We’re just days away from the deadline for submitting comments on the proposed expansion of the West Elk Coal Mine in Gunnison County. Have you weighed in yet?

The Forest Service is accepting comments until July 24 on Arch Coal’s proposal to lease 1,700 acres of wildlands in the Gunnison National Forest for mining 17 million tons of coal. The agency’s analysis of that proposal can be found by clicking here. Under Arch Coal’s plan, more than six miles of roads would be bulldozed and as many as 48 drilling pads with vents to release methane would be built in the Sunset Roadless Area, which is adjacent to the West Elk Wilderness.

Please submit comments by July 24 through the agency’s website: https://cara.ecosystem-management.org/Public//CommentInput?Project=32459.

Advocacy 101: How to Write Effective NEPA Comments

The National Environmental Policy Act (NEPA) requires a federal agency to prepare a detailed statement of effects for major Federal actions significantly affecting the quality of the human environment, such as allowing coal mine expansion on National Forest lands. Agencies must engage the public in the NEPA process, and respond to written comments received on their NEPA analysis.


  • Focus on Cause and Effect – If you allege that the Forest Service’s expansion proposal and analysis does or does not do something, then clearly connect the dots. For example, “The EIS underestimated the effects of the mine expansion on recreation because it failed to consider direct, indirect and cumulative impacts to big game. I have hunted in the Upper North Fork, and future hunting would be compromised by this proposal. The EIS does not account for these impacts.” Or focus on the relationship between methane emissions from the mine and your enjoyment of snow-dependent winter recreation.
  • Provide Factual Support – If you have support for your statement, cite to it! Include news articles, scientific papers, or statements you’ve heard made by agency staff.
  • This is Not a Popularity Contest – While it is important to let the agency know your general opinion on a project, specific information is much more helpful than general statements of support or opposition. The most effective comments are those that provide useful information to the agency. Comments on the DEIS are not counted as votes or as part of a referendum. They are used to improve the document and analyses, and to ensure that the impacts are adequately determined before the agency makes a final decision on the proposed project.
  • Point Out Shortcomings in the EIS – Point out areas where the EIS is not clear or is missing necessary information. State clearly that you were not able to analyze potential impacts of the decision due to the lack of information.
  • Click here to download A Citizen’s Guide to NEPA to learn more.