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Sent: Sunday, August 22, 2010 4:31 PM
Subject: Suction Dredge Mining
Dear Senator Atkinson;
My name is Tom Kitchar, and besides being a suction dredge miner in SW Oregon for the last 23 years, I have also had the honor of being president of the Waldo Mining District (WMD) since 2001. (NOTE: The Waldo Mining District was established in April of 1852 as the first governmental body in SW Oregon Territory). As president of the WMD, I represent more than 100 small-scale (mostly suction dredge) miners and their families that have mining claims or mineral interests in SW Oregon.
I am also the designated spokesman for a group of 25 individuals that represent many of the small-scale mining organizations throughout Oregon. As a group, we have worked extensively with DEQ in the writing of the 2005 Oregon Suction Dredge Permit (700PM) and the new 2010 700PM permit issued at the end of July this year.
Needless to say, we found your statements about suction dredge mining in the Friday, Aug. 20 Medford Mail Tribune quite disturbing. It appears to us that you either have some misunderstandings about the effects of suction dredge mining on the environment and aquatic species, or, someone has fed you a pack of falsehoods and over-exaggerations (i.e.; lies).
For instance, the article mentions how suction dredge mining kills or destroys fish eggs by passing them through the dredge or burying them in tailings. The fallacy here is that under the present permit and guidance of ODFW, suction dredge mining is not allowed during times that fish eggs (and even young fish) may be present. In general, the In Water Work Period in SW Oregon is from June 15 through Sept. 15.
The article also mentioned the spreading or stirring up of mercury. Normally, mercury is not found in most Oregon streams as a separate mineral but instead a miniscule amount is occasionally found stuck to a small piece of gold. A recent very unscientific study (and I use the term loosely) in California by the CDF&G found that an old out-dated and beat-up four inch suction dredge safely recovered 98% of any liquid mercury present in the gravels. That's the safe removal of 98%! That's 98% of the mercury safely removed from the streams and waters.... and even better, this was all done at absolutely no cost what-so-ever to the state or tax-payers!
The article also speaks about the stirring up of silt and the destruction of the river bottoms. First of all, this seems rather absurd during a time that we are ripping dams out of the rivers, releasing hundreds of thousands of cubic yards of silt that has built up behind these dams to just flush down the rivers during periods of high water flows. Put in perspective, according to the Grants Pass Daily Courier dated Oct. 7, 2009, there are an estimated 200,000 cubic yards of sediment within the first 1,000 feet upstream of the Savage Rapids damsite. It would take between 2,222 to 3,333 four inch suction dredges, working four (4) hours per day thirty (30) days to move that much sediment!
According to Don Rossbaugh, project engineer for the Dept. of Reclamation, "It's going to take years to move it (the sediment) all..."; and every time it moves it is going to create massive amounts of turbidity and siltation for miles and miles down the Rogue River.
Senator Atkinson, we (a small group representing some of the mining organizations in Oregon with a total membership of around 1,500 individuals) respectfully request an opportunity to meet with you at your earliest convenience. We would like to hear your concerns regarding our activities, and be given a chance to quite possibly set your mind at ease about the actual scientifically proven effects (or lack of effects) of suction dredge mining.
Just as a few examples showing no actual harm from suction dredge mining, I quote the U.S. Army Corps of Engineers from 1994, the USDA in 1997, and:
Author(s): US Army Corps of Engineers
Title: Special Public Notice 94-10
Source: US Army Corps of Engineers, SPN 9410, Sept. 13, 1994
Purpose: To show the finding of de minimis (inconsequential) effects on aquatic resources for 4-inch and less suction dredges and hand mining.
Method(s): results of field studies and court decisions
Conclusion(s): Four-inch and smaller dredges have inconsequential effects on aquatic resources. "This is an official recognition of what suction dredgers have long claimed; that below a certain size, the effects of suction dredging are so small and so short-term as to not warrant the regulations being imposed in many cases. The U.S. Environmental Protection Agency (EPA), has ignored this concept, although numerous studies, including the EPA's own 1999 study of suction dredging, repeatedly and consistently support the Corps finding de minimis effects. The reports consistently find no actual impact of consequence on the environment, and so almost always fall back to the position that potential for impact exists. Studies to date have not shown any actual effect on the environment by suction dredging, except for those that are short-term and localized in nature." Suction dredges of larger than 4 inches generally have more than de minimis effects on the aquatic environment and therefore requires authorization. (emphisis added)
"The regulatory agencies should be consistently and continually challenged by the dredging community to produce sound, scientific evidence that support their proposed regulations. To regulate against a potential for harm, where none has been shown to exist, is unjustifiable and must be challenged." (emphisis added)
Author(s): US Dept. of Agriculture, 1997
Title: Suction Dredging in the National Forests
Source: US Dept. of Agriculture, 1997
Purpose: To make sure that dredging is done in a manner consistent with current law and good natural resource management
Method(s): an educational handout to the public
Conclusion(s): When done properly, legal dredging must be allowed by law and effects are acceptable (emphisis added)
Author(s): Peter B. Bayley, Dept. Fisheries & Wildlife, Oregon State University, Corvallis, OR..
Title: Response of fish to cumulative effects of suction dredge and hydraulic mining in the Illinois subbasin, Siskiyou National Forest, Oregon; dated April, 2003.
Source: Siskiyou National Forest DEIS to approve suction dredge operations. Cumulative Effects Study.
Discussion and Conclusions:
The statistical analyses did not indicate that suction dredge mining has no effect on the three responses measured, but rather any effect that may exist could not be detected at the commonly used Type I error rate of 0.05.
The reader is reminded of the effect of scale. Localized, short-term effects of suction dredge mining have been documented in a qualitative sense. However, on the scales occupied by fish populations such local disturbances would need a strong cumulative intensity of many operations to have a measureable effect.
Given that this analysis could not detect an effect averaged over good and bad miners and that a more powerful study would be very expensive, it would seem that public money would be better spent on encouraging compliance with current guidelines than on further study. (Emphasis added).
For over the last 30 years, suction dredge mining has been attacked by extremist environmentalists time and again, forcing government agencies at all levels to spend hundreds of thousands of dollars (if not millions) of tax-payer money performing study after study after study; apparently with the hopes that sooner or later, someday, someone will reach a conclusion showing an actual harm. To date, no such study, out of literally hundreds, has shown a specific proven measureable harm from this activity. In fact, the few studies that have found a measureable or even hinted at effect found that the effects from suction dredge mining are actually beneficial to fish, aquatic species, and the environment!
Senator Atkinson, I respectfully request that you take some time out of your busy schedule and sit down and meet with us; and learn the true facts about what we do before you take steps that will destroy an industry that helped found and build Oregon for no real reason at all.
Please feel free to contact me either via email at the address below, or leave me a phone message and a way to contact you or your aid to schedule such a meeting.
President, Waldo Mining District
P.O. Box 1574
Cave Junction, OR 97523
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