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considers all lands mapped as Qa and Qvf on Exhibit 16-2 to be alluvial valley <br />floors. <br />AVF Findines <br />The Division has determined that an alluvial valley floor exists within the <br />affected or adjacent area. Therefore, the following findings are in order for the <br />alluvial valley floors known as Sage Creek and Dry Creek located East and <br />Northwest, respectively, of the permit boundary. <br />1. With regard to Dry Creek, the Division finds that activities proposed by the <br />applicant will not interrupt, discontinue, or preclude farming on the alluvial <br />valley floors that are irrigated or naturally subirrigated except for small <br />areas which may provide negligible support for the farm's agricultural <br />production (4.24.3(1)) and 2.06.8(5)(a)(i)). <br />The only mining related activity which would interrupt farming on an <br />alluvial valley floor is the tie across haul road which has already been <br />completed. The Division previously determined that the 2.3 acres of <br />hayland on the Dry Creek AVF which would be taken out of production <br />represented only 0.2% of the farm unit and was therefore of negligible <br />impact. Actual mining operations will be conducted a half mile or more <br />from the alluvial deposits of Hubberson Gulch, Dry Creek, and Sage Creek. <br />2. With regard to Hubberson Gulch, Sage Creek and Dry Creek, the activities <br />will not materially damage the quantity or quality of water in the surface or <br />ground water system (4.24.3{3) and 2.06.8(5)(a)(ii)), and the proposed <br />activities will comply with the requirements of the Act and the Regulations <br />with respect to alluvial valley floors (2.06.8(5)(a)(iii). <br />a. Subirrigated and flood irrigated croplands and points of diversion on <br />Hubberson Gulch are located upstream from the 006 Gulch confluence <br />and are hydrologically upgradient from the proposed mine area. So <br />long as coal reserves south of the proposed permit area are not <br />included in the life of mine plan, there is no potential for diminution of <br />the quality or quantity of water supplied to the irrigated farmland on <br />the Hubberson Gulch AVF, and no detailed impact evaluation is <br />warranted. <br />b. Due to the extremely limited acreage of proposed disturbance within <br />the Sage Creek watershed, and the fact that regional ground water flow <br />is to the west, the potential for material damage to the quality or <br />quantity of water supplied to the AVF is negligible. No measurable <br />impacts to the quantity or quality of water supplying the Sage Creek <br />AVF are projected. <br />40 <br />