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Chapter 2 , 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. 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 miners and must be reduced to acceptable levels under MSHA rules. High levels of methane gas in the mine can lead to loss of federal property if the leased, mineable coal is destroyed through explosive or thermal events and cannot be mined. The only way to reduce methane to safe and acceptable levels is to install the methane drainage wells, which require temporary roads. Exception applies to all proposed road construction associated with methane drainage wells on all IRA ]ands included in the federal coal leases on which operations are proposed. Exception No. 7 -continuation, extension, renewal of a mineral lease on lands that were under lease as of 1/12/2001 The roads to access methane drainage wells are needed for coal mining operations and continuation of leases on lands that were under lease as of January 12, 2001. Exception applies to proposed road construction associated with methane drainage wells on all IRA lands included in the federal coal leases C-1362 and COC-56447 on which operations are proposed exce t for a 160-acre lease modification which extended lease C- 1362 on Oct. 2001). The need for proposing operations on the federal coal leases that overlap with the IRA is based upon the configuration of the mining operations, meeting MSHA approval for the mine ventilation plan (which includes having adequate methane drainage facilities), functionality of the mine ventilation system, and limitations on using directional drilling because of overburden thickness. General mining operations for recovering the E Seam reserves at the West Elk Mine include developing longwall panels in oriented in a southeast to northwesterly direction. Mining these panels would occur from southeast to northwest. The configuration of the mine plan in federal coal reserves is reviewed by the BLM to ensure that maximum economic recovery of the coal resource occurs. Thus, the projected mine plan is configured to ensure that all recoverable reserves are included. Based on experience mining B Seam reserves at other parts of the West Elk Mine, MDWs work most efficiently when placed on the "headgate" side of the longwall panel where fresh air is brought into the active workings by the ventilation system. If MDWs are not placed in this manner, then the ventilation system `fights' with them and makes them less efficient, which leads to reduced capacity to regulate the amount of methane in the workings leading to safety concerns and operational downtime. For the E Seam reserves, to maximize efficiency, the MDWs are placed on the north side of the planned longwall panels where the headgate for each panel will lie. The alignment of the longwall panels and need to place MDWs near the headgate side requires that these facilities be placed in the IRA. Spacing requirements for MDWs of 750 feet are currently directed by MSHA based on anticipated mine conditions as submitted in a Mine Ventilation Plan provided by MCC, as is the need for additional ventilation at the beginning of a longwall panel which is also the limit of recoverable E Seam coal reserves. The t 20 Deer Creek Ventilation Shaft and E Seam Methane Drainage Wells DEIS ,