Mining in National Parks and Wilderness Areas: Policy, Rules, Activity
Duane A. Thompson
Analyst in Energy and Minerals Policy
Environment and Natural Resources Policy Division

February 12, 1996

96-161 ENR
SUMMARY
The National Park Service and other agencies are responsible for protecting and preserving national parks and wilderness areas, while recognizing and accommodating mineral exploration and development. Although there has been some omnibus legislation enacted that provides uniform standards for use, many units are also protected by site specific provisions in their enacting legislation. These provisions are typically designed to meet the needs of a particular unit and protect its unique, often fragile, and irreplaceable features. This report provides a brief explanation how these conflicting and often intractable land use policies evolved. It provides a background on the general laws establishing national parks and wildernesses. Finally, it offers more detailed information on restrictions for mineral exploration and development applied to specific park and wilderness units.
Although the National Park Service and other agencies managing wilderness areas cannot deny access to mining claims by those having valid existing rights, they have authority to regulate development to control the impact on park, recreational, or wilderness values. Data show that 33 of 368 National Park System units have at least one mineral development activity occurring on them; at least 817 operations are ongoing, including 15 hardrock metals (primarily gold), 28 for sand, gravel, soil and similar substances, and 709 for nonfederal oil and gas. Conversely, available data suggests that there are no on-going mining operations in currently designated wilderness areas.
INTRODUCTION
Since the establishment of the National Park and National Wilderness Preservation Systems, agencies of the Federal Government have faced the formidable task of reconciling two allowed, but fundamentally incompatible activities--hardrock mining and preserving lands as essentially untouched by development. Mining, usually involves major disturbance and sometimes permanent change of the environment, while management of national parks and wilderness areas seeks to minimize disruption of landscapes and wildlife habitats.
The competing demands for mineral extraction and land preservation/recreation have led to some of the more difficult and complex resource decisions faced by Federal policymakers. Today, vast highly-mineralized areas of the western United States, once coveted largely for their precious metals, are also highly regarded for their unique aesthetic values, habitats for endangered and other species, recreational use, or opportunity for solitude. Ironically, some of these areas are historic mining districts, that provided the raw materials for the industrial revolution in the mid-1800's. In many instances, servicing these mines stimulated the construction of railroads that later served the growing agricultural and commercial sectors of the Midwest and the Great Plains. More recently, however, the demand for raw materials and minerals to supply industrial needs has had to compete with or been supplanted by the demand for more recreational space, and the protection of woodlands and wildlife.
BACKGROUND ON MINING AND PUBLIC LANDS
Historically, a major incentive for the private sector to invest in mineral development originated with the Mining Law of 1866, which declared all mineral lands of the public domain open to exploration and occupation. The 1866 Mining Law was superseded by the now greatly debated General Mining Law of 1872. The concepts of conveying rights and land title, contained in the earlier Act, were generally included, but expanded by the 1872 Mining Law. The Law states that:
...except as otherwise provided, all valuable mineral deposits in lands belonging to the United States, both surveyed and unsurveyed, shall be free and open to exploration and purchase, by citizens of the United States and those who have declared their intention to become such.
Individuals were assured exclusive rights to develop a mineral deposit upon location and establishment of value, and to profit solely from any development. In addition to mineral ownership passing to the claimant, the Mining Law contained provisions for title to the land (surface as well as subsurface) to pass to private hands as a "land patent." A claimant who has expended $500 worth of labor or improvement on a claim may apply for a patent and take title upon payment of either $5 or $2.50/acre depending on the type of claim--lode or placer, respectively. Other than requiring $100 annual expenditures (including value of work accomplished) by the claimant (to establish intent to develop) and assessing filing fees, the Federal Government did not participate in any profits from mineral development under the Mining Law. No royalties are paid to the Federal Government.
The 1872 Mining Law did, however, differ from the earlier law by including the clause "except as otherwise provided," which expressly left the door open for subsequent limitations on mineral exploration and development. This language may have been a recognition by Congress that certain geological and geographical sites were so unique, fragile, and irreplaceable that they might be protected from any type of degradation, including mineral exploration and development. Only a few months earlier in 1872 Congress enacted legislation creating the first and one of our most magnificent national parks--Yellowstone.
The 1872 mineral disposal framework applied to virtually all minerals on Federal lands until 1920, when oil, natural gas, coal, and certain other bedded, defense related minerals were removed from location and patent laws and placed under a leasing system that required royalty payments to the Government.
