Public pushes back on drilling project

A large group of ranchers, environmentalists, indegenous activists, scientists and other concerned people from Custer and the surrounding area came out to the public meeting held by the Black Hills National Forest to address a proposed exploratory drilling project last Thursday.
The meeting was intended to run town-hall style with community memebers interacting in small groups with representatives from the Forest Service and F3 Gold. Due to the large number of people in attendance, the meeting switched tracks to a comment and question session. District ranger Rob Hoelscher said near the start of the meeting that F3 Gold representatives would be present to answer questions, but, when asked to show their hands by a questioner had either declined to identify themselves or already left.
The Newark Exploration Drilling Project is set to start in May and be completed within one year. The  project is anticipated to take up  four and a half total acres of National Forest System land. The project would take place 24 hours a day at 39 identified drill sites northwest of Custer and upstream of French Creek, the same creek in which gold was first discovered in the Black Hills nearly 150 years ago.
The project is proposed by F3 Gold, LLC of Minneapolis, Minn. According to their website is “not a mining company,” but an “exploration and prospecting company.” The difference of prospecting from mining is that no minerals are extracted for profit. Whether or not the exploration project could lead to mining is up for specuation, but many say mining is the natural next step of exploration.
“Our focus is on staking prospective ground to evaluate the geology, with the goal of locating a high-grade underground gold deposit,” says its website.
The Black Hills Clean Water Alliance (BHCWA) begs to differ.
“[Exploration drilling projects] may also lead to a large-scale mining operation in the future,” it says in a recent social media post.
“The Black Hills is a tourism destination that hosts over 3.6 million visitors per year. Tourism and recreation are two of South Dakota’s economic driving forces.  These exploration mining projects will affect our water, wildlife, endangered species that may be in close proximity, outdoor sports and recreation, cultural sites, and communities downstream,” the post also says.
The project proposes diamond core drilling at no more than 39 drill sites, temporary access routes, drill pad site clearing, and reclamation activities. No mining, milling or processing is proposed as part of this exploratory project. Half of the anticipated acreage impacted by the project are for the 39 designated drill pads. A drill pad is the physical space occupied by all equipment, materials and personnel needed for the drilling operation. Each drill pad is approximately 50 by 50 feet, about 1/20th of an acre. The drill pads will take up approximately 2.24 acres of land, although they may not end up using each drill site, which would consequently lower the total acreage used.
“Depending on the results of preceding drill holes, some of the drill sites may not be needed and would ultimately not be constructed,” reads the scoping letter for the project. If nothing is found after drilling at one drill site, the company will have 24 hours to fill the hole. The width of the drill holes is approximately 3-4 inches and would range from 500 to 3,000 feet in depth dependent on the results of each hole. Average drill depth would be 1,000 to 2,000 feet.
Water needed for the diamond core drilling operation will not be sourced from surface water sources such as lakes or streams but instead from an approved municipal or industrial source. The water will be trucked from the source to storage holding tanks located at the drill sites or staging area.
“Municipal, potable water is water that has been treated for human consumption. We live in a semi-arid region. Using human drinking water for gold exploration is not the best use of this limited resource. It would be better to use some human drinking water for humans, protect the rest of the water for future use and skip the gold drilling,” says the BHCWA.
The project is also a concern for some Custer County residents who live and raise livestock nearby to the proposed drill sites. Many others are concerned about how the project will affect water in the area. Dr. Elizabeth Racz, a Custer resident, fifth-generation “South Dakotan from this area” and biologist at the South Dakota School of Mines and Technology spoke at the meeting.
“How are you going to guarantee that we don’t have our waters poisoned? How are they going to keep cyanide out of our water when they process the gold they find?” asked Racz.
“What about our downtown businesses and tourists who come here for the beauty? They expect clean water,” said Racz.
“Hazardous materials and toxic substances are not used for the actual drilling or coring in the ground. The only hazardous materials utilized under this plan are only for refueling the drill rig and lubricating the mechanical parts,” reads the plan of operations for the project.
To this the BHCWA says “If their exploration led to gold mining – again, which is the goal – modern gold mining uses cyanide to leach gold out of the ore. Toxic arsenic and heavy metals are often byproducts. Heavy metals from past gold mining in the northern Black Hills can be found in the Cheyenne River all the way to the Missouri River – about 170 miles away from the mining.”
These concerns were amplified by the possibility of establishing a categorical exclusion in the National Environmental Policy Act (NEPA) for the project.
A categorical exclusion would advance the project without the conducting an environmental assesment or an environmental impact statement. Categorical exclusions are not exemptions or waivers of NEPA review, but instead one type of NEPA review. Categorical exclusions are for proposed activities that, on the basis of past experience, normally do not require environmental review.
Although this particular project does not involve gold mining, gold has been mined in the Black Hills continuously since the 1870s. In fact,  gold was first disocvered in the Black Hills in Custer in 1874 by Horatio Ross, a miner with Gerorge Custer’s Black Hills Expedition. Currently, the Wharf Mine near Lead is the only gold mine in the Black Hills and only large-scale mine in South Dakota. Before closing in 2002, the Homestake mine, also near Lead, was the largest and deepest gold mine in North America.  
“Exploration activities have very minor, or no environmental impacts. We do this by limiting our exposure to creeks and lakes; limiting our surface disturbance; planting trees to replace ones that may be removed; and working with the Forest Service, BLM and Department of Environment and Natural Resources, and local groups to ensure our activities abide by environmental best practices,” says F3 Gold’s website.
While the Forest Service can impose limitations reasonable and necessary to protect National Forest land, F3 gold does have a right, under the General Mining Act of 1872 to explore its BLM lode mining claims for exploration purposes.
Previous mining activity in the Black Hills has not gone without environmental impacts, however. Mining in the northern Black Hills has led to the establishment of two superfund sites.
The Forest Service is collected public comments on the project. Currently, the 30-day comment period is set to end March 8, although Hoelsher commited to extending the period to allow for more comments. Audience members expressed that a 90-day or six month period would be more appropriate to allow time for “snowbirds” to provide comments.
“We need to have your local input as to how we move forward,” said Hoelscher.
Comments can be submitted through a variety of avenues:
• Mailed or hand-delivered to Rob Hoelscher, District Ranger, 1019 North Fifth St., Custer, South Dakota 57730
• Emailed to  comments-rocky-mountain-black-hills-hell-canyon@usda.gov with the subject line “Newark Exploration Drilling Project;”
• Verbal comments over the phone by calling 605-673-9301
• Submmited via the Forest Service’s online form at cara.fs2c.usda.gov/Public//CommentInput?Project=63527
Project documents, such as the scoping letter, plan of operations and various maps can be viewed online at fs.usda.gov/project/?pro
ject=63527