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-lo- More detailed information regarding the extent of alluvial deposits (as opposed to colluvium) and subirrigation would need to be submitted to justify a negative determination for these areas. ~ 6. Y The application states that flood irrigation on Foidel Creek would not be feasible due to the ephemeral nature of Foidel Creek and fluctuating .~ water supply. The application references a feasibility study conducted y by Leonard Rice Consultants for the Eckman Park Permit. The Leonard ' Rice study projected that 395 acres of land on Foidel Creek could _ ~`.:, `' potentially be irrigated, based on water availability and topographic suitability. However, the study concluded that irrigation would not be l~ ` •~ feasible in actuality because the cost of reservoir and ditch ,~1, ~^, construction would greatly exceed potential revenues. ._ ; `_ .Zu _. ~~ Apparently, the Leonard Rice study did not take into consideration the ~~ J existence of Reservoir No. 1 on upper Foidel Creek and Reservoir No. 2 on the South Fork of Foidel Creek, which were evidently constructed for irrigation storage. If there are reasons for not considering the renovation and use of existing facilities in the feasibility study, they should be explained. Otherwise, the application should determine the acreage which could be irrigated, based on the storage capacity of Reservoirs No. 1 and No. 2 and water use and engineering feasibility assumptions included in the Leonard Rice study. ~_ Soils - Rules 2.04.9, 2.05.3(5), 2.05.4(2)(d) and 4.06 1. ~' On page 2.05-25 and 26, the application states that "... soil series without a B horizon include the Binco Silty Clay Loam, the Dunkley - Skyway Complex and the Routt Loam". This is evidently a typographic error since these soils do have B horizons. "Without" should be changed to "with". 2. / The application states that only the top 10-12 inches of the Binco Series will be salvaged since the quality of the associated subsoil is rated as poor due to high clay content. Table 32, however, indicates that an average depth of 30" would be salvaged from Map Unit F10 (which is Binco Series). Please clarify. Also, Table 18 data shows that Routt Loam subsoils are texturally similar to Binco subsoils (both have high clay contents). Why is the Binco subsoil not proposed for salvage ~~~ while the Routt Loam subsoil is proposed for salvage? The applicant proposes not to salvage soils on slopes steeper than 20 degrees (approximately 63 acres within the disturbed area.) This proposal would result in the loss of significant quantities of high quality topsoil. The applicant's plan to mitigate this loss by salvaging the deep soil accumulations in valley bottoms would not replace the vegetative propagules and seed pool contained near the soil surface.