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vegetation. This azea is also delineated on Map I S of the PAP. PR-OS approved undermining a portion of the AVF on Foidel Creek. AVF Determination -Negative Determination Foidel Creek Prior to PR-03, an alluvial body along Foidel Creek in sections 28, 29, 31 and 32, TSN R86W, was determined not to be an AVF based on a finding of insufficient water to support flood irrigation, and a determination that subirrigated azeas were less than 10 acres in extent and supported species which were not agriculturally useful. Due to the significant expansion of mining operations proposed in the LOM revision application (PR-O1), the potential impacts to identified alluvial valley floors were reevaluated. Areas previously determined by the Division to not meet alluvial valley floor criteria were not reexamined. As a result of additional vegetation data and land use information submitted by the applicant and site visits made by Division staff, however, certain lands previously identified as alluvial valley floors were found not to meet AVF criteria. Based on the limited extent of arable land and relatively high percentage ofnon-agriculturally useful species as documented by species composition data included in the September 22, 1986 submittal, the Division concluded that the area of subimgated alluvium on lower Foidel Creek denoted as "Pasture 19" on supplemental Map No. 1 is not an alluvial valley floor. The extent of farmable acreage would be 10 acres or less. The azeas aze not presently and have not historically been farmed and evidence presented indicates that farming is not typically practiced on similaz parcels in the region. During PR03 review, the Division determined that areas upstream of the Leiske ditch crossing of Foidel Creek as shown on Map 15 (Sections 14, 21, 22, 23, and 28, TSN, R86W) are not alluvial valley floors. This determination was based on the lack of sufficient water for flood irrigation, the lack of flood irrigation, the small size of the valley bottom and the narrow nature of the stream, and the lack of meaningful production or cover differences between the creekside and upland vegetative communities. Therefore, in summary, the Division has previously found that all valley bottom areas along Foidel Creek above the County Road No. 33 crossing aze not alluvial valley floors. Middle Creek Prior to PR-03, no previous AVF determination had been made for azeas above the Foidel/Middle Creek confluence AVF on Middle Creek, as these azeas were not proposed to be affected or impacted by the Foidel Creek mine operation. During the PR-03 review process, the applicant submitted information to support that azeas along the Middle Creek valley floor in sections 12, 23, and 26 TSN R86W are not alluvial valley floors. Twentymile Coal Company provided information which is contained in the permit application as Exhibit 42a 30