F3 Gold, which is based in Minneapolis, has mining claims on claims in about 62 sections (square miles) in the central Black Hills, stretching from Sheridan Lake to north of the Lawrence-Pennington County line. It also has a large block of claims just west and north of Custer. Most of the central Hills claims are in the Rapid Creek watershed. The watershed, Rapid Creek, and its attached aquifers supply the water for Rapid City, Ellsworth Air Force Base, and communities and ranches down to the Missouri River. An exploration or mining accident in the central Black Hills could have far-reaching impacts on human health, wildlife, ranchers, and our tourism and recreation economy.
The federal government, through the Bureau of Land Management, gives mining claims to whoever stakes one under the 1872 Mining Law. The law also gives whoever stakes a claim the right to mine – and to move anyone who happens to live or have a business on the area to be mined. The miners pay no federal royalties.
The company has applied to the Forest Service for permission to drill for gold in the Silver City/Jenny Gulch area (Jenny Gulch project) and to drill directly west and north of Custer (the Newark project).
WHAT DOES THE COMPANY WANT TO DO AT JENNY GULCH?
The Jenny Gulch project is immediately upstream from Pactola Reservoir, the most active recreation area in the Black Hills. F3 Gold already has its state exploration permit in this area – the state gives out mining exploration permits without notice to the public or a hearing, just requiring a fee and an application.
The company’s Plan of Operations, which acts as an application to the Forest Service, was filed with the Mystic Ranger District in Rapid City in November 2019. F3 Gold asks to build and drill from 42 drill pads. It does not say how many holes it plans to drill from each drill pad, but it could drill multiple holes from each pad. Drilling would take place 24 hours a day, and heavy equipment would be moved in and out along Silver City Road and Rochford Road, according to the Plan of Operations. The company would cut brush, grade roads, plow snow, and create 4700 feet (.9 mile) of “temporary overland trails for drill site access.” If you’ve seen a drilling rig, you know that they need a fair amount of space to maneuver.
F3 Gold wants to drill down from 500 feet to 6000 feet (1.1 miles). At least some of this would be directional drilling – which means they would be drilling at an angle, rather than straight down. There is no detail on this, so it’s unclear if they will be staying under Forest Service land or reaching under Pactola Reservoir, which is half a mile away. They do have mining claims at the Reservoir. The geology of the central Black Hills has not been researched in any detail, so it’s not clear where there are fractures in the rock or pockets of water that might be disturbed.
Drilling water would be trucked to the drilling areas. F3 plans to use “5,000 – 10,000 gallons of water per day per drill rig.” The Plan of Operations does not provide enough information to tell how much water this would actually be. Wastes from the drilling would be dispersed on the ground. The company thinks the project will last about a year.
WHAT DOES THE COMPANY WANT TO DO WEST OF CUSTER?
F3’s Newark project starts about a mile west of Custer and extends part way to Jewel Cave along Highway 16, and then north from that line another nine or more miles. F3 Gold does not have a state exploration permit for this project at this time, but it has applied to the Forest Service to drill, as discussed more below.
The Plan of Operations for the Newark project was filed on August 11, 2020 in the Hell Canyon Ranger District in Custer. The project stretches northwest of town along French Creek, but there is some question about exactly where the drilling would be located. The area is a favorite of hikers and bicyclists, featuring forest interspersed with wetlands and waterways.
The Newark Plan of Operations asks to drill at 46 sites. As with the Jenny Gulch project, there could be multiple holes at a drill pad. The drill pads would be accessed by heavy equipment using Highway 16, county roads, Forest Service roads, and 3.5 miles of new “overland trails.” The amount of water to be used is just as mysterious as for the Jenny Gulch project. Potential problems at the drill sites are similar to those for the Jenny Gulch project, although the Newark site is not known for hosting bighorn sheep.
WHAT ARE SOME POTENTIAL PROBLEMS?
The Jenny Gulch project would be one-half mile upstream from Pactola Reservoir, a recreation and relaxation hotspot. No one wants to swim or boat in a mining accident. Ask the folks in southwest Colorado, where a mine accident destroyed their recreation and agriculture economy in 2015.
Many comments to the Forest Service about this project talked about the area’s recreation, relaxation, and spiritual values for individuals and for families over generations. Many also talked about the environmental justice aspects of the project, which would negatively and unreasonably impact Lakota and other indigenous peoples in the region. As the comments to the Forest Service show, people across the region are passionate about this area and its potential destruction by gold mining.
The company could be drilling over a mile underground in any direction with little geological information about the area. This could lead to unknown problems. Waste of unknown composition would be dumped on the ground. An unknown amount of water would be used. Residents of the area – human and wildlife – would be subjected to noise, traffic, and lights 24 hours a day. Around a mile of new roads would be built into the forest. Toxic materials, such as gasoline, would be used and, if they leaked, could end up in Rapid Creek. Directional drilling under Pactola Reservoir might occur, bringing unknown impacts. In short, one of the big problems with this project is that so much is unknown.
The other big issue is the presence of a bighorn sheep birthing area in the south part of the proposed drilling site. Bighorn sheep are designated as a “Sensitive Species,” and governments have spent a great deal of effort and taxpayer money to increase their numbers in the Black Hills. The South Dakota Department of Game, Fish, and Parks (GF&P) noted the sheep’s vulnerability to disturbance during the birthing time period and their attachment to certain locations for the birthing process. Drilling activity could make the sheep abandon their birthing area. GF&P suggested that all exploration activities, including pedestrian access and nearby noise, be stopped from April 15 to August 31.
WHAT’S HAPPENING WITH THE FOREST SERVICE?
