Background

We’ve been tracking the proposed Sheep Creek Mine project – located in the headwaters of the West Fork of the Bitterroot River — since its inception, and we were among the roughly 500 concerned citizens and conservation groups that joined an emergency hearing in front of the Ravalli County Commissioners in December of 2025. The message was clear: the West Fork—an important headwaters of the Bitterroot River and the Clark Fork River watershed—is too precious, pristine and valuable to jeopardize. 

The Ravalli County Commissioners agreed, sending a letter to federal representatives urging the Sheep Creek Mine exploration project be removed from the Trump Administration’s “fast-tracked” FAST-41 list. A few of Montana’s Congressional representatives initially agreed as well but quickly backtracked and instead spoke out in favor of the proposed project as long as the appropriate permitting processes are followed. As a result, the project remains on the FAST-41 list. 

In mid-December, the mining company behind the project – U.S. Critical Minerals, Inc. – submitted its first Draft Plan of Operations to the Bitterroot National Forest, which should ostensibly allow the Forest Service to identify and evaluate any environmental impacts from the proposed project. Unfortunately, the company’s Draft Plan is woefully insufficient and provides almost no detail about how exploration or mining activities might impact water resources. Among other deficiencies, the Draft Plan includes: 

• no baseline information on existing groundwater or surface water resources in the area; 

• zero information about how exploration/mining activities will be conducted without impacting these water resources; 

• no information on water rights or permits needed for exploration activities; 

• no plan for stormwater management for exploration and mining activities or waste rock storage; 

• no information on how the project might impact water quality, aquatic life or fisheries within Sheep Creek or the W. Fork of the Bitterroot. 

In short, the Forest Service simply cannot evaluate the potential impacts from the project based on the information submitted. We continue to anticipate serious risks, including impacts to water quantity, water quality, fish and wildlife habitat, and the overall health of the watershed. There will be much to do in the months and years ahead, but CFC remains committed to ensuring that the Bitterroot River is protected from this misguided proposal. 

Latest Update: September 10, 2026

On September 10, 2026, CFC submitted comments to the Bitterroot National Forest, arguing that USCM’s Revised Draft Plan of Operations raises serious concerns about impacts to water quantity, water quality, aquatic life and fisheries in the headwaters of the West Fork Bitterroot River. We strongly urged the Forest Service to conduct a full Environmental Assessment to evaluate these impacts before any mining exploration activity can take place in this sensitive area. A copy of our comments can be viewed here. 

August 27, 2026

The Bitterroot National Forest has opened a 30-day Public Comment Period, closing September 13, to accept input on the proposed Sheep Creek Exploration Project in the headwaters of the West Fork of the Bitterroot River.

Background
The Project would authorize U.S. Critical Materials (“USCM”) to conduct rare earth element mineral exploration across a significant footprint within the headwaters of the West Fork, a land and water resource of enormous ecological, recreational, economic and cultural value. Exploration would occur at 4 locations within the 11-square mile proposed mining site and will require heavy drilling equipment, chemicals, explosives and underground sumps to collect and reuse water and settle mine waste.

Over 4,000 helicopter flights will transport excavated rock material (ore), equipment, imported water and other mining materials to, from, and within the site. Up to 6 million pounds of potentially toxic excavated rock material will be transported along 30 miles of the West Fork of the Bitterroot from the Sheep Creek exploration site to Conner. USCM proposes using a heavy-duty truck and trailer. Any waste rock will be left on site. USCM’s Draft Plan states that exploration activities will take place within one year and that reclamation will occur within 12 months of completing exploration work.

The Process
The Forest Service is currently considering whether to authorize the Sheep Creek Project under a Categorical Exclusion (CE) to the NEPA process. Categorical Exclusions represent an expedited track available for a limited set of agency actions that normally do not have a significant effect on the human environment. CFC believes that a CE is not appropriate because the Project is likely to have significant impacts on the environment and because there are several circumstances that by rule preclude the use of a CE. Instead, we believe the Forest Service should, at a minimum, prepare an Environmental Assessment.

