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Section 785.19(c) Continued. Revised 11/(2080 should be evaluated. In this effort, watersheds of similar physiographic, agricultural, geologic, climatic, hydrologic, soils, and vegetation characteristics could be identified. The region containing these watersheds might include a few counties or an area a few tens of miles about a permit area. Within this area, all current or historically successful flood irrigation areas could be identified. Flood irrigation in valleys with drainage basins of similar of smaller size could then be evaluated on site to determine the height above the channel of irrigated lands, the type of irrigation practiced, and other important site conditions. Following this regional evaluation, all lands in the surface water adjacent area or permit area with similar physical conditions would be identi- fied as flood irrigable." • Consultations were held with MLR and OSM technical staff on April 2 and April 16, 1980, which predated the OSM Guideline of June 11, 1980 to discuss alluvial valley floor issues concerning the expan- sion of the Kerr Mine. These meetings were documented with follow- up letters dated April 24 and April 30, 1980 to MLR and OSM from Kerr Coal representative Michael S. McCarthy of Conover, McClearn, Heppenstall fi Kearns. As a result of the consultations with MLR and OSM staff, the criteria for determining flood irrigation capa- bility includes a feasibility study using irrigation methods and costs which are typical of the region. It has been further speci- fied that water available from the entire year should be used, provided that reservoir storage of water from snowmelt and runoff is a common practice in the region. According to the OSM Guideline, legal water availability is not a criteria for determining flood irrigation capability for the purpose of identifying alluvial valley floors, and was not considered in the feasibility study. Exhibit 37a, Flood Irrigation Feasibility Study, has incorporated all of the above criteria into a comprehensive document of irriga- 785-17 as