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 http://www.icmj.com/UserFiles/file/recent-news/Review-of-Available-Suction-Dredging-Studies.pdf 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 http://www.klamathriver.org/Documents/Peter-Moyle-Expert-Report-on-Suction-Dredging-on-Klamath.pdf) 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.  
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50 thoughts on “Dredging Up The Truth

  1. Scott says:

    How come no comments are posted on this in response to your aligations?
    Also, there is much more gold found than you know. I make a profit mining each time I go out. And was making much more when I could dredge. The act of dredging is nothing more than slowly (SLOWLY!) moving small amount of gravel 8 to 10 feet down stream slowly a little at a time. The gravel does not pass through an impeller, it uses a venturi to create suction on the main hose so the small gravel passes through the hose until it gets to the sluice box. Where the heavey metals are captured by the small riffles. This to me is an environmentally friendly method of mining gold. The alternative is to use a shovel, an excuvator, or backhoe, but this will not get most of the gold out of the bedrock crevises liek the dredge will, and thats where most of the gold resides within a streambeds.
    I know I cannot convice you to change your mind about gold dredging, and how wonderfully UNimpactful it is compared to other methods of extracting gold from streams, but I can let you know that you are entiltled to your opinion and thank you for keeping the conversation going.
    What are your thoughts and opinions about rare earth metals for National Defense. Gold is a rare earth metal, and it is used in national defense. Should we rely on foreign countries to supply us with natural resources we have within our borders for Natioanl Defense, that could put us at a disadvantage.
    I know what your thinking, gold dredgers don't find enough gold to make a difference. How would you know? I am just an average miner, and I have found pounds of gold through out my life, and I'm not even a full time miner, because I have a wonderful career in the computer industry.
    But I can assure you, if you enjoy fishing and the outdoors, you would positively love dredging and finding good gold with it.

  2. bob says:


    Nothing was posted because no one other than you responded.  Your post assumes that the gold has to be mined.  That is not a given.  I also question some of your claims particularly as your e-mail is linked to a webbsite that sells mining equipment. You are hardly a disinterested party in the issue.


  3. Scott says:

    Hi Bob, not sure I follow. Comcast.net sells mining equipment, I've never purchased any from them. And I am an interested party in the matter. As for the comment about gold has to be mined, Yes preferribly by me and hopefully they are big nuggets.
    More times than not, I have found fantastic gold dredging and I only had move a few inches of gravel to get to the nuggets wedged in the crevises on the bedrock, man its like suba diving and finding sunken treasure, but instead of gold coins, their gold nuggets worth lots of money.

