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specific information regarding extent or use of subirtigated alluvium, [he Division finds that the Trout Creek alluvial valley floor is significant to farming. The required findings are set forth below. The proposed mining operations would not interrupt, discontinue or preclude farming on the alluvial valley Floor. Mining activity would not directly impact any portion of [he Trout Creek AVF. Any impacts would be indirect, as a result of discharge of affected water into Foidel Creek and Fish Creek. Fish Creek is tributary [o Trout Creek, and Foidel Creek is tributary to Middle Creek, which is tributary to Trout Creek. Indirect impacts are addressed under No. 2 below. 2. The proposed mining operations would not cause material damage to the quantity or quality of surface and ground water that supply the alluvial valley floor. The only potential for the diminution of the quantity of water supplied to the Trout Creek AVF would be as a result of undermining of Fish Creek and Foidel Creek, which are tributary to Trout Creek. Dewatering of the streams az a result of undermining is not considered to be a possibility for reazons explained in the Fish Creek and Foidel Creek AVF Findings section of this document. Rule 2.06.8(Sxb) of the Colorado Regulations specifically refers to potential increazes in electrical conductivity of water supplying AVFs to levels above threshold value at which crop yields decrease az constituting material damage. The rule further cites a specific paper by E.V. Maaz and G.J. Hoffman of the U.S. Salinity Laboratory published in the Journal of the Irrigation and Drainage Diversion, ASCE., June, 1977. In their paper, Maas and Hoffman list research-derived salinity threshold levels and response rates for selected agricultural species, and group those species az well az a number of additional crops into four categories based on relative tolerance to salinity (sensitive, moderately sensitive, moderately tolerant and tolerant). The Division has taken the approach that a positive material damage finding would be made if projected salinity increases resulting from mining would result in significant decreases in production or shifts in species composition based on the Maas and Hoffman paper. On the Trout Creek AVF, the applicant sampled vegetative cover within a number of farmed fields az denoted on Map No. 1 of Exhibit 42. Vegetative production, az well az cover was sampled in one field (Pasture 11). A majority of the species on the AVF would be considered moderately tolerant, and on an acreage weighted basis only 18.4% of the cover was made up of moderately sensitive species (salinity threshold reached at root zone soil saturated paste extract electrical conductivity of 1.5 mmhos/cm). A number of the species encountered have not been ranked by Maas and Hoffman, and other references were consulted. In general, Aveneae tribe grasses and Trrfolir<m species were considered to be moderately sensitive, while Triticeae, Stipeae, and Poeae tribe grasses (with the exception of Dacrylis) were considered to be moderately tolerant. Carex andluncus species were also considered to be moderately tolerant. Estimates submitted by the applicant project mining will impact Trout Creek water salinity, producing EC levels in the vicinity of 1.23 mmhos/cm (1230 umhos/cm X .73 ratio = 922 mg/I TDS). Assuming that a root zone saturated extract soil salinity of 1.845 mmhoslcm would result from flood irrigation water with a specific conductance of 1.23 mmhos/cm, some decrease in crop production would be expected. The assumed relationship between irrigation water salinity and root zone soil salinity is within the typical range reported in USDA Handbook 60. Based on leaching calculations included in the TCC permit application, and on soil sampling conducted on the Fish Creek AVF by the Division, C:U H B\C82056\RN03\RN03FI ND.doc 33