The provisions of the early mining laws have led to litigation on many issues over the years. There is a substantial body of case law intended to interpret what originally may have been considered "simple" provisions and their application. Courts have been required to rule on such concepts as: the value and marketability of a mineral deposit; extra-lateral rights of a claimant or patentee; and whether a hypothetically "prudent man" would develop the ore body. For its part, when creating conservation areas, Congress has usually protected "valid existing rights." Determining what these are and reconciling mining with the laws establishing and protecting national parks and wilderness areas has been challenging, particularly with an almost infinite combination of geographic and legal circumstances associated with discovering, claiming, and patenting specific mineral deposits. Although legislative proposals have been introduced to clarify some of these issues, Congress, for the most part, has allowed the provisions of the laws to be interpreted through regulations and court decisions.
NATIONAL PARKS
From the very beginning, the national parks were established for current recreation and educational use while protecting them for the future. According to the Department of the Interior:
Congress charged the national Park Service (NPS) with the responsibility of managing the various units that comprise the national Park System so as to preserve and protect the resources and values of those units for current and future generations.
To achieve this goal of protection, the NPS has a number of management tools at its disposal. These include prohibiting certain activities, regulating activities to reduce their adverse effects, and purchasing private lands and/or mineral rights to prevent the onset of such activities. Consistent with the Park Service's mandate, when most park units are created, the lands are withdrawn from mineral entry at that time.
However, the value of a park or wilderness, particularly in the West with its dry air and distant vistas, may be affected by the lands beyond the area's boundaries. Federal efforts to preserve the unspoiled nature of an area may be affected by activities including mineral development on adjacent or nearby lands over which the NPS or other Federal agencies have little direct control, absent acquisition or condemnation of the lands--an often lengthy and expensive process.
An example of land acquisition to protect park values has occurred at a nearby unit. While standing on a rock outcrop at Harpers Ferry, Thomas Jefferson remarked that the view was worth crossing an ocean to see. Consequently, the Harpers Ferry National Historic Park has sought to acquire property rights, whether full title or scenic easement, to all lands within eyesight of "Jefferson Rock," some of which are several miles distant, to prevent commercial and residential development that arguably would destroy the scenic view.
Buffer zones have occasionally been proposed in which development activities that would detract from the aesthetic or natural values of an area could be either restricted or prevented altogether. This concept is very controversial and no legislation directly authorizing buffer zones has been enacted.
Typically, lands within the National Park System have been withdrawn from new mineral entry or location. However, many of the national parks and monuments were established with ongoing mining operations or other valid existing rights. Such rights may permit the holder to explore on or develop minerals in a claim or on patented lands, within park boundaries. A valid existing right may also exist in situations where privately-owned minerals underlie a federally-owned surface--the so-called "split estate." Holders of valid claims and patents may exercise their rights to develop the minerals, "subject to such regulations prescribed by the Secretary of the Interior as he deems necessary or desirable for the preservation and management of those areas." According to the Bureau of Land Management (BLM), the location of a claim inside a park unit does not invalidate the right to go to patent. The BLM is only concerned whether the applicant has met the tests (marketability, etc.) to go to patent, first at the time the park is established and second, at the time application for patent is made.
In 1976, Congress enacted the "Mining in Parks Act" (P.L. No. 94-429, 16 U.S.C. 1901 et seq). This Act found and established as a matter of policy that, because of changes in mining technology, the continued application of the mining laws to areas of the National Park System conflicts with the purposes for which they were established and that all mining operations in areas of the National Park System should be conducted to prevent and minimize damage. The exercise of valid existing mineral rights on both patented or unpatented mining claims in System units was made subject to regulations the Secretary of the Interior deems "necessary or desirable for the preservation and management" of those areas. The ability to regulate mining varies, depending on the nature of the mining rights--generally there is less Federal control over lands fully owned by private parties than over unpatented mining claims.
The Act also required the recording of outstanding mining claims within System units and established a presumption of abandonment for claims that were not recorded. The payment of compensation was authorized for any owner found by a court to have suffered a taking of property compensable under the Constitution. However, according to the Geologic Resources Division of the National Park Service, recorded claims are presumed to be valid unless they are invalidated at either the time the park unit is established, or the time of the patent application. The Resources Division estimated total unpatented claims at 12,428 as of January 1995. In addition to this large number of unpatented claims, the Park System also contains 746 valid mineral patents.
