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Interoffice Memo <br />To: Tom Kaldenbach <br />From: Janet Binn&*oequa RE: Permit applic y review, Peabody Sage Creek Mine, C2009-087 <br />Cc: Dan Hernandez <br />Peabody Sage Creek Mine Review: C2009-087 <br />As requested, I have reviewed the Peabody Sage Creek Mine (PSCM) permit application for adequacy for <br />the following sections; 2.04.9, 2.04.10, 2.04.12, 2.04.13, 2.05.3(5), 2.05.4(2)(b), 2.05.4(2)(c), (d), and (e), <br />2.06.6, 4.15, 2.05.6(2) (in relation to vegetation). Please find my following comments regarding my <br />review. The name of the operator, Sage Creek Coal Company, has been abbreviated SCCC. <br />2.04.9: SCCC has provided in depth soils information for soils within the proposed disturbance area <br />boundary and the potential travel corridor for the Sage Creek Mine. SCCC also provides details <br />discussion of the reconstructed soils used on the reclaimed areas of the Seneca II reclamation <br />that will be incorporated into the Peabody Sage Creek Mine permit. This is acceptable and <br />complies with the requirements of Rule 2.04.9. No adequacy questions for this section. <br />2.04.10: <br />1) On page 2.04-123, SCCC adds "Yoast Haul Road Corridor-Improved Pasture/CRP" to <br />Table 2.04.10-T5 along with the Mountain Brush and the Sagebrush reference areas. This is the <br />first indication of a road corridor-Improved Pasture/CRP reference area. A road corridor- <br />Improved Pasture/CRP reference area is not depicted on Map 2.04.10-M1. Is SCCC adding a <br />third reference area? There is no discussion of the condition of this reference area or its <br />application to reclaimed areas at PSCM. Please provide additional discussion, location and <br />application of the Road Corridor-Improved Pasture/CRP reference area. <br />Table 2.05.4-T4 only includes two reference areas; Mountain Brush reference area and <br />Sagebrush reference area. Please keep all tables regarding references areas consistent <br />throughout the PAP. Will there be two or three reference areas? <br />Exhibit 2.04.10-E1 discusses potential Threatened and endangered plant species of "sensitive" plant <br />species that could potentially be found within the permit area. Most of the plant species on the T&E or <br />sensitive species list have little probability of exiting within the study area due to elevation, soil or <br />geologic strata, or other climactic factors. One species, Ipomopsis aggregate var. weberi (Rabbit ears <br />gilia), has the potential to be found in within the study area. SCCC states that due to sampling for the <br />baseline data later in the growing season in 2008, SCCC would conduct additional sampling earlier in the <br />growing season in 2009 for potential T&E or sensitive species that may have senesced by mid-July.