Potential Talking Points for Comments

• The West Fork of the Bitterroot comprises some of the highest quality water resources and aquatic habitat in the Clark Fork Basin. The people and the economy of the Bitterroot Valley depend on the integrity of these high-quality water resources. USCM’s plan fails to explain how both water quantity and quality will be protected in Sheep Creek and the West Fork, and the Forest Service must take closer look.
• Painted Rocks Reservoir and its storage water rights quite literally keep the West Fork alive and flowing during periods of low flow. The Sheep Creek Project anticipates the use of up to 8,800 gallons of water per day for drilling operations, dust control and other uses, but the Draft Plan contains no details as to where Project water will be sourced. Local water resources and water rights are too important to leave these questions unanswered.
• The West Fork above Painted Rocks is home to an enormously important meta population of native Westslope cutthroat trout and is also a stronghold for threatened bull trout. Both of these species require clean, cold and connected waterways in order to thrive, and both are highly sensitive to disturbances in water quality from pollutants such as sediment, heavy metals, and increases in water temperature. The loss of acceptable, high-quality habitat — like that of the West Fork — is the primary reason that bull trout are listed as threatened under the ESA. The Sheep Creek Project threatens these native species and their habitat.
• USCM’s plan requires the use of tens of thousands of gallons of water and over 100 gallons of additives for the drilling and bulk sampling processes and mentions the need to settle out solids and neutralize acids in order to reuse this process water. However, there is no plan for treating and disposing of this water after the exploration process is complete, and no investigation of the potential for ongoing acidification that could result from the exploration process. USCM simply asks the FS and the public to trust that no discharge to ground or surface waters will occur from their operations.
• Many of the proposed exploration activities are well known to increase erosion and take place in close proximity to Sheep Creek and other small tributaries, yet there is no evaluation of the likely increase in sediment loading. The plan asserts that the project will not construct any new stream crossings but fails to consider the impact of increased traffic use on existing primitive crossings. The plan also emphasizes that many activities will not require extensive surface preparation or will take place on areas that have been formerly disturbed, but the proposed 11,800 square feet of disturbance will likely lead to increased erosion and sediment loading regardless of the prior condition of the disturbed area. The minimal erosion control measures put forth in USCM’s plan are not sufficient to minimize sediment issues.
• Not only does USCM’s plan fail to explain how water resources will be protected, it explicitly states that the company will not monitor either pre- or post-exploration water quality conditions to determine whether any negative impacts have occurred.
• At a minimum, the Forest Service must prepare a Draft EA to examine the impacts of USCM’s exploration activities on local and downstream water resources. The presence of numerous ESA listed species, including bull trout, combined with the likelihood of direct or indirect impacts to these species, precludes the use of a CE. The Forest Service must take the “hard look” that NEPA requires.

Comments can be submitted via email to Sheep.Creek.Comments@usda.gov OR through the comment portal on the Bitterroot National Forest website. To ensure your comment is received, consider submitting it via both mechanisms.

The Bitterroot Water Partnership has also put together an example comment letter and instructions, found at the link below:

July 13, 2026

The Forest Service Must Require an Environmental Assessment for the Sheep Creek Mine Exploration Plan

When the Federal Permitting Council enrolled the proposed Sheep Creek Mine project into the FAST-Track program in November of 2025, the permitting process included an Environmental Assessment (EA). On July 13, 2026 an updated timeline reports ‘Environmental Assessment cancelled.’ We are concerned that removal of the EA indicates US Critical Materials, the exploration company, changed its proposal to evade environmental review and eliminate public comment.

On July 1, 2026 The Forest Service released a new Plan of Operations from US Critical Materials (USCM) which proposes industrial exploration in the headwaters of the West Fork of the Bitterroot, including blasting, drilling, fuel storage, explosives, drilling chemicals, helicopter flights, and trucking 6 million pounds of hazardous material along the river to Conner. The plan does not address how wastewater will be safely managed, how groundwater contamination will be avoided, how the operation will mitigate threats to fish and wildlife, or how the company will uphold its promises of transparency and open communication with the public.

Simply put, the current plan lacks the detail we need to assess how the resources we care about might be impacted. The US Forest Service is obligated to evaluate the impacts of the project and protect these resources on our behalf. For these reasons, we believe the Forest Service should conduct an Environmental Assessment of potential effects and prioritize a robust public comment period.

Additionally, the proposal must also be reviewed and licensed by the Montana Department of Environmental Quality. Similar to the Forest Service process, proposals will have different levels of scrutiny and public engagement depending on the scale of the project and level of potential impact.

Submit Your Comments

The Forest Service has created an email address to receive comments. This is NOT the same as a formal comment period that comes with greater legal weight but allows your concerns to earn a place in the public record, especially if no public comment period is offered.

We’ve made it easy to take action in just a few minutes by drafting a letter outlining these concerns – just click the button below to view a template letter that you can edit and email to to Sheep.Creek.Comments@usda.gov.

January 15, 2026

The Clark Fork Coalition submitted comments to the Bitterroot National Forest in response to U.S. Critical Material’s draft plan of operations, which failed to provide baseline information on potentially impacted water resources, surface waters, groundwater, seeps and springs, water quality data, aquatic life, fisheries (populations and habitat) and/or sensitive or protected species such as ESA-listed bull trout and native Weslope cutthroat trout, and more. CFC holds that without this information, the Forest Service cannot evaluate the potential impacts of the project, nor can it determine whether those impacts will be significant enough to require an EIS.  

Following public comment, the mining company withdrew its Draft Plan of Operations with plans to resubmit a revised plan in the near future. CFC expects that the U.S. Critical Materials will take its obligations to protect Montana’s environment seriously and prepare a full, detailed and transparent accounting of their planned exploration activities and the potential environmental impacts for review by the Forest Service. We look forward to reviewing this information once it becomes available.