March 2, 2012
COUNTY OF SISKIYOU COUNTY ADMINISTRATIVE OFFICE
Ric Costales, Natural Resource Policy Specialist P.O. Box 750 ? 201 Fourth Street, Yreka, CA 96097
Phone: (530) 842-8012, Fax Number: (530) 842-8013 Email: [email protected]
Suction Dredge Program
Revisions to Proposed Amendments Department of Fish and Game, Northern Region 601 Locust Street
Redding, CA 96001
RE: Revisions to the Suction Dredge regulations
To Whom It May Concern:
Siskiyou County has already commented on the Suction Dredge Supplemental Environmental Impact Report (SEIR) on which these proposed regulations are based. It is clear from the proposed changes in the program that the vast majority of Siskiyou County’s SEIR comments (attached) were not addressed in a manner that respects the rights of miners to access their private property in a feasible manner, or any manner whatsoever in the case of small streams of 6 feet or less in width and specially designated cold water refugia areas.
The excessive restraint on operating hours/seasons and numbers of permits issued and the over-reliance on complete closures are all arbitrary and capricious in the face of the preponderance of scientific study that has shown de minimis impact from suction dredging as conducted under the previous regulatory program in California. It is impossible to understand how such a prescriptively oppressive regulatory barrier to legitimate rights inherent to American citizenship can be allowed to stand.
Please revise this program to eliminate the numerous “takings” implications as well as restrictions that render many otherwise viable and environmentally sound operations infeasible (specific examples are included in our attached comments on the SEIR). It will save everyone a lot of time, money and grief. Reasonable compromise in this regard will have no significant effect on the resources for which the Department of Fish and Game is responsible. However, such action will make an important stride in upholding the proper balance that must exist between environmental protection and the fundamental principles that allow America the economic ability to grant the environment such a high societal priority.
Ric Costales, Natural Resource Policy Specialist County of Siskiyou