Posts Tagged ‘silt’


General Response to Joe Greene

[Editor's note: When the New 49er's griped about the bias of scientists involved in the public advisory committee for suction dredging in California, the State eventually acquiesced allowed the New 49ers to invite two people with science degrees from their camp.  They selected Joe Greene and Claudia Wise retired EPA scientists from Oregon and current officers in the Millennium Diggers organization.  These parties were invited by virtue of their positions on the issue rather than their expertise on the topics at hand.  Both have made comments characterizing themselves as "experts" and not initially disclosing their memberships in Millennium Diggers or their participation in or passion for suction dredging.  Ms. Wise has posted few comments, but Mr. Greene has posted numerous comments to both suction dredging posts (Suction Dredging…Sucks and Dredging Up The Truth) requiring a general statement to him personally]

Dear Joe,
Since I did not mention you by name in my Dredging Up the Truth blog, I can hardly see how my post was a personal attack.  It becomes a personal attack only because you see yourself in those comments.  But since you have opened the door here, let’s play. 
Former EPA scientist Joe Greene, an avid gold prospector who has been suction dredging since the 1960s, is less than impressed with the EPA’s propaganda and Tomten’s claim that dredging is illegal under the CWA (see here)
In the first place, certainly I agree with free speech.  I have defended that right my entire life.  But that is separate from the concept of professional ethics.  You have been involved in dredging for nearly 50 years, so you—as a scientist offering scientific opinions—have a huge conflict of interest.  Your access point to this debate is as a suction dredging advocate.  You have crossed a professional line with your comments and attacks on scientist with actual credentials in this field.  But in addition to the concept of professional ethics there is also a question of the extent of your credentials in this specific arena and the quality and thrust of your commentary.  
Having worked as an ecological consultant in 1980s—sometimes on fisheries matters—I was often asked to synthesize masses of studies that dealt either directly or indirectly with the species or habitat in question and draw my best conclusions based on the body of work available and those studies that were most applicable.  Where there were conflicts and confusion I had to dig deeper until I felt comfortable with my ultimate conclusion about that element.  A lot enters into this including examining experimental design and dealing with changing evaluation methodologies and scientific standards.  This was the same careful and considered process that was conducted by Dr. Moyle.  His logic was sound and his use of the literature, cautionary remarks, and conclusions were all appropriate. 
On the flip side we have you.  I found it interesting that in your initial comments that you made derisive remarks about Dr. Moyle using the work of his former graduate student (i.e., “So, Moyle stated for science he was relying on data published by his former grad student Bret Harvey.  Great move.”)  Using Dr. Harvey’s work in the context of what Dr. Moyle was asked to do was totally appropriate and you should know that.  What was inappropriate was your comment.  It was both disrespectful and incorrect.
So let’s deal with the thrust and quality of your work as exemplified by your traveling power point presentation and advocacy.  Words fail me when I look at this.  It is hard to find a single slide in this presentation that is not purposely misleading or dangerously paranoid.  Working for the EPA you should be well aware that there is a difference between sequestered toxics and those re-suspended in the water column—shame on you.  You also know fully well that the arguments about “very little” becomes a big deal when talking about suspended materials and chemicals that are often measured in parts per million.  And your quoting of water chemistry conclusions from a nearly 75-year old study is pretty much laughable—what professional scientist would do that?  Taken in sum, your presentation is deceptive, unprofessional in nature, and politically and personally motivated.  I could do a slide by slide critique but after about slide 40, it makes me sad that you have slipped so low.
So Joe, I can absolutely live with disappointment from you.  I might actually wear it as a badge.  And I am glad that you get reinforcement and compliments from the mining community because you certainly will not get them from your former peers or from the scientific community where it actually counts.  I suspect it is also gratifying that your contrarian views and emerging status in the mining community affords you a notoriety that you never enjoyed during your career as a federal bureaucrat—I hope it is worth it.  
–Bob Ferris
P.S. In terms of your characterization of my qualifications as being non-biological, my undergraduate degree is in Environmental Studies and Biology which means that I completed the degree requirements for both majors.  Moreover, my exit requirement for biology involved being above the 75% mark on the subject GRE which was easy and why I later was accepted into masters and PhD programs.  Much of this is not on my LinkedIn profile because the later 20 years of my career are more relevant.  So I left out paid teaching assignments (not unpaid courtesy appointments) at San Jose State University and UC Santa Cruz (full courses not short courses) as well as my ecological consulting and research experience in the 1980s.  

