1982-08-20_GENERAL DOCUMENTS - C1981013

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MAXWELL MINE File No. C-013-81 Response to Draft Findings Document VIIZ . Alluvia] Va.11_ey Floors (2 .06 .8 , .24 ) The generalized Land Use Map (Map 4 ) should not be construed as depicting the precise location of historica.J_7y 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 historica,7_l,y 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 determination:; , CF&I is concerned about the Division ' s reluctance to evaluate on a regional basis rather than on a, site-specific basis . CFRrI has provided a substantive address to the consequences of its activities on the alluvial system. That address indicates the Purgatoire River valleys to be the only areas where irrigation has been historically practiced , where perennial stren,ms exist, where ground water is sufficiently abundn.nt to ^upport, hydro- ph,ytic vegetation and where topography is conducive to irrigation practices . References cited in Exhibit 6 , USG" publications on the geology and hydrology of the area, U .P, . Soil ConsPrva,t,ion ~ervice publications and known pending studies should provide sufficient information for the Division to determine that the north fork, mid-.fork and mainstem of the Purgatoire River are the only segments of the system that can reasonably be regarded as containing an alluvial_ val-ley floor . "hoiald 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 BLP7 is provided as an aid for the Division to find the north fork, mid-fork, south fork n.nd mninstem of the Purgatoire system to be of concern with respect to elements of alluvial val-ley floor determi.nnti_ons . ?Iad the tracts , subjects of the inventory , progressed to development , the current Division approach would dictate a, rigorous ,)II-ilvi.al valley determination for each of the canyon^ beyond the Picketwire Valley after the FLM had previously declared them suitable to mine.