Contact Oregon DEQ To Let Them Know You Oppose Pending Pollution Permit For Suction Dredging

Suction dredging is a common small-scale mining operation practice where sections of a riverbed are sucked into a motorized high-pressure water pump, filtered for dense material including gold, and spit out at another location in that same riverbed. In light of recent calls by Oregon’s mining community in the southwestern part of the state, Oregon’s Department of Environmental Quality (ODEQ) has recently requested a pollution permit for the pollutant plumes created by the machinery used in this practice and is accepting public comments on the decision until June 8th. It is imperative that we let them know we oppose this permit because the effects of this practice can be detrimental for water quality, aquatic habitat and threatened and endangered aquatic species.

Sign this letter to ODEQ and Contact State Representatives to let them know this permit would be in direct violation of the Clean Water Act and you oppose granting it. ODEQ’s function is to regulate negative environmental impacts, not allow them because of public outcry.

Aside from the mere fact that spitting pollutants into creeks and streams where water clarity and temperature affect a multitude of aquatic and terrestrial species is not only a bad idea for the health of the environment and in turn the local community, but the practice of misplacing gravel and sediment from sensitive spawning beds is itself disruptive to the natural habitat of coho and Chinook salmon (T.E Lisle and B. C. Harvey), among others that we as a community at large are trying to protect and restore.

Suction dredging in southwest Oregon has been in the news lately, with a recent tightening of restrictions for the practice. It has been advised by the US Forest Service that fishery managers be wary of this practice and it has been banned all together in the state of California. Although environmental impacts can be reduced by restrictions, it’s important to note that they are under-enforced and therefore commonly ignored. Voicing opposition to this permit is critical to follow in California’s footsteps and ban the practice in Oregon, where we value our salmon populations and water quality.

If you would like to know more about the studies that have been conducted on the effects of suction dredging, please refer to the above Lisle and Harvey link, as well as the Effects of Suction Dredging on Streams: a Review and an Evaluation Strategy by the same authors. Here, you can also read ODEQ's press release dated April 26, 2010 where they announce their request for public comment.

Please either sign a prepared letter by our friends and colleagues at KS Wild or copy the letter below and send to or call one of the following:

• Beth Moore, Oregon Department of Environmental Quality
  (503) 229-6402
  moore.beth@deq.state.or.us
• Senator Ron Wyden
  (202) 224-5244
• Senator Jeff Merkley
  (202) 224-3753
• Rep. David Wu
  (202) 225-0855
• Governor Ted Kulongoski
  (503) 378-3111
  

Sample Letter To Be Sent To Your Representatives:

Dear DEQ,

Thank you for the opportunity to comment on DEQ’s proposed Clean Water Act 700-PM general permit for suction dredge placer mining in Oregon waterways.

I am very concerned about the impacts of suction dredge mining on water quality and fish species. In 2009, California banned suction dredging until the state Department of Fish and Game completes a comprehensive environmental analysis on the impacts of this activity. I ask that DEQ suspend this permit process, and place a moratorium on suction dredging, until California completes its analysis. Such action will ensure that DEQ has the most comprehensive and up-to-date scientific data to issue a pollution permit that will protect Oregon’s waters and fish.

I am also concerned that this permit is an exercise in futility given that there is no enforcement mechanism and no requirement to disclose specific mining locations or submit monitoring reports.

If DEQ proceeds with this permit, I ask that you make the following changes to the draft:

1. Require that all people who register under this permit disclose the waterbodies and exact stream locations where they will be operating so that enforcement of permit conditions is possible.
2. Require that all people who register under this permit submit discharge monitoring reports detailing operating dates and locations, just like other pollution permits.
3. Not authorize operators to move in-stream structures, such as logs or boulders that create vital habitat for fish.
4. Clarify that suction dredging in any state scenic waterway is not allowed.
5. Prohibit suction dredging in streams that are designated as critical habitat for endangered and threatened fish species, including Coho and Chinook salmon and bull trout. 
6. Reduce cumulative harm by limiting the number of dredges that can operate in close proximity to one another.

Thank you. I look forward to hearing how DEQ proceeds with this pollution permit.

Sincerely,

YOUR NAME AND ADDRESS

CC:

Governor Kulongoski
Representative Peter DeFazio
Senator Ron Wyden
Senator Jeff Merkley