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<br />The decision to disqualify this area as an AVF is based on <br />regional investigation by the applicant and a regional inventory <br />conducted by Kerr Coal Company for the adjacent Marr Mine. Both <br />studies indicate that no current or historical regional prece- <br />dence exists for practicing flood irrigation on acreage of this <br />size (p. 9 Addendum I, of the permit application). <br />Based on the above, it is evident that the potential for <br />flood irrigation does not truly exist along North Fork. The <br />applicant, however, has used some questionable data in developing <br />i~ this conclusion. In Addendum I, page 11, the applicant presents <br />~~' ~ calculations indicating that 4,545 acre-feet of water could be <br />1 ~ expected as the mean annual flow in Bolton Draw. In the Phase I <br />I~ ~ Apparent Completeness Review, the applicant was asked to also <br />~~ ~ quantify the yield from the North Fork of Bolton Draw. The <br />,,\ ~ ~ response to that question was inadequate: the applicant only <br />~ I ~ ^~ reiterated a statement on page 92, Vol. 1 of the permit applica- <br />~ ~ ~ tion that 2.7 percent of the potential surface water flow to the <br />~ ~ <br />Q ~~ ,~, Bolton Draw drainage will result from sediment pond detention <br />`~ ~•~~~ from the Canadian Strip Mine. The applicant derived 2.7 percent <br />t~ ~ from the information that flow from 185 acres in the North Fork <br />L i <br />'~ basin will be detained in sediment ponds out of a total 6,784- <br />~ ~~' <br />'~ ~ acre Bolton Draw watershed. As discussed in the Surface Water <br />I\ ~ u <br />~`l~ section of this TEA, the proposed sediment ponds will actually <br />~~~1\ impound flow from 396 acres, or 6 percent of the Bolton Draw <br />~1.~ water volume. Using the direct drainage area to flow percentage <br />~~~ that the applicant utilizes in this discussion, the North Fork <br />h basin which comprises 1152 acres, is 17 percent of the total <br />,v ~ Bolton Draw watershed. Therefore, 17 percent of 4,545 acre feet <br />~.~ results in a mean annual yield of 773 acre feet from North Fork. <br />~r~ This indicates that an abundant supply of water could be made <br />available for flood irrigation of the North Fork alluvium. <br />The mean annual water yield calculated for both North Fork <br />and Bolton Draw appears to be much greater than could reasonably <br />be expected to occur. The assessments provided by the applicant <br />were based on two questionable assumptions: 1} as already dis- <br />-85- <br />