If you have any feedback on how we can make our new website better please do contact us and we would like to hear from you.
Patrick Russell President of 

VA Council 259

8th District Representative for Minnesota, North Dakota, Iowa,
Nebraska and South Dakota.

I am President of the American Federation of Government Employees (AFGE) Local 1539 representing professional and non-professional employees at the Hot Springs, South Dakota Veterans Administration Hospital.

Help Requested from All AFGE Activists and Veterans to Stop the Closure of the Hot Springs VA

From Patrick Russell, President AFGE Local 1539, Hot Springs, SD

Environmental Impact Statement

Most Environmental Impact Statements fail because the public did not respond during the Public Comment Period. It is imperative that we get as many responses as we can during the open period (May 16 to June 16th).




The director of the Hot Springs VA announced on December 12, 2011 that the VA wants to close the Hot Springs VA hospital, move the domiciliary to Rapid City, South Dakota and build or lease an outpatient clinic in Hot Springs. The plans call for building a new 100-bed facility in Rapid City. The Hot Springs dom currently houses 100 veterans and could house more if necessary. At one time the domiciliary in Hot Spring housed 450 domiciliary patients. The VA plans call for spending almost $100 million of our tax money to build something they already have in Hot Springs.


The Hot Springs Save the VA Committee has consistently exposed agency errors in the data they have used to justify the move. The bottom line of the entire proposal for the VA is to outsource veteran care to the private sector. Their plan does not take into consideration the impact on rural veterans from the pan handle of Nebraska, the veterans living on the Pine Ridge and Rosebud Indian reservations or the veterans from eastern Wyoming. These veterans have voiced their support of the Hot Springs VA.


On May 14th  the Veterans Administration announced the awarding of a contract to Labat Environmental from Bellevue, Nebraska to conduct studies as required by the National Environmental Policy Act (NEPA) to include an Environmental Impact Statement (EIS). On May 16th  the VA announced the opening of a thirty day comment period for citizens to provide input for the EIS. After this comment period closes on June 16th citizens will not be allowed to have their say.

National Environmental Policy Act (NEPA)

The National Environmental Policy Act (NEPA) requires federal agencies to integrate environmental values into their decision making processes by considering the environmental impacts of their proposed actions and reasonable alternatives to those actions.

To meet NEPA requirements federal agencies prepare a detailed statement known as an Environmental Impact Statement (EIS). EPA reviews and comments on EISs prepared by other federal agencies, maintains a national filing system for all EISs, and assures that its own actions comply with NEPA.

Filing an EIS--Draft, Final and Supplemental

Federal agencies are required to prepare Environmental Impact Statements (EIS) in accordance with Section 1502 of the Council on Environmental Quality (CEQ) Regulations for Implementing The Provisions Of The National Environmental Policy Act. Federal agencies are also required to file EISs with EPA as specified in 1506.9 of the CEQ Regulations. The EISs must be filed no earlier than they are transmitted to commenting agencies and made available to the public. This will assure that the EIS is received by all interested parties by the time the EPA Notice of Availability appears in the Federal Register, and therefore allows for the full minimum review periods prescribed in 1506.10.

EPA amended the EIS Filing System Guidelines (PDF) (3 pp, 202K About PDF) on August 24, 2012. Federal agencies file an EIS by submitting the document with e-nepa, including appendices. In addition to the EIS filed with EPA Headquarters, agencies should provide a paper copy of the EIS directly to the appropriate EPA Regional Office(s) for review and comment. Material which is incorporated into the EIS by reference is not required to be filed with EPA.

Once received by EPA, each EIS is given an official filing date and checked for completeness and compliance with 1502.10 of the CEQ Regulations. If the EIS is not “complete” (i.e., if the documents do not contain those elements outlined in 1502.10 of the CEQ Regulations), EPA will contact the lead agency to obtain the omitted information or to resolve any problems prior to publication of the Notice of Availability in the Federal Register.


