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On Thursday, January 16, I attended a public information meeting at the Black Hills National Forest Mystic Ranger District Office. The purpose of the meeting? To share with the public F3 Gold LLC’s proposed Jenny Gulch Exploration Drilling Project. If you want to know more details, I encourage you to read the project scoping letter, but here’s a rough summary.
If you know all of this already, and want to jump to how to make an official comment, click here.
The Jenny Gulch Exploration Drilling Project
F3 Gold LLC — a private gold prospecting and exploration company based out of Minneapolis has proposed core drilling at up to 42 exploratory sites north of Silver City, in Pennington County, SD. They don’t want to mine the area, just look for gold. To do this exploratory drilling, they would primarily use existing road and trail, but they would also create roughly 4,700 linear feet of temporary trail to permit access to the drill sites. At the end of the project, F3 Gold LLC would be responsible for filling in the core holes, in accordance to all federal and state regulations, as well as returning the drill sites and the temporary trails to natural conditions.
No mining or processing of ore is proposed in this project — just the core drilling. F3 Gold would use no local surface water, only water from approved municipal or industrial sources. Wastewater is supposed to be collected and properly disposed of off-site, not in the Black Hills.
Where are we at in the process?
This project is under review at the moment. They’re preparing an Environmental Assessment (EA) under the National Environmental Policy Act (NEPA), and as part of this, are accepting public comments until February 5th. At that point, stakeholder concerns will be reviewed, and then taken into consideration during the environmental assessment. Barr Engineering, also out of Minneapolis MN, has been contracted to conduct the environmental assessment.
Once complete, the environmental assessment will let the Forest Service — and F3 — know how to proceed. If the EA finds that there is no significant impact, then a decision will be made, likely in favor of the drilling. Should the EA find that there is a likelihood of significant environmental impact, and F3 wants to press on, then it kicks off a whole new process of creating an Environmental Impact Statement (EIS).
Environmental Assessment VS Environmental Impact Statement
I’m not an expert at the NEPA process, but as far as I can tell, the EIS is a much more comprehensive document that requires all the information one would gather for an EA, but also a deeper look at potential alternatives, as well as a thorough discussion of the long-term and cumulative impacts of the proposed project. This includes looking at all current and foreseeable development in the project area.
This means an EA doesn’t take into consideration what happens after the core samples are taken. The EIS does. And right now that’s the unspoken piece of this puzzle — the Jenny Gulch Exploration Drilling Project doesn’t propose any mining, milling, or processing, but I find it hard to believe that if they find gold that no one will have an interest in mining it.
For that reason, I think it’s important that stakeholders contribute public comments voicing our concerns. I believe that it’s in everyone’s best interest — even F3’s — to conduct the more thorough Environmental Impact Assessment.
What’s all this mean?
The simple question is this — should F3 Gold LLC be permitted to search for gold in the Jenny Gulch area of the Black Hills National Forest?
My answer is no.
The more complicated question — and the one that matters when the decision is actually made — is why or why not. But before we dive into that, let’s take a second to review why this discussion is happening in the first place.
National Forests and Resource Extraction
If you’ve read my article on National Forests, then you may remember that the mission of the Forest Service is, “To sustain the health, diversity, and productivity of the Nation’s forests and grasslands to meet the needs of present and future generations.” Or, as Gifford Pinchot, first chief of the Forest Service put it, “to provide the greatest amount of good for the greatest amount of people in the long run.”
The greatest amount of good for the greatest amount of people can include resource extraction. These resources include “timber, clean water, wildlife habitat, forage for livestock and outdoor recreation.”
And mineral extraction — mining.
This is actually governed by a pretty old law, the General Mining Law of 1872, though it has subsequently been amended a number of times. A more drastic amendment was attempted in 1994, and I think we’re overdue for another shot at reform. As it stands, however, here’s the gist of the law.
Qualified prospectors can try to find mineral deposits on public lands. If they find something valuable, they can record a claim to protect it from others trying to claim it. From there, they can mine it if doing so won’t cause too much damage to the other resources on the land. In the case of National Forests, this is regulated by 36 CFR 228. Basically, it protects trees, water, wildlife, habitat, recreation, and other National Forest values from unnecessary or unreasonable mining damage.
It’s a little more complicated than that in practice, but as a summary that’s the rough idea. Here’s a non-technical way of looking at it. The forest service controls what’s on top of the ground, but not necessarily what’s underneath it. Legally, prospectors can seek out potential mineral resources, and lay claim to them. When they submit a project application, the forest service can’t just say no. But they don’t have to simply say yes, either.
In short, even though mining on public lands is legal, you can’t go out all willy-nilly and start digging holes. There’s a process in place, for better or worse.
Is Mineral Extraction Bad?
We may not like the idea of mineral extraction in National Forests. I get it. It’s easy to look at our public lands and say, “we shouldn’t even allow mineral extraction here!” That’s absolutely, 100% my gut reaction. But the law says it can happen, and it is occurring on public lands in the US. We don’t have to like it, but we should be aware of it.
Because the harsh truth is that we’re all extracting resources from somewhere. Have a gold wedding ring? It came out of the ground at some point. Drive a car? Fossil fuels. Electric-car drivers aren’t exempt either — the metals that make the battery possible are also extracted from somewhere. Even the computer or smartphone that you’re using to read this is made using metals that were mined from the earth somewhere.
So while I would like to see a world where mining isn’t necessary, we’re not there yet. What we can do, as a society, is to try to make resource extraction as safe, sustainable, and ecologically sound as possible. That means that some places aren’t a good fit for extraction, for a number of reasons. I think this project’s search for gold in the Black Hills is one of them.