  4. Rick says:

    Hi Bob…. following you over to your new post.
    Let's get something straight from the beginning here. You assume the small scale suction dredgers were thrown off the rivers due to some sort of scientific evidence. Let's get the facts straight here- the tossing of the miners from the rivers was entirely politically motivated. The source of the miners killing fish fantasy, came from the Karuk Indians who gill net millions of fish a year (obviously no conflict of interest) I believe it started with SB670 being pressured through the Schwartznegger administration- since there virtually was zero lobbying effort on behalf of the mainly small mom and pop mining compaines (due to the fact there is no industry lobby for this rag tag group), it was a no-brainer that the Republican Schartznegger would throw the small miners under the bus. Then came along AB120, railroaded through an entirely Democratically controlled legislature. AB120 was authored by Assemblyman Jared Huffman and it meant to defund the completion of the EIR AND throw the small miners off the rivers; that way, the mis-use of science would never see the light of day. In following AB120 it was amazing the political manuvering shown by the authors of the bill. The bill was hidden from all to see until the day it was voted upon, and then it would disappear again. We were calling representatives up and down the state, and no one had ever heard of the bill, and then suddenly, it was voted on. For such innocous bill affecting such a small industry, it was amazing to see the political manuvering attempted in order to ram this bill through. We talked to several Republican representatives and they told us since the Democrats have a super majority, they don't even get invited to the votes, since all it takes is a majority vote to win, and since the Republicans are  in the minority, they aren't even invited to the votes.
    Now let's take on a few of your points that I can try to address. Now, remember I am not an "expert" in anything, I am just a small businessman who is being railroaded out of my business. Since it appears I have no political support (since the Democrats don't appear to have any sympathy for the small miner businessman), I must try to get my point across in blog rebuttals.
    All of the references you point to in this blog post are to: CA Dept FIsh & Game, Suction Dredge Permitting Program, Literature Review. Apparently I didn't make myself clear in my last statement to you in this regard: the current EIR and all of its references should be suspect. Since the legislature outlawed dredging (because it "may" harm fish- based soley upon the opponents of small mining' claims of damages), the contractor who was chosen to do the research for the EIR, chose to NOT INCLUDE the last 70 years of scientific review which supports the fact that the "damages" caused by dredging are extremely localized and of virtually no significance. Instead, since the "moratorium" was in place, the contractor instead chose to use a baseline for the EIR as if DREDGING HAD NEVER BEEN AN INDUSTRY. So in effect, that is why the whole 2000 page EIR was full of conditional verbs (could have, should have, presumably, maybe, etc). Rather than rely upon proven science, it was thrown out the window and the document was crafted to come to a pre-determined conclusion of damage caused by dredges.
    "The Steelhead runs…" With millions of yards of cement like silt covering millions of acres of timberland, you would think, following your reasoning that since a single dredge dredging in a watershed damages a river, that MILLIONS of YARDS of Silt would ALSO seem to damage rivers. The fish had to come back up the streams to reproduce, and as near as I can tell, the streams are alive with fish as we speak. If a volcano won't disrupt the steelhead, my guess is a couple of dredgers won't either.
    "Invertebrate populations…." And so, Mr Fisherman, since a single dredger working in a 20'x20' area for a season in a watershed does such irrepairable damage in a watershed, what do you think 3 million fishermen walking miles of creek a day will do? At least the small scale dredger stays confined in one area, while the fisherman feels the need to spread his wrath of destruction across miles of river and creekbeds, all in the pursuit of the enjoyment of torturing and killing fish. Who's the bad guy? If the level of scrutiny spent focusing upon the dredger was levelled on the fishermen, the tables would quickly turn as I am sure 3 Million fisherman HAVE to do more damage than 3000 dredgers working single locations do.
    "Suction Dredging damage mimics storm disruption" – Have you ever heard of summertime lightning storms? Especially over recently burned areas? When areas are exposed to extreme fire temps it destablizes the hillsides and during the summertime lightening episodes, you can be assured that in one canyon more sediment will be released than all of the dredgers do all over the state in a season. Yet the fish and other invertebrates survive, as they have done for millions of years previous. The small scale dredger is NOT introducing anything that doesn't already reside in the river systems, and since the dredger is working within the wetted area of the stream, the sedimentation is orders of magnitude less than what a recently denuded hillside would release in a summertime thunderstorm.
    "We clean the gravels"- Well, we DO clean the gravels of the rivers. What other user group, as a integral part of what they do, cleans the rivers as often and effectively than dredgers? We clean all the lost fishing weights, you fishermen left in the rivers; we clean garbage from the rivers left by river rafters, kayakers, flood debris, old cars, old metal, and of course, the dreaded Mercury- we even clean that out of the rivers, but as everyone knows, it is much better to leave 100% of the mercury in the river than to have the dredgers remove 98% of it.
    "Mom and pop businesses"- Like it or not, the small miner supports all of the local communities we work in. In most cases, we live in the same communities. Here's a "shocker" – we also pay local property taxes on our mining claims! Hard to believe it is true, we "freeloaders" pay taxes ( I paid over $1000 a year in local taxes on my mining claims). And we have expenses where we purchase locally produced materials, buy fuel and spend our "findings" in local stores. Hard to believe, but the small rural communities depend upon the profits of the small miners. Now, you throw your big numbers around- $2B fishing industry, but the most important part of that number is- where is that $2B spent? The lion's share goes to State governments and businesses outside of the areas where you fishermen torture and kill fish. The local miners support local business, and from the look of your attack on the small miners, you support economically destroying small communities. And if you look beyond this discussion, you will note that many of your "environmental" brethern are attacking other rural industries because of their lack of your kind of "environmental priorities".
    Bob-  I really like your 2nd to the last sentence, as it describes exactly how we miners feel about the "envriomental non-profits" which have decided to run the small miners out of business – at any expense. Being in the boots of a small miner, you begin to wonder if you stepped into the twilight zone- where up is down, good is bad and no matter what you do to make things right, it is always wrong.
    I would suggest you take some time to review the political railroading which has driven the small miner almost to extinction. And my guess is, the powers that are doing this will soon set their sights on the fishermen population as their damages to the river systems obviously overshadow what the small miners do. Personally, I think this has to do with economically destroying rural America, and I think you may be (witting) or unwittlingly part of the problem.

  5. bob says:


    The only thing politically motivated here are the comments of the retired EPA employees.  And please do not presume to lecture me on what constitutes science and what does not, because I am not sure that you are qualified to judge.  

    In addition, while we are talking politics, it is helpful to note here that you are not only a dredger but a founding member of the Western Mining Alliance (see http://westernminingalliance.org/).  That would have been something to disclose in your earlier posts.  And do you really want to argue that is not an organization with a political and philosophical agenda?  

