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measurements in the type. Justification for a sampling intensity of 30 samples in the <br />Rangeland Type was also provided in the August 20 letter. It was also brought to the OMLR's <br />attention that the cropland areas within the study area were not going to be cropped during the <br />1987 growing season. On September 3, 1987 the OMLR responded to Peabody's August 20 <br />correspondence, concurring with the requested sampling intensity in the Rangeland type and <br />the change in cover sampling methodology for the Swale/Drainage Type. Based on the <br />OMLR's comments on the Irrigated Pasture, Peabody completed sampling for all parameters in <br />the type. <br />The issue of reference areas was addressed in both Peabody's and the OMLR's <br />correspondence. It was Peabody's opinion and is WFC's opinion that adequate reclamation <br />success standards can be developed without the use of reference areas with the exception of <br />dryland pasture. Baseline sampling during the 1987 field season reconfirmed the great <br />variation in management objectives of individuals and the highly diverse nature of the soils, <br />geology, and ground and surface water regimes. In many cases the management plans of <br />operators (both within and adjacent to the study area) changed weekly. This occurred even on <br />lands where Peabody had a reasonable level of control. Crop rotations or pasture and hayland <br />• renovation could easily eliminate or change the nature of a reference area at the time of bond <br />release evaluations. Personal management objectives and methods are highly variable for the <br />various landowners or lessees. Irrigation water management, fertilization programs (if any), <br />harvest period, hay/pasture management, cropping, and grazing management were different <br />for nearly all landowners contacted. The end result of the above is a situation of no <br />guarantees. Guarantees of long term and somewhat consistent management are a critical <br />element that must be reasonably assured when using reference areas. Therefore, Peabody <br />has developed alternate reclamation standards as allowed for under 4.15.7(d) of the <br />Regulations. These standards are discussed in Section 2.05.4(2)(e), Revegetation. <br />For the 1999 vegetation baseline studies, sampling procedures were used that corresponded <br />with those agreed upon in the 1987 permit for sampling sagebrush, irrigated pasture, irrigated <br />hay, and swale/ drainage. In addition, three other plant communities occur in the proposed <br />permit expansion boundary but are outside the area of disturbance. These areas were agreed <br />to be described in a qualitative narrative. These communities are the flood plain of Tuttle draw, <br />a small area of deciduous trees fed by irrigation water on a north facing mesa side slope of the <br />(REVISED 9/99) 2.04.10 - 9 <br />