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<br />Michael G. Altavilla ©~'l ~T <br />Seneca Coal Company <br />Page 3 <br />April 23, 1999 <br />subirrigated. If this is true, the field would meet the regulatory definition of an alluvial valley <br />floor under subparagraph III of the rule cited above. <br />SCC may wish to consider investigating one piece of information which the Division does <br />not currently have. Rule L04(142) defines unconsolidated stream laid deposits, which are a <br />necessary part of an alluvial valley floor, as flood plains and terraces in the lower reaches of <br />valleys which contain channels that are greater than 3 feet in bankfull width and greater than <br />0.5 feet in bankfull depth. At this time, the Division does not know if the portion of Sage <br />Creek near the field in Section 18 meets these criteria. <br />7. The Division generally agrees with SCC's findings regarding the availability of water in Sage <br />Creek subsequent to the failure of the Sage Creek Reservoir dam. However, the potential <br />exists for future irrigation of the hay field located in Section 30, T6N, R87W, if the Sage <br />Creek Reservoir dam is rebuilt or if another diversion dam is constructed downstream on <br />Sage Creek closer to the hay field in Section 30. SCC asserts that the potential for irrigation <br />of the field does not exist. Please provide some documentation supporting this assertion. Tn <br />regard to this question, please consider the following. <br />Based on information currently available to the Division, the field in question appears to meet <br />the regulatory definition of an alluvial valley floor. This would be based on rules <br />2.06.8(3)(I)(B)(I) and (In, since the field was historically irrigated and the capability of being <br />flood irrigated again may exist. Please note that rule ?.06.8(3)(I)(B) dictates that the Division <br />find an alluvial valley floor exists if historical use OR capability for irrigation exists. <br />In order to find that this area does not meet the criteria of 2.06.8(3)(I)(B)(11), the Division <br />would have to find that the capability for future irrigation does not exist based on streamflow <br />yields (already provided by SCC), water quality, topography and regional practices. <br />However, it is not cleaz how the Division could find that the criteria of 2.06..8(3)(I)(B)([), <br />since the field in question was historically irrigated. <br />Site WSSF4 is still referred to on page 42, of Tab 17. As stated in your response, there is no <br />WSSF4. Please update the PAP accordingly. <br />9. The PHC projects total dissolved solids in lower Sage Creek will increase to 2l 18 mg/l. This <br />constitutes suspect material damage outside the permit area. The PHC needs to address the <br />potential impacts to the hydrologic balance outside the permit area in the Sage Creek basin. <br />specifically in terms of quality of water that is or may be used for irrigation. Please address <br />all potential impacts on irrigation use of water. This PHC update should include detailed <br />information on the impacts to water quality in the Sage Creek Reservoir Outlet Ditch and <br />