I am declaring my concern regarding the following in regards to the current proposal for suction dredging regs:
1: Issuing a limited number of annual permits has the potential of denying me of my rights to conduct mining operations on my claims for which I pay annual fee’s/taxes to both the Federal Govt. (BLM) and local County agencies.. It is discriminatory to require me to pay associated liabilities while withholding my right (if I am unable be purchase a permit) to conduct legally granted placer mining operations. Non-claim owners should not be granted priority over valid, taxpaying claim-holders!
2: The hours of operations are extremely limited, especially when compared to the hours allowed for fishermen to conduct their activities. Why not limit fishing and boating to the same restrictions??
3: Campers and boaters are not required to provide fuel containment for their activities on/or/ near waterways, why place this discriminatory requirement only on dredge operations?
4: Once more: you require that dredges be 500′ apart, but have no similar density restrictions on fishermen, rafters, kayak’s, or boats. Will your field agents/wardens be provided with GPS devices (or other means) to enable them to accurately determine the distance between dredges? What will this add to the annual DFG budget?
5: Have you provided cost estimates for the collection, evaluation, and storage of the daily dredging activity logs as proposed? It would appear that a new department within DFG will be required for the proposal!
6: In regards to disturbing riparian vegetation, I am aware of USFS and various Fishing Organizations performing plant eradication along the shores/banks of waterway systems. Why are dredgers being restricted from removing some plants that are naturally removed by extreme spring runoffs (high water events), but yet nothing is done to those who are removing “noxious species”?
7: Rafters and other water activities create as much, if not more, disruption to aquatic-life (frogs, fish, birds) than dredging operations. For instance I have seen rafting/kayakers screaming loudly as they enjoy their activities which often carry them for more than 10 miles down the N. Yuba, and American rivers. Dredgers are very localized and do not disturb native species for a multitude of miles!
I could enumerate many more issues, however, I truly believe that no attention will be given even the few I have expressed above! It is obvious that the Commission charged with proposing new Dredging Regulations has no interest in a fair and unbiased set of regulations!
Retired School Teacher/District Superintendent Claim-holder and Dredger of 35+ years Responsible Tax-paying Citizen