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-a- Items a, b, and 6 relate to ground water nionitoriny and should be reviewed by Roy. VIII. Alluvial Valley Fluors Foidel Creek Alt hough not required, the applicant has chosen to provide additional information and discussion with regard to the proposed Alluvial Valley Floor determination for Foidel Creek. 1) The applicant points out that the second area of unconsolidated streamlaid deposits along Foidel Creek is outside of ttre permit area and is not on the CYCC property, therefore no emperical data exist. The applicant should be reminded that he is responsible for providing sufficient information to make the required determinations for the permit area and adjacent areas. The Division will attempt to make the required firrdinys using information now available. Conservative assumption may be used to fill data gaps. However, if critical data gaps 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 The two-acre foot criteria discussed by the applicant was superseded in June, 1980. The preamble to the June 11, 198U OSfd Alluvial Valley Floor Guideline indicates that the trvo-acre foot/acre between play 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 (impoundment of spring runoff). Tlris 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 designed, to conclude that flood irrigation 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, the capability for flood irrigation should be based upon physical considerations. Based upon the information provided thus far, it appears that the Foidel Creek study area is capable of flood irrigation. 3) The applicant has provided additional discussion which indicates that subirriyation is limited to areas directly adjacent to tfre strewn channel, that these areas are less bran 10 acres in size, and that these areas contain species that are not agriculturally useful. If these statements can be confirmed with information contained in the permit application (or otherwise available), the area would not be identified as an alluvial valley floor because of subirrigation. (Sandy, you or someone else with a vegetation background needs to review this section.)