2008-10-10_PERMIT FILE - C1980007 (5)

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E 2 through E 12 Longwall Panels Methane Drainage Wells Project Plan PR-14 Page7of 13 a Cultural Resource Inventory of Mountain Coal Company L.L.C.'s E Seam MDW Drilling for Panels E4-E9, Gunnison County, Colorado, in August 2008. The attached surveys are for all of the E Seam Panels and no cultural resources were identified. The surveys were sent to the USFS Archaeologist and the Colorado State Historic Preservation Officer (SHPO). Other previous cultural resource surveys for the adjacent drilling are titled "Mountain Coal Company, West Elk Mine, Drill Pads for Panels 16, 17, 17S, Class III Cultural Resource Inventory, Gunnison County, Colorado" and "Mountain Coal Company, West Elk Mine, Drill Pads for Panels 18 to 24, Class III Cultural Resource Inventory, Gunnison County, Colorado". No cultural resources were identified in these investigations. A "Cultural Resources Survey Mountain Coal Company, West Elk Mine, Methane Drainage Wells 19-09, 19-10 and 19-11 and Access Corridors, Cultural Resource Inventory, Gunnison County'', prepared by Greystone Environmental Consultants,of a nearby area (within approximately one-half mile) was conducted. The results indicate that, "Pad location 19-09 is on an area of reasonably flat ground but it is on a high, inaccessible ridge top far from any reliable source of water. The other two locations are on a small, moderately sloping portion of steep slopes above an unnamed ,gulch. Most of the access is along extremely steep slopes with no reliable source of water and no distinctive or abundant resources. None of these locations have any potential for undiscovered subsurface cultural materials. Greystone Environmental Consultants, Inc. submitted the report to Susan Collins, the Colorado State Archaeologist June 7, 2005. In total there have been 20 Archaeological and Cultural Resources surveys completed in the area and none have resulted in a finding of cultural resources. See the attached references in the attached "Alpine Archaeology Consultants, Inc., E Seam MDW Drilling for Panels 10, 11, 12, E 1, E 2, E 3, Gunnison County, Colorado" and a "Cultural Resource Inventory of Mountain Coal Company L.L.C.'s E Seam MDW Drilling for Panels E4-E9, Gunnison County, Colorado". PROPOSED LOW-VOLUME ROADS and INGRESS/EGRESS ROUTES The project will be accessed from the mine which is off State Highway 133 and Sylvester Gulch Road, as much as possible. MCC has a Road-Use Permit (December 2007, attached) with the USFS to use existing USFS classified roads. Oversize/over length vehicles such as the drill rigs and semi trucks would access from the west through the town of Paonia then via Minnesota Creek Road in Delta County and then to County Road 710 in Gunnison County to USFS 711. Approximately 10.02 miles of road will be required to complete the accessibility to Panels E 2 through E 12 methane drainage wells. These low-volume roads will be designed as described in "AASHTO Guidelines for Geometric Design of Very Low-Volume Local Roads, 2001" or as directed in the field by USFS engineering and roads personnel. Document "FSH 2509.25 Watershed Conservation Practices Handbook" and "Best Management Practices" will dictate MCCs road. design criteria for cross-drains and other sediment and erosion control features. The pad footprints will be kept small (approximately 0.5 acre average). The estimated total disturbance associated with each pad will range from 0.25-acre to 2.0 acres. Total disturbance 7