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.- -~ <br />location, haul road and conveyor corridors, train loadout and rail loop, coal processing <br />facility and coal mine waste disposal area. The mine entries are depicted extending to the <br />east, from the northern end of the Resource Survey area, within federal lease C-0125516. <br />Prospective extent of underground workings is not depicted on the figures, and as such, <br />the full extent of the proposed Affected Area as defined by Rule 1.04(7) is not delineated. <br />Our assumption is that the workings would be contained within federal leases C-0125516 <br />and C-0125515. <br />Based on review of available information, including the McClane and Munger Canyon <br />permit application documents, the June 1985 OSM publication "Draft Reconnaissance <br />Maps to Assist in Identifying Alluvial Valley Floors, West-Central and Northwestern <br />Colorado, the map figures provided in your April 28 submittal, field reconnaissance and <br />review of pertinent satellite imagery ("Google Earth"), our informal opinion includes the <br />following points, which are based on the preliminary information available. <br />1) It appears that there are no alluvial valley floors within the 1890 acre Resource <br />Survey Boundary, or within federal coal leases C-0125515 or C-0125516. These <br />uplands contain only steep ephemeral drainages with relatively small watersheds, <br />with headwaters in the Bookcliffs. The small streams do not provide sufficient <br />water for irrigation and are generally too narrow and steep for agricultural <br />development. If the proposed Affected Area is limited to these areas, our <br />informal opinion is that the affected area would not contain alluvial valley floors. <br />2) It appears that two larger streams, segments of which maybe included within the <br />Adjacent Area, do meet the alluvial valley floor criteria. Conservatively, the <br />segment of Big Salt Wash downstream of the Buninger Canyon confluence to the <br />Highline Canal, and the segment of East Salt Creek downstream of the Munger <br />Creek confluence to the Highline Canal, would potentially be included within the <br />Adjacent Area. Both stream segments appear to meet the geomorphic and water <br />availability AVF criteria. There is current flood irrigation agricultural activity in <br />certain locations along East Salt Creek between the Munger confluence and the <br />Highline Canal, and there is historical and possibly current flood irrigation <br />agricultural activity in certain sections of Big Salt Wash between Buninger <br />Canyon and the Highline Canal. <br />Without more detailed operational information (for example, mine workings and <br />mine water discharge locations), adjacent areas pertinent to alluvial valley floor <br />findings cannot be defined with certainty. It is possible that portions of the East <br />Salt Creek and Big Salt Wash segments can be excluded from the adjacent area <br />based on information provided in the permit application. <br />Areas of alluvium on lower East Salt Creek and lower Big Salt Wash that are <br />imgated by diversion from the Highline Canal, would logically be excluded from <br />the Adjacent Area, since those areas would appear not to meet the Rule 1.04(6) <br />definition of Adjacent Area ("land...where...surface or ground water, vegetation, <br />