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away from these structures, it seems unlikely that any damage to the structures will occur. (Rule 4.20) No renewable resource lands lie within the permit azea. Information provided in the application indicates that the Pine Gulch drainage, which at one time was suggested to be a renewable resource area, does not in fact qualify as one. These is no aquifer or rechazge azea for an aquifer in the Pine Gulch area. Core hole data supplied with the original application demonstrate that the bedrock section above the level of the coal is dry. The survey of wells and springs in the azea of the mine has established stratigraphically lower aquifers whose rechazge azeas do not include Pine Gulch. The Pine Gulch azea is also not one utilized for agricultural or silvicultural production of food and fiber nor does it serve as a pasture land. The confluence of Pine Gulch and Hay Gulch approximately three miles downstream from the mine was determined to be an alluvial valley floor on which agricultural activities aze conducted. These activities however, do not rely on the surface or ground water resources originating in the Pine Gulch azea. Provisions of the proposed mining plan, furthermore, will minimize any potential for mining related subsidence impacts on the Pine Gulch drainage. Elongated pillazs will not be extracted during final retreat. As a result, the Pine Gulch drainage azea will be assured of continued long term stability. XIV. Operations on Alluvial Valley Floors A. The Division has determined that an alluvial valley floor exists within the affected or adjacent azea. Therefore, the following fmdings are in order for the alluvial valley floor known as Hay Gulch located 7 miles SW of Hesperus, Colorado. There aze currently three coal mining operations located within Hay Gulch: the King Coal Mine (permitted, active), the Blue Flame Coal Mine (revoked and reclaimed), and the La Plata No. 1 Mine (revoked and reclaimed). All three mines aze considered in the alluvial valley floor discussion. Field observations by Division staffand information contained in permit applications indicate that small azeas ofunconsolidated stream-]aid materials aze present in adjacent drainages. However, these azeas aze not extensive enough to meet the size criteria of AVFs. It has been determined that Hay Gulch meets the criteria for an AVF based upon three fmdings: (1) The valley contains unconsolidated stream-laid deposits; (2) The valley contains sufficient water to support agricultural activities as evidenced by (a) the historical use of flood irrigation in the area, and (b) the demonstrated capability of the area to be flood irrigated, and (3) The valley has demonstrated sub-irrigation. It should be noted that Hay Gulch does not presently contain a stream. It is thought this is due to agricultural practices in the gulch that diverts naturally occurring flow 22