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1. Section 2.04.5 of the permit application provides information on Grassy Creek, a <br />perennial stream. Section 2.04.6 of the permit application provides a lithologic <br />description of the PSCM's overburden. Section 2.05.3 of the permit application <br />provides information regarding PSCM's depth of mining, height of mining, room <br />and pillar dimensions, and a map of the workings. Exhibit 2.05.6 of the permit <br />application contains a prediction of the worst possible consequences from <br />subsidence. PSCM predicts subsidence will not occur because pillars will not be <br />removed from the underground mine workings. Based on this detailed subsurface <br />information, the Division finds that PSCM's proposed undermining of Grassy Creek <br />stream will not cause material damage to the stream. (4.20.4). <br />XIII. Operations on Alluvial Valley Floors <br />Section 2.06.8 of the permit application contains information on alluvial valley floors <br />(AVFs). The following three AVFs are within the area of influence of the PSCM: the Fish <br />Creek AVF, the Grassy Creek AVF, and the Little Grassy Creek AVF. The Fish Creek AVF <br />extends the length of Fish Creek to its confluence with Trout Creek. The Grassy Creek AVF <br />is a 45-acre area near the Grassy Creek/Little Grassy Creek confluence. The Little Grassy <br />Creek AVF is a 40-acre area that extends along a narrow strip on both sides of Little Grassy <br />Creek upstream from the Little Grassy/Grassy Creek confluence. The Division previously <br />determined that Cow Camp Creek, an ephemeral tributary of Fish Creek, is not an AVF <br />based on severely limited farmable acreage due to the meandering nature of the stream <br />channel. <br />The Division affirms its previous AVF determination for the Fish Creek AVF that is <br />documented in the findings documents of the Foidel Creek Maine (C-82-056). Alluvial <br />deposits on Fish Creek meet alluvial valley floor criteria based on existing flood <br />irrigation, potential for flood irrigation and subirrigation. <br />The existence of a currently flood-irrigated field on lower Fish Creek and the presence of <br />diversion structures and irrigation ditches on various stream segments as delineated on Map <br />15 in the Foidel Creek Mine permit application document the potential for flood irrigation. <br />Alluvial soil types in the Fish Creek drainage exhibit late growing season ground water <br />elevations within 6 feet of the surface (Foidel Creek Mine permit: Exhibit 16 - Soil Mapping <br />Unit Descriptions, and backhoe pit data, page 2.06 -9). Hay crop species commonly grown <br />in the Yampa Basin would be expected to derive benefit from ,ground water when present at <br />such shallow depths. <br />The major vegetation type on the Fish Creek AVF within the permit area is a sagebrush <br />meadow community dominated by silver sagebrush with a number of sedge and rush species <br />contributing significantly to the community. All of these species are hydrophytes typically <br />associated with subirrigated conditions. <br />In connection with a review of the Foidel Creek Mine permit application, the Division <br />received a letter from one of the surface owners in the Fish Creek drainage, Mr. Edward <br />Camilletti, dated January 23, 1998. The letter estimates 1% of the production of the <br />Peabody Sage Creek Mine 35 May 7, 2010