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-a- Items 4, 5, and 6 relate to yround water monitoring and should be reviewed by Roy. • VIII. Nlluvial Valley Floors Foidel Creek Althouyh not required in our preliminary adequacy review, the applicant has chosen co provide additional infunuatiun and discussion with regard to the proposed Alluvial Valley Floor determination for Foidel Creek. 1) The applicant points out tfrat the second area of unconsolidated strea~nlaid deposits along Foidel Creek is outside of the permit area and is not on the CYCC property, therefore no e~nperical data exist. The applicant should be reminded that he is responsible for providiny sufficient information to make the required determinations for the per~ait area and adjacent areas. The Division will attempt to make the required finainys using information now availaole. Conservative assumption may be used to fill data yaps. However, if critical data yaps exist, the applicant is responsible for providing sufficient information. 2) The applicant has provided additional discussion concerning the capability for flood irrigation. The two-acre foot criteria discussed by the applicant was superseded in June, 19fiU. The preamble to the June 11, 1980 OSI~h Alluvial Valley Floor Guideline indicates that the two-acre oot acre between Ptay 1 and September 15 criteria was being abandoned in favor of water availability based upon water use requirements characteristic of the region where the assessment is made. The Leonard Rice study was based upon local water requirements (2.11 acre-ft/acre) and regional irrigation practices (i~npound~uent of spring runoff). This study concluded that there was an adequate physical supply of water for flood irrigation in the Foidel Creek drainage. The Leonard Rice study goes on, using the flood irrigation system they desiyned, to conclude that flood irriyation of the area studied is not economically feasible. I do not necessarily disagree with this conclusion. However, economic feasibility is not an appropriate criteria for the identification of alluvial valley floors. As discussed in my January 6th memo (attached), the capability for flood irriyation should be based upon physical considerations. fused upon the information provided thus far, it appears that the Foidel Creek study area is capable of flood irriyation.