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<br /> <br />-4- <br />Items ~l, 5, and 6 relate to ground water monitoring and should <br />be reviewed by Roy. <br />VIII. Alluvial Valley Floors <br />Foidel Creek <br />Although not required, the applicant has chosen to provide additional <br />information and discussion with regard to the proposed Alluvial Valley <br />Floor determination for Foidel Creek. <br />1) The applicant points out that the second area of unconsolidated <br />streamlaid deposits along Foidel Creek is outside of the permit <br />area and is not on the CYCC property, therefore no emperical <br />data exist. The applicant should be reminded that he is <br />responsible for providing sufficient information to make the <br />required determinations for the permit area and adjacent areas. <br />The Division will attempt to make the required findings using <br />information now available. Conservative assumption may be used <br />to fill data gaps. However, if critical data gaps exist, the <br />applicant is responsible for providing sufficient information. <br />2) The applicant has provided additional discussion concerning the <br />capability for flood irrigation. The two-acre foot criteria <br />discussed by the applicant was superseded in June, 1980. The <br />preamble to the June 11, 1980 OSM Alluvial Valley Floor <br />Guideline indicates that the two-acre foot/acre between May 1 <br />and September 15 criteria was being abandoned in favor of water <br />availability based upon water use requirements characteristic of <br />the region where the assessment is made. The Leonard Rice study <br />was based upon local water requirements (2.11 acre-ft/acre) and <br />regional irrigation practices (impoundment of spring runoff). <br />This study concluded that there was an adequate physical supply <br />of water for flood irrigation in the Foidel Creek drainage. <br />The Leonard Rice study goes on, using the flood irrigation <br />system they designed, to conclude that flood irrigation of the <br />area studied is not economically feasible. I do not necessarily <br />disagree with this conclusion. However, economic feasibility is <br />not an appropriate criteria for the identification of alluvial <br />valley floors. As discussed in my January 6th memo, the <br />capability for flood irrigation should be based upon physical <br />considerations. <br />Based upon the information provided thus far, it appears that <br />the Foidel Creek study area is capable of flood irrigation. <br />3) The applicant has provided additional discussion which indicates <br />that subirrigation is limited to areas directly adjacent to the <br />stream channel, that these areas are less than 10 acres in size, <br />and that these areas contain species that are not agriculturally <br />useful. If these statements can be confirmed with information <br />contained in the permit application (or otherwise available), <br />the area would not be identified as an alluvial valley floor <br />because of subirrigation. (Sandy, you or someone else with a <br />vegetation background needs to review this section.) <br />