Suction Dredge Mining

 

 

 

We can protect Washington rivers and wild salmon from highly destructive suction dredge mining.  Washington has virtually no regulation of this activity which harms our water quality and salmon and steelhead habitat.  That can and should change.

 

The Washington Department of Fish and Wildlife will be undertaking a public process this summer to develop rules to regulate this activity. Because Washington State has not regulated suction dredge mining like our neighbor states many of our rivers and streams are now literally a free for all for any "recreational" gold miner wanting to put a diesel motor and a hose into one of our streams.  In fact many miners come from out of state because of our lack of protections.

 

Washington is investing millions of dollars to restore our wild salmon runs and protect habitat.  It is past time to regulate mining in our rivers and streams to protect these efforts and help assure clean water and wild salmon.

 

 

·       erosion and sedimentation in streams

·       mobilization of mercury and other heavy metals

·       increases in water temperatures due to elevated turbidity and loss of riparian vegetation

·       water contamination at access areas (e.g., gasoline spills)

·       physical impacts to fish eggs, juvenile fish, invertebrates, and other aquatic organisms

·       interruption of natural stream form and function (and creation of fish stranding hazards)

·       denuded riparian habitat caused by repeated equipment access and long-term encampments

·       destruction of habitat features (e.g., removal of large woody debris)

 

Comments can be sent to: 

Washington Department of Fish and Wildlife

Attn: Randi Thurston

600 Capitol Way N. 
Olympia, WA 98501-1091

 

Here is a draft comment letter......

 

Dear Washington Department of Fish and Wildlife,

 

Thank you for the opportunity to provide comments on Rulemaking for 220-660 WAC related to motorized mineral prospecting. Reforms to Washington State’s motorized mineral prospecting regulations – which currently lack requirements for oversight, accountability, and compliance with federal laws – are urgently needed to protect our state’s water quality, native fish populations, overall watershed health, and significant taxpayer investment in recovery of our fisheries resources.

The opening of rulemaking to address suction dredge mining is a significant step in the right direction. However, there are key elements that must to be addressed during rulemaking to complying with state and federal laws and adequately protect Washington’s fisheries resources under the new rule:

·       All motorized mineral prospecting methods should be removed from coverage under the Gold and Fish Pamphlet, not just suction dredge mining. For example, high-banking, which involves excavation of streambanks and riparian areas, causes just as much damage to habitat and should be regulated in the same manner as suction dredge mining.

 

·       WDFW’s new motorized mineral prospecting rules should include provisions for:

·       Endangered Species Act (ESA) compliance. ESA-designated Critical Habitat should be off-limits or a Habitat Conservation Plan approved by NOAA Fisheries and U.S. Fish and Wildlife should be required.

·       Clean Water Act (CWA) compliance. Because motorized mineral prospecting involves discharges to Waters of the State, WDFW’s program should include a programmatic NPDES permit or other CWA permit issued by the Washington State Department of Ecology, in order to ensure permittees are in compliance with the federal CWA.

·       Invasive species prevention, including equipment inspections and cleaning requirements.

·       Proof of Notice of Intent (NOI) for activities on U.S. Forest Service lands, which should be submitted with HPA application.

·       At least 3 site visits by WDFW compliance officers (i.e., pre-, during, and post-project to ensure compliance with HPA permit requirements)

·       Suction dredges should be registered with Washington State, so that equipment can be tracked to owners. This is important because suction dredges are often illegally left unattended in streams while not in use.

 

Thank you for considering these comments. I strongly believe reforming motorized mineral prospecting regulations represents an essential step toward protecting our vital fisheries, water quality, watershed health, and taxpayer investments in Washington State.

 

Sincerely,