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-6- <br />The Division does not necessarily disagree with this conclusion. <br />However, in order for the Division to make its own negative alluvial <br />valley floor determination, some additionl information should be <br />incorporated into the permit application. <br />1. The AVF reconnaisance snap showing areas of flood irrgation and <br />areas of unconsolidated strearnlaid deposits must be included in <br />the permit application. <br />2. The assessment of the capability for flood irrigation is based <br />upon regional flood irrigation practices. Therefore, the <br />applicant must expand his discussion of flood irrigation beyond <br />the two-mile radius to include an assessment of the capability for <br />flood irrigation based upon regional practices. This assessment <br />should describe the flood practices in the region in valleys the <br />same size or smaller than Grassy Creek. If flood irrigation is <br />not practiced in such valleys or if the area of concern is <br />physically different from those valleys in some way that makes the <br />area unsuitable for irrigation then the area would be found to be <br />not capable of flood irrigation. (Capability should be assessed <br />on the basis of physical water supply, water quality, soil <br />suitability, size of the area capable for flood irrigation as <br />practiced regionally, or some other physical condsideration.) The <br />capability for flood irrigation is not based upon direct economic <br />considerations <br />XII. Vegetation - Kules 2.U4.1U, 2.U5.4(2)(e) and 4.15 <br />The following deficiencies have been identified with respect to <br />vegetation information and the re vegetation plan as presented in the <br />application. <br />1. In the statistical analyses, proposed reference areas were <br />included in the general population. Proposed reference areas were <br />not compared to the baseline population. keference area data <br />should be removed from the affected area data and compared to the <br />baseline data to determine equivalence. <br />Two reference areas have been identified and sampled for both the <br />Aspen type and the Sagebrush type. The applicant should clarify <br />how two reference areas will be utilized for determination of <br />re vegetation success, and comparisons with affected area data. <br />The total ac re aye disturbed and proposed for disturbance in each <br />vegetation type should be stated in the application. <br />4. Kevegetation success criteria for species diversity and woody <br />plant density are not addressed in the application. <br />