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• detailed Peabody Coal Company's (Peabody) proposed sampling program for the New <br />Horizon 2 study area. Included in the letter were approximate acreages for the various <br />vegetation or agriculture types and accompanying detailed descriptions of the types and the <br />natural and manmade conditions controlling their expression on the landscape. Sampling <br />parameters and intensity were also proposed in the letter. The OMLR response to this <br />proposal was received on August 11, 1987 and specified concurrence for the sampling <br />techniques proposed for the Irrigated Hayland Type, Irrigated Cropland Type, and the <br />Farmstead, Facilities, Orchards, etc. Questions were raised as to why all parameters (i.e., <br />production, cover, woody plant density) were not sampled for the Irrigated Pasture Type, as <br />welt as concern for a lack of adequate sampling intensity in the Swale/Drainage and <br />Rangelands Types. On August 20, 1987 Peabody responded to the OMLR's comments and <br />concerns and provided clarification on several items. Peabody agreed to increase sampling <br />intensity in the Swale/Drainage Type and provided a discussion supporting justification for <br />using ocular cover estimates versus point-intercept cover measurements in the type. <br />Justification for a sampling intensity of 30 samples in the Rangeland Type was also provided in <br />the August 20 letter. It was also brought to the OMLR's attention that the cropland areas <br />• within the study area were not going to be cropped during the 1987 growing season. On <br />September 3, 1987 the OMLR responded to Peabody's August 20 correspondence, concurring <br />with the requested sampling intensity in the Rangeland type and the change in cover sampling <br />methodology for the Swale/Drainage Type. Based on the OMLR's comments on the Irrigated <br />Pasture, Peabody completed sampling for all parameters in 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 />(Revised August 2006) 2.04.10-17 <br />