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~. <br />• 1 • <br />h <br />-5- <br />2) The applicant has provided additional discussion <br />concerning the capability for flood irrigation. The <br />two-acre foot criteria discussed by the applicant was <br />superseded in June, 1980. The preamble to the June <br />11, 1980 OSM Alluvial Valley Floor Guideline indicates. <br />that the two-acre foot/acre between May 1 and <br />September 15 criteria was being abandoned in favor of <br />water availability based upon water use requirements <br />characteristic of the region where the assessment is <br />made. The Leonard Rice study was based upon local <br />water requirements (2.11 acre-ft/acre) and regional <br />irrigation practices (impoundment of spring runoff). <br />This study concluded that there was an adequate <br />physical supply of water for flood Irrigation in the <br />Foidel Creek drainage. <br />The Leonard Rice study goes on, using the flood <br />irrigation system they designed, to conclude that <br />flood irrigation of the area studied is not <br />economically feasible. I do not necessarily disagree <br />with this conclusion. However, economic feasibility <br />is not an appropriate criteria for the identification <br />of alluvial valley floors. As discussed in my January <br />6th memo (attached), the capability for flood <br />irrigation should be based upon physical <br />considerations. <br />Based upon the information provided thus far, it <br />appears that the Foidel Creek study area is capable of <br />flood irrigation. <br />3) The applicant has provided additional discussion which <br />indicates that subirrigation is limited to areas <br />directly adjacent to the stream channel, that these <br />areas are less than 10 acres in size, and that these <br />areas contain species that are not agriculturally <br />useful. If these statements can be confirmed with <br />information contained in the permit application (or <br />otherwise available), the area would not be identified <br />as an alluvial valley floor because of subirrigation. <br />(Sandy, you or someone else with a vegetation <br />background needs to review this section.) <br />The applicant failed to address the final concern in the AVF <br />section, which asked whether the study area established for the <br />Eckman Park Mine is sufficient for the proposed operation. <br />