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Initial Comment on Irrigation Activity <br /> The issue of irrigation continues to be the source of substantial confusion. As you know, <br /> we are challenging the Board's August 2019 decision in litigation,an issue which will not <br /> be solved here. <br /> Exhibit G to the 112 permit clearly states that Fontanari will continue to irrigate lands in <br /> parcels 1,2,3 and 6 within the permit area. I have attached a diagram of these parcels, <br /> major portions of which are within the permit area,and which are specifically described <br /> by legal description in the 112 application.As a point of fact,the irrigation of these <br /> parcels is in the first paragraph of Exhibit G. In accord with the cease and desist order, <br /> Fontanari has not resumed irrigation on the high mesa which lies above the two small <br /> pits and the crushed stone pile.Your inspection should have confirmed this. <br /> Your inspection seems to indicate problems with irrigation of the middle field,a small <br /> portion of which apparently lies within the permit area approximately Y2 mile distant <br /> from the flood irrigation which was the subject of the August 2019 Board hearing.We <br /> had approached Division in May to describe our irrigation plans in that area providing a <br /> diagram of irrigated areas and the direction of tail water flows based on topography and <br /> historical experience. <br /> Division seems to question whether these fields were historically irrigated. Let me speak <br /> directly to the field where Mr. Fontanari applied some irrigation water earlier this year <br /> (the available water from Cottonwood Creek was very limited, turned off, and was back <br /> on for one short period)and which was the subject of your report in the inspection <br /> documents.As you can see, this is a developed and leveled field; although historically <br /> irrigated dating from the turn of the last century, these fields were reworked and <br /> developed in 1985 and irrigation water applied when available.The lands were owned <br /> at that time by Mr.Orr, for whom contract work was performed,and, later owned by <br /> the Fontanari Trust. <br /> The best map of which we are aware of irrigation resources in this entire area was the <br /> Town of Palisade ma of 1983;this ma shows the area irrigated under the Martin <br /> P P g <br /> Crawford Ditch. I attach both a portion of the map and the Town of Palisade identifier <br /> (prepared by Leonard Rice Water Engineers from a USGS base map).You can pretty <br /> easily see where this irrigated area fits into Parcels 1,2,3 and 6,significant portions of <br /> which are within the permit area. <br /> i <br /> i <br /> i <br /> Page 04 <br />