The Newark Project is newer than the Jenny Gulch project, and less is known. Last we knew, the Forest Service was waiting to complete tribal consultation. Once that happens, we would expect to see an Environmental Assessment.
At the Jenny Gulch project, the Forest Service received F3 Gold’s Plan of Operations in November 2018. It is well along in the environmental review process. It held a “scoping” comment period in early 2020. About 90 people attended a public information session, at which the Forest Service and engineers presented general information on the project and answered a few questions. The maps that were provided at the session had so few landmarks that it was difficult to tell where the potential drilling could be located. When one citizen tried to ask questions of a Forest Service staffer individually, she rushed over to her supervisor, who cut off her communication with the public.
Documents received under the Freedom of Information Act (FOIA), a federal law requiring federal agencies to provide information to the public, show that this is not an isolated incident. Indeed, Forest Service personnel appear afraid to answer the public’s questions and often go to their supervisors for help in responding to questions from people who oppose F3’s proposed project. Forest Service staff magnify unfounded rumors of threats to the agency by passing them around. They watch and comment on those who oppose the project. Sometimes they just stonewall, which has led to two lawsuits by Black Hills Clean Water Alliance against the Forest Service in an attempt to get the full information we originally requested starting in 2018.
After the Jenny Gulch scoping comment period ended, Forest Service personnel summarized and created responses to the issues raised by the almost 500 comments received. Then they developed three alternatives for the drilling project. These were issued in September 2021 in a Draft Environmental Assessment. The first Alternative, which is required for all federal environmental processes, was to do nothing. This has been the alternative preferred by most people who commented. The second Alternative was the work described in F3 Gold’s Plan of Operations. And the third Alternative was put forth by the Forest Service. It suggested moving some drill pads around to avoid sensitive areas and creating 5 additional drill pads. The Alternative also suggested adding another 1.9 miles of wider roads.
Most notably, the tribal consultation discussed in the Draft Environmental Assessment was extremely weak, and any unrecognized tribal cultural resources would not be protected. Four tribal governments said that they wanted government-to-government consultation, but that did not happen due to covid-19. The many comments that pointed out that the Black Hills are Lakota territory by treaty were not recognized, with the Forest Service directing its response to the 1872 Mining Law.
The Forest Service has moved ahead anyway. So has the company, even without its Forest Service permit.
F3 Gold’s work has been clearly visible in the proposed project area, with people seeing trees being cut back, and trucks and other equipment actively working toward the gold project. As the public wrote its comments on the Draft Environmental Assessment, which were due in October 2021, the company and the Forest Service ignored their pleas to stop the project. The Forest Service uses the 1872 Mining Law as an excuse, saying that there is nothing it can do to stop the project. This is not true. The Forest Service has the authority to place conditions on F3’s project, and those conditions can – and should — be extensive in this special and unique area of the special and unique Black Hills.
The next expected step is for the Forest Service to issue a final environmental assessment and their decision on the project. This will be followed by another opportunity for the public to object to the project. Hopefully, the Forest Service will take a stronger stance than it has in the past.
WHAT DOES F3 SAY?
The company sets itself up as “just” an exploration company. But there is only one reason to explore for gold, and that is in the hope of eventually mining for gold. While F3 might be honest in saying that they will not do the mining themselves, they could sell out to someone who would. There would be no economic reason to explore, find gold, and then leave it sitting underground.
The company also says it is environmentally conscientious, but its environmental declarations don’t hold up. Its principal owners talk about going to college in Rapid City and loving the Black Hills, but someone who truly loved the Black Hills would not plan to do work that could lead to mining destroying a key wildlife area, beautiful countryside, people’s livelihoods, likely cultural resources, and the most important recreation area in the Hills.
F3 Gold needs to stop its operations, withdraw its application to the Forest Service, and go back to Minneapolis. This is no place for gold exploration or mining.
Older news and blog posts:
Sept. 25, 2020 blog post – JENNY GULCH AREA IS UNDER ATTACK – STATE APPROVES GOLD EXPLORATION
F3 Gold, a Minneapolis company, has received its state exploration permit from the S.D. Department of Environment and Natural Resources. State exploration permits do not require public input and are not appealable.
The company would need to get permission from the U.S. Forest Service before it could explore on federal lands in the area, but could now drill on private lands. The exploration permit covers an area from about a quarter mile upstream of Lake Pactola and Silver City, follows along and near Rapid Creek and Jenny Gulch Road, and goes almost to the Lawrence County line.
A map and additional documents are available below.
Rapid Creek and Lake Pactola provide the water for Rapid City and Ellsworth Air Force Base, as well as for ranchers and reservation and rural communities all the way to the Missouri River. The City of Rapid City opposes gold exploration and mining in the Rapid Creek watershed, as does Black Hills Clean Water Alliance.
100 HOLES NOW MIGHT LEAD TO HUGE OPEN PIT GOLD MINE LATER!
According to their EXPLORATION NOTICE OF INTENT: … “this gold exploration area is generally located from 0.25 to 3 miles north of Silver City, South Dakota, within Sections 19, 30, and 31; T2N-R5E and Sections 13, 14, 24, and 25; T2N-R4E, Pennington County.
Operations are anticipated to begin upon approval of the Plan of Operations from the US Forest Service and upon issuance of written restrictions pertaining to the Notice of Intent. The exploration project will consist of core drilling up to 100 holes to a depth not to exceed 6,000 feet. A maximum of 47 drill pads may be constructed under this Notice of Intent. Drill pads will average 50 feet by 50 feet. Approximately 12,500 feet of existing trails and new trails, including up to 7,800 feet of new trails, may be utilized under this Notice of Intent.”