2008-06-09_PERMIT FILE - C1980007 (5)

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• Alternatives Considered in Detail Supplement to Coal Methane Drainage Project Panels 16-24 Enviromnental Assessment for Sylvester Gulch Road Construction and Long Draw Saddle Extension Upgrade). Project traffic on the Minnesota Creek Road was an issue that has arisen from Delta. County and the town of Paonia. in previous analysis. The Sylvester Gulch Road is currently under construction and anticipated to by completed September, 2007. Oversize/over-length vehicles such as the drill rig and semi trucks (large equipment transport) would access from the west through the town of Paonia, then via Minnesota Creek Road in Delta County, Gunnison County Road 710, and NFSRs 710, 711. The estimated traffic associated with use of county roads for oversized vehicles is estimated at 5 round trips per year until project completion. For shaft construction activities where cement hauling is required, an estimated 7 round trips per day with full-sized vehicles (not to exceed 20,000 pounds per axle) will use these routes. Estimated duration of cementing on shaft is fall 2007 through summer 2008. MCC has developed a maintenance agreement with Delta County to avoid any conflicts with road use. All project traffic would also use the existing life of mine administrative access roads known as the West Flatiron Road, Long Draw Saddle (and Extension), in addition to NFSRs 710, 711, 711.2A and 711. 2B. About 22.6 miles of road construction or reconstruction between existing roads and new drill pads would occur. Approximately 2.3 of these miles are in the West Elk IRA. Approximate new road access disturbance is up to 62.6 acres (approximately 6.8 acres in the West Elk IRA; 6.6 acres associated with Lease COC-1362, and 0.2 acres on Lease COC 56447) over 12 years. These roads would be for project and administrative use only, and would not be available for public use. These mileages would be decoininissioned by obliteration after project use. An existing life of mine (i.e. to _ approximately 2030) administrative access road in the SE1/4 Section 27, T 13S, R 90W would be re-routed to mitigate existing resource and maintenance problems due to geologic hazards, sedimentation and slope steepness. The existing administrative access road would be decommissioned by obliteration upon construction of the re-route. The existing access route and proposed re-route are both in the West Elk IRA. The re-route is about 0.6 miles, and would decrease the mileage of the existing route by 0.6 miles. The re-route would be decotrnnissioned by obliteration at the end of mine life. The re- route would be for on-lease activity and administrative use only, and would not be available for public use. Total miles of new road in IRA would be 2.3 miles. • Per decisions issued in 2002 and 2006 Long Draw Saddle life of mine road will be decommissioned to an ATV trail. At the end of the project, Poison Gulch Road (NFSR 711.X) the majority of the route except the very northern end would change from a full sized system road to a System ATV trail (which is the current primary use of the route). The development of a road network in the project area poses a challenge because it is difficult to estimate project needs due to topographical and geological influences. Therefore, road placement is an estimate and would be refined in the field with appropriate design standards and additional mitigation measures added on a site-specific basis. Additionally, well and pad placement would be based on need as established by the conditions in the mine as well. as surface conditions and will be designed site-specifically as the project progresses. It is estimated that a lower number of wells would actually be needed than are proposed at this time. Deer Creek Ventilation Shaft and E Seam Methane Drainage Wells FEIS 19