PERMFILE100098

• Permit No: C1980007
• IBM Index Class Name: Permit File
• Doc Date: 7/15/2002
• Doc Name: Adequacy Review Letter
• From: DMG
• To: MCC
• Section_Exhibit Name: Exhibit 80 Drilling Activities - TR96
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
7313 Sherman 6t., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
27 March 2002 ~`~
Henry Barbe
Mountain Coal Company
P.O. Box 591
Somerset CO 81434
Re: West Elk Technical Revision 96 Adequacy Review
Deaz Mr. Barbe:
The Division has reviewed the subnttal for Technical Revision 96 -Methane Drainage
Wells Project Plan, Panels 16 through 24
It is noted that the text in the revision discusses a proposed new road up Sylvester Gulch,
which is not a part of this revision. This revision discusses existing and proposed roads
and improved ATV trails that would branch off to degas drillpads. These aze considered
light-use roads, and as such, Rule 4.03.3 applies.
Following aze numbered comments relating to the submittal.
(1) The road proposed for drillholes 22-03b and 22-03 follows the contour on a
southeast-facing 50% sideslope, starting from an existing road neaz the floor of a valley.
It appeazs from the map that these sites could be reached by an alternative road from site
22-04, 200 feet to the north on a ridge, rather than the proposed.2,200-foot road along the
steep sideslope. This is just a suggestion for a road that maybe easier to construct and
maintain.
(2) The road proposed for drillhole 23-04 follows the contour on a 50% side slope for
300 feet starting from an existing road neaz the floor of a valley. Again, it appeazs from
the map that this site could possibly be accessed from the road north and west of the
proposed tazget (near site 23-OS) by a road along the ridge rather than the proposed 1000-
footlong road, 300 feet of which is on the steep side slope. Same as comment (1), this i;
merely a suggestion for a road that maybe easier to construct and maintain.
(3) Two drillpads do not show a proposed access road. For sites 23-08 and 16-08, please
indicate the proposed road access route.
DIVISION OF
MINERALS
GEOLOGY
RECLAMATION
MINING•SAf ETY
Bill Owens
Governor
Greg E. Walther
Executive Director
Michael B. Long
Division Director
(4) The applicant states that roads will be maintained with water bazs and appropriate
sedimentation controls as required during the drilling phase. The Division recommends