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S ENEC: <br />Coal Company <br />May 10, 2012 <br />Mr. Jason Musick <br />Division of Reclamation, Mining and Safety <br />1313 Sherman Street, Room 215 <br />Denver, CO 8020 <br />RE: Seneca II Mine (Permit C -80 -005) <br />SL -5 Updates to the Vegetation Section <br />Mr. Musick, <br />As a result of the review of the Phase II Bond Release Application (SL -1) for the Peabody Sage Creek Mine <br />(PSCM), DRMS identified concerns with the Revegetation (cover) Success portion of the application. <br />Specifically, at issue is sample adequacy for the mountain brush reference area and statistical considerations <br />when performing success evaluations. Dr. David Buckner, representing PSCM, developed an alternative <br />approach to establishing the first -hit herbaceous cover standard from the PSCM mountain brush reference <br />area. The standard is statistically derived from the sample data and uses the 90% confidence range of the <br />upper limits of the true mean, or 15.1. The derivation and supporting information of this alternative <br />approach was 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 reapplied <br />accordingly. Further, the 2010 Evaluation of Revegetation Success for Phase II Bond Release report <br />prepared by ESCO Associates, Inc. has also been revised and is included in this package. The previous report <br />sections should be discarded as described in the attached Insertion Instructions. Finally, the supporting <br />presentation documentation presented to DRMS in March by Dr. Buckner is included as new Attachment H <br />to the revised SL-1 application. <br />We would appreciate your consideration and cooperation in facilitating timely review and approval of this <br />submittal. Once you have had opportunity to review this submittal package, please feel free to contact me at <br />970- 276 -7003 with any questions or comments. <br />If there are further questions, please contact me at (970) 276 -5217. <br />Sincerely, <br />G` <br />Roy A. Karo <br />Reclamation Manager <br />Seneca Coal Company <br />Seneca Coal Company <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276 -5219 • FAX (970) 276 -5222 <br />