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As a result of 1990 AVF investigations in the Sage Creek watershed, Seneca Coal <br />Company concluded there aze no AVF's in this basin in hydrologic communication with <br />the proposed Yoast Mine. Based on information submitted by the applicant, field <br />reconnaissance, interviews with farmers, and previous findings by the Division and the <br />applicant related to the Seneca U-West Mine, the Division does not concur with the <br />applicant's conclusion. The Division concludes that two azeas along Sage Creek <br />downstream from the Yoast permit azea meet the regulatory definition of alluvial valley <br />floors. These areas are discussed below. <br />Sage Creek Reservoir Site <br />Two fields located just upstream from the former Sage Creek Reservoir dam (Sections <br />13 and 18) are identified in the Yoast application as subirrigated native wetlands and <br />subirrigated grass hay. The native wetland azea is basically the area once covered by <br />the reservoir, which failed in 1985. This area is currently used for grazing. The area <br />immediately upstream from the former reservoir site is currently used as a grass hay <br />field. <br />These fields aze located in the upper reaches of Sage Creek, and therefore are not <br />typical of alluvial valley floors in this azea with agricultural potential. However, the <br />upper field (approximately 10 acres) is currently being farmed for hay, and the other <br />larger field appeazs to have the potential to be put to use as a subirrigated hay field. <br />Furthermore, during a site visit on May 19, 1995, the upper grass hay field was being <br />flood irrigated by means of an imgation ditch along the eastern edge of the field. This <br />was confirmed during the review of PR-1. Due to the existence of flood irrigation and <br />the presence of subimgation of the unconsolidated streamlaid deposits in the fields <br />immediately upstream from the old Sage Creek Reservoir, these fields aze determined <br />to be alluvial valley floors. <br />The field just above the breached Sage Creek dam is dissected by the streambed. <br />This area is undeveloped rangeland that is currently used for grazing. The limited <br />size of the field would make it difficult for farm equipment to operate. This field <br />is not typical of agriculturally productive alluvial valley floors in this region. <br />However, the upper field in Section 18, TSN R88W, is currently being farmed for <br />hay. The creek was diverted from the center to the perimeter ofthe field and the creek <br />bed was filled to create a manageable flood irrigated field. The field is ten acres and <br />is flood irrigated during high flow. The family that manages the field does not have <br />adjudicated water rights for the surface water in Sage Creek. They have an <br />agreement for early runoff withdrawals, allowing limited flood irrigation until mid- <br />June when stream flows decline to a level precluding further withdrawals. It is <br />unlikely the Feld will be irrigated with water at the projected worst-case salinity <br />levels, but SCC did provide an estimate of what the potential worst-case impacts to <br />the agricultural operation would be. <br />Yoast Mine 40 February 28, 2006 <br />