1982-08-24_GENERAL DOCUMENTS - C1981013 (5)

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MAXWELL MINE File No. C-013-81 Response to Draft Findings Document VIM . Alluvial Valley Floors (2 .06 .8, .24) The generalized Land Use Map (Map 4) should not be construed as depicting the precise location of historically irrigated lands . The purpose of the map is to illustrate the location of use practices with respect to each other as shown on the Las Animas County Land Use Map and as cited in the legend of Map 4 of the permit application. Plate 6A identifies the specific areas within the valley floors that have been historically irrigated. The maps utilized in the proper context eliminates the un- certainty expressed , and the need for a stipulation in the draft findings document. With respect to alluvial valley floor determinations, CF&I is concerned about the Division' s reluctance to evaluate on a regional basis rather than on a site-specific basis. CF�CI has provided a, substantive address to the consequences of its activities on the alluvial system. That address indicates the Purgatoire River val-leys to be the only areas where irrigation has been historically practiced, where perennial streams exist, where ground water is sufficiently abundant to support hydro- phytic vegetation and where topography is conducive to irrigation practices. References cited in Exhibit 6 , USGS publications on the geology and hydrology of the area, U.S . Soil Conservation Service publications and known pending studies should provide sufficient information for the Division to determine that the north fork, mid-fork and mai.nstem of the Purgatoire River are the only segments of the system that can reasonably be regarded as containing, an alluvial valley floor. Should the Division engage in such determination, the exercise would eliminate the imposition of a microscopic address to each of the side canyons tributary to the Purgatoire River. The accompanying letter from BLM is provided as an aid for the Division to find the north fork, mid-fork, south fork and ma.instem of the Purgatoire system to be of concern with respect to elements of alluvial valley floor determinations. Had the tracts, subjects of the inventory, progressed to development , the current Division approach would dictate a rigorous alluvial valley determination for each of the canyons beyond the Picketwire Valley after the RLM had previously declared them suitable to mine.