Gold exploration company plans Black Hills drilling project; comments due soon

Opponents are concerned that project could lead to full-scale mining operation.

BLACK HILLS NATIONAL FOREST, S.D. — A Minneapolis-based company is seeking the U.S. Forest Service’s permission to conduct exploratory drilling near Silver City and Pactola Reservoir in search of gold.

Opponents of the project say that exploration will lead to mining, and that the location – just upstream from Pactola Reservoir and the Rapid Creek Watershed – puts the drinking water for Rapid City and other downstream communities at risk.

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Jenny Gulch Road, where it intersects with Silver City Road

The public’s opportunity to comment on the project is running out. The comment period on the environmental assessment closes Friday, October 22.

NewsCenter1 reached out to the company, the Forest Service, and the opposition to provide a comprehensive analysis of the proposed project and what that means for the Black Hills region.

Information on how to submit a public comment can be found near the end of the article.


Screenshot 2021 10 19 110023A cylindrical bit encrusted with industrial diamonds drills down into rock and forces a solid column of rock to the surface to be used as a core sample. Samples are then analyzed both physically and chemically to determine their mineral content.

These exploration holes range anywhere from 100 to 5,000 feet and are typically drilled in 10 inch increments.

According to F3 Gold’s website, exploratory drilling uses the diamond bit with a steel pipe, clean potable water, and biodegradable lubricants in order to collect samples.

Once drilling is complete, the hole is sealed and the area is reclaimed.


Many states require a reclamation plan be established during the initial stages of mine planning. While F3 Gold is not currently applying for a mining permit, they do have reclamation plans in place for the drill pad sites.

F3 Gold says “all contractors working on this project will be employing low-impact methodology” to limit disturbances, and that “once completed, [their] program will leave no trace.”

Drill holes will all be capped, sealed, and plugged following state regulations once each hole is complete.

Drill pads and staging areas will be smoothed, brushed materials will be spread, and reseeding with the Forest Service’s reclamation mix will occur. Safety signage will be removed. Other stockpiled materials will be spread, stacked, or removed. Any overland trails created to access drill pads will be reseeded back to pre-existing conditions.

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A visual timeline of exploration provided on F3 Gold’s website

A U.S. Forest Service report says that while the productivity of reclaimed land should at least equal that of the pre-mine surface, “[this] does not necessarily mean that the site must be restored to an approximation of its original condition, or that surface uses after mining will be the same as those existing prior to mining.”


“The specific timeline and conditions for our project will ultimately be determined by USFS when they issue a permit, but the expected timeline for our project is 12 months from commencement of drilling to complete exploration work,” said F3 Gold Vice President Brian Lentz.

The U.S. Forest Service’s Plan of Operations for Mining Activities on National Forest System Lands includes the following project description:

  • No mining, milling, or processing is proposed as part of this project (exploratory drilling only unless profitable resources are found)
  • No proposed construction of roads or structures (temporary trails allowed for drill site access but would be removed once the project ends)
  • No dredging or removal of soils; any soils scraped to clear pads will be saved for use during reclamation
  • No water sourced from Rapid Creek or other local surface waters (water used for drilling would come from approved municipal/industrial sources)
  • Diamond drill holes drilled from 500ft. to 6,000ft. in total depthDiamond Drilling Usfs Anatomy Of A Mine From Prospect To Production
  • Maximum of 42 drill pad sites and two laydown/drill sites (some drill sites may not be used depending on the result of previous drill holes)
  • Drilling would take place 24 hours a day with two, 12-hour shifts
  • Each site would have a maximum footprint of 2,500 square feet (0.06 acres)
  • Two staging areas for equipment at 0.25 acres each
  • Main access roads: Jenny Gulch Road via Rochford Road (north), Jenny Gulch Road via Silver City Road (south)
  • Total size of the project: 3.8 acres

Forest Service Mystic District Ranger Jim Gubbels said, “A lot of things I have read describe this as a gold mining project – which it is not – it has never been – and the project proposal does not include any mining activity – it is exploratory drilling.”


F3 Gold provided detailed information to the U.S. Forest Service about how they plan to protect and preserve environmental resources in the exploration area.

As with any exploration or mining activity, water quality concerns are paramount. The company says that each drill rig for the Jenny Gulch Project is estimated to use between 5,000 and 10,000 gallons of water per day. They say this water will not be sourced from the Rapid Creek watershed, nor will drilling occur in the Madison or Minnelusa aquifers.

“All water will be sourced from an approved municipal or industrial source,” wrote F3 Gold in their U.S. Forest Service Plan of Operations.

Screenshot 2021 10 20 085941For water quality monitoring, the General and Drill Contractors will conduct ongoing visual inspections throughout the project. The company says water will be recirculated and recycled whenever possible.

According to the Forest Service Plan, no endangered fish or wildlife species exist in the area. Additionally, no drilling is set to occur near historic mine shafts where bat populations could be disturbed.

