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Methane Drainage Wells Project Plan
<br />Technical Revision 101; Holes 19-09, 19-10 and 19-11
<br />Page 7 of 14
<br />completed under the Federal Exploration License Numbers COC-51751, COC-5381,
<br />COC-53793, COC-58219, COC-60622, and those described in the 1996 revision of the
<br />West Elk Mine, CDMG Permit No.C-80-007. No cultural resources were identified in
<br />those investigations. Additional cultural resource reports titled, "Mountain Coal
<br />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. Other previous cultural
<br />resource surveys for the adjacent drilling are titled "Mountain Coal Company, West Elk
<br />Mine, Drill Pads for Panels 16, 17, 175, Class III Cultural Resource Inventory, Gunnison
<br />County, Colorado" and "Mountain Coal Company, West Elk Mine, Drill Pads for Panels
<br />18 to 24, Class III Cultural Resource Inventory, Gunnison County, Colorado". No
<br />cultural resources were identified in these investigations.
<br />To facilitate the agency review of this plan, a Cultural Resources Survey (attached, as
<br />"Mountain Coal Company, West Elk Mine, Methane Drainage Wells 19-09, 19-10 and
<br />19-11 and Access Corridors, Cultural Resource Inventory, Gunnison County" prepared by
<br />Greystone Environmental Consultants) of the proposed disturbed area was conducted and
<br />the results indicate that, "Pad location 19-09 is on an azea of reasonably flat ground but it
<br />is on a high, inaccessible ridge top far from any reliable source of water. The other two
<br />locations are on a small, moderately sloping portion of steep slopes above an unnamed
<br />gulch. Most of the access is along extremely steep slopes with no reliable source of water
<br />and no distinctive or abundant resources. None of these locations have any potential for
<br />undiscovered subsurface cultural materials." The report was prepazed by Greystone
<br />Environmental Consultants, Inc. and submitted to Susan Collins, the Colorado State
<br />Archaeologist June 7, 2005.
<br />PROPOSED ACCESS ROUTES
<br />The access route for these wells will be via a new road constructed off an existing
<br />exploration road that takes off from Sylvester Gulch. This road alignment is depicted on
<br />the attached map. This access road will be built in conformance with the CDMG light
<br />use road requirements in CDMG Rule 4.03.3. A temporary stream crossing structure
<br />such as concrete track pads placed in the bottom will be used to facilitate the crossing of
<br />Sylvester Gulch. This will allow crossing of equipment without affecting the normal
<br />flow or gradient of the stream or adversely affect aquatic habitat or related environmental
<br />values.
<br />PRE-DRILLING ACTNITIES
<br />Prior to any construction or drilling activities, an on-site inspection of proposed drill sites
<br />and access routes will be conducted with representatives from CDMG to discuss site-
<br />specific concerns. CDMG will be notified at least 48 hours before any construction or
<br />drilling equipment is mobilized into the project areas. Construction and drilling activities
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