The EIS is a statement of any social, economic or environmental issues that result from an agency action. Taxpayers have a right to comment because their money is being used to construct something we already have. Veterans have a right to comment because their care will be compromised. Family members of veterans have a right to comment because of the impact on loved ones. Land owners have a right to comment because of the impact on property taxes and resale values. Business owners have a right to comment because of the economic impact on their businesses. Minority groups have a right to comment because of hardship in traveling longer distances for treatment.


The closing of the Hot Springs VA hospital and moving the domiciliary to Rapid City affects access to care for rural veterans. Many of the former Post Traumatic Stress Disorder (PTSD) and substance abuse patients have commented on the role the Hot Springs VA played in their recovery. One of the components of the Save the VA proposal is a demonstration project to compare the success rates of recovery in a rural versus urban setting. The VA does not have adequate data available to show any improvement in care by providing services in an urban setting. The feeling of the Save the VA Committee is that an urban area provides more temptations for recovering veterans and the chances of relapse are greater.


At a time when the Veterans Administration is under investigation for issues dealing with waiting lists and access, it is incredulous that they would want to eliminate an access point for rural veterans. The VA, and many of our politicians, are saying that the answer is to outsource veterans’ care to the private sector.  It is our opinion that the private sector is not prepared to handle issues related to traumatic brain injury (TBI), post-traumatic stress disorder (PTSD), military sexual trauma (MST) and Agent Orange. At a VA hospital providers are trained to treat a specific patient population. The issues and patient demographics are more well defined for our military veterans. When our veterans go to private sector hospitals they will be told to take a number and wait in line. Veterans are telling the VA and our politicians that they want to continue getting their treatment in VA Hospitals and clinics.


We are asking all concerned citizens, Union Brothers and Sisters and veterans to supply input to support the Hot Springs VA and rural veterans. ANY CITIZEN CAN COMMENT ON THE PROPOSAL! Go to:


Environmental Impact Statements; Availability, etc.: Black Hills Health Care System Proposed Improvements and Reconfiguration, Hot Springs and Rapid City, SD; FR Doc. #2014-11316



With the publication of this notice, VA is initiating the scoping process to identify issues and concerns to be addressed in the integrated EIS. Federal, state, and local agencies, environmental organizations, businesses, other interested parties and the general public are encouraged to submit their written comments identifying specific issues or topics of environmental concern that should be addressed. VA will hold two or more public scoping meetings within the VA BHHCS service area; the dates, times, and locations of which will be announced and published at least 14 days prior to the meetings. All written comments on the proposal should be submitted by June 16, 2014. VA will consider all comments received during the 30-day public comment period in determining the scope of the integrated EIS.



Submit written comments on VA's notice of intent to prepare an integrated EIS through Regulations.gov or vablackhillsfuture@va.gov. Please refer to: “VA BHHCS Notice of Intent to Prepare an Integrated EIS”. Comments may also be submitted to


Staff Assistant to the Director

VA Black Hills Health Care System

113 Comanche Rd

Fort Meade, SD 57741


For Further Information Contact

Staff Assistant to the Director, VA BHHCS, at the address above or by telephone, 605-720-7170. Documents related to the VA BHHCS proposed reconfiguration will be available for viewing on the VA BHHCS Web site: http://www.blackhills.va.gov/VABlackHillsFuture/ . Caution: These are management documents and some have already been proven to be inaccurate such as the number of veterans in the catchment area (VA ‘forgot’ to include 7,000 veterans from the Scottsbluff, NE area), the anticipated need for mental health services and the capacity for the private sector to meet an unexpected influx of veterans to community health system.


For  current updates on the status from the community group please go to the SAVE THE VA website. Much of the information there will provide a history of our campaign and documentation from community workgroups that reinforce our claims that we can provide more comprehensive care to our nation’s heroes.

