The California Sportfishing Protection Alliance, along with 19 other conservation, fisheries and community organizations, submitted comments on March 5, 2021 to the California State Water Resources Control Board on a proposed National Pollutant Discharge Elimination System (NPDES) General Permit for Suction Dredges Mining Discharges.
Suction dredge mining was prohibited in California in 2009. In 2015, the California Fish and Game Code and Water Code were amended, requiring miners to obtain both (1) a permit from the State Board or a letter from the State Board stating no such permit is required, and (2) a permit from the California Department of Fish and Wildlife to suction dredge mine in California. The State Board requested comments on the proposed new NPDES permit.
The CSPA & coalition comment letter urges the State Board to maintain its previous recommendation that suction dredge mining “be permanently prohibited,” because the significant environmental effects of this destructive activity cannot be fully mitigated. The letter states that if the it does decide to selectively allow suction dredge mining, the State Board must:
- Maintain strong prohibitions on suction dredge mining in areas where there has been historic gold mining or that have high levels of heavy metals, such as mercury.
- Prohibit mining in waters that are impaired for sediment; areas with rare, sensitive, threatened or endangered species; and areas with cultural, recreational, and aesthetic resources.
- Create and distribute descriptions and maps that accurately describe all areas where suction dredge mining is prohibited—such as national parks, wilderness areas, and military areas—to avoid confusion and conflicts.
- Require real-time monitoring to ensure that water-quality violations do not occur.
- Issue only individual permits and not a general permit, because site- and operation-specific impacts can only be analyzed on a permit-by-permit basis.