Largely because of valid mineral rights existing when the NPS units were created, mining occurs in some national parks. The general mining regulations for national parks are contained in Title 36, Part 9, Subpart A (Mining and Mining Claims) and Subpart B (Nonfederal Oil and Gas Rights) of the Code of Federal Regulations (C.F.R.). Subpart A regulations cover a broad range of topics including, but not limited to: access permits (§9.3); surface disturbance moratorium (§9.4); recordation of mining claims (§9.5); transfer of interests (§9.6); assessment work (§9.7); use of water (§9.8); plan of [mining] operation (§9.9); plan approval (§9.10); reclamation requirements (§9.11); supplementation or revision of plan of operations (§9.12); performance bonds (§9.13); appeals (§9.14); use of roads by commercial vehicles (§9.15); penalties (§9.16); public inspection of documents (§9.17); and surface use and patent restrictions (§9.18). Subpart B. (Nonfederal Oil and Gas Rights) contains provisions similar to those above plus requirements unique to oil and gas well safety and proper disposal of well wastes.
The following table 1 lists national park units that have special mineral provisions, identifies relevant regulations for mining in the parks, and provides the most recent available information on the status of mining in the listed areas. It shows that 33 of 368 National Park System units have at least one mining activity occurring on them; at least 817 operations are ongoing, including 15 hardrock metals (primarily gold), 28 for sand, gravel, soil and similar substances, and 709 for nonfederal oil and gas.
Table 1. National Park System Units with Special Mineral Provisions
Name Special Provisions On-going Operations 
Bering Land Bridge NP, Alaska Part 9; Subparts A & B  5 (gold) 
Kenai Fjords NP, Alaska  ditto (do)  1 (gold) 
Cape Krusenstern NM, Alaska  do  1 (sand and gravel) 
Lake Clark NP, Alaska  do 1 (gold) 
Wrangell-St. Elias NP, Alaska  do  2 (gold) 
Gauley River NRA, W. Va.  do  11 (nonfederal oil and gas) 
New River Gorge NR, W. Va.  do  1 (coal); 2 (nonfederal oil and gas) 
Upper Delaware, New York  do  5 (sand and gravel) 
Cuyahoga Valley NRA, Ohio do 1 (clay)
Hopewell Culture NHP, Ohio do  1 (sand and gravel) 
Saint Croix NSR, Wisc.  do  5 (sand and gravel)
Acadia NP, Maine do 1 (sand and gravel)
Lake Chelan NRA, Washington do  3 (sand and gravel) 
Ross Lake NRA, Washington do 3 (sand and gravel); 1 (topsoil) 
Curecanti NRA, Colorado  do 1 (decomposed granite) 
Big Cypress NPr, Florida  do  30 (nonfederal oil and gas) 
Big South Fork NR&RA, Tennessee  do  210 (nonfederal oil and gas) 
Chattahoochee River NRA, Georgia do  2 (sand and gravel) 
Obed Wild and Scenic River, Tennessee  do  2 (undisclosed); 244 (nonfederal oil and gas) 
Alibates Flint Quarries NM, Texas do 1 (nonfederal oil and gas) 
Aztec Ruins NM, New Mexico  do  3 (nonfederal oil and gas) 
Big Thicket NP, Texas  do  2 (sand); 15 (nonfederal oil and gas) 
EI Malpais NM, New Mexico  do  1 (cinder) 
Hot Springs NP, Arkansas  do 1 (novaculite) 
Jean Lafitte NGP & Pr, Louisiana  do 1 (nonfederal oil and gas) 
Lake Meredith NRA, Texas  do 180 (nonfederal oil and gas)
Padre Island NS, Texas  CFR §7.75(h)--Mineral exploration and extraction. Regulations for the scope of mineral extraction, exercise of nonfederal and gas rights, and applicability of state laws. 14 (nonfederal oil and gas) 
Poverty Point NM, Louisiana Part 9; Subparts A & B  12 (nonfederal oil and gas) 
Salinas Pueble Mission NM, New Mexico do  1 (stone) 
Death Valley NP, California/Nevada  CFR §7.26(a) through (e)--Limits claims mining purposes only, provides restrictions for road construction and water use.  1 (borax); 1 (gold). 20 (unspecified) 
Joshua Tree NP, California  Part 9; Subparts A & B 1 (garnet and epkidote);
4 (precious metals) 
Mojave NPr. California do 28 (unspecified) 
Saguaro NP, Arizona do 1 (wulfenite and gold)
WILDERNESS AREAS
The Wilderness Act created the National Wilderness Preservation System n 1964, set out appropriate management direction, and was the first of many laws (total of 117 laws from 1964 through 1995) designating wilderness areas. The 1964 Act included a general policy statement for the use of designated wilderness areas: (8)
In order to assure that an increasing population, accompanied by expanding settlement and growing mechanization, does not occupy and modify all areas within the United States and its possessions, leaving no lands designated for preservation and protection in their natural condition, it is hereby declared to be the policy of the Congress to secure for the American people of present and future generations the benefits of an enduring resource of wilderness.
