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Peabod <br />IIIMIllillillii ENERGY <br />April 26, 2012 <br />Mr. Jason Musick <br />Colorado Division of Reclamation Mining & Safety (DRMS) <br />1313 Sherman Street, Room 215 <br />Denver CO 80203 <br />Re: Peabody Sage Creek Mine (Permit No. C -2009 -087) <br />SL -1 Updates to the Vegetation Section <br />Mr. Musick: <br />Peabody Sage Creek Mining, LLC <br />Peabody Sage Creek lime <br />PO Box 250 <br />36600 Routt County Road 27 <br />Hayden, CO. 81639 <br />oce <br />P,pR 21 ? 0x <br />S e" <br />As a result of the review of the Phase II Bond Release Application (SL -1) for the Peabody Sage <br />Creek Mine (PSCM), DRMS identified concerns with the Revegetation (cover) Success portion <br />of the application. Specifically, at issue is sample adequacy for the mountain brush reference <br />area and statistical considerations when performing success evaluations. Dr. David Buckner, <br />representing PSCM, developed an alternative approach to establishing the first -hit herbaceous <br />cover standard from the PSCM mountain brush reference area. The standard is statistically <br />derived from the sample data and uses the 90% confidence range of the upper limits of the true <br />mean, or 15.1. The derivation and supporting information of this alternative approach was <br />presented to the DRMS staff on March 12, 2012. The SL -1 application has been revised to <br />include the alternative approach and the statistical analysis for the success evaluation was <br />reapplied accordingly. Further, the 2010 Evaluation of Revegetation Success for Phase II <br />Bond Release report prepared by ESCO Associates, Inc. has also been revised and is included in <br />this package. The previous report sections should be discarded as described in the attached <br />Insertion Instructions. Finally, the supporting presentation documentation presented to DRMS in <br />March by Dr. Buckner is included as new Attachment H to the revised SL -1 application. <br />We would appreciate your consideration and cooperation in facilitating timely review and <br />approval of this submittal. Once you have had opportunity to review this submittal package, <br />please feel free to contact me at 970 - 276 -7003 with any questions or comments. <br />Best regards, <br />. Scott Cowman <br />Senior Environmental Specialist <br />Peabody Sage Creek Mining LLC <br />Peabody Sage Creek Mine <br />attachment(s) <br />