Reply to Interior Land Withdrawal

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Crevice Mining Group LLC

Crevice Mining Group LLC

614 South 8th Street (P.O. Box 487)

Livingston, MT 59047


February 16, 2017


Supervisor’s Office, Custer-Gallatin National Forest

U.S. Department of the Interior

10 East Babcock Ave. (P.O. Box 130)

Bozeman, MT 59771


Bureau of Land Management

Montana State Office (MT924)

5001 Southgate Drive

Billings, MT 59101


Re:      Comment on Proposed Mineral Withdrawal near Yellowstone National Park


To Whom It May Concern:


This comment is submitted by Crevice Mining Group LLC, a Montana Limited Liability Company (“CMG”), in opposition to the segregation and proposed mineral withdrawal (the “Withdrawal”) by the U.S. Department of the Interior (“DOI”) of approximately 30,000 acres of U.S. Forest Service land near the northern entrance of Yellowstone National Park (“Yellowstone”), as outlined in the DOI’s press release dated November 21, 2016, and the Federal Register on November 22, 2016. The press release for the Withdrawal expresses concern about mining at “…the doorstep of Yellowstone National Park…” and the need to “…balance the benefits of our natural resources and recreation-based local economies against mineral extraction…” The press release further provides that the mineral withdrawal is focused on ensuring “relatively undisturbed natural conditions” in the area, maintaining high water quality and high-value fisheries, and ensuring that wildlife corridors to Yellowstone remain intact. CMG supports maintaining these components of the natural environment; however CMG opposes the means DOI intends to employ to reach these ends. A mineral withdrawal of lands holding valuable mineral resources ignores the economic benefits such activities bring to the area, and turns a blind eye to the reality that mineral extraction can occur without significant detriment to recreational and wildlife activities in the area.





  1. Historic Mining in the Region


The Withdrawal will directly impact mineral extraction in the Emigrant and Jardine-Crevasse Mining Districts north of Yellowstone. Mining in the Jardine-Crevasse Mining District, located just north of Yellowstone, began in 1879 with the discovery of gold at the Highland Chief Mine. From 1898 to 1908 a total of 6,763 ounces of gold with a value of $128,363 was produced. In 1932, extraction began at the Tower Grove and Snowshoe Mines and by 1939 total production reached 718 ounces of gold. Gold and scheelite were also extracted from the nearby Medona Mine. Current estimates put total production from the Jardine-Crevasse Mining District at 7,692 ounces of gold with minor by-products of silver and scheelite.[1]


Renewed interest and exploration in the Jardine-Crevasse District began in the early 1970s. The Crevice Mountain area represented the second largest gold anomaly but because of preferable access, better mining developing and a better mill site along Bear Creek, the Mineral Hill Mine was developed first. In 1993, focus shifted to Crevice Mountain with exploration of what is known as the Conrad Zone.[2] The results of this and more recent exploration work projects that significant high-grade ore bodies still exist in the area. It is notable that previous mineral withdrawals and wilderness designations did not include the Crevice Mountain area, likely due to the known gold deposits in the region. This letter urges DOI to not sway from previous management approaches in the Jardine-Crevasse District and to allow CMG, other parties, and the public, to continue to realize the full potential of valuable mineral resources in the area.


  1. CMG’s Interests in the Withdrawal Area


  1. The Crevice Mountain Project

CMG has worked since 2012 to develop the Crevice Mountain Project in the Jardine-Crevasse Mining District. Thus far, CMG spent more than $1 million in purchasing mineral rights, obtaining mining leases, staking unpatented mining claims, and evaluating and modernizing historic mining and exploration data. Overall, CMG holds mining leases to 30 patented mining claims covering 503 acres, 57 unpatented claims covering 803 acres and mineral rights to approximately additional 200 acres of fee land within the district. CMG’s review of the notice in the Federal Register, and a map prepared by a third party, attached as Exhibit 1, indicates that the claims held by CMG on and near Crevice Mountain are fully within the area of the proposed Withdrawal.[3]


Technical review of the Crevice Mountain Project anticipates an approximately eight-year mine life on the mineralized material identified by historic exploration and the historic reserves and resources on Crevice Mountain. Mining of the present mineral domain, based upon current modeling, would yield approximately 245,000 ounces of gold from 608,000 tons of ore. Additional exploration and modeling will likely yield a more prolonged project life.[4]


CMG estimates the Crevice Mountain Project would require an additional $17 million to begin operations, and cost $158 million to operate over the defined project life. Anticipated tax payments to the state of Montana, and the federal government, are estimated at $5 million and $25.6 million, respectively. Royalty payments to local land owners would be approximately $12.1 million, and an estimated 70 full-time employees with competitive salaries and benefits would be hired by CMG to directly work on the project. It is also anticipated that an additional 7 jobs would be created in the industries servicing the project.[5] CMG urges DOI to not ignore these figures and the economic benefits the Crevice Mountain Project will bring to the area. Admittedly, the Withdrawal will not immediately halt CMG’s activities; however it will certainly limit CMG’s ability to expand operations should additional mineral resources be found in the area. CMG is also concerned that the Withdrawal will bring increased and unwarranted negative scrutiny of CMG’s operations.