But I don’t want to to be disingenuous, and I don’t want to imply that any kind of resource extraction is inherently evil. I’m simply saying that in this instance I don’t think it’s wise to move ahead with this project. I think the potential negatives far outweigh any potential benefits.
And we actually have a pretty good idea of some of the potential negatives, because unfortunately, resource extraction hasn’t always been done responsibly in the Black Hills.
Some Context for Gold Mining in the Black Hills
I’m not going to dive into the entire history of mining in the Black Hills, but there’s contextual information that plays a significant role in how many people view prospective drilling and mining in the area, and if you want to know about the risks and rewards of mining in the Hills, it’s worth taking a look back.
If we wanted to talk gold, we could all the way back to Custer’s expedition in 1874, or the Homestake Open Mine, but I think when it comes to potential drilling and mining in the Black Hills, people most often reflect upon more recent history. In fact, during all my conversations about the topic, the same three words have come up again and again.
Gilt Edge Mine
The Gilt Edge mine has existed since 1876, but it’s not the 19th century history that upsets most people. No, it’s more modern problems. In 1986 the Brohm Mining Company began development of a significant open pit operation, using cyanide heap leaching to free the gold from other minerals. As gold prices fell, Brohm went bankrupt and abandoned the operation, as well as the responsibility to clean up the results of the mining, including acid rock drainage and the resulting water pollution.
The EPA declared the mine a Superfund site in 2000. Superfund sites are heavily polluted and contaminated sites that the EPA cleans up by forcing responsible parties to do the necessary clean up, or to reimburse the government when it has to foot the bill. In the case of the Gilt Edge Mine groundwater and surface water, like Strawberry Creek, were heavily contaminated with various acids and heavy metals.
So it’s understandable that despite the area’s mining history — or perhaps because of it — residents are apprehensive when it comes to new potential mining projects in the area.
So, what now?
At this stage, the Forest Service and Barr Engineering are seeking public comments from stakeholders. They want to know what concerns we have about the Jenny Gulch Exploration Drilling Project. The deadline for these comments is February 5th, which isn’t a lot of time, so if you’re a stakeholder who wants to have their say, don’t just put it on Facebook, make it official.
In the broadest sense of the term, all US citizens are stakeholders, by virtue of this being federal land. But when it comes down to the most meaningful comments for the Environmental Assessment, the most weight will be put on comments from individuals who will be directly affected. Those who live, work, and play in the area. There’s private land that is right alongside the proposed drilling area — the owners will be directly affected. Silver City lies just south of the project area and many residents rely on wells for their water supply. They stand to be directly affected if anything went wrong. Anyone who relies on the roads in the area, or has a special use permit for the trails, will be directly affected.
How to make an official comment
The easiest way is by email — you can send comments to firstname.lastname@example.org with “F3 Jenny Gulch Exploration Project” as the subject.
You can also print this form, and mail it to 8221 Mount Rushmore Rd., Rapid City, SD 57702 — or you can fax it to 605-343-7134.
What should I say?
Be up front and honest — don’t make up concerns, be sincere. Do you foresee issues with flora or fauna? Do you have concerns about the area being closed off to traffic or recreation? Are you worried about possible negative effects on the watershed? Are you aware of any endangered species in the area, or cultural resources that should be protected? Share your concerns — that’s what this process is for!
Keep in mind that neither the Forest Service or Barr Engineering is your enemy. Try to be unemotional, and of course be respectful — cursing, name-calling, and angry rhetoric simply won’t be taken seriously on comments.
Explain your use of the public lands and why you consider yourself a stakeholder — again, greater weight will be given to those who live, work, and play in the locality.
Explain what has you concerned, and back it up as much as possible. If you have an understanding of the science or law involved, please include it. Any points that are clear, backed up with evidence, and well-articulated will be most helpful.
Public Lands belong to all of us
Look, if you think this is a good project, and you think it should move forward, I’m not here to shame you. F3 Gold has a history in the Black Hills, claims to want to employ locals and students, and cites environmental stewardship as a priority. I’m not suggesting that any of that isn’t true, and if you think this project is good for the area, I encourage you to make your comments official as well — even though we don’t agree.
But I would like to see as much thoughtful contribution from stakeholders as possible, and would like the Environmental Assessment to lead to the more comprehensive Environmental Impact Statement. This would require looking at potential future developments and cumulative impacts over time — including potential extraction and processing.
Looking to the future
That’s why I want an Environmental Impact Statement. Because it requires an answer to the question, “what happens after this project?”
Because I understand that F3 isn’t extracting gold. The Jenny Gulch Exploration Drilling project is just trying to to locate gold. But history has shown that if there’s gold in them thar hills, somebody will want it. If F3 finds gold, someone will want to mine here, and at best that process will leave a much larger footprint than some exploratory drilling. At worst, we could have another Gilt Edge Mine, with contaminated water making it’s way into Pactola Lake.
This question won’t determine whether F3 Gold gets to move ahead with the Jenny Gulch Exploration Drilling project or not — mining isn’t part of the proposal. What matters now is whether concerns for this project warrant a more thorough environmental investigation. I think that they do, and encourage stakeholders to make official comments before the February 5th deadline.
Want to learn and do more to prevent drilling and mining in Jenny Gulch? Visit Protect Pactola, a grassroots organization committed to protecting the environment, water supply, and recreation areas of the Black Hills, including Jenny Gulch and Pactola Lake.