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flooded. Using the GEMCOM model approximately 84 acres would be impacted by subsidence. It should be <br />noted that the 16 acres identified columns 3 and 5 of Table 7 in the SubTerra Report presented in Exhibit 7-e3 <br />• presents the surface area of Fish Creek prior to subsidence (16 acres) and this azea is subtracted out of the total <br />AVF flooded area presented in columns 2 and 4 in the table. <br />In reference to a change in the gradient of Fish Creek, SubTerra analyzed the creek from stations 200 to 2020. The <br />analysis included evaluating the gradient both before and after mining. The result of this analysis is presented on <br />Table 4 in the report (see Exhibit 7-e3). Also, the narrative includes a discussion of change in gradient. <br />Mining of the 12 Right panel will result in no impact to the AVF. As mining continues to the north and coal is <br />removed from panels 13 Right through 16 Right the cumulative number of acres to be flooded during the low flow <br />period is 70 acres using the mathematical model and 84 acres using the GEMCOM model. Panel 13 Right will <br />involve flooding 26 (mathematical model) or 39 (GEMCOM model) acres, panel 14 Right will involve flooding 15 <br />(mathematical model) or 24 (GEMCOM model) acres and panel 15 Right will involve flooding 19 (mathematical <br />model) or 13 (GEMCOM model) acres, panel 16 Right will involve flooding 10(mathematical model) or 8 <br />(GEMCOM model) acres. <br />In reference to TCC's agricultural operations (Trout Creek Ranch), approximately 15,000 acres area utilized in the <br />ranching operation. The ranch does utilize flood-irrigated bottomland for hay production. The hay crop is <br />typically sold to other ranchers for feed. None of these areas will be impacted by the proposed mining operation. <br />The vast majority of TCC's land holdings aze either pastureland or rangeland, which are used for the production of <br />beef. <br />TCC's property will be subsided by the mining of panels 13 Right and 14 Right. Fish Creek and its alluvial valley <br />floor aze located within these panels. Of the 39 acres to be impacted in the 13 Right panel, approximately 26 acres <br />• are owned by TCC and the remainder by the Ashley's. TCC presently leases this land from the Ashley's for its <br />ranching operation. Of the 24 acres to be impacted in the 14 Right panel, all acres are owned by TCC. Using the <br />GemCom model this will result in 0.33% of TCC's ranching operation lands being impacted by subsidence of the <br />alluvial valley floor. In reference to the Ashley's ranch it is comprised of approximately 450 acres of fee land and <br />then an associated state lease. The Ashley's lease their property to Twentymile for the purpose of grazing animals. <br />The area that will be flooded along Fish Creek represents 4% of their fee holdings. Presently, this alluvial valley <br />floor area has not been flood irrigated and TCC does not depend upon it for any critical aspect of its operation. <br />The loss of production from this area does not materially damage TCC's ranching operation. <br />In regards to the impact upon TCC's ranching operation the total number of acres that will be taken out of <br />production due subsiding the alluvial valley floor is 50 acres, which represents 0.33% of the operations productive <br />area. Although the production measured from the AVF study area is approximately twice the production from the <br />upland area it is not significant enough to cause an impact to the financial position of the ranching operation. For <br />example, TCC typically uses a stocking rate of 1 steer per 4 acres, in the valley bottom the rate could be decreased <br />to 2 acres per steer. This means the difference of grazing approximately 26 head of cattle. TCC typically gazes <br />from 2800 to 3200 head of cattle on its property, again showing that this loss is not materially damaging to the <br />financial health of the operation. <br />There are two other ranches associated with the undermining and subsiding of Fish Creek, those being, Camilletti <br />and Sons and the Ashley's. In reference to Camilletti and Sons, they own approximately 920 acres in the <br />immediate area of the mine, 3,500 acres in vazious sections of T6N, R86W and approximately 1,040 acres in T7N, <br />R86W. The property within the immediate azea of the mine will be impacted by the mining of panel 16 Right. <br />Personal communication (December, 1997) with Mr. Frank Camilletti of Camilletti and Sons indicates that this <br />• acreage is not critical to the continued operation of the ranch and will not materially damage same. This due to the <br />fact that this parcel of land is narrow and in a canyon and is not conducive to flood irrigation for the production of <br />hay crops. This area is not cropped and is treated as unimproved rangeland. <br />PR 03-06 2.05-184.5 05/07/03 <br />