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upstream to elevation 6,800 feet. The narrative references Map 66, which we are unable <br />to locate, as delineating areas of alluvial deposits and agricultural areas supported by <br />"irrigation or flood irrigation". Narrative asserts that alluvial deposits on Minnesota Creek <br />and the East Fork of Minnesota Creek that support irrigated agriculture do meet AVF <br />criteria, but that an alluvial deposit on the Dry Fork of Minnesota Creek immediately <br />upstream from Minnesota Reservoir does not meet AVF criteria. The Division accepted the <br />documentation presented, and concluded that the Dry Fork alluvial body did not meet AVF <br />criteria. <br />Narrative indicates that, for the purposes of the evaluation, mapping was stopped along <br />Minnesota Creek at the west section line of Section 2, T14S, R90W, "a point over two <br />miles from the permit boundary and downstream of the headgates of the Turner Ditch and <br />Minnesota Ditch". Based on this description, it would appear that the reference to "R90W" <br />is erroneous and should be "R91 W". <br />North Fork of the Gunnison <br />The narrative indicates the presence of irrigated agriculture in lower portions of the valley <br />where the alluvial deposits widen (apparently downstream from the mouth of Gribble <br />Gulch). Various alluvial areas further upstream in narrower portions of the valley were <br />evaluated, but arguments are presented in the narrative to support the contention that these <br />areas do not meet AVF criteria, for various reasons. Map 66 is also referenced in regard to <br />the North Fork of the Gunnison AVF investigation. <br />Based on our review of the permit application narrative and available maps, and the RN-4 <br />findings document as summarized above, we have the following requests related to Alluvial <br />Valley Floor Determination, pursuant to Rule 2.06.8(3). <br />4. Much of the alluvial valley floor reconnaissance information required by Rule <br />2.06.813)(bl, and upon which the Division's previous AVF determinations were <br />based, was apparently presented on Map 66: This map cannot be located in the <br />Division's copy of the approved permit application document, and was not included <br />in the maps submitted as a part of the PR-10 application. The map may not have <br />been updated for many years, and an updated reconnaissance investigation may be <br />warranted to ensure that the status of agricultural activities as described for the <br />alluvial deposits along the various stream valleys in the life of mine permit and <br />adjacent areas remains accurate. <br />Please provide a properly updated version of Map 66, with any additional maps as <br />may be necessary to comply with the requirements of 2.06.8(3-la)(i-, (ii), and (iii). <br />Please provide in addition, revised narrative as may be warranted to reflect any <br />changes in the nature or extent of flood irrigated or sub-irrigated agricultural <br />activities in the subject stream valleys, which may have occurred subsequent to the <br />original reconnaissance investigation. <br />5. There appears to be an erroneous reference to the west section line of Section 2, <br />T14S, R90W, on page 2.06-5 of the approved permit application. This was <br />described as the endpoint of mapping on Minnesota Creek, but based on the <br />description, it appears that the correct reference would have been to the west <br />section line of Section 2, T14S, R91W. This apparent error was incorporated into <br />the Division's subsequent findings documents. Please address this apparent error, <br />and amend the narrative reference as appropriate. <br />4 <br />