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The boundaries of the Fish Creek AVF aze shown on Map 15 of the PAP. The AVF includes <br />all alluvial deposits within and downstream from the permit area as shown on supplemental <br />Map 1. Information discussed below has reaffirmed the Division's original determination <br />that alluvial deposits on Fish Creek meet AVF criteria based on existing flood irrigation, <br />potential for flood irrigation, and subirrigation. <br />Map 15 shows the following features in the Fish Creek AVF: areas having potential for <br />flood irrigation, currently flood- imgated fields, diversion structures, and irrigation ditches. <br />Several of the soils in the AVF exhibit late growing season ground water elevations within 6 <br />feet of the surface (Exhibit 16, Soil Mapping Unit Descriptions and backhoe pit data <br />provided on Page 2.06 -9 of the PAP). Hay crop species commonly grown in the Yampa <br />Basin would be expected to benefit from such shallow ground water. <br />The principal vegetation type in the Fish Creek AVF within the permit area is a sagebrush <br />meadow community dominated by silver sagebrush, with a number of sedge and rush <br />species contributing significantly to the community. All of these species aze hydrophytes <br />typically associated with subin•igated conditions. <br />The Division received a letter from one of the surface owners, Mr. Edward Camilletti, on <br />January 23, 1998, regarding the significance of the Fish Creek AVF to fanning in sections <br />10 and 15, TSN, R86W. The Camellettis use these lands as undeveloped rangeland. The <br />landowner estimated that 1% of the ranch production is attributed to the Fish Creek AVF. <br />Twentymile Coal Company owns a significant portion of the lands in and adjacent to the <br />Fish Creek AVF. Twentymile Coal Company operates a cattle operation on these lands and <br />manages the land, through its ranch manager, Trout Creek Ranch, as undeveloped rangeland. <br />TCC does not utilize the Fish Creek AVF as cropland. TCC projects that impacts to the Fish <br />Creek AVF will not significantly impact the cattle operation. <br />TR-14 approved the undermining and subsidence of a small portion of Fish Creek due to <br />longwall extraction in panels 5, 6 and 7 in the Southwest Mining District. No farming <br />activities are currently undertaken along Fish Creek in this area. Subsidence would not <br />preclude the farming of this area. <br />Fish Creek is the only AVF proposed for undermining during PR-06 mining. TCC predicts <br />the mining proposed in PR-06 will cause little or no adverse impacts to water in Fish Creek <br />or its alluvium (Exhibit 7e-6 of permit application). TCC predicts minimal potential for <br />water-loss from subsidence-caused surface fissures and associated "stream pirating". Neither <br />surface fissures nor stream pirating were found during previous undermining of Fish Creek <br />by panels 13 Right and 14 Right. Over those panels rock types at the ground surface are <br />similar to the rock types at the ground surface in the area proposed for undermining in PR- <br />06. In past mining, surface cracking has been confined to azeas where the Twentymile <br />sandstone crops out or is near the surface. The Twentymile sandstone lies several hundred <br />feet below the ground surface in the PR-06 mining azea. <br />32 <br />