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10 <br />July 16, 2018 <br />Page 3 <br />7. Section XXII. Operations on Alluvial Valley Floors — Rule 4.24, Page 53. The Division's <br />citations to maps in the permit is incorrect. Map 7 and 1 I do not exist in the PAP. <br />Maps 11, 12, 12B, and 12C do not document the AVFs as stated by the Division. Please <br />revise. <br />8. Section XXII. Operations on Alluvial Valley Floors — Rule 4.24, A. Designation of <br />Alluvial Valley Floors, Page 54. The Division denotes several drainage inside and <br />outside of the permit boundary that the Division's states have been determined to be <br />AVFs. In this statement the Division did not take into account the change in AVFs <br />approved under TR -109. The Division needs to remove the references to Wilson Creek <br />and Jubb Creek and update all references to Map 11 A as the permit does not contain a <br />Map IIA. <br />9. Section XXII. Operations on Alluvial Valley Floors — Rule 4.24, A. Designation of <br />Alluvial Valley Floors, Page 54. The Division denotes "proposed future operations" on <br />portions of Good Springs Creek. Those words should be remove and the wording <br />"current operations" should be inserted as no propose future operations are currently <br />permitted within the Good Springs Creek watershed. <br />10. Section XXIT Operations on Alluvial Valley Floors — Rule 4.24, B. Primary Impacts, <br />Page 55. The section is incorrect and needs to be updated based on the revised AVF <br />determination permitted and approved under TR -109. <br />11. Section XXII. Operations on Alluvial Valley Floors — Rule 4.24, C. Secondary Impacts, <br />Page 55. Please see comment 1 has it pertains to AVFs on Wilson Creek. The section of <br />the findings document needs to be complete updated as Wilson Creek area adjacent to the <br />Gossard Loadout has been determined not to be an AVE Also, the Gossard Well needs <br />to be noted as a monitoring well and not an alluvial well with the revised AVF <br />determination approved under TR -109. <br />12. Section XXII. Operations on Alluvial Valley Floors — Rule 4.24, D. Specific Findings <br />Required by Rule 4.24, Page 56. The section is vague and not entirely correct since the <br />approval of TR -109. Please update to be more specific to the currently approved <br />monitoring program and AVF determination approved under TR -109. <br />Tri-State appreciates the opportunity to provide these comments on the RN -07 proposed <br />decision, and if you should have any additional questions please feel free to contact Tony <br />Tennyson at (970) 824-1232 or ttennyson(a-,tristategt.org. <br />AN EQUAL OPPORTUNITY I AFFIRMA77VE ACTION EMPLOYER <br />A Touchstone Energy' Cooperative <br />