2022-04-29_PERMIT FILE - C2010089 (20)

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Section 2.06.8 Page 5 December 2021 (RN-02) to the non-conformity of the topographic characteristics, the several days spent performing the wetland survey of this site reveals that the area of Tuttle Draw in the vicinity of the proposed equipment corridor crossing does not consist of alluvial geologic materials, and hence cannot be considered to meet the definition of an AVF. The extent of all areas which have historically been flood irrigated is identified on Map 2.04.3-1 - Land Use Map. The extent of all areas corresponding to different agricultural activities, including flood irrigated lands, pasture lands, undeveloped rangelands are found shown on Map 2.04.3-1 - Land Use Map and are addressed in the discussion of land use found in Section 2.04.3. Detailed site specific measurements of vegetation productivity of these corresponding land uses by soils map unit are found in Section 2.04.9 and in the discussion of vegetation found in Section 2.04.10. As discussed in these sections, there has never been any historic flood irrigation in the Tuttle Draw equipment corridor crossing area. With respect to the potential for subirrigation in the floodplain of the areas along Tuttle Draw, it can be concluded that more detailed vegetation information and wetland mapping of these areas, obtained in connection with the environmental studies performed in connection with this permit application have better addressed the potential for agricultural development of this site. The vegetation characteristics of this site are found in the narrative found in Section 2.04.10 - Vegetation Information and on Map 2.04.10-1 Vegetation Map. A preliminary discussion of the wetland information is found in the discussion of wetlands found in 2.05.6(2) and on Map 2.05.6(2)-1 Wetland Map. With respect to the potential of future agricultural development in the Tuttle Draw area, the following discussion is appropriate. According to the report by Hardaway and others (1977b), the areas along the floodplain in the bottom of Tuttle Draw would not meet the current AVF criteria for a number of reasons. Firstly, many of the floodplain areas are less then 15 meters wide, making it impracticable to develop such areas. These authors conclude that “these narrower valleys are not essential to agricultural operations.” Since the bottom of Tuttle Draw contains a very narrow riparian fringe, it is NHN’s opinion that this area would not meet the “size criteria “ of an AVF found at 2.06.8(3) as it would be operationally unrealistic and economically impossible to develop and farm such a small, narrow strip of land.