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~~OUNTAIN COAL COMPANY~.~.~. A Subsidiary of Arch Western Resources, LLC April 11, 2002 FdECE9~E® APR 1 7 2002 Division of ldinerals and Geology Mr. James Burnell Colorado Division of Minerals and Geology (CDMG) Office of Mined Land Reclamation 1313 Sherman Street; Room 215 Denver, Colorado 80203 West Elk Mine POBoz 591 5174 Highway 133 Somerset, CO 81434 (970)929-5015 Fax <970) 929-5595 Re: Mountain Coal Company LLC (MCC), West Elk Mine; Permit No. C-80-007; Technical Revision No. 96 (TR-96), Methane Drainage Well (MDW) Drilling Project Plan, Panels 16- 24, MCC Responses to the CDMG Adequacy Review Letter Dated 27 March 2002. Deaz Mr. Burnell, Mountain Coal Company, L.L.C. is submitting these responses to CDMG's letter dated 27 Mazch 2002. Technical Revision No. 96, is for MCC's request for authorization to drill MDWs for Panels 16- 24 on MCC's Federal Coal Leases C-1362 and COC 56447. The technical revision included changes to the pennit document and maps associated with the United States Forest Service (USFS) Environmental Assessment (EA) and their anticipated approval for this drilling project. The following aze the CDMG's numbered comments with MCC's corresponding response (in bold): (1) The road proposed for drillholes (sic) 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 and 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. MCC realizes that the roads in this project will need to be field-fitted with CDMG and USFS personnel. For more information regarding the road please refer to Map-1 and Tables T1A and T1B in the USFS EA Document. (2) The road proposed for drillhole (sic) 23-04 follows the contour on a 50%sideslope for 300 feet from an existing road near the floor of a valley. Again it appears from the map that Yhis site could possibly be accessed from the road north and west of the proposed target (near site 23- 05) by a road along the ridge rather than the proposed 1,000-foot long road, 300 feet of which is on the steep side slope. Same as comment (1), this is merely a suggestion for a road that may be easier to construct and maintain.