Significant and Unavoidable

The Suction Dredge – Destroyer of Worlds

Suction gold dredging has been ongoing for over forty years in California.  The world’s largest manufacturers of gold dredges are located in California.  It surprised us all to find suction dredging caused “significant” harm to the environment.  With forty years of history behind us we should expect, no scratch that, we should demand that actual science be used to determine the effects of dredging.

After forty years are you seriously going to tell us that you speculate dredging “may” cause significant harm to the environment?  Well, that’s what the draft Subsequent Environmental Impact Report (SEIR) says.  It states that in at least eight areas we “could” cause substantial and significant harm to the environment.  Ponder that for just a second.  It’s you and your 4” suction dredge and you are responsible for significant harm to the environment?  The problem with the SEIR is it’s speculative in nature.  Although the California Environmental Quality Act (CEQA) requires that the existing conditions be used for the baseline of an Environmental Impact Report (EIR) the SEIR provides nothing but “mays” and “mights.”

                                                                                                     The Suction Dredge – Public Enemy #1

Don’t believe us, let’s just do a simple word check of the SEIR.  You can try this trick at home, simply reassemble all the sections of the SEIR into one big, very big document.  How big?  How about 1,388 pages (by the way, CEQA says a EIR should normally be about 150 pages, and if it’s complex then 300 pages so we got lucky and got an extra 1,000 pages to sift through).

Here is the word check looking for conditional verbs.

 That’s a total of 1,698 occurrences of “mays or mights.”  That’s a lot.  After all we’ve been dredging for forty years – why speculate.  As a matter of fact I’ll invite them to my claim and they can study it all they want for proof of damage.  Hell, I can’t even tell where I left off dredging the year before.  At the end of a season if I’m doing well I’ll write down in a notebook something like 300 paces downstream from the trail near the large rock.  I almost always do this and yet more than once I’ve dropped the dredge hose in a hole I dredged before certain that I hadn’t.  It’s not until I hit pine cones on the bedrock that I realize I’ve been there before.   If I can’t tell, even underwater then where is the proof we’re harming the environment?

On the Way to the River We Heard a Funny Story

Mark Twain once said “There are three kinds of lies; there are lies; damned lies and statistics.”  Parts of the SEIR were almost absurd and we thought someone had tried to inject some humor into a pretty dry document.  We’re not going to knock Horizon, imagine the amount of work they put into this document, it’s actually pretty amazing and we don’t fault them for their work, but the content leaves a lot to be desired.  To understand the content you have to understand how a EIR is prepared according to CEQA.  CEQA requires the lead agency to coordinate with every other agency that would have an interest in it - virtually guaranteeing the end result will be a horrible mish mash of conflicting information.  The part we’re most concerned with is the water quality because bad water quality results means regulation by the State Water Quality Boards, like we need that.

Let’s consider some of the more ridiculous points in the SEIR such as “scouring.”  The SEIR theorizes that suction dredges could create “nicks” – no we’re not making this up, in the bedrock.  Nick marks – what are nick marks and when did anyone line the bottom of these streams in terrazzo?  Apparently a suction dredge can create one of these nicks which according to the SEIR could then travel upstream which apparently would create a fissure draining the stream of all water, increasing global warming, releasing toxic fumes and killing polar bears.

       Dredge vs. River, River Wins Every Time

A second topic we thought they were joking about was “Cultural Resources.”  According to the SEIR suction dredging can destroy Historical and Cultural Resources.  Now it’s been over two years since I’ve had a dredge hose in the water but I’ve not dredged up so much as a chicken bone in all my years of dredging.  In forty years of dredging you think they could point to specific examples of this damage such as we dredged away an old townsite which of course the hydraulic mines did.  Now, here’s the irony.  In a conversation with CDFG we asked them about this, assuming they were just kidding.  The response?  The garbage from the old mining days is now historical resources.  Yup, square nails are historical resources even though there is no telling where they came from.  What does CEQA say about cultural and historical resources – not that.  According to CEQA we’d have to be dredging away an old building or graveyard to qualify for significant damage and even then the old building would have to be such that it would qualify for listing on the historical register.  CEQA doesn’t happen to mention what happens when that old building was burned down, the remnants washed into a stream and pulverized by spring floods but somehow we doubt anything we dredge up would qualify as a historical or cultural resource.

Special status passerines?  We had to look up on Wikipedia what a “passerine” was and we found they are songbirds which 50% of the bird population in the world is.  There are four of these birds on the list that would be so traumatized by dredging that they would throw their eggs into the river, abandon their nests and move to Mexico.  We tried really hard to figure out the differences between three of them, they’re all subsets of one bird, not that we’re anti-bird but when you need DNA testing to tell the difference we’re really splitting hairs.  The SEIR says our “activities” would disturb them and cause nesting failures.  We tried hard to figure out how a suction dredge in the river putting along would disturb these guys to a greater extent than say removing their trees but we’re stumped – no pun intended.  Logging and clear cutting is exempt from CEQA so removing their trees doesn’t bother these birds, but running a dredge does.  Now, I hold claim to about a mile and half of river, and being old and slow I can work maybe a hundred yards.  I spend most of my time looking down, not up, but I just can’t figure out how my one dredge on one hundred yards of a mile and half causes nesting failure.  Again, not being anti-bird or anti-tree but if a dredge motor running causes trauma to these birds I don’t hold out much hope for them.

Bad Research is Bad for Us

The intent of this article is to provide an overview of just how flawed the SEIR is and the injustice being done to us simple miners.  How the world turned against us is hard to understand.  I thought we pretty much kept to ourselves but somehow we became public enemy number one.  I can live with that, but we’d sure like to see justice and fact based information.  The facts are suction dredging doesn’t harm the environment and it’s up to all of us to fight this.  The new regulations will cause significant harm to the mining community.  It will close five of my claims, I’ll still have claims to work but I don’t feel like letting them close my claims without a fight.

All of us need to understand these issues and voice our opinion.  We believe the final SEIR will be posted in January or February of this year.  It will be posted for a thirty day final comment period.  What happens if you don’t comment?  Simple, you lose your standing to challenge it.  If the final SEIR is similar to the draft then we will be facing the next twenty years of environmental groups fighting to kick us off the rivers because we are causing “significant” damage to the environment.  Do we really want that?  Know the issues and understand them.  Our mission is to inform you of the issues.  The Significant and Unavoidable issues in the SEIR are:

Over the next few months we will continue to publish our research on these issues with fact based research you can use to respond to the final SEIR.  In December we published our findings on the Yellow Legged Frog.  In January we’re going to cover how mercury data was developed in the SEIR and then we will cover each of the significant issues.  We will arm you with the facts.

We can always use more researchers.  If you want to tackle anything on the above list and write a research paper on it, we’d be glad to have you.  After all we’re just a couple of old miners trying to fight bad science.  If you’re counting on us to win alone – aint’ going to happen.  Not until we all band together and fight as a group will we win.  Join the fight, you don’t have to join the WMA, but please join with someone and as always we encourage you to donate to Public Lands for the People, the only people in the thick of the fight.  They’re fighting for all of us, put aside your differences, personal opinion and send some money.

Keep up the fight.

Monde Labe

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