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The four gulches (No Name, Johnson, Pyeatt, and Flume) lack sufficient water availability <br />for flood irrigation. According to the Soil Conservation Service, local irrigation requires <br />approximately 5 acre-feet of water per acre, after allowing for evaporation losses (letter from <br />Hill, 1980 referenced on page 2-539 of permit application). Summertime evaporation in <br />Moffat County exceeds precipitation by approximately 30 inches (Evaporation from Lakes <br />and Reservoirs by A.F. Meyer, 1942, Minnesota Resources Commission, page 58). The <br />largest annual water yield for any of the four gulches is calculated to be the 225 acre-feet <br />yield from Flume Gulch (page 2-412 of permit). This amount of water would irrigate only <br />45 acres based on the 5 acre-feet of water per acre requirement, rendering flood irrigation an <br />uneconomic business venture. Flood irrigation is generally the only type of irrigation <br />practiced in small stream valleys in northwestern Colorado where wheat, alfalfa, and hay are <br />grown; the 77-day growing season limits farming in Moffat County to these or similar crops. <br />Sub-irri ation Agricultural Potential <br />OSM's Alluvial Valley Floor Identification and Study Guidelines (page C-10) explains that <br />in terms of alluvial valley floors, sub-irrigation occurs if enough water is available for a <br />sufficient time to have a recognizable effect on the species type and the productivity of a <br />plant community. Agricultural crops or rangeland must receive enough sub-irrigation that <br />the community is notably more productive or more agriculturally useful when compared to <br />dry land areas. <br />Sub-irrigation of agricultural plants can be expected to occur in the wide, flat valley bottoms <br />of the Yampa River and Williams Fork River. The four gulches (NO Name, Johnson, Pyeatt <br />and Flume), though, lack sufficient water availability for sub-irrigation agricultural activities <br />based on examination of those valleys in connection with renewal application RN-04/PR-05. <br />Two Division representatives and two representatives of the applicant jointly examined <br />Flume Gulch in order to verify the presence of AVF features. No evidence was found for the <br />increased agricultural plant productivity that would be expected in the bottom of the <br />drainage if a significant amount of sub-irrigation was occurring. Agricultural species types <br />and productivity appeared uniform across the drainage. Wetlands plants (cattails) are <br />growing in the lower end of Flume Gulch within the channel area, but the wetlands preclude <br />the potential for sub-irrigation agricultural activities. A Division representative also <br />inspected parts of Pyeatt, Johnson, and No Name drainages. Agricultural species types and <br />productivity appeared uniform across those drainages. <br />Alluvial Valley Floor Determination <br />Based on the presence of unconsolidated stream-laid holding streams and the presence of <br />water availability sufficient for flood irrigation agricultural activities, the following two <br />alluvial valleys have been determined to be alluvial valley floors: the Yampa River in the <br />Big Bottom area and the Williams Fork River near its confluence with the Yampa River. <br />The four gulches (No Name, Johnson, Pyeatt, and Flume) are determined to not be alluvial <br />valley floors based on their absence of water availability sufficient for irrigation or sub- <br />Trapper Mine 30 July 25, 2008