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4 <br />Mike Boulay -44- April 11, 2011 <br />CAM: New Map-22 shows the agricultural lands. Vegetation measurement in terms of <br />productivity and type are shown on page 2.04-32 and discussed in Volume 1 Tab <br />5, Vegetation. <br />108. The narrative in the permit application in Section 2.06.8 says the proposed permit <br />area is considered undeveloped rangeland. (This land use term is not used in the <br />AVF report and is not consistent with the land use information in Section 2.04.3). <br />The same narrative also references two topsoil samples indicating high sodic <br />values. Please reference where the samples are found in the permit. High <br />sodic levels would be a limiting factor to agriculture activities and should <br />also be referenced in the AVF report. Please use consistent land use types <br />in Sections 2.04.3 and 2.06.8 of the permit application. Need to address <br />undeveloped rangeland and sodic comment sample location. <br />CAM: Page 2.06-2 has been revised for consistency with PAP as well as AVF report. <br />TLO-2 and TLO-3 are part of the soils report and can be found in Exhbit 7. Table 1 <br />discusses the 'strongly saline, and very highly sodic' nature of the soils samples, <br />and test results immediately follow Table 1. <br />109. What has been the past management practices and/or grazing use of the <br />rangeland areas in the permit, particularly with the regard to the irrigated <br />drainage wetlands? Are there special management practices or value to the <br />landowners? <br />110. In reference to 2.06.8(3)(b)(iv), has irrigation or subirrigation been used to <br />enhance production of agriculturally useful vegetation? Have the irrigated <br />wetland areas been historically harvested for hay or otherwise managed <br />differently from adjacent areas based on their enhanced production of <br />agriculturally useful vegetation? <br />111. Based on 2.06.8(3)(b)(vi), an analysis of a series of aerial photographs, <br />including color infrared imagery flown at a time of year to show any late <br />summer or fall differences between upland and valley floor vegetative growth <br />and of a scale adequate for reconnaissance identification of areas that may <br />be alluvial valley floors need to be submitted. ERO's report states they used <br />an aerial photo from 1937 and a review of current aerial photos. Please describe <br />the results of the aerial photos as they relate to AVF determinations. <br />112. At this point, the Division does not have adequate information to make a <br />determination on the presence or absence of AVF's. Once the questions above <br />are adequately addressed, we will make a determination as required by Rule <br />2.06.8(3)(c). Additional information may be needed if we make a positive <br />determination that an AVF does exist. <br />CAM: Please see the amended AVF report, Exhibit 14.