover is demonstrated. <br />BRB-3 Cover <br />Calculation of 90 percent of the cover performance standard based on the Haul Road Reference <br />Areas appropriate for 2016 sampling is demonstrated below. <br />90% of the Haul Road Cover Standard = 0.90*27.4% = 24.7% <br />SL-8 - 7 <br />
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