The Department of Environmental Quality is seeking public comment on a Draft Environmental Assessment analyzing potential environmental impacts from mineral exploration activity proposed by Lucky Minerals. The proposed mineral exploration project would be located on private patented mining claims known as the St. Julian Claim Block in the Absaroka Mountains approximately 12 miles southeast of Emigrant.

Lucky Minerals is proposing to obtain core samples from up to 46 drill holes located on 23 drill pads. The drill pads would be within the prism of an historic mining road that crosses the patented mining claims. The Draft Environmental Assessment discloses potential impacts on area resources, including land use, recreation, soils, vegetation, aesthetics, wildlife and geothermal resources.  The Draft Environmental Assessment has been posted at

DEQ will accept comments on the Draft Environmental Assessment until December 12, 2016. Comments can be submitted via the DEQ comment portal at

Download a Sample Comment Letter

Comments can also be mailed to:

Jen Lane
Department of Environmental Quality
P.O. Box 200901
Helena, MT 59620-0901

DEQ will analyze and respond to comments in a final document. For additional questions, please contact Jen Lane at

Key Points

  • The Department of Environmental Quality (DEQ) should adopt the 4th option as presented in Section 1.5 of the Draft EA – determining the need for further environmental analysis, with an Environmental Impact Statement (EIS), so that any and all potentially significant environmental impacts are disclosed to the public and properly analyzed.
  • The proposed action is supposed to be on private lands, yet Lucky’s map shows one claim and at least three proposed drill sites that appear to be on public lands. Lucky needs to complete a survey and produce an accurate GIS map. This lack of attention to detail on something as fundamental as the primary map is unacceptable.
  • The proposed action shows a lack of clarity around Lucky’s water rights up Emigrant Gulch. Lucky needs to disclose and provide a record of the exact water rights transferred to them by recording those documents at the Park County Clerk and Recorder.
  • Despite overwhelming opposition from the community and hundreds of businesses, the Canadian mining company Lucky Minerals has not given up its plans to dig for gold up Emigrant Gulch, just north of Yellowstone and above Chico Hot Springs.
  • Lucky Minerals has made it clear that they want to create a large-scale, potentially open pit gold mine. They do not want to just explore for gold, yet the environmental review that Montana recently released only examines a small fraction of what Lucky Minerals has in store on Emigrant Peak.
  • Without looking at Lucky Mineral’s full plan we do not get the full picture, nor can we or the State truly assess and weigh the potential consequences. The proposed gold mine would leave behind permanent scars and threaten this world-famous landscape not only in the short term, but for generations to come.
  • Socioeconomic impacts: The Draft states that past exploration in this area didn’t affect local socioeconomics, therefore there’s no need to analyze impacts of the current proposal. I disagree. The last drilling occurred here between 1991-1993 – more than 20 years ago. The local socioeconomics have changed dramatically since 1992. For example, today the Old Chico area hosts nine vacation rental businesses and six private residences that did not exist in the 1990s. DEQ needs to consider impacts to current socioeconomics, as required by Montana law.
  • Montana’s assessment recognizes that Lucky Mineral’s proposal could potentially have dangerous impacts on the pristine waters and intact wild lands that are vital to our local businesses and economy. However, the State ultimately concluded that there would be no significant impacts from Lucky Minerals’ operation. This is based on assumptions about the wildlife that do and don’t live there, the value of cultural and historic artifacts in the area, and the potential impacts a spill may have on surrounding creeks that feed into the Yellowstone.
  • The EA often notes that the area has been mined in the past, using it as an excuse to allow more mining in the area. Emigrant Gulch does have a history of mining, and the impact of those mines are still seen and felt in the area today, but the land is healing. To open up the gulch to more mining will set this restoration back, and the mine that is Lucky’s ultimate goal has the potential to make a much larger impact than any previous operations.
  • Bonding: The Draft says bonding is required, but doesn’t discuss specifics of how much money the state requires. A DEQ bond calculation in 2015 estimated that reclamation for each bore hole would cost more than $8,000 apiece, and that pad reclamation would cost an additional $3,380. But Lucky Minerals VP Shaun Dykes told the press in late 2016, “The holes will be filled with cement at a cost of about $2,000 each…” (“Vancouver company at the centre of gold mining controversy on edge of Yellowstone National Park,” DeSmog Canada, Nov. 22, 2016.) This discrepancy is disturbing. DEQ must provide updated reclamation estimates for 2017, and disclose how much bond DEQ is requiring, and how long Montana will hold the bond.