WHAT DOES THE COMPANY WANT TO DO AT JENNY GULCH? This project is now under a mineral withdawal for 20 years.

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 received permission from the Forest Service to drill in 2024.

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. The area is a favorite of hikers and bicyclists, featuring forest interspersed with wetlands and waterways.

WHAT’S HAPPENING WITH THE FOREST SERVICE?

Projects are the Jenny Gulch (POO) and the Newark (POO)

At the Jenny Gulch project, put on hold in December 2024 as a result of tribal government action and citizen action as a result of the Pactola Reservoir-Rapid Creek Watershed Withdrawal. The Forest Service received F3 Gold’s Plan of Operations in November 2018. It was 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.

Jan 17, 2020 – After the Forest Service and F3’s Powerpoint presentation they said they would answer questions in small groups again, however people asked them to address the entire room on questions asked, which they did.

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.

Plan of Operations – Jenny Gulch – 11-18Download

Notice-of-filing-exploration-permit-f3-9-25-20-1 Download

2-Exploration Permit Application to DENR 9-15-20 Download

f3-gold-exni-map-public-9-20-2 Download