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Exhibit 33 of the permit application package shows the acreage at the UTL area identified as <br />"historically flood irrigated". With PR-4 SCC has submitted new exhibits for insertion into the <br />permit application package. Exhibit 33-1, Irrigated Fields 10-14-76 and Exhibit 33-2, <br />Potentially Irrigated Fields 11-16-94 show the irrigated fields prior to, and after loadout site <br />development. Based on aerial photos taken on Octoberl4, 1976 there were a total of 26.1 <br />irrigated acres at the UTL. Of the total, 13.9 acres are located inside the loop and 12.2 acres are <br />outside the loop. Therefore, it would be possible for the Operator to restore the capability of <br />flood irrigation to 12.2 acres, 87% of the acreage for which irrigation water is available. <br />Only minor disturbance has occurred outside the UTL loop. Reclamation and restoration of the <br />essential hydrologic functions outside of the UTL loop area will involve minimal regrading to <br />reestablish the original topography, replacing topsoil, and revegetating. Although the 12.2 acres <br />outside the loop that were previously irrigated are now heavily overgrown with brush and <br />cottonwood trees, the industrial use will not prohibit the capability to restore flood irrigation to <br />these 12.2 acres. <br />In summary, surface coal mining and reclamation operations will be conducted to preserve, <br />throughout the mining and reclamation process, the essential hydrologic functions of the alluvial <br />valley floors not within the permit area, and operations will be conducted to reestablish the <br />essential hydrologic functions of alluvial valley floors within the permit area (4.24.2(1). The <br />permittee will be required to restore the essential hydrologic functions on the entire alluvial <br />valley floor where disturbance has occurred,with exception of the area located inside the UTL <br />loop as a result of the postmine land use change from wildlife habitat to industrial/commercial <br />with PR-4. As described above, the postmine land use change will preclude the Operator's <br />capability to restore flood irrigation to a small amount (1.8 acres) of the original 14 acres for <br />which water is available. Subirrigation throughout the UTL area is not affected by the postmine <br />land use change associated with PR-4 and no actions are necessary to reestablish subirrigation. <br />Rapid/Cottonwood Creek Area <br />Four distinct areas were examined for identification of alluvial valley floors in the vicinity of Rapid <br />Creek and Cottonwood Creek. These areas were Cottonwood Creek, Rapid Creek, minor ephemeral <br />streams and the Colorado River adjacent to the Rapid Creek and Cottonwood Creeks watersheds. <br />None of these areas are covered by the "grandfathering" exemption. <br />The Cottonwood Creek valley does not meet the geomorphic characteristics of an alluvial valley floor. <br />The valley is narrow, and any fill material does not meet the AVF size criteria. <br />Valley fill deposits located along Rapid Creek have been interpreted as a mudflow fan deposit which <br />has been modified and reworked by Rapid Creek to form three terrace levels. The upper terraces (T2 <br />and T3) are irrigated or have been irrigated with the flow from Rapid Creek. The lowest terrace (Ti) <br />is narrow and has not been flood irrigated. The T1 terrace includes a narrow band of subirrigation <br />along the creek, but the species present are not agriculturally useful. Subirrigated species located on <br />the T2 terrace are deep rooted and do not indicate the general availability of groundwater to <br />agriculturally useful species. The T3 terrace does not have vegetation indicating subirrigation. <br />Several minor ephemeral streams also drain the permit area. The stream valleys are narrow, steep, and <br />contain very little alluvium. None of these valleys contain deposits meeting the AVF size criteria. <br />Permit Revision No. 4 54 February 3, 2009