December - 2009

California Department of Fish & Game
Mark Stopher California Department of Fish and Game
601 Locust Street Redding, CA 96001


Dear Mr. Stopher:

This e-mail is in response to your written invitation to me [as a 2009 suction dredge permit holder] to submit scoping comments regarding the DFG Suction Dredge Permit Program. Specifically, comments were requested as to the range of actions, alternatives, significant environmental effects and mitigation measures to be discussed in the draft Subsequent Environmental Impact Report [SEIR]. I believe the following questions and issues should be addressed in the SEIR:

1. How will objective comparisons of environmental impacts be made between rivers and waterways that [a] involve no active suction dredging and [b] rivers and waterways that do not involve active dredging? For example, there are several rivers and waterways in California that have no history of ever having been significantly dredged due to the well known absence of gold bearing gravels. COMMENT: It is scientifically more reliable and credible when assessing environmental impacts to utilize comparisons BOTH of ecosystems that do not experience the activity to be studied [in this case, suction dredging] with ecosystems that do experience the activity to be studied in order to form a valid opinion.

2. As of August 6th 2009 no suction dredging is lawful in the state of California. What will be the DFG methodology in preparing a SEIR during times that no active suction dredging is lawful in the entire state of California? COMMENT: The DFG SEIR should place greater reliance on data and opinions that in the past were developed prior to the time that suction dredging was made illegal on August 6, 2009. Such data and opinions were gathered in prior EIRs performed by DFG regarding suction dredging when EIR studies had the benefit of actual and measurable observation of the thing being studied [suction dredging].

3. I have personally removed substantial amounts of elemental mercury [Hg] that is amalgamated with some of the gold I have recovered while using a suction dredge in California. This Hg no longer is in the waterways of California and thus not capable of adding to the methyl-mercury levels of those waters. To what extent will the SEIR address the positive environmental impact that Hg removal by suction dredging has on the environment? COMMENT: The prevention of methyl-mercury development by the removal of elemental mercury through the use of suction dredges is environmentally significant and should be addressed in the current SEIR.

4. I personally have removed many pounds of lead, copper, zinc and other heavy metals from California waterways while employing my suction dredge. COMMENT: The SEIR should address the amount of environmental impact that results from the removal of heavy metals by suction dredges from California waterways.

5. I have personally observed spawning salmon fight each other over the privilege of nest building in recently dredged gravel tailings and I have observed them shun silty, mud packed river bottoms. Fish egg parasites and harmful molds thrive in silty, mud choked river beds, but they do not thrive in freshly dredged gravels tailings. COMMENT: The SEIR should address the environmental impact that results from the creation of suction dredge tailing piles and why spawning salmon are intuitively attracted to them.

6. I personally dredge down to bedrock while suction dredging for gold nuggets and flakes because this is where the gold pay streaks typically are most prevalent. In the course of removing the strong layers of cemented gravels that were formed from the hydraulic mining clays of the 19th century, I noticed that fish and other forms of aquatic life, especially during the hot summer months, congregated at the bottoms of these holes even AFTER I removed my suction dredge. It occurs to me that the water temperature at the bottom of these holes is lower than that of the ambient river water. This, in turn, likely is due to the removal of those tough, cemented gravels which no longer can choke off the seepage of cold artesian water from the bedrocks cracks and crevices thus exposed. COMMENT: The SEIR should address the environmental impact that dredge holes provide by providing thermal refugia for aquatic life during the hot summer months.

7. It is well established that a healthy river bottom is well oxygenated. Suction dredges dissolve much oxygenation into the waters where they are deployed by bringing oxygen depleted water in direct contact with the atmosphere. COMMENT: The SEIR should address the positive impact that suction dredges create by dissolving badly needed oxygen into the rivers of California, especially during the hot summer months when river water is less able to hold dissolved oxygen due to increased heat.

8. I have personally observed migrating salmon utilize deep dredge holes as rest areas. COMMENT: The SEIR should address the environmental impact to migrating salmon that suction dredges provide by the creation of deep dredge holes all along the length of salmon habitat rivers.

9. It is common knowledge that both the periodic release of water from dams during the summer and the release of water by summer monsoon rain storms create vast amounts of turbidity up and down the entire length of a river for days at a time. This is so because in each of those cases water volume is increased throughout the river. Increased water volume, in turn, increases water pressure which, in turn, increases water velocity which, in turn, is the cause of massive turbidity in California river systems. Dredging, on the other hand, does not add any water to the river, cannot increase water pressure throughout the river and cannot increase water velocity throughout the river and is entirely localized for short periods of time. COMMENT: The SEIR should address the localized significance of river turbidity generated by suction dredging in comparison to the total and enduring turbidity caused by the large scale release of dam water and natural rainfall.

10. I am a law abiding small scale prospector who is deeply committed to a healthy California water environment. To what extent does DFG publicize that it has tribal partners, but not suction dredge partners, in helping to improve the California natural river environments? Why is this so? Is there a place in this quest for small scale suction dredgers such as myself and my wife [ages 67 and 61 respectively]? COMMENT: The SEIR should address a range of actions that INCLUDE rather than EXCLUDE small scale suction dredge operators, particularly in light of a suction dredge operator's potential to contribute positively to the water quality of California.

Thank you for considering these comments.

Martin H. Milas - President
The Prospector's Club of So. Calif. Inc.













Home Page

Copyright 2000-2013 PCSC