Unlike national park lands, which are exclusively under the jurisdiction of he National Park Service in the Department of the Interior, wilderness areas, as stated in the Act, "shall continue to be managed by the Department and agency having jurisdiction thereover immediately before its inclusion in the National Wilderness Preservation System...." Consequently, lands in the wilderness system can be administered by Departments other than Interior (e.g., he Department of Agriculture, in the case of wilderness areas under the auspices of the Forest Service) and by other agencies within the Interior department (e.g., the U.S. Fish and Wildlife Service and the Bureau of Land Management). A brief list of some of the major legislation expanding the wilderness system is contained in the table below. Many other statutes have designated wilderness areas.
Table 2. Major Wilderness Laws Title Public Law # Date Brief Description of Major Provisions
Title Public Law # Date Brief Description of Major Provisions
The Wilderness Act P.L. 88-577 1964.00 defined wilderness for purpose of establishing and maintaining the Nat 'l Wilderness Preservation Sys (NWPS). specified that only Congress had authority to designate future wilderness areas.
required study of certain Forest Service, NPS, and national wildlife refuge lands.
special prov. allowed for mining on valid claims and mineral development on leases established before Dec.. 31, 1983
 
Eastern Wilderness Act P.L. 93-622 1975.00 added 16 wildernesses in the East, implicitly easing the standards for areas in the East
designated roadless areas in the East should be included and managed as part of the NWPS
 
Federal Land Policy and Management Act P.L. 94-579 1976.00 the Bureau of Land Management joined the Forest Service. NPS. and Fish and Wildlife Service as a partner in wilderness review and management
existing loses such as mining, mineral leasing...permitted to continue in study areas subject to regulations set by the Secretary of the Interior.
 
Endangered American Wilderness Act P.L. 95-237 1978.00 added 16 areas to the NWPS
criteria for assignment changed to encourage the establishment of wilderness areas near large cities even though some of these areas had previously been influenced by man
 
Alaska National Interest Lands Conservation Act (ANILCA) P.L. 96-487 1980.00 added 56 million acres to the NAPS (most in units of the NPS and the National Wildlife Refuge System), nearby tripling total acreage
vast areas were authorized for further study
use of certain vehicles authorized and wilderness cabins to be maintained with some new cabins added
 
Colorado Wilderness Act P.L. 96-560 1980.00 set guidelines for livestock grazing in all national forest wildernesses
prohibited establishment of buffer zones around wildernesses provided for release of remaining wilderness study areas to traditional management planning and uses
Generally, Congress permitted mineral-related activities in designated wilderness areas for 20 years following the enactment of the Wilderness Act in 1964. During that period, new mineral rights could be established. However, following December 31, 1983, new mineral rights could no longer be established, although Congress did permit prospecting in designated wilderness areas. Valid existing mineral rights, some of which may have been established during the 20-year grace period, may still be exercised and developed in designated areas, subject to reasonable regulations to protect the wilderness character of the lands.
Some literature asserts that mining in wilderness areas is an extremely complex legal issue, and that regulating exploration and mining activities is site-specific. Maintaining the unspoiled character of wilderness can be especially confounded in the East, where the mineral estate has often been split from the surface estate. Although the surface of a wilderness may be under the authority of a particular agency, the subsurface rights may have been severed and reside in private ownership. In these instances, a question of access for mineral development often arises. The Federal agencies generally cannot deny access to privately held mineral estate, but can regulate mineral activities to varying degrees.
Congress has generally pursued a situational approach and has adopted several approaches to mineral development. Congress has sought either to accommodate mineral development by drawing the boundaries of the wilderness to exclude highly-mineralized, potentially-developable areas or to avoid development by acquiring mining rights through purchase or exchange. The following Table 3. identifies wilderness areas and/or laws that contain special provisions on mining. As noted, no ongoing mining operations are currently occurring in wilderness areas.
Table 3. Wilderness Areas with Special Mining Provisions
Name Special Provisions
River of No Return Wilderness
The Central Idaho Wilderness Act of 1980,
P.L. 96-312
Prospecting, exploration and development of mining of cobalt and associated minerals in the Clear Creek Special Mining Management Zone of the River of No Return Wilderness shall be permitted beyond the December 31, 1983 deadline, subject to regulations.
San Rafael Wilderness
P.L. 90-271
Wilderness Act of 1964.
San Gabriel Wilderness
P.L. 90-318
Wilderness Act of 1964.
