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~~ s DATE: January 6, 1983 1 11 ~ III III'll lll'III'll uu•nnl",rur nl n•^.lnnnl m•;n,..„.r~, 999 n ~.,..~~,, r ~ •..,. r . , , , ~ .~ 11I\I~;I) I,.\1I1 lil;l:I,111:1"11(1\ 423 CeNennial Rid Lung 1313 Sherman Shy: el Denv cr. Colora Flo Cr1203 inl 1.3U 31 i'. i~-3~i67 David C. Shelton Director T0: Sandy Emrich FR014: Jerry ~•impfer :~"'y~ RE: Foidel Creek Underground t•1ine, AVF Determination In thinking about yesterday's meeting 1+ith Getty Coal I realized that I did not fully respond to George Young's question concerning what additional information could be provided to change the preliminary Foidel Creek alluvial valley floor determination. The follol+ing discussion should provide the company with some nuidance, and should be for~•+arded to the applicant. Information included in the application indicates that the area in question (Foidel Creek) is capable of flood irrigation because sufficient 1+a ter is physically available, but that flood irrigation 1•+ould not be economically feasible. This area should not be given a negative determination on the basis of economic feasibility. Cost-benefit analyses are too dependent upon the particular scenario analyzed, and too easily adjusted to provide the desired results. There are, ho1•+ever, other pfrysical considerations, other than the quantity of a+ater available, that could be considered. The v+ater available for flood irrigation is not suitable for flood irrigation because of its quality. 4later of a similar quality is not used regionally for flood irrigation. The soils in the area under consideration are not suitable for flood irrigation. Those soil types are not flood irrigated in the region. The areas under consideration are topographically or geographically different from the areas in the region where pond/ditch flood irrigation is practiced. That difference makes the areas under consideration unsuitable for this type of flood irrigation. (For example, the area under consideration is significantly smaller in acreage than the areas where such flood irrigation systems are used. The areas where such systems are used are all at a lo1•+er (or higher) elevation and that the difference in elevation makes these areas not useful agriculturally. The areas flood irrigated by such systems are located within 5 foot elevation of the stream channel, and if the same limitation is applied to the area in question, the acreage remaining is too small to be agriculturally useful.)