TSF Comments on Suction Dredge Environmental Review Scope

NEVADA CITY – On Thursday, December 3 The Sierra Fund submitted comments on the California Department of Fish and Game (DFG) Draft Subsequent Environmental Impact Report (SEIR) scoping document regarding the environmental impact review of suction dredge mining for gold.  TSF, along with a coalition of other organizations, also signed to a more broad range of comments submitted by the Karuk Tribe, available here. The SEIR was circulated for public review earlier this fall, and was the subject of three public hearings where the SEIR process was explained and comments taken. The opportunity for public comment on the document closed December 3, 2009. 

The Sierra Fund letter was written by Carrie Monohan, Ph.D., Science Director; and Elizabeth “Izzy” Martin, CEO (for complete text click here).  These comments focused on the scope of the environmental review, and outlined five areas where the scope of the SEIR needed to be broadened:

 1. The Air Quality discussion inadequately characterizes the potential air quality impacts of suction dredging by failing to discuss the impact of mercury that is retorted as part of gold recovery.  The acknowledged common practice of retorting mercury on-site, as part of routine processing of materials from suction dredge mining, has a potentially significant impact on air quality and public health and must be analyzed further in the SEIR.

2. The Biological Resources checklist understates the problems of heavy metal contamination on fish embryos and the stream benthic community.
Reactive mercury that has been mobilized by suction dredge mining has potentially significant impacts on fish embryos and stream benthic communities.  These impacts must be studied and analyzed further in the SEIR.

3.   The Hazards and Hazardous Materials checklist fails to discuss fully the potential hazards of mercury both used and recovered by suction dredge miners. The hazards associated with nitric acid and mercury use as part of routine suction dredge gold mining including the handling, transportation, storage, use and disposal of mercury must be analyzed further in the SEIR.

4. The Hydrology and Water Quality section needs to be revised to address the many hazards associated with mercury and suction dredge gold mining.  The effect of recreational suction dredging on water quality should be considered first and foremost among the impacts of the project.  The impacts of disturbing and re-distributing mercury in the environment, on water quality, wildlife health and fish populations need to be fully analyzed in the SEIR.

5.  Many of our concerns about the SEIR are focused on public health, water and air quality and other issues outside of the charge of the lead agency.  State agencies charged with protecting air and water quality must be part of the regulatory mechanism permitting suction dredge mining, and should be included in the development of the Environmental Impact Report as well as developing any new regulations or procedures promulgated as part of this effort. 

The “Notice of Preparation of a Draft Subsequent Environmental Impact Review (SEIR)” is part of a process required by a court order. In December 2006, the Alameda County Superior Court issued an order with the consent of all parties, directing DFG to conduct further environmental review pursuant to California Environmental Quality Act (CEQA) of its suction dredge mining regulations, and to “implement mitigation measures to protect Coho salmon and/or other special status fish species in the watershed of the Klamath, Scott, and Salmon Rivers, listed as threatened or endangered.”  

DFG is currently prohibited by court order from issuing suction dredge permits. Additionally, on August 6, 2009, Governor Schwarzenegger signed SB 670 (Wiggins) into law, prohibiting the use of vacuum or suction dredge equipment in any California river, stream or lake, regardless of whether the operator has an existing permit issued by DFG.