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.; <br />Sandy Emrich -2- January 6, 1983 <br />With regard to subirrigation, the concern is not whether or not the <br />subirrigation occurs through all or only part of the growing season. <br />The concern is whether or not the subirrigation enhances productivity <br />in an agriculturally useful manner. Thus, subirrigated areas can <br />be given a negative AVF determination, if they are shown not to be <br />agriculturally useful. <br />The area under consideration is too small to be agriculturally <br />useful. Less that 10 acres in size, or less than a larger <br />threshold based on regional practice. <br />The subirrigated areas have no agricultural use, based upon <br />either the plant species present, or upon regional practice. <br />Other physical or agricultural considerations may also allow for a <br />negative AVF determination. Such approaches, however, are new to <br />the Division and require the interaction of several specialties. <br />The applicant should be encouraged to work closely with the Division <br />in pursuing such investigations, so that the result will be satis- <br />factory to both the applicant and the Division. <br />/PP <br />cc: Jim Pendleton <br />Ed Bischoff <br />Roy Cox <br />