Image from our comment letter: Figure 7: Map of Existing Forest Trail/Roads and Drill Sites.

WGF cosigns formal comments on proposed mining in Bend deposit

Click here to read the PDF of the joint letter by ELPC, Wisconsin’s Green Fire, River Alliance, and Sierra Club – Wisconsin Chapter on metallic mining proposed in the Chequamegon Nicolet National Forest in Taylor County.

Update July 3, 2025: Opportunity for Action

Janelle Crocker, the Forest Supervisor for the Chequamegon-Nicolet National Forest (CNNF) has extended the public comment period for this proposed project!

The new deadline for comments is July 31, 2025. 

• Review more detailed proposed action description and project maps at:
  • https://usfs-public.app.box.com/s/qjcjqdj05rasojme4glexx8hjqyfhk3c or the
  • CNNF webpage: https://www.fs.usda.gov/r09/chequamegon-nicolet/projects.
• Submit written comments to Danielle Eklund, District Ranger
  • By mail: 850 N. 8th, State Highway 13, Medford, WI 54451
  • By fax: (715) 748-5675
  • By email: SM.USDA-FS.CNNF.MPF.NEPA@usda.gov
• For questions or additional information, contact:
  • Matt Monahan at 715-748-4875 Ext. 7484834, email: matthew.monahan@usda.gov

Wisconsin’s Green Fire (WGF) is a proud cosignatory to formal comments related to Green Light Wisconsin LLC’s permit to prospect for minerals in the Chequamegon-Nicolet National Forest in Taylor County. These comments were drafted by the Environmental Law and Policy Center (ELPC) and submitted on Friday, June 27, 2025 to the United States Forest Service (USFS) in Medford, Wisconsin. Additional cosigners include the Sierra Club – Wisconsin Chapter and River Alliance of Wisconsin.

These comments lay out a well-reasoned argument to conduct an environmental assessment (EA) prior to any prospecting/drilling.

The area in question is commonly referred to as the “Bend deposit.” This mineral deposit rests below the Chequamegon-Nicolet National Forest. Green Light Wisconsin has filed for a permit to conduct drilling to explore the extent of the deposit. (This drilling permit is different than the drillholes for which work has started as of late June 2025.) While mineral exploration is permitted on lands managed by the USFS, it must be done “through environmentally sound responsible development.” According to the Chequamegon-Nicolet National Forest Land and Resource Management Plan (“LRMP”), the USFS is required to “sustain the health, diversity, and productivity of the Nation’s Forest…”

Originally, the USFS intended to conduct an EA for this permit request.

But, the USFS is now considering a “categorical exemption” (CE), a lower standard of review. Our comments highlight that a CE would be inadequate or inappropriate because:

“the proposed project will extend beyond one year, and, second, the amount of repairs to existing roads and construction of new roads required for the project exceed the amounts permissible under 36 C.F.R. § 220.6(e)(8).”

Even if the prospecting/drilling were to conclude within a year’s time, the CE process must evaluate extraordinary circumstances which would likely prompt an EA. Those circumstances are:

• (i) Federally listed threatened or endangered species or designated critical habitat, species proposed for Federal listing or proposed critical habitat, or Forest Service sensitive species;
• (ii) Flood plains, wetlands, or municipal watersheds;
• (iii) Congressionally designated areas, such as wilderness, wilderness study areas, or national recreation areas;
• (iv) Inventoried roadless area or potential wilderness area;
• (v) Research natural areas;
• (vi) American Indians and Alaska Native religious or cultural sites; and
• (vii) Archaeological sites, or historic properties or areas.

These extraordinary circumstances would indicate the need for an EA.

The EA would consider the cause-effect of the prospecting. This would be including, but not limited to:

1. Impact to the Wood Turtle, a species found in the area and listed as threatened statewide,
2. Impact to the Northern Goshawk, listed as a USFS Sensitive Species for the Chequamegon-Nicolet National Forest, and
3. Impacts to the massive network of wetlands in the area.

There are four actions that the signers look to the USFS to consider with its review of the permit application.

• First, the USFS should determine that an Environmental Assessment (“EA”) is the appropriate level of environmental review required for GLW’s permit application, not a decision memo pursuant to the categorical exclusion (“CE”) set forth in 36 C.F.R. § 220.6(e)(8). GLW’s proposed project does not qualify for a CE under Section 220.6(e)(8).
• Second, even if the USFS were to determine that the CE set forth in Section 220.6(e)(8) applies, USFS should find that extraordinary circumstances are present here which nonetheless require an EA. These extraordinary circumstances are the risk that GLW’s proposed prospecting will result in harmful impacts to species, wetlands and important cultural sites absent an EA.
• Third, GLW’s planned waste disposal method risks contaminating groundwater and the watershed as a whole, so, if the USFS approves the project, it should condition any such approval upon a requirement that GLW instead dispose of its waste at a licensed sanitary landfill as prescribed by Wisc. Admin. Code § NR 130.110(2)(a)(1).
• Fourth, if the USFS approves the project, in order to adequately protect the National Forest, USFS should impose stipulations that are at least as stringent as those it imposed on previous prospecting projects in the National Forest, as well as nine project-specific stipulations that Environmental Organizations propose detailed in the full comments.

>> Read the full comment letter here.

A storm gathers over a lake in the Chequamegon-Nicolet National Forest near Medford. Photo: Will Vuyk

Contact us with your questions or thoughts about our work.

Read more about exploratory drilling of the Bend deposit in our June 26, 2025 blog post: Company explores for copper and gold in national forest in northern Wisconsin.

Does our work on mining or public lands inspire or inform you?

Please consider supporting our work with a donation to Wisconsin’s Green Fire. An annual gift of any amount makes you a member. Thank you!