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Rule 2.06.8(5)(b) of the Colorado Regulations specifically refers to <br />potential increases in electro-conductivity of water supplying AVFs to <br />levels above threshold value at which crop yields decrease as <br />constituting material damage. The rule further cites a specific paper by <br />E.V. Maas and G.J. Hoffman of the U.S. Salinity Laboratory published in <br />the Journal of the Irrigation and Drainage Diversion, ASCE., June, 1977. <br />In their paper, Maas and Hoffman list research derived salinity threshold <br />levels and response rates for selected agricultural species and group <br />those species as well as a number of additional crops into four <br />categories based on relative tolerance to salinity (sensitive, moderately <br />sensitive, moderately tolerant and tolerant). <br />The Division has taken the approach that a positive material damage <br />finding would be made if projected salinity increases resulting from <br />mining would result in significant decreases in production or shifts in <br />species composition based on the Maas and Hoffman paper. <br />On the Trout Creek AVF, the applicant sampled vegetative cover within a <br />number of farmed fields as denoted on Supplemental Map No. 1. Vegetative <br />production, as well as cover was sampled in one field, Pasture 11. A <br />majority of the species on the AVF would be considered moderately <br />tolerant, and on an acreage weighted basis only 18.4% of the cover was <br />made up of moderately sensitive species (salinity threshold reached at <br />root zone soil saturated paste extract electro-conductivity of 1.5 <br />mmhos/cm). A number of the species encountered have not been ranked by <br />Maas and Hoffman, and other references were consulted. In general, <br />Aveneae tribe grasses and Trifolium species were considered to be <br />moderately sensitive, while r-Titiceae, Stipeae, and Poeae tribe grasses <br />(with the exception of Dactylis) were considered to be moderately <br />tolerant. Carex and Juncus species were also considered to be moderately <br />tolerant. <br />As shown in TABLE 17 of this document, projected Trout Creek water <br />quality for flood irrigation is approximately .5 mmhos/cm. Assuming that <br />a root zone saturated extract soil salinity of .75 mmhos/cm would result <br />from flood irrigation water with a specific conductance of .5 mmhos/cm, <br />no decrease in crop production would occur. The assumed relationship <br />between irrigation water salinity and root zone soil salinity is within <br />the typical range reported in USDA Handbook 60. Based on leaching <br />calculations included in the application and soil sampling conducted on <br />the Fish Creek AVF by the Division, the 1.5:1 relationship is considered <br />conservative. No decrease in production of any of the species currently <br />grown on the Trout Creek AVF would be expected unless the conductivity of <br />the irrigation water were to exceed 1 mmhos/cm. Based on species <br />composition data submitted, significant production decreases (13% for a <br />farm unit) would not occur unless irrigation water salinity were to <br />exceed 1.5 mmhos/cm. In summary, projected flood irrigation water <br />quality is .5 mmhos/cm and material damage would not occur unless water <br />quality were to exceed 1.5 mmhos/cm. <br />-21- <br />