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Exhibit 15 Vegetation Information <br />7zs,h1C. <br />5586 Overhdl Dr. Fort Collins, Colorado 80526 (970) 223 -0775 <br />October 7, 2011 <br />Mr. Jim Stover <br />J. E. Stover & Associates, Inc. <br />2352 N. 7" St. Unit B <br />Grand Junction, CO 81501 <br />Dear Mr. Stover: <br />On September 18 -20, 2011 Cedar Creek Associates, Inc. biologists performed a CDRMS approved <br />vegetation survey of the proposed RDA #1 expansion area for New Elk Coal Co. As part of this survey, <br />Cedar Creek personnel documented all flora observed within the project area during systematic coverage <br />of the site. This effort resulted in the documentation of 23 species of grasses or grass -like plants, 68 <br />species of forbs, and 24 species of woody or succulent plants for a total of 115 taxa. All taxa <br />encountered were identified to species with the exception of one sedge, (Carex sp.) that exhibited <br />insufficient seed heads to facilitate identification. <br />As a result of this effort, no plants Federally listed as threatened or endangered were observed <br />within the survey area (which included the proposed RDA #1 expansion area as well as the undisturbed <br />portions of the valley containing the current RDA facility. Furthermore, no plants listed by the Bureau of <br />Land Management or the U.S. Forest Service as "sensitive" were among those identified from this area. <br />However, one species (Herrickia horrida) (syn. Eurybia horrida) was identified from the survey area. <br />This species is globally ranked as G2? ( "imperiled - at high risk of extinction due to very restricted range, <br />very few populations (often 20 or fewer), steep declines, or other factors" with the question mark adding <br />"inexact numeric rank ". It also has been given the Colorado State ranking of S1 ("critically imperiled — at <br />very high risk of extinction due to extreme rarity (often 5 or fewer populations), very steep declines, or <br />other factors ". In Colorado, this taxon is known only from the Animas River basin — Las Animas County. <br />This taxon is better known from Northern New Mexico, Colfax County where the plant is found within a <br />range of 125 miles and can be frequently observed within this range. Both the range and abundance are <br />too great to facilitate qualification as rare under the New Mexico RPTC criteria. The taxon has great <br />ecological amplitude occurring on dry, south - facing slopes in high mountains and shaded, north - facing <br />slopes at low elevations. <br />