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Relief from Lease Stipulation Conventional ventilation shaft construction time is estimated at 16 to 18 months and would be constructed prior to underground mine operations reaching the shaft location. MCC is requesting relief from Winter Range Restrictions on lease C-1362 (December 1, 2007-Apri130, 2008) to allow these emergency structures to be installed in a timely manner if conventional shaft construction is planned. If mine operation timing permits, a less disruptive shafr construction method may be used which would result in lower surface disturbance, less spoils, and would not require relief from the big game winter range lease stipulations. While currently not anticipated, site-specific relief from lease stipulations relating geohazards, moderate or steep slopes, or riparian areas could arise during project implementation. The scale of stipulations mapping may not identify all surface features where the stipulation applies. This could require additional IDT review and analysis. Proposed Activities in Inventoried Roadless Area Operations are proposed on two active federal coal leases, and one federal coal lease effective date March 1, 2007. Portions of these are in the West Elk IRA. Approximately 3.2 miles of road construction is proposed on these leases in the West Elk IRA. The road construction is necessary for access to 35 sites for methane drainage wells. Seventeen of these sites would be located in the IRA. Roads proposed in the IRA would be for project and administrative use only, and would not be available for public use. A break down of activities proposed in IRA per lease is as follows: C-1362 • Proposed on IRA portion of lease (including the 160-acre extension): 10 methane drainage well drill sites with 2.2 miles of road construction. • Proposed on 160-acre modification: Two methane drainage well drill sites with one-tenth mile of road construction. • Ventilation shaft/escapeway proposed on this lease is not in an IRA. COC-56447 • Proposed on lease: approximately 240 feet road construction in IRA. COC-67232 Proposed on IRA portion of lease: 14 MDWs on 7 locations, and approximately 1 mile of road construction. Road construction activities associated with methane drainage wells proposed in the West Elk IRA may be constructed or reconstructed because they are exempt from the prohibitions of the RACR under Exception No. 1 - protection of public health and safety in the cases of imminent threat that without intervention would cause loss of life or property. The road construction associated with the wells on the portion of lease C-1362 (that which was leased in 1967), and the road construction on lease COC-56447 (leased in 1995) are also exempt from prohibitions of the RACR under Exception No. 7 -continuation, extension, renewal of a mineral lease on lands that were under lease as of 1/12/2001. L~ u a Conventional wnsVUCtion (top down) consists of all construction activities on the surface. All materials produced from the shaft sinking must temporarily be stored on the construction pad, including mine water discharge. Conventional sinWline construction is completed by excavating down to bedrock to instal] a concrete collar as the foundation for a hoist. The shaft is then sunk using drilling and blasting where all excess rock is removed and brought to the surface for temporary storage. A concrete shaft lining would be placed as the drilling and blasting proceeds. The rationale for applying the exemptions from the RACR is as follows: Exception No. 1 -protection of public health and safety in the cases of imminent threat of flood, fire, or other catastrophic event that, without intervention, would cause loss of life or property. High levels of methane gas in the mine create unsafe working conditions for i S-8 Deer Creek Ventilation Shaft and E Seam Methane Drainage Wells DEIS