The Proposal


As the work groups progressed it became apparent that the effort was bigger than saving one community.  It was ultimately about conflicting visions of care for our nation’s veterans.  It was also about the importance of providing care for rural veterans.  Veterans care facilities were first placed in rural locations such as Hot Springs because of the quiet and caring environment.  More and more the country is seeing veterans care relocated and consolidated in urban centers.  The campaign questioned whether urban settings were appropriate for many veterans suffering from PTSD and substance abuse problems.  The campaign learned from many rural veterans how important the Hot Springs facility has been to their care.  Finally, the campaign further questioned the overall economic impact such consolidation had for rural communities with long traditions of serving veterans.  Hot Springs certainly was not the first rural community to be threatened, and all indications were it wouldn’t be the last.


Therefore the vision of the campaign grew.  It grew beyond only Hot Springs and the veterans within the catchment area.  Although both the community and service for regional veterans remains at the core of the campaign, the mission grew to encompass a larger purpose.  And that purpose was to address several questions:


·         Can services be provided in a rural location like Hot Springs using strategies that can result in cost savings for the system?

·         Can a partnership be created between the VA system and a community like Hot Springs that can impact both the quality of veterans care as well as having a positive impact on community revitalization?

·         Could Hot Springs serve as a demonstration model for veterans services provided in rural settings across the country?


So, the concept grew from a local concern, to a national concern.  The concept of a counter proposal grew from addressing only the local issues but also national issues.  The focus grew from simply a counter proposal to a national demonstration project that would address these and many more questions with the results helping to serve as a blueprint for rural veteran’s health care for years into the future.


The complete Save the VA proposal for a National Demonstration Project at the VA in Hot Springs can be read here: National Demonstration Project Proposal.


A collection of each of the committee's white papers, the collection of data upon which this proposal is founded, can be found here: Proposal Appendices.

Comments from the Appendices

These are excerpts from the white papers written by citizen volunteers of the community workgroups. Many of their observations directly contradict what the VA has used to justify their plans to close the Hot Springs VA and move the domiciliary to Rapid City.

Appendix A: Fall River Hospital Committee White Paper

Discussion of VA’s official public contacts and of FRHS board’s contacts with VA officials is as follows:

In summary, the contents of the proposal presented by the local VA and VISN leadership on December 12, 2011 came as a surprise to the board of directors of Fall River Health Services who, despite the fact that the VA chose to publicly suggest some type of collaboration with FRHS, had no prior knowledge of such a plan. To date, any suggestions or proposals made directly by the VA to FRHS have been very vague, at best—lacking any detail or sense of a business plan. Despite The VA Director’s public mention of “building a wing” or “co-locating” at FRH, the FRHS board has never publicly or privately encouraged or responded, feeling, rather, that it is very unlikely that such an idea is feasible.

Discussion of general differences between veteran care in a private hospital, such as Fall River Hospital (FRH), and care provided by a VA facility, including discussion of unique challenges confronting veterans and those providing their care, is as follows:

In summary, health issues of veterans are often complex and unique when compared to the general population. Typically, non-VA medical personnel, including physicians and other professional staff, lack the knowledge, training, and experience needed to navigate the VA bureaucracy and its regulations. Without this knowledge, veterans do not receive all the benefits they have earned, nor the specific health care they deserve.

Comparison of services provided at FRHS and the HSVA is as follows:

In summary, the following are vital services that FRHS does not provide: mental health services (including suicide prevention program), pharmacy consultation services, prosthetics, audiology, optometry, fluoroscopy, nuclear medicine (including nuclear stress testing), nephrology, urology, ENT, full-time podiatry, dentistry, routine alcohol and drug detoxification, on-site social work services, dialysis, chronic disease management, and home-based primary care program. Additionally, FRHS has no medical library or on-site security service or fire station. It is also quite likely that other small community hospitals that the VA would be “purchasing care” from would not have these services available to veterans.

Discussion of charges for inpatient care at FRH is as follows:

In summary, Fall River Hospital is a federally certified Critical Access Hospital and, as such, utilizes charges predicated on a cost-based system. To date, the board of directors of Fall River Health Services has received no reimbursement proposals, cost analysis, needs assessments, or business plan from the VA that would permit initiation of contract negotiations for delivery of inpatient care to veterans at Fall River Hospital.

