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Class III cultural inventories were conducted in the methane project azea and are attached
<br />as part of the submittal. The results of the surveys were negative and were submitted to
<br />the USFS. Cultural inventories have been conducted on the adjoining Ravens Gulch
<br />Exploration Area (COC-60622; expired). The list of studies includes six Class III surveys
<br />and two Class II surveys (Metcalf Archeological Consultants, Inc., 1987, 1989, 1993,
<br />7/94, 8/94, 11/94, 1996, 1997); (Archeological Environmental Reseazch Corp., 1990).
<br />The surveys were completed under the Federal Exploration License nos. COC-51751,
<br />COC-5381, COCO-53793, COC-58219, COC-60622, and those described in the 1996
<br />revision of the West Elk Mine, CDMG Permit No.C-80-007. No cultural resources were
<br />identified in those investigations. Additional cultural resource reports titled, Mountain
<br />Coal Company's West Elk Mine Gob Vent/De-gas Boreholes Class III Cultural Resource
<br />Inventory T13S, R90W, Sections 23, 26, 27, 34, and 35 Gunnison County, Colorado,
<br />June 2001, and Mountain Coal Company, West Elk Mine, Block Cultural Resource
<br />Inventory (140 acres) for Five Drill Pad Locations and Access, T13S, R90W, Gunnison
<br />County, Colorado, August 2001, also showed negative results. Attached aze the cultural
<br />surveys for the proposed drilling titled "Mountain Coal Company, West Elk Mine, Drill
<br />Pads for Panels 16, 17, 175, Class III Cultural Resource Inventory, Gunnison County,
<br />Colorado." and "Mountain Coal Company, West Elk Mine, Drill Pads for Panels 18 to
<br />24, Class III Cultural Resource Inventory, Gunnison County, Colorado". No cultural
<br />resources were identified in these investigations.
<br />PROPOSED ACCESS ROUTES
<br />The access route for the methane drainage project azea may potentially utilize Gunnison
<br />County Road 710 to USFS 711 and could potentially utilize the road to "Lower Cow
<br />Camp" and beyond to previously disturbed drilling and exploration roads that lead to
<br />SOM 53 and RAV-8. The road leading to SOM-53 may require field adjustment and re-
<br />alignment due to previous reclamation and installation of tank traps, This road will be
<br />gated, locked and closed to the general public. This activity will be conducted only with
<br />the authorization of the USFS. A field inspection with USFS personnel will be required
<br />prior to the field adjustment to the RAV-8 drill road and existing ATV access. The roads
<br />will be reconstructed, field-fitted, and or constructed in coordination with the USFS
<br />Forest Trails Coordinator, Zone Engineer. These roads have been inspected by MCC
<br />personnel and the USFS in the field, and are depicted on the enclosed map.
<br />Alternatively, access to the project area could be via Sylvester Gulch. Access to the azea
<br />is proposed in Sylvester Gulch where a remnant drill road exists in or neaz the bottom of
<br />the gulch or some other alignment that the USFS would approve. This road will need to
<br />be improved for approximately 4,200 feet where it would intercept the West Flat Iron
<br />access road. The road would be improved to support drilling operations and would be
<br />maintained at a 14' width. The road is necessary for the following: to eliminate the need
<br />for access from FR 711.2B, increased efficiency of access, the road would allow MCC to
<br />control the access from MCC's fee lands, and could allow for reclaiming approximately
<br />9,200 feet of road from the existing locked gates (West Flat Iron road access point) at FR
<br />211.2B to the intersection with the proposed Sylvester Gulch road. If this access is
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