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D. Alternative test: Assessment of the Presence of Native Species — Comparison of <br />number of native species in the sample area to the referenced area. <br />(Permit Exhibit 2.05.4 -E1, pages 13 -13 -8, 13 -13 -9, and 13- 13 -10) <br />Cover data show that based on meeting mandatory Test A and both Test C and Test D <br />alternative tests of species diversity, BRB -4 will likely achieve the diversity standards. <br />The high vegetative diversity observed during the bond release inspection supports the data <br />submitted with the bond release application. It appeared during the June 14, 2011 bond <br />release inspection that BRB -4 displayed a lower cover, with a higher component of native <br />species and somewhat higher over -all diversity, as compared to previously released BBB's. <br />This can be attributed to the later seeding and any interseeding completed in BRB -4. <br />The observations during the on- the - ground inspection and the quantitative data indicate a <br />relatively diverse vegetative cover of perennial species and life forms supportive of the <br />rangeland /wildlife habitat postmining land use. <br />Sedimentology <br />The Peabody Sage Creek Mine is located within two adjacent drainage basins: Grassy Creek <br />and Fish Creek. The permit area is principally drained by Grassy Creek, with minor <br />tributaries of Fish Creek draining the southeast corner of the permit area. Surface water <br />runoff and sediment control consists of the construction and maintenance of sedimentation <br />ponds, stock ponds, and postmine drainage channels. <br />The two sedimentation ponds associated with the PSCM SL -01 bond release request are the <br />PECOCO pond and Pond 004, which have been approved as permanent impoundments. The <br />PECOCO pond was approved as permanent in 1990 and Pond 004 was approved as <br />permanent in 2006 under permit C- 1980 -005. Pond 004 is within BRB -4, for which the <br />Division is proposing to approve Phase II Bond Release. The PECOCO pond was previously <br />granted Phase II release under C- 1980 -005, SL -03; however, the PECOCO pond is now <br />within the approved disturbance area of the Peabody Sage Creek Mine and collects runoff <br />from the SL -1 bond release area draining to Grassy Creek. <br />The PECOCO pond discharge flows into Little Grassy Creek and then into the Wadge <br />Impoundment (Pond 002) and discharges through an NPDES point at the Wadge <br />Impoundment outlet. The outlet of Pond 004 is also designated as an NPDES discharge <br />point. Runoff from all disturbed areas for which the Division proposes to approve Phase II <br />bond release passes through one of these two NPDES discharge points prior to exiting the <br />permit area. In Attachment F of the PSCM SL -01 bond release document, PSCM submitted <br />pond discharge sample data for all of the ponds receiving discharge from the proposed release <br />area, as well as receiving stream sample data from monitoring points upstream and downstream <br />of the pond outfalls. The pond outfall data indicate that total suspended solids (TSS) <br />contributions do not exceed the limits set forth by the Colorado Department of Public Health <br />and Environment. Monitoring data of the upstream and downstream receiving stream sites <br />indicate that TSS is reduced from the upstream site at the downstream site. <br />Peabody Sage Creek Mine Page 11 July 22, 2013 <br />Phase 11 Bond Release <br />