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f MOUNTAIN COdI /~' ~COMPANYL.~.~. A Subsidiary afArch Weslem Resources, LLC February 10, 2003 RECEIVED FEB 1 1 2003 Divisional Minerals and Ceolagt~ 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 P.O. Box 591 1174 Highway 133 Somerset, CO 8]434 (970) 929-5015 Faz (970) 929-5595 Re: Mountain Coal Company LLC (MCC), West Elk Mine; Permit No. C-80-007; Minor Revision No. 291, Request to Add One Methane Drainage Well Pad and Three Methane Drainage Wells and Associated Road for Longwall Panel 17. Dear Mr. Burnell: MCC is requesting this minor revision to the mining and reclamation permit to construct one Methane Drainage Well Pad, a short road, and drill three Methane Drainage Wells neaz MDW 17-01. The minor revision is necessary and prudent in order to complete this needed drilling and related activities by the end of Mazch, which is when the mining of Panel 17 is scheduled to commence. The methane drainage situation at the West Elk Mine has changed over the past several weeks. Without this drilling MCC expects high levels of methane to exceed current methane drainage capabilities. Additional drainage capabilities will reduce methane levels in the mine and provide for a safer work environment. Recently MCC learned that the methane content in this azea is more severe than expected. Schlumberger Data and Consulting Services (BOGS) has updated the "gas in place" model (as indicated in their December 5, 2002 report prepared for MCC), based on newly required gas content measurements. With this new information, SCDS updated the West Elk Mine model that indicates the mining of Longwall Panel 17 will result in increased methane liberation. More than previously estimated. Further, MCC was able to develop and extend Longwall Panel 17 more to the east than originally anticipated. MDWs completed in 2002 were designed and located based on projected geologic conditions and limitations. Actual geologic conditions encountered in the development of Longwall Panel 17 were less prohibitive than projected. As such, development proceeded further eastwazd providing for maximum economic recovery of the leased reserve as required by the Bureau of Land Management. However, as a result of this further than anticipated eastward development, the existing MDWs will not accommodate methane drainage for the initial mining or "start-up" of Longwall Panel 17.