  1. Environmental Concerns


The press release announcing the Withdrawal states that its primary purpose is to ensure “relatively undisturbed natural conditions” in the area, maintain high water quality and high-value fisheries, and ensure that wildlife corridors to Yellowstone remain intact. The methods to be employed by CMG, and used by current and past operations in the area, will not have a significant impact on these recreational and wildlife values.


A common concern with mining activity is the negative impact it will have on the ground covering the ore deposit. The methods CMG has employed in its exploration operations, and continued operations, involve very little surface activity. Ore will be removed via focused underground drilling utilizing the “room and pillar” method of underground mining. Anticipated initial surface disturbances will likely remain near five acres. These disturbances will be for operational facilities necessary for daily operations at the mine, and storage of any rock removed in accessing the ore body. Excess rock will also be used to maintain and improve pre-existing access roads. All excess rock will be tested prior to application on pre-existing access roads. Any remaining excess rock will be placed in the mine workings underground. A large portion of the area has already been logged so tree removal will be kept to a minimum. A photo of the project site viewed from within Yellowstone is attached hereto as Exhibit 2. CMG’s minimal surface activities will neither significantly change the viewshed from the park nor will they negatively impact migration patterns of wildlife entering Yellowstone. Given that other mining operations within three miles of Yellowstone have already disturbed 30 acres of land, CMG’s relative impact will be negligible.


Acid mine drainage (“AMD”) is another area of concern for a mining operation. AMD occurs when water flows over or through sulfur-bearing materials forming solutions of net acidity. CMG does not anticipate AMD will be an issue in the project area. This is because little to no groundwater water has been experienced in the project area. Further, any mine water encountered will be contained in a closed-loop circuit, held in temporary underground sumps, and recycled for use in drilling. The table below details the groundwater experienced at different levels in the project area.[6]



Key Point of Interest




Groundwater Observation

Proposed Crevice Portal /

Exploration Decline




Little to no water expected based on historic data


First Chance Adit



No water encountered or presently observed (795 total

feet driven)

Base of Crevice

Exploration Decline




Little to no water expected based on historic data


Vindicator Adit



No water encountered or presently observed (415 total

feet driven)

Highland Chief Adit 7837 No water encountered or presently observed

Crevice Tunnel Project



Water encountered along Palmer fault, which is 650

feet below base of planned decline and over two miles away from planned Crevice exploration area.


Over 125 years, the ore, waste and mines, developed over 1000 vertical feet, although not reclaimed, in CMG’s project area have not shown evidence of acid mine drainage or water discharge from the underground workings. Sulfide-bearing deposits have been exposed to water and air in historic mine workings, yet water quality sampling in the Mineral Hill area show pH values that are neutral or slightly alkaline with low sulfide concentrations.[7] Given this, it is not anticipated that acid mine drainage will present itself as an issue at CMG’s project area. However, water quality sampling will continue during the life of the project to ensure that surface water is not negatively impacted.


CMG will also process the ore removed at a facility off-site and no sulphidic material will remain on the surface on Crevice Mountain following completion of the project. Given this, It appears that DOI’s focus on mining operations such as CMG’s may be misplaced.


III.       Conclusion


CMG welcomes DOI’s efforts to preserve the natural beauty of Yellowstone and the surrounding area. However, a mineral withdrawal of the magnitude proposed by DOI appears to be a solution in search of a problem. Mining activity has been present in the Withdrawal area for more than 100 years and has presented few if any significant environmental impacts. CMG believes that the Withdrawal will unnecessarily hinder development of a valuable mineral resource and the potential for increased economic activity that will benefit local residents. For these reasons, CMG opposes the Withdrawal.


Thank you for your consideration.








Dr. Michael A. Werner

Crevice Mining Group LLC








































8 It is also important to note that the Mineral Hill Mine, operating under a cynanide permit within three miles of Yellowstone, received the 2011 Bureau of Land Management Hardrock Mineral Environmental Award.

9 Gardiner-Park County Water and Sewage District v. Nat’l Park Service, et. al., Case No. 1:16-CV-00175-SPW-TJC (D. Mt. December 21, 2016).

[1] John Andreassa and Dr. Michael Werner, Crevice Mine Project Study, October 2015.

[2] Id..

[3] Representatives of CMG requested a map from DOI indicating the area of withdrawal. As of the date of this comment, DOI has not fully responded to this request.

[4] John Andreassa and Dr. Michael Werner, Crevice Mine Project Study, October 2015.

[5] Id.

[6] Data provided from Plan of Operations, Exploration Program Crevice Mining Project prepared for Montana Department of Environmental Quality Hard Rock Mining Program, October 16, 2015.

[7] Montana State Department of Lands, 1994

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