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the vast majority of TCC's land holdings are 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 through 14 Right. Fish Creek and its alluvial <br />valley floor aze located within these panels. Of the 39 acres to be impacted in the 13 Right panel, approximately 26 <br />acres 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 are owned by TCC. Again, TCC leases <br />this land from the Ashley's for its ranching operation. Using the GEMCOM model this will result in 0.33% of <br />TCC's ranching operation lands being impacted by subsidence of the alluvial valley floor. >n reference to the <br />Ashley's ranch it is comprised of approximately 450 acres of fee land and then an associated state lease. The <br />Ashley's lease their property to Twentymile for the purpose of grating animals. The area that will be flooded along <br />Fish Creek represents 4% of their fee holdings. Presently, this alluvial valley floor area has not been flood irrigated <br />and TCC does not depend upon it for any critical aspect of its operation. The loss of production from this area does <br />not materially damage TCC's ranching operation. Personal communication with the Ashley's indicates that loss of <br />this area will not materially damage their ranch. A letter from the Ashley's is presented in Exhibit 4e-5, and is <br />considered to be confidential. <br />In regazds to the impact upon TCC's ranching operation the total number of acres that will be taken out of <br />production due to 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, refer to <br />Exhibit 7j-1 for production data. For example, TCC typically uses a stocking rate of 1 steer per 4 acres, in the valley <br />bottom the rate wuld be decreased to 2 acres per steer. This means the difference of grazing approximately 26 head <br />of cattle. TCC typically grazes from 2800 to 3200 head of cattle on its property, again showing that this loss is not <br />materially damaging to the financial health of the operation. <br />• There are two other ranches associated with the undermining and subsiding of Fish Creek, those being, Camilletti and <br />Sons and the Ashley's. th reference to Camilletti and Sons, they own approximately 920 acres in the immediate area <br />of the mine, 3,500 acres in various sections of T6N, R86W and approximately 1,040 acres in T7N, R86W. The <br />mining of panel 16 Right will impact the property within the immediate area of the mine. Personal communication <br />with Mr. Frank Camilletti of Camilletti and Sons indicates that this acreage is not critical to the continued operation <br />of the ranch and will not materially damage it. This due to the fact that this parcel of land is narrow and in a canyon <br />and is not conducive to flood irrigation for the production of hay crops. This area is no[ cropped and is treated as <br />unimproved rangeland. <br />TCC conducted a vegetation study of the adjacent upland area and the bottomlands to evaluate the productivity of the <br />respective areas. The study is presented th Exhibit 7j-l, Norihem Mining District, Fish Creek Vegetation Study. <br />The data presented in the study verifies TCC position that the productivity between the two areas is not different <br />enough to warrant any conclusion different than TCC's. <br />The fuutl area to be impacted by subsidence is that associated with the mining of panels l6 and 18 Right. The State <br />of Colorado is the surface owner of the parcel, located in the SW/4 of Section 10, TSN, and R86W, to be <br />undermined and subsided. As presented above, the mining of this panel will flood a total of 3 acres. As is the case <br />for all the lands along Fish Creek to be undermined and subsided no flood imgation system has been established to <br />increase the productivity of the land nor are the management practices established for haying this area. The land is <br />Veated as unimproved rangeland utilized for grazing by the lessee. <br /> <br />`,n.,; .f .. ... , <br />PR 99-OS 2.06-25.2 8/27/99 <br />