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[,A OUNTAIN COAL <br />COMPANYL.L.C. <br />A Subsidiary of Arch Westem Bituminous Group, LLC <br />April 21, 2010 <br />1?1?`f 0 3 ?p10 <br />Mr. Tom Kaldenbach p?;rin9 S <br />Colorado Division of Reclamation Mining and Safety <br />Office of Mined Land Reclamation <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />West Elk Mine <br />P.O. Box 591 <br />5174 Highway 133 <br />Somerset, CO 81434 <br />(970) 929-2200 <br />Fax(970)929-5050 <br />Re: Mountain Coal Company, LLC, West Elk Mine; Permit No. C-1980-007; Technical <br />Revision No. 121, Temporary Access to E3 and E4 MDWs <br />Dear Mr. Kaldenbach: <br />Mountain Coal Company (MCC) submits the attached revision form and information for <br />Technical Revision No. 121 to Mining and Reclamation Permit No. C-1980-007 to reopen <br />temporary access to methane drainage well (MDW) locations for longwall panel E3 that have <br />been relocated to and incorporated along the road; and to construct a new temporary access <br />to MDWs for longwall panel E4 (within already approved polygons per PRA 4). As shown on <br />the attached drawing, projected MDW locations E3-71 through E4-83 are located within an <br />Inventoried Roadless Area (IRA) delineated per the 2001 Roadless Area Conservation Rule <br />(now enjoined by federal court and in appeal). Because of the USDA Secretary's <br />Memorandum 1.042-154 issued last May, any land disturbing proposals within an IRA must be <br />routed through the Forest Service (FS) to the Secretary of Agriculture. Since that memo was <br />issued and in the 1-1/2 years since PRA4 was reviewed and approved, road building and <br />MDW locations have been authorized within IRAs so that the necessary methane ventilation <br />can be completed to better ensure the safety of mine operations. <br />It is MCC's intention to construct the most effective MDWs within each projected longwall <br />panel while minimizing the area of land disturbance for these MDWs, whether on private lands, <br />within the regular Forest or within the enjoined IRA. Considering such, MCC proposes to <br />reopen approximately 3,430' of an existing, and currently decommissioned road (including <br />about 3,100' within the IRA) that had been used for exploration in 1996, for MDW access in <br />2002, and again for exploration access last year. Instead of creating new pads for proposed <br />MDWs E3-71 through E3-78 as approved per PR-14, these MDWs will be located and <br />incorporated along the previously disturbed route. A new temporary access will also be <br />constructed to extend approximately 1,320' to the southeast from the existing, re-opened road <br />to the pad locations for E4-81 through E4-83 approved per PR-14. <br />The construction of temporary light-use roads and MDW locations will be completed as <br />described and approved in TR-96, PR-14, and MR-354, and as described on approved permit <br />pages 2.05-26 and 2.05-30 (see attached). The average width of the overall road disturbance <br />will be about 30' (up to a maximum width of about 76), including any necessary cuts and fills, <br />and will be expanded to about 150' wide where the E3 MDW locations will be incorporated