Results of research of various VA hospitals, clinics, or programs that have been closed or downsized or targeted for same are as follows:

In summary, then, the initiation, termination, and longevity of contracts involving CBOC and hospital care and personnel are quite unpredictable, without apparent regard for veterans’ needs, and totally at the discretion of the VA.


Comments and suggestions of committee members are as follows:

In summary, it is evident that the promises that VA makes when they initiate downsizing or closure are not fulfilled, resulting in the veterans feeling like second-class citizens. The VA has a history of ending clinic and hospital contracts, without providing local alternatives. In the end, the veteran is left with fewer services being available nearby, and he must travel longer distances to obtain care. Routine admission of veterans to FRH for inpatient services does not appear to be a viable option financially or logistically. The scope of services currently provided veterans hospitalized at the HSVA would not be available at FRH. Veterans prefer care at VA hospitals and clinics. This has been obvious to anyone who has attended any of the community meetings that the VA has held. Health care for veterans is unique, and contract care solely from the private sector is not adequate to meet these needs.

Appendix B: Residential Rehabilitation Treatment Program (RRTP) Physical Plant White Paper

The suggestion to abandon the Hot Springs VA campus is tragic. The domiciliary in particular is a beautiful building with no structural defects. If vacated, the buildings on the Hot Springs VA campus will still have to be maintained to a high degree due to its National Historic Landmark status. If the property is going to have to be maintained anyway, it might as well be modernized and used for the reason it was constructed—serving veterans. Even if the cost to modernize the building costs twice as much as what we estimate, it would still be more cost effective than the plan to move the RRTP to Rapid City.

*Disclaimer: These figures are an estimated guess to the best of our ability.








**Note: This cost savings does not take in account the energy cost savings that would be gained with the installation of better insulation, thermal windows and Liquid Natural Gas. We believe that over the next 30 years the energy savings would be a minimum of $400,000.00 per year totaling a savings of $12,000,000.00


By revitalizing the RRTP, the VA will show its commitment to quality veteran care, providing care where veterans are—many of them being rural, and its own Historic Preservation standards which advocate for using historic buildings. Remodeling the RRTP in its present serene environment will increase the quality of life for veterans, their families, VA employees and the community of Hot Springs.

It is hoped that the VA Administration would see the “gem” that is the Hot Springs VA with its unique architectural plan and sandstone buildings sitting high on a hill overlooking the city.

Most of all, we hope that the VA Administration would move forward with the Save the VA plan which is guided by these considerations, in this order:

§ *What is best for Veterans

§ *What is best for Taxpayers

§ *What follows Federal Law

§ *Impact on VA Employees

§ *Impact on the Community.


Appendix C: Residential Rehabilitation Treatment Programming White Paper

The Residential Rehabilitation Treatment Program (RRTP) in Hot Springs is the primary entry point into a multifaceted mental health rehabilitation continuum of care. While many RRTP’s are single focused programs, i.e., a 28 day Substance Abuse Program, the Hot Springs VA is full service RRTP. This is desirable to many veterans because they are able to address their needs in a comprehensive and holistic manner. Concurrent treatment for multiple mental health and chronic medical conditions is a cost effective method designed to meet the multiple needs of our most at risk veterans.

It is the conclusion of the Save the VA group that the systematic reduction in services to our most needy veterans; the homeless, the Substance Abusers, and the Veterans with PTSD must be stopped. A reconstruction programming to include an appropriate level of staffing and services is clearly indicated.

Urban Versus Rural Residential Rehabilitation

The Rapid City area does not represent the majority demographic of the RRTP in Hot Springs. According to VHA data system, 9% of veterans using the RRTP are from the Rapid City area. Data reflects that 91% of the RRTP veterans of the Hot Springs RRTP are NOT from the Rapid City area, and do NOT relocate in Rapid City on discharge but return to their home area.

Special Emphasis Populations served by the VA Hot Springs RRTP

The RRTP serves several populations which are considered Special Emphasis in the Veterans

Health Administration. These special emphasis populations are:

Homeless Veterans:

ü  23% of the homeless population are veterans

ü  33% of the male homeless population are veterans .

