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RULE 2 PERMITS <br />• Local and regional agricultural economics are prohibitive to developing irrigation projects within <br />these valley bottoms, and such practices are in decline locally, especially on such a small scale as <br />would be required by the narrow and fragmented nature of irrigable bottomlands within the <br />subject drainages. <br />The narrow width and fragmented nature of the minimal flat land, depth to ground water, and <br />impracticality of economically irrigating or mechanically farming the valley bottoms within Collom <br />Gulch, Little Collom Gulch, and West Fork of Jubb Creek of the Collom Mine Expansion area indicate <br />that those drainages do not qualify as alluvial valley floors. <br />Specific discussion of the Collom Gulch Valley <br />As noted in the previous text, alluvial materials are present in the valley bottoms of the Collom Gulch <br />drainages but the materials are intermixed with significant fractions of colluvium and sheetwash from <br />adjacent slopes. This can be seen in the geologic description of the monitoring well (MC -04-02) in the <br />lower portion of Collom Gulch in Section 24, T. 3 N., R. 93 W. The cuttings obtained from the drill hole <br />are predominantly silty clays, with minor amounts of sand and gravel (<25%). <br />Based on depth to groundwater in this drill hole (10 feet below ground surface), it is doubtful that <br />subirrigation of any plant crop is possible. Further to the north, near the confluence of Collom Gulch and <br />Little Collom Gulch, monitoring well MLC -04-01 has a ground water level of between 40 and 50 feet <br />below ground water surface. <br />In addition, active erosion in the Collom Gulch channel is causing further incision, which is lowering the <br />unconfined groundwater table found in the valley. The incision in Collom Gulch is at least two feet and <br />in excess of 20 feet in sections before that flow of Collom Gulch exits through the `Iles formation <br />hogback' and flows onto the Mancos Shale located in the Axial Basin to the north. The incision is also <br />widening due to the downcutting and erosion of the supporting banks during periods of higher flow <br />(normally occurring during the spring). With the low surface water flow rates and the reduced flood <br />frequency, this has reduced the ability of the valley bottoms to support any agricultural use other than <br />rangeland. <br />Local and regional agricultural economics are prohibitive to developing irrigation projects within these <br />valley bottoms, and such practices are in decline locally, especially on such a small scale as would be <br />required by the narrow and fragmented nature of irrigable bottomlands within the subject drainages. <br />The narrow width and fragmented nature of the minimal flat land, depth to ground water, and <br />impracticality of economically irrigating or mechanically farming the valley bottoms within Collom <br />Gulch indicate that these drainages do not qualify as alluvial valley floors. <br />AVF Studies- Gossard Loadout and surrounding areas <br />All the streams/creeks that exit the Collom syncline/Iles formation hogback still exhibit the deep <br />downcutting that originates in the Collom Syncline lands. This downcutting is easily visible in all <br />streams/creeks exiting the hogback and continues for several miles downstream. This downcutting was <br />due to the 1983/1984 mass -wasting event discussed above. The two streams that will be affected by the <br />Collom Mine Expansion are Jubb Creek and Wilson Creek, near the Gossard Loadout. <br />The possibility of any AVF in Jubb Creek was discussed above. As noted, there is no AVF in the Jubb <br />Creek valley north of the hogback. With respect to Wilson Creek, after the creek exits the hogback, a <br />broad valley filled with valley fill materials is encountered. In the area where the Collom haul road <br />Collom — Rule 2, Page 130 Revision Date: 1/6/17 <br />Revision No.: TR -109 <br />