F3 Gold says the remoteness of the project will limit disturbance to both visitors and residents.

In a statement released online, F3 Gold said:

“The bottom line is that we have proposed an exploration drilling project, not a mining project, and we are confident that the EA process the USFS is currently conducting will provide the necessary review, above and beyond the normal requirements of a Categorical Exclusion, to determine what, if any, environmental risks exist. We look forward to the results of the EA and taking this project to the next phase.”


It’s important to keep in mind that the current proposal from F3 Gold is not a mining project. However, it’s important to address the potential impacts if exploration is successful in locating precious metals.

In a 2004 report, the U.S. Environmental Protection Agency (EPA) said that hardrock mining is the number one source of toxic pollution. In 2000, the EPA declared 40% of all western watershed headwaters polluted by mining.

“The Jenny Gulch area where F3 wants to explore is actually the place where all the drinking water for Rapid City, Rapid Valley, Ellsworth Air Force Base, and many downstream communities actually comes from,” said Justin Herreman with Rapid Creek Watershed Action. “The reality is that mining exploration could result in mining which, likely – very likely – would result in negative impact to the drinking water quality in Rapid City.”

A major waste generated by mining operations is mine water, which must be pumped or drained out. According to an EPA Framework, when mining operations end and the pumping stops, groundwater “will usually recover to its pre-mining level, although this can take decades or centuries.”

Hear from Justin Herreman, a representative from Rapid Creek Watershed Action, on water usage for the Jenny Gulch Exploration Project:

An EPA report says that the metal mining industry was the largest toxic polluter in 2000 – releasing 3.4 billion pounds of toxics – or 47% of the total released by U.S. industry.

One notable local example of environmental destruction is the 360-acre Gilt Edge Mine site located east of Lead, South Dakota. The site was abandoned in 1999 by then-operator Brohm Mining Company. The cessation of water treatment to address the acidic, heavy-metal-laden water – BMC’s responsibility – has resulted in the mine becoming a Superfund site managed by the U.S. Environmental Protection Agency.


It’s important to keep in mind that the current proposal from F3 Gold is not a mining project. However, it’s important to address the potential impacts if exploration is successful in locating precious metals.

According to the World Gold Council, in 2013, gold mining companies contributed over $171.6 billion to the global economy through production and expenditure. 70% of total expenditures by gold mining companies are payments provided to suppliers, contractors, and employees.

In 2013, gold mining companies directly employed more than one million people and another three million more indirectly, including a large percentage of local workers. U.S. Bureau of Labor Statistics shows that South Dakota employed more than 26,000 people in the mining, logging, and construction industries in July 2021.

South Dakota imposes a severance tax on gold and other precious metals mined in the state at a rate of $4 per ounce.

A severance tax is “a state tax imposed on the extraction of non-renewable natural resources that are intended for consumption in other states.”


The Mining Act of 1872 – still in use today – actually allows exploration and mining activities to occur on public lands without payment of royalties to the government. Mining opponents have been working to change the law for years, saying it’s outdated and archaic.

The law itself calls for no environmental protections, but mining and related development are still subject to state and federal environmental regulations – including ones the Forest Service and Bureau of Land Management put in place. Regulations like the National Environmental Policy Act, Clean Air and Clean Water Acts aren’t specifically directed towards the mining industry, but companies are still required to comply.

The 1872 Mining Act still applies – even to exploratory drilling projects.

Hear from U.S. Forest Service District Ranger Jim Gubbels on what the 1872 Mining Act requires of the U.S. Forest Service in this situation:


Public comment is due by Oct. 22, 2021. Anyone wanting to submit a comment can do so one of two ways:


F3 Gold’s Exploration Notice of Intent to the South Dakota Department of Environment and Natural Resources 


Map of the F3 Gold Jenny Gulch Exploratory Drill Program project area

U.S. Forest Service Plan of Operations for Exploration Activities on National Forest System Lands – F3 Gold Jenny Gulch Project

South Dakota Department of Revenue Metal Mining Taxes Fact Sheet

South Dakota Codified Laws – Energy Minerals Severance Taxes

U.S. Forest Service – Jenny Gulch Exploration Drilling Project

South Dakota Department of Agriculture and Natural Resources Minerals and Mining Program

Rapid Creek Watershed Action 

Black Hills Clean Water Alliance

F3 Gold

Big Rock Exploration

U.S. Forest Service Anatomy of a Mine from Prospect to Production 

Earthworks 1872 Mining Law Fact Sheet

Mineral Withdraws and the 1872 Mining Law from Kalmiopsis Rivers Homegrown Movement

Environmental Protection Agency Hardrock Mining Framework

U.S. Environmental Protection Agency Office of the Inspector General Nationwide Identification of Hardrock Mining Sites (2004)

Gilt Edge Mine EPA Superfund Site

World Gold Council – The Social and Economic Impacts of Gold Mining (2015)

U.S. Bureau of Labor Statistics – South Dakota (by industry)

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