ü  47% served Vietnam-era

ü  33% were stationed in war zone

ü  76% experience alcohol, drug or mental health problems

On a single night in January 2009, the states with the highest estimated share of veterans among their total homeless populations were Kansas (34%), North Dakota (22%), South Dakota (23%) and Wyoming (22%). In these same states, veterans make up a relatively small share of the total population (8, 8, 10 and 9) percent respectively.

Homeless is a result – not a diagnosis. Providing a veteran a bed will not end homelessness. To end homeless one must address and conquer the reasons for becoming homeless. Veterans must be given the opportunity to “stand down”. They must be given the opportunity, time, and resources to heal their soul, to regain their health with nutrition, medical, mental health and dental care, to remain drug and alcohol free, to be a part of a healing community, and to learn the skills needed to live on his/her own. This does not happen in 28 days. The Hot Springs RRTP meets the multiple complex needs of our homeless veterans.

Native American Veterans:

Rural and highly rural Native Americans are drawn to the rural nature of the RRTP in Hot Springs. The facility operates the first sweat lodge ever established on VA grounds. The beauty and peaceful surroundings in Hot Springs are welcoming to the Native American. Moving this facility to an urban area is not in the best interests of our Native American veterans. Travel will be longer, families will be further away, and there will be more negatives influences in Rapid City as evidenced by the high crime rate and number of liquor establishments.

Post Traumatic Stress Disorder:

PTSD is a condition of anxiety and the quest for feeling safe. Failing to use this historic site for mending the wounds of war – as it has done for Spanish American, WWI, WWII, Peacetime, Korean, Viet Nam, and now Gulf War and OEF/OIF veterans is to ignore two aspects of “psychosocial rehab” that of healing the spirit and the mind. This facility provides a basic requirement healing – safety.

Rural and Highly Rural Veterans

Despite greater health care needs, rural Veterans are less likely to access health services for both physical and mental illness either through the VA or the private sector. In particular, rural Veterans have lower access to care for chronic conditions such as hypertension and post-traumatic stress disorder. (VHA Office of Rural Health www.ruralhealth.va.gov)

Appendix D: Inpatient Committee White Paper

We consider the Hot Springs VA a rural health hospital, and offer this summary of what we believe would be an ideal mix of services to enhance and grow the services offered at this facility. While we understand we cannot be all things to all veterans, we truly believe that services and clinics need to be brought back to life at this facility. A 15-year erosion of services, staff, and equipment has occurred as a result of unsuccessful facility integration with the Ft. Meade, SD, and campus.

The Data table below from the Office of Rural Health does not support the statement that there is a demographic shift in urban veterans seeking care in the VA System. If fact, there has been a decrease in unique urban males served by the BHHCS. Further research in the use of non-VA health resources in Rapid City and the availability of alternate health insurance coverage for urban veterans may prove helpful to fully understand the health needs and demands of the Urban Veterans living in Pennington, Meade and Box Butte Counties.



FY 08

FY 09

FY 10

FY 11

% of total Unique (FY 11)


Rural Male






Rural and Highly rural male veterans account for 71% of the BH Unique in FY 11

Highly Rural Male






*Urban Male (Pennington, Meade, Box Butte Counties)







Rural Female






Rural and Highly rural female veterans account for 8% of the BH Unique.

Highly Rural Female






*Urban Female (Pennington & Meade Counties)













Total R & HR = 79%

Total Urban = 21%

Numbers represent Unique veterans

Rural Health Profile dated 1/12/2012   (568 Black Hills)- All Pharmacy only unique excluded

Rural Health Profile dated 1/12/2012   (568 Black Hills)- All Pharmacy only unique excluded


Recruitment We propose that the efforts for long-term career positions include nation-wide advertisement, offers of permanent employment, and enhancing attraction of positions by providing information about education debt-reduction programs and benefits. The argument that professional employees do not want to live in a small town is unsubstantiated.

Patrick Russell

PO Box 307
Hot Springs, SD 57747




  Site Map