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Flood irrigated hayland and vegetation sample locations are depicted on Map No. 1. Irrigated hayland <br />is the predominant land use on the Trout Creek AVF and the dominant species are Kentucky <br />bluegrass, Smooth brome and Timothy. Based on the extent of existing flood irrigated farmland, and <br />lack of specific information regarding extent or use of subirrigated alluvium, the Division finds that the <br />Trout Creek alluvial valley floor is significant to farming. The required findings are set forth below. <br />1. The proposed mining operations would not interrupt, discontinue or preclude farming on the alluvial <br />valley floor. <br />Mining activity would not directly impact any portion of the Trout Creek AVF. Any impacts would be <br />indirect, as a result of discharge of affected water into Foidel Creek and Fish Creek. Fish Creek is <br />tributary to Trout Creek, and Foidel Creek is tributary to Middle Creek, which is tributary to Trout <br />Creek. Indirect impacts are addressed under No. 2 below. <br />2. The proposed mining operations would not cause material damage to the quantity or quality of surface <br />and ground water that supply the alluvial valley floor. <br />The only potential for the diminution of the quantity of water supplied to the Trout Creek AVF would <br />be as a result of undermining of Fish Creek and Foidel Creek, which are tributary to Trout Creek. <br />Dewatering of the streams as a result of undermining is not considered to be a possibility for reasons <br />explained in the Fish Creek and Foidel Creek AVF Findings section of this document. <br />Rule 2.06.8(5)(c) of the Colorado Regulations specifically refers to potential increases in electrical <br />conductivity of water supplying AVFs to levels above threshold value at which crop yields decrease as <br />constituting material damage. A reference initially used is a paper by E.V. Maas and G.J. Hoffman of <br />the U.S. Salinity Laboratory published in the Journal of the Irrigation and Drainage Diversion, ASCE., <br />June, 1977. In their paper, Maas and Hoffinan list research-derived salinity threshold levels and <br />response rates for selected agricultural species, and group those species as well as a number of <br />additional crops into four categories based on relative tolerance to salinity (sensitive, moderately <br />sensitive, moderately tolerant and tolerant). <br />The Division has taken the approach that a positive material damage fmding would be made if <br />projected salinity increases resulting from mining would result in significant decreases in production or <br />shifts in species composition based on the Maas and Hoffman paper. <br />On the Trout Creek AVF, the applicant sampled vegetative cover within a number of farmed fields as <br />denoted on Map No. 1 of Exhibit 42. Vegetative production, as well as cover was sampled in one field <br />(Pasture 11). A majority of the species on the AVF would be considered moderately tolerant, and on <br />an acreage weighted basis only 18.4% of the cover was made up of moderately sensitive species <br />(salinity threshold reached at root zone soil saturated paste extract electrical conductivity of 1.5 <br />mmhos/cm). A number of the species encountered have not been ranked by Maas and Hoffman, and <br />other references were consulted. In general, Aveneae tribe grasses and Trifolium species were <br />considered to be moderately sensitive, while Triticeae, Stipeae, and Poeae tribe grasses (with the <br />exception of Dactylis) were considered to be moderately tolerant. Carex and Juncus species were also <br />considered to be moderately tolerant. <br />Estimates submitted by the applicant project mining will impact Trout Creek water salinity, producing <br />EC levels in the vicinity of 1.23 mmhos/cm (1230 umhos/cm X .73 ratio = 922 mg/l TDS). Assuming <br />that a root zone saturated extract soil salinity of 1.845 mmhos/cm would result from flood irrigation <br />water with a specific conductance of 1.23 mmhos/cm, some decrease in crop production would be <br />expected. The assumed relationship between irrigation water salinity and root zone soil salinity is <br />32