Sawtooth National Recreation Area,
P.L. 92-400
The Secretary may acquire mineral interests in lands within the recreation area (which includes the wilderness) with or without the consent of the owner. Subject to valid existing rights, all federal entry, and patent under the U.S. mining law.
Hells Canyon National Recreation Area,
P.L. 94-199
do.
The Endangered American Wilderness Act of 1978,
P.L. 95-237
Extends the mineral exploration, patenting, and development period for the Gospel-Hump Wilderness from December 31, 1983, to December 31, 1988.
Boundary Waters Canoe Area Wilderness,
P.L. 95-495
No mining of minerals owned by the U.S. is permitted; no exploration or mining of nonfederal minerals is permitted if such action would adversely affect navigable waters. The Secretary may acquire minerals and mineral rights owned by the private sector. Specific guidelines are provided for any mining activity or acquisition of minerals rights.
The Alaska National Interest Lands Conservation Act,
P.L. 96-487
(Misty Fjords National Monument Wilderness) The Secretary of Agriculture shall allow installation, maintenance, and use of navigation aids, docking facilities, and staging and transfer facilities associated with the development of the mineral deposit at Quartz Hill. Such activities shall not include mineral extraction, milling. or processing
Monongahela National Forest,
P.L. 97-466
(a) Exploration activities, including core drilling and use of mechanized ground equipment, is allowed in the Cranberry Wilderness to determine the value of the nonfederally owned mineral resources there, under regulations set by the Secretary of agriculture. (b) The Secretary of the Interior is directed to acquire nonfederal owned coal deposits and other minerals interests and rights within the Cranberry Wilderness, and such interests and rights outside the wilderness according to certain requirements Guidelines are provided for the acquisition of these mineral interests and rights.
The Vermont Wilderness Act,
P.L. 98-322
All federally-owned lands within the White Rocks National Recreation Area Which includes portions of the big Branch and Peru Peak Wildernesses) are withdrawn from all forms of appropriation under the mineral and geothermal leasing laws.
California Wilderness Act of 1984,
P.L. 98-425
Various sites within California. Mineral prospecting, exploration, development, and mining are permitted in the North Fork Smith Roadless Area under laws applicable to nonwilderness national forest lands.
The Florida Wilderness Act of 1984,
P.L. 98-430
Specifies that phosphate leases shall not be permitted on Osceola National Forest (which includes the Big Gum Swamp Wilderness) unless:
  1. the President defines need;
  2. there is a procedure for public input;
  3. the President specifies impacts;
  4. the President specifies conditions and stipulations to govern any mining activity;
  5. Congress approves the President's recommendation by joint resolution.
The Wyoming Wilderness Act of 1984,
P.L. 98-550
Oil and gas exploration and development activities on the Palisades Wilderness Study Areas shall be administered under reasonable conditions to protect the environment under regulations and laws generally applicable to nonwilderness lands. Subject to valid misting rights, the Palisades Wilderness Study Area is withdrawn from all forms of appropriation under the mining laws.
The Pennsylvania Wilderness Act of 1984,
P.L. 98-585
The Secretary of Agriculture is authorized to acquire land, including oil, gas, and mineral interests or scenic easements, within the wildernesses by various means.
Arizona Desert Wilderness Act of 1990,
P.L. 101-628
Private mineral rights within wilderness areas designated by this tie be acquired as expeditiously as possible by the Secretary using existing authority to acquire such rights by exchange.
Los Padres Condor Range and River Protection Act,
P.L. 102-301
(a) Subject to valid existing rights, federal owned lands depicted a map entitled "Mineral Withdrawal Area, California Coastal Zone, Big Sur--Proposed are general withdrawn from mineral entry. (b) Subject to valid existing rights, all mining claims located within the withdrawal area shall be subject to such regulations as the Secretary of Agriculture may prescribe to ensure that mining will be consistent with the protection of scenic, scientific, cultural, and other resources of the area. In instances where a land patent is issued following the date of enactment only title to the minerals will be conveyed.
El Malpais National Monument,
P.L. 100-225
Section 504 provides for the Secretary of the Interior to exchange Federal mineral interests for private mineral interests--both described in detail within the section.
Washington Park Wilderness Act of 1988,
P.L. 100-688
Subject to valid existing rights, the lands within recreation areas are withdrawn from...disposal...under the United States mining laws, and disposition under the United States mineral leasing laws: Provided, however, That within that portion of the Lake Chelan National Recreation Area which is not designated as wilderness, salad, rock and gravel may be made available for sale to the residents of Stehekin for local use....
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