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The OSM Guideline, reports on page A -18 that "flood plain alluvium" and "stream terrace <br />alluvium" associated with AVF's commonly occur on slopes of less than two percent. Since the <br />slopes in all areas having wetland vegetation are greater than two percent, it can be concluded <br />that these sites exceed the commonly encountered slopes associated with AVF's. Thus, this <br />evidence suggests that these sites would not satisfy the alluvial valley criteria. <br />In conclusion, the OSM AVF Guideline, states (page II -1) that "stream valleys which do not <br />have any agricultural importance or whose importance is not related to greater water availability <br />of the valley are not alluvial valley floors" and that "alluvial valley floors having only the <br />capability to be surface irrigated can be assumed to be [agriculturally] insignificant and need not <br />be evaluated further." For the reasons outlined herein, it can be concluded that there are no <br />AVF's in the area corresponding to the NHN Mine Permit area. <br />Section 2.06.8 Page 8 April 2011 <br />