:: :: New 49'er comments on California's proposed regulations

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New 49'er comments on California's proposed regulations ( 10:12:13 TueApr 12 2011 )

I have invested a healthy portion of the last month reviewing the massive Subsequent Environmental Impact Report (SEIR) along with relevant portions of the California Fish & Game Code, the Resources Code and the Government Code. With the collaborative efforts of our staff and numerous responsible members that also have substantial experience in dredging matters, I have authored 38 pages of comments on behalf of The New 49’ers. This comprehensive response is in a format which allows text to be copied & pasted to help with your own written comments.

The naked truth is that DFG is attempting to impose substantial additional restrictions upon our existing suction dredge regulations (adopted in 1994). They are not doing this by providing any evidence in the SEIR that a single fish has ever been harmed by suction dredgers; but by adopting an entirely new baseline to which the affects of suction dredging are being measured.

During 1994, the impacts of suction dredging were measured against the baseline of ongoing dredging activity dating back to the 1960’s. But this Subsequent EIR is measuring the effects of suction dredging to a new arbitrary baseline of “no dredging activity” in order to make them appear to be substantial. This is because of the existing moratorium on suction dredging, according to the SEIR. But the moratorium was Ordered because DFG made Declarations in recent litigation that they had evidence to show a potential deleterious impact upon fish from ongoing dredging activity under the 1994 regulations. However, DFG’s “evidence of harm” has not materialized in their SEIR. Rather, they have decided to reevaluate all of the previous information (that was addressed in the 1994 EIR) against a “no dredging” baseline.

As if that is not bad enough; DFG has even taken it a step further in this SEIR by evaluating the negative economic and social consequences resulting from drastic reductions in our existing regulations as a “beneficial impact upon mineral development and economics.” The truth is that the burdensome additional restrictions they seek to impose upon us would eliminate dredging (in places where existing regulations allow it) across vast areas of California, and would reduce nozzle sizes along the remaining open areas to the point where it will be difficult to make money with a suction dredge. This will undermine millions of dollars worth of property values and, to a large degree, undermine dredge-mining as a small business activity in California. But rather than acknowledge the real consequences, this SEIR is measuring the economic impacts against an arbitrary “no dredging” baseline and making the case that lifting the moratorium would be a positive gain!

There are numerous mandates from the California legislature which require state agencies to measure real environmental impacts against the cost to Americans of implementing more restrictive regulations, especially upon small business. My own impression is that DFG officials have made a deliberate and underhanded attempt to corrupt this process. If you take the time to read my formal comments, I believe all of you will agree with my assessment.

It is a real awakening to discover that some government agencies are actively working to subvert the legal processes which they are supposed to follow, all in an attempt to eliminate economic opportunity that belongs to the public which they are supposed to serve.

Because DFG has overreached their legal authority with this SEIR, we have an excellent opportunity to push them back where they belong. But we are all going to have to help with this, because California is larger than Oregon and therefore requires a stronger push. It is not enough that we have figured out what is wrong with the SEIR and Proposed Regulations. We also need to generate a very loud cumulative objection! That’s where you guys come in.

Here is an Action Alert that includes a link to our suggested talking points which you will can cut and paste into your own comments.

If you have time, I encourage you to take a look at the comments I have linked to in this thread. They provide a clear demonstration of what is wrong with government today, and also show why California is so broke!

Rod_Seiad

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Re: New 49'er comments on California's proposed regulations ( 18:11:56 TueApr 12 2011 )

Dave, I've read your "formal comments" excellent work!

I believe anybody can derive benefit and understanding from your truthful and factual body of work.

The 2011 SEIR ought to be entirely struck down. It has proven nothing new.

beammaker

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Re: New 49'er comments on California's proposed regulations ( 22:30:12 TueApr 12 2011 )

:doublethumbsup: THANK YOU MR. DAVE MACK

You and your associates---have (once again) done an excellent job of stating the facts--pointing out the flaws, and stating both legal and common sense reasons why the CDFG and Mr. Stopher are total idiots.

I have an original copy of the 1994 dredge studies, and not a xxxx thing --here proposed-- will improve on the 1994 regulations. EVERYTHING proposed is just to pile more bullxxxx on more bullxxxx---and to give them reasons to hire more wardens---which of course---just brings California's death bed closer to reality.