Dredging Up The Truth

By Bob Ferris
With every complicated, science-based issue we seem to tackle, from climate change to wolves and from forestry to diesel particulates, there seems to be a handful of slide-rule era-educated, contrarian scientists who pull themselves up from the depths of retirement to confuse the issue.  These self-proclaimed mavens generally have some credentials, but not the applicable ones and they tend to be motivated more by self-interests and politics than by science.  And the suction dredging issue is no exception (please see comments section for Suction Dredging…Sucks).
Sure, they will be fairly careful in their statements and have the skills necessary to “cherry pick” and present information in a manner that sounds convincing to the lay public, but at the end of the day their arguments are mainly logic wrapped around a kernel of deception.  Here are a few of the myths they try to promulgate and why we all should look deeper for the rest of the story.  See how many of these myths you can spot in the suction dredging comments.
There is not a single study that shows that suction dredging kills fish.  This is misleading because the issues are not primarily about adult fish but rather spawning beds, eggs, young fish, food resources, miss-timed disturbance, added stress on heat-challenged fish, and legacy pollution. (Please see California Dept. of Fish & Game, Suction Dredge Permitting Program Literature Review (2009) at 4.3-2 – 4.3-13.)
The steelhead runs after Mount Saint Helens broke records.  Steelhead are anadromous fish (i.e., breed in freshwater and grow in the ocean) and were at sea when the volcano erupted. In any case, the success of that record run was determined 3-4 years beforehand by reproductive success in the rivers and streams.  It is not an argument that fish are not affected by silt. (Please see, e.g., Peter A. Bisson, Charles M. Crisafulli, Brian R. Fransen, Robert E. Lucas, and Charles P. Hawkins, Ecological Responses to the 1980 Eruption of Mount St. Helens, 173 (Springer 2005).
Turbidity does not harm fish.  While it is fun to use the word turbidity, that is really not the issue—siltation is.  Turbidity—the opaqueness of water associated with suspended particles—can be a minor problem at the wrong time, but siltation (when those particles settle and where) is nearly always a problem. (Please see California Dept. of Fish & Game, Suction Dredge Permitting Program Literature Review (2009) at 4.3-22.)
Invertebrate populations rebound quickly after disruption, so it is not a problem.  Young salmon, steelhead, and other fish require invertebrates for food.  Steelhead fry (young fish) are also territorial and defend territories; so they also need those invertebrates in their territory. If food resources are locally damaged for any length of time, that can have detrimental impacts on fry.  And if these young fish have to move to find food, they also become more vulnerable to predation by other fish and birds. (Please see California Dept. of Fish & Game, Suction Dredge Permitting Program Literature Review (2009) at 4.3-10, 4.3-16.)
Suction dredgers are good at removing mercury contamination.  Studies indicate that this not an accurate statement.  These studies indicate that suction dredging resuspends sequestered mercury and that discharges from dredges in mercury contaminated areas exceeded legal limits by some 10-fold (see page 8 of the following report)
Suction dredging damage mimics annual storm disruption.   This is not true on two fronts. First and most importantly, the timing is off.  Aquatic species in streams and rivers co-evolved with river systems that ran wild during the wetter months and were calm during summer and early fall.  If you alter that pattern, impacts to species whose life cycles have evolved in that system occur.
There is also the argument that materials moved are not much relative to the amount of materials moved in association with storm events during the wet seasons for the entire watershed.  In fact, one analysis in California showed that the percentage of materials moved by suction dredging was 0.7 % of that moved by the river naturally.  That is a crafty but disingenuous argument because natural movement is spread throughout the watershed and suction dredging is localized and intense.  In other words, suction dredging may very well not cause much damage relative to total materials moved, but relative to what a particular locale normally experiences, the change can be profound.  This same argument can be made for cyclones (i.e., that they are relatively insignificant to annual winds), but I suspect that the person whose house no longer exists sees the situation very differently.  
We clean up gravels and improve spawning areas.  This statement is misleading as several studies have looked at the impact of suction dredge tailings.  And two things become apparent from these studies.  One is that fish tend to not use these tailings when natural spawning habitat is also available.  The second is that when fish used these tailings and the river flows are high, spawning success is reduced (i.e., fertilized and developing eggs are destroyed) because of the instability of tailings as spawning grounds. (See California Dept. of Fish & Game, Suction Dredge Permitting Program Literature Review (2009) at 4.1-4, 4.1-8, 4.3-2)
Stopping suction dredging puts Mom and Pop businesses at risk.  As a group, suction dredgers tend to lose money.    When we look at the California experience, suction dredgers on average suffer net losses of from about $5,500 to $9,000 annually to look for gold (please see for baseline numbers).  
Average California Suction Dredger Gold Recovered 
One miner X 35 days per year X $16-$122/per day = $560 to $4,270 per year in gold
Average California Suction Dredger Expenses
General Expenses per miner = $6,250/year
Fuel and Dredge Maintenance = $3,000/year
Average Dredge Cost per Miner (average dredge cost $6,000, assume 10-year life) = $  600/year
Total expenses per average miner = $9,850/year
Crunching these numbers a little more, we see that the total economic activity generated by suction dredging in California came in at about $15-$36 million for everything (e.g., dredge sales, motels, gold recovered, etc.).  While this seems like significant revenue, this pales in comparison to recreational fishing which is a $2 billion plus industry embedded in the $2 trillion California economy.  
This is certainly not the economic engine that proponents argue, and California was absolutely their best case scenario.  Moreover, it is not appropriate to characterize all of this as potentially lost economic activity, as this sector of the public will likely shift their expenditures to other similar recreational endeavors.  
When dealing with endangered and declining aquatic species found in public waterways and surrounded by public lands, we fully agree with Dr. Peter B. Moyle’s view (please see that the burden absolutely needs to be on the suction dredging industry to demonstrate through independent science that they will not harm these species, either directly or indirectly.  Instead, the industry’s strategy has been to malign dedicated experts, discount evidence as rumor, and attempt to confuse the public on the science.  I suppose it is much easier and more profitable to sell dreams of riches to the vulnerable members of society, than it is to deal with reality and science.  
Please sign and share our petition.
And please read:

Suction Dredging…Sucks

By Bob Ferris
My access point to my career in the conservation field came originally from fish.  I caught my first trout on the Eel River in northern California while my family was on their way to visit the 1962 World’s Fair in Seattle.  As we were on our way north, my mother grudgingly allowed me to fish for 15 minutes—no more.  And on my premier cast with my older sister’s telescoping metal pole and an ancient JC Higgins reel, I felt that first electronic jolt that changed my life.  (Yes, this was a salmon egg catch, but I did not know any better at the time.)
That memory is golden to me and the thought of anyone taking any action that would rob someone of a similar moment rankles me no end.  That’s why the notion of some yahoo sticking a 4”-6” inch motor-driven suction hose into the hard bottom or gravel of a trout or salmon bearing stream and muddying the water literally makes me just a little angry.  And that ire only rises a little higher when I learn that these “modern 49ers” seeking flakes of gold in the silt they are spraying around are being egged on and legislatively supported by some modern day equivalent of snake oil salesmen hitting the KA-CHING button with each $8900 suction dredge they sell.  
It’s an old game where the “pick and pan” salespeople make the real money preying on the suggestible and greedy.  And part of the pitch seems to be that mucking up rivers flowing through public lands is an honest-to-goodness, Don’t-Trend-On-Me, All-American right.  Poppycock!  Suction dredging sucks and the sooner we all gravitate to that point of view, the better for all concerned.  (Okay so the dredge dealers will not be happy, but I can live with that quite comfortably, Thank You.)
Doing the “gold fever” math: Proven placer claims yield in the vicinity of 0.025 ounces per yard of material processed or roughly $45 per yard.  Recreational suction dredgers can move up to 25 cubic yards per year before being classified as commercial operations.  So if they are lucky and gold prices hold they can gross $1125 annually in Oregon.  When the cost of the machine and gear as well as other costs such as permitting, trailer registration, gas, and maintenance are factored in it becomes crystal clear that the “gold strike” here is for the equipment sellers rather than these hopefully prospectors.   
Suction dredging is not a “right” nor is mucking up the water for the rest of us—particularly in streams and rivers that run though public lands or hold imperiled species such as Coho and Chinook salmon or bull trout.  We and many others who have worked hard to clean up and protect waterways throughout Cascadia see only one solution to this issue:  An all-out ban on suction dredging in the salmon-bearing water systems of Cascadia.  The practice is banned in California and restricted in Washington, Oregon, Alaska, and Idaho.  We think it is high time that all of us who would like to see the return of vibrant salmon and steelhead speak up on this issue with one voice.  
Please check out our suction dredging and high banking page, sign our petition to the governors of Oregon, Washington, Alaska, and Idaho, and pass this all along to others 
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