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Fish Creek 1. The proposed minim_ operations will not interrupt, discontinue or preclude farming of the alluvial valley Floor. The boundaries of the Fish Creek alluvial valley Floor are as delineated on flap No. l ~ of [he Foidel Creek Life of dine application and include all alluvial deposits within and downstream from the permit area as delineated on supplemental Ivtap No. I. Information discussed below has reaffirmed the Division's original determination that alluvial deposits on Fish Creek meet alluvial valley door criteria based on existing flood irrigation, potential for flood irrigation and subirrigation. The existence of a currently flood irrigated field on lower Fish Creek and the presence of diversion structures and irrigation ditches on various stream segments as delineated on Ivtap 15 document the potential for flood irrigation. The alluvial valley floor and surrounding areas are managed as undeveloped rangelands with rangeland and pastureland as the approved post-mining land use. Mine plan expansion into the Northern Mining District predicts subsidence of up to 67 inches. Twentymile Coal Company presents the subsidence prediction information in Exhibit 4e-3. Twentymile Coal Company predicts an increase in the surface area of Fish Creek of 84 acres overlying longwall panels 12 Right through 16 Right. Observations of undermining of Foidel Creek found that the pooling of the subsided panel areas occurred primarily during high flow of [he creek. No[ all subsided panel areas pond concurrently. Instead, ponding occurred over the first panel undermined (longwall panel 9 Right) then over only the most recently mined longwall pane{. Information provided in application Exhibit 16 (Soil Mapping Unit Descriptions) and backhoe pit data provided on permit page 2.06 -9 show that a number of alluvial soil types exhibit late growing season ground water elevations within 6 fee[ of [he surface. Hay crop species commonly grown in the Yampa Basin would be expected to derive benefit from ground water when present a[ such shallow depths. The major vegetation type on the Fish Creek AVF within the permit area is a sagebrush meadow community dominated by silver sagebrush with a number of sedge and rush species contributing significantly to the community. All of these species are hydrophytes typically associated with subirrigated conditions. Rule 4.24.3(1) allows for interruption of farming on, "undeveloped rangelands which are not significant to farming..." The Division received a letter from one of the surface owners, Mr. Edward Camilletti , on January 23, 1998, regarding the significance of the Fish Creek AVF to farming in sections 10 and l5, TSN, R86W. The Camelletti's use these lands as undeveloped rangeland. The landowner estimated that 1% of the ranch production is attributed to the Fish Creek AVF. Subsidence and potential flooding of Fish Creek and its alluvial valley floor will have negligible impact to the ranching operation. Twentymile Coal Company owns a significant portion of the lands in and adjacent to the Fish Creek AVF. Twentymile Coal Company operates a cattle operation on these lands and manages the land, through its ranch manager, Trout Creek Ranch, as undeveloped rangeland. TCC does not utilize the Fislt Creek AVF as cropland. TCC projects that subsidence impacts [o the Fish Creek AVF and associated pooling of Fish Creek will not significantly impact the cattle operation. C:\JHB\C82056\PROS1PR05 FINDINGS 62800.doc 30