The reasons to dredge, highbank, snipe, drywash, metal detect the "GOLDEN STATE" are rapidly disappearing. I told Colorado Nuggets recently---if it is down to three months, then we can get three months in both Wyoming and Colorado. Why waste the efforts, headaches, and substantial moneys to be among friends in an unfriendly environment.

I wished to have a 1 to 4 year vacation in your wonderful Klamath Valley and the desert states (wintertime). From 2005 to the present, I have paid over $10,000 in pre-positioning costs, yet the Karuk/treehugger/bureaucratic/legislative nightmares precluded making the final efforts to implement the vacation. "DREDGING IS THE KEY"

I will continue to help you financialy, as much as possible, but if this nightmare-by the CDFG/representing the legislature becomes fact, then my retirement plans are ruined and I will just hunker-down in the Rockies or move to the desert states to get out of the frozen.

:thankyou: again for all you do-BEAMMAKER

riverwatcher

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Re: New 49'er comments on California's proposed regulations ( 02:40:37 WedApr 13 2011 )

enjoyed the read Mr Dave

this was in my email that I sent to Mr.Stopher F&G
last week, its simple in form but I do see
I did express some of the subjects you have sent except yours has alot better stucture than what I could ever come up with.

riverwatcher

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Re: New 49'er comments on California's proposed regulations ( 02:43:48 WedApr 13 2011 )

Please accept these as my comments regarding the 2011 Suction Dredge DEIR.
Cindy Reamy

Mark Stopher
Environmental Program Manager
California Department of Fish and Game
601 Locust Street
Redding, CA 96001

I am not a dredger, but I have taken a interest in the proposed dredging regulations that are under review at this time.

As a person who hasn't had the experience of dredging nor the ability at this time to dredge, I would like to explain something I have researched thru common sense evaluation over a 2 year period.

I have compared and observed the turbity of river flow when river is at flood stage or during a dam release,and a video of a dam break and snow melt and then the turbity of a single dredge and from what I have seen the dredge in its heaviest working ability
cannot match nor preform any comparison to the activity the flood or snow melt can. And I have sat for hours fishing from a dock numorous weekends and watched boats being fueled up by fisherman and boaters and noticed the spilling of gas into the water time and time again without soak pads being used to absorb the spillage and just a guessing average the amount of fuel would be possibly more than 1 gallon spilled per 2 days of ongoing boaters fillups. And watching youtubes videos of how a dredge motor is located there seems to be a catch pan which makes me think that and the fact with Less dredgers compared to boaters on any and all waters the level of impact is less than 1 percent done by dredgers, if it takes place at all.

And knowing that the flow of water will change the layers and sediments each time the flow from snow melts and rains on most all rivers it seems the local area a dredger changes is mainly the demensions of less than a 20'x20' and it fills back in as the river flows thru its changing rates
naturally and again less than 1 percent compared to the natural river flow during each season.

And I have watched dredging video on you tube and gold prospecting websites where the dredge has collected lead fishing weights and other metals and a few have collected and removed Mercury from the enviroment which to me is something they don't have to do but feel they should do because it helps to clean up the ecosystem and protects wildlife and our water systems from the contamanites which naturally gets stirred up thru floods and flows.

I have watched videos of fish being with the dredgers and I admit in a webforum I read one person said they were caught off guard by a snake in the water and sucked the snake up thru the hose and when he went to check the output the snake swam away unharmed because the pump that dredgers use
are designed to only be pumped thru the hose and not thru a pumping chamber that can possibly injure things sucked into it .

So now my overall opinion after this 2 years study brings me to conclude that modern day dredging is less likely to have a impact on our enviroment and wildlife than cars driving the roadways, boat props and fuelings of boats and skidoos and fisherman, which if you compare the amount of dredgers to all those other catigories the question is why modern day dredging being placed under a microscope with such strict regulations ??

And why is this proposal meant to restrict a person from doing hard work that not many can or will do that has benefits to our enviroment while they earn a hard days pay to support themselves and families?

And why is it common sense compairison is being avoided by the stop dredge protesters?
Just because a group gets together and decides there are reasons to stop this other small group
and place these accusations on paper doesn't make it so.

Time should be taken to really know the truth for yourself, because sometimes people lie to people who trust them, to just get what they personally want .
This is Not a bully system political controlling powers issue because we can subject is it?

Work from facts and common sense comparison and if you dont have the time why are you in this
position of making such dicisions?

Thank you for allowing me to add my comments.

CJ Reamy

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