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,-'j <br />Mark Loye Page 2 <br />April 15, 1986 <br />the legal riyht to use these water sources. Valco, Inc. will not be able to <br />use water from the pit far the mining operation unless replacement water for <br />the additional consumptive use is included in the plan for augmentation. <br />The surface area of the pond that will be formed in the mining process is 48 <br />acres. The amount of water lost to the Arkansas River basin aue to evapo- <br />ration from this amount of water surface is 179 acre-feet. The portion of <br />these losses which occurs during the irrigation season is equivalent to the <br />amount of water needed to meet the irrigation needs of approximately 69 acres <br />of corn. We used the Modified Blaney-Griddle Formula to calculate this <br />figure. Since the Arkansas River is already over-appropriated, this will <br />result in a significant loss of water to downstream irrigators. <br />Unless a plan for augmentation is developed to replace the water loss to the <br />system due to evaporation, the operation will inure existing water rights. <br />Therefore, we cannot recommend approval of the permit until the applicant is <br />capable of mitigating the injury that will be caused by the project. Further, <br />we will order Valco, Inc. to cease operations if our Water Commissioner deter- <br />mines ground water is being exposed witnout a well permit or there is deter- <br />mined to be a wasteful use of grouna water occurring. <br />HDS/JCM:ma/7485H <br />cc: Bob Jesse, Div. Eng. <br />