2012 B.W. Letter

Mark Stopher

California Dept of Fish and Game

Northern Region

Suction Dredge Program

601 Locust Street

Redding, CA 96001

Re: Suction Dredge Regulations Revisions

Dear Mr. Stopher,

Thank you for accepting my comments in this matter. I know that you and your staff have worked hard to comply with the Alameda Court Order to revise the suction dredge regulations.

However I must oppose the Revised Regulations on the grounds that they are biased against suction dredging due to a lack of peer reviewed scientific data for their basis. The proven studies on dredging that are on record indicate a “de minimus” effect on the environment, meaning that the effects are so small that they cannot be measured. In reviewing the Proposed Regulations I find that a total of 615 rivers are closed to dredging completely. From my 32 years of prospecting I know that some of these streams are seasonal and DO NOT have fish in them, EVER. What are you attempting to protect here? Another restrictive addition to the Regulations is the requirement to fill in our holes that are a byproduct of dredging. It has been proven that dredge holes are used as holding areas for migrating Salmon. Why would you add a requirement to destroy one of the benefits to fish of suction dredging?  These are just two examples of stifling restrictions on dredging in these Regulations that are unnecessary, arbitrary, biased toward a pre conceived anti suction dredging conclusion and perhaps illegal. The Proposed Regs. as stated will cause substantial economic harm to me and my family.

I strongly oppose the Regulations in total as written and respectfully request the entire EIR and the Regulations be discarded as illegally biased against suction dredging.


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