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The small area of alluvium on Dry Creek in Section 9 was originally determined by the <br />Division to be an alluvial valley floor. However, based on amended vegetation mapping <br />and narrative presented in TR-50 (amended Tab 17 pages 129 through 129c, and new Map <br />1 Attachment to Exhibit 16-3, Sht. 2) the Division has revised its original determination. <br />Based on the information presented in TR-50, the Division finds that the subirrigated <br />parcels on Dry Creek in Section 9 do not meet AVF criteria. Native wetlands dominated by <br />species that are not agriculturally useful comprise the major portion of the northern parcel in <br />the vicinity of the reservoir embankment. Meadow grass types potentially enhanced by <br />subirrigation occur in the southern parcel, and as a minor type in the northern parcel. The <br />grass meadows may have been managed for hay production in the past, but the report <br />indicates that there is no evidence of management for hay production in recent years. <br />Further, the largest contiguous acreage of potentially subirrigated grass meadow owned by a <br />single landowner is 1.1 acres. Estimated production from the 1.1 acre field would support <br />less than 3 animal unit months (AUM's). <br />The Division concludes that the Dry Creek Section 9 parcels do not constitute an alluvial <br />valley floor. This finding is based on the fact that the native wetland community does not <br />support agriculturally useful vegetation and as such does not meet AVF criteria. Further, <br />the meadow parcels, due to small size, split ownership, and limited production potential do <br />not play a significant role in support of an economically viable ranching or farming <br />operation, nor do they serve a special role in agricultural land use in the region. As such, <br />the meadow parcels do not meet AVF criteria. <br />AVF Findings <br />The Division has determined that an alluvial valley floor exists within the affected or <br />adjacent area. Therefore, the following findings are in order for the alluvial valley floors <br />known as Sage Creek, Hubberson Gulch, and Dry Creek located east, west, and northwest, <br />respectively, of the permit boundary. <br />1. With regard to Dry Creek, the Division finds that activities proposed by the applicant <br />will not interrupt, discontinue, or preclude farming on the alluvial valley floors that are <br />irrigated or naturally subirrigated except for small areas which may provide negligible <br />support for the farm's agricultural production (4.24.3(1)) and 2.06.8(5)(a)(i;)). <br />The only mining related activity which would interrupt farming on an alluvial valley <br />floor is the tie across haul road which has already been completed. The Division <br />previously determined that the 2.3 acres of hayland on the Dry Creek AVF which <br />would be taken out of production represented only 0.2% of the farm unit and was <br />therefore of negligible impact. Actual mining operations will be conducted a half mile <br />or more from the alluvial deposits of Hubberson Gulch, Dry Creek, and Sage Creek. <br />Seneca II-W Findings Document 56 C1982057 <br />Permit Renewal No. 5 December 9, 2010