    Bob Ferris

  6. Rick says:

    Bob- Why are the comments by the Retired EPA scientists politically motivated?- what do they have to gain? They are defending themselves, as I am defending myself. YOU are the attacker. And since you are the science expert (and clearly I am not), maybe you could describe to me your qualifications to be such an expert on science?
    Yes, I am a founding member of WMA, but so what? I started this organization because there was no single voice which seemed to represent the independent mining claim owners and standing up for private property rights of the independent miner. Someone had to do it and I guess I was the schumuck who took the challenge. Believe me, I have my own business to run and this thing takes me away from trying to maintain my diminishing income. I am getting near retirement age and I wanted to have an avocation where I could enjoy the outdoors and make a little money at the same time. I believe in working for a living and in my retirerment, that was my plan- until people like you came along and decided your "river runs through it" aspirations trumped my private property rights, while damning all accepted science and replacing it with science with pre-determined outcomes.
    Yours and many of the environmental non-profits have decided there was big money in running other legit businesses off the rivers and rural areas, much to the benefit of themselves and to the detriment of the the local communities where the mining and other legit activites activity took place. I decided to take a stand- because someone had to. No one makes any money at WMA, we all are working tirelessly to try to slow down the assault upon our private property rights. Your environmental groups seem to have unlimited funds, and plenty of political friends with international money to back them up. The miners are just mom and pops, makiing a honest, decent living while having the opportunity to work in some of the most beautiful country in the world. Who wouldn't want to have a business like that? One thing we can both agree upon is we both enjoy the wilderness and the wildlife. You enjoy the serenity while killing and torturing fish, and I enjoy interacting with the wildlife while mining for gold. If I am working in a hole long enough, I have names for all the fish I share it with- we have a shared co-existence- that is until the fishermen come along to torture or kill the fish.
    WMA was organized to defend our livelihoods from people like you who are constatly attacking us. We are overworked and see no end to the assault on our livelyhoods, so here we sit responding to your un-ending attacks. You are the one who is trying to shut down OUR industry, not the other way around, so why would I have any political agenda trying to defend my industry from YOUR attacks? A better question is why is it so important for you to focus so much attention on putting 3000 independent businessmen  and women out of business? Why do you make no effort to find a happy medium where the dredgers can co-exist? Why is it so important for your groups to run us entirely off the rivers and decimate the economies of the small towns which support our presence? More importantly, what is YOUR AGENDA? 

  7. Scott says:

    Hey, wow, thanks for the link, I can use all the free advertising I can get. I've only lanched about a year ago producing the bucketdigger, the only pull action shovel on the market. I'm very proud of its design and quality. I've sold it to Miners, Archiologists, Landscapers and people that are cleaning silt out off their flooded homes. Oh and a few sand castle builders/sculptors.
    Bob, on another note try to step back from this and look at it with some applied commonsense, example: If I plop my dredge in a stream and dredge down in an area of 3 or 4 feet in diameter to a depth of 3 feet in one day only on Sat and Sun, for just the summer months I'm only affecting a small amount streambed compared to the thousands of miles of stream and rivers out there. I'm talking less than a needle in a haystack. One large tree falls from a high wind into the streambed, it will affect more than my small dredge operation, and there are a lot of trees falling every year.

  8. bob says:

    My qualifications (i.e., 40 years in the field, graduate and undergraduate degrees, appointments, and publications) are all pretty easy to find on any number of electronic sources–knock yourself out.  You can find mine just as easily as I found yours.  

    As to this "Ma and Pa only trying to make a living" arguement –it proves false when you look at gross numbers in California and subtracting the average yields from average expenses.  I am sure some folks are making money but on average that just is not true.   

    And my agenda is pretty darn transperant and has been for decades.  I am a classically trained ecologist who is a proponent for biodiversity preservation and the protection and restoration of endangered species.  I am also a life-long fisherman who believes strongly in clean water as well as preserving and enahncing the opportunities for to experience wilderness as it should be experienced.  

    I run a non-profit with a mission statement right on the front page.  Not a whole lot hidden there.

    Bob Ferris

  9. bob says:

    I suspect you'll find few customers on this site.  Either they would not buy it or they are your colleagues trying to sell something else themselves.

    My point still stands that your unsubstantiated statements lose value when your commercial stake in this debatte is exposed.

    Bob Ferris

  10. Rick says:

    I've made dozens of references about your hobby, fishing. Can you honestly tell me that 3 million fishermen in the state of CA have less impact on the environment than 3000 dredgers, who at any one time may number up to 300 working in California rivers and creeks? I personally have nothing against fishermen, as I used to fish when I was a kid, but now I try to walk with a lighter footprint and try not to kill or torture anything un-necessarily for sport. My mining claims are thick with rattlesnakes, and I don't kill them either- they live there and I am just visiting. If I were living there, and they posed a health issue, maybe my consideration would change, but for now, I am careful where I walk and if I see one, I push it off the trail with my hiking stick.

  11. bob says:

    Actually the number is closer to 2 million and I suspect that not all of them are on the water at the same time and many of those only fish in saltwater, lakes or reservoirs.  And some of those cruise through on boats, never touching the bottom.  But when I think about times that I have fished in streams or rivers, I can think of nothing that I have ever done that would leave more than a momentary impact and certainly nothing that would be in evidence days or months later or a year or more.  I have also participated in innumerable clean up and restoration activities on beaches and waterways and the garbage found is generally not associated with fishermen.  

    And I used to dig up creeks looking for gold when I was a young boy in California, but as I matured I lost interest in that sort of thing.

    Bob Ferris

  12. Scott says:

    I've been selling the bucketdigger for a little over a year, I've been mining for gold 40 years now. And my primary motivation for designing and producing the bucketdigger was to help people dig more efficiently with a pull action shovel, which has a hugh benefit for people with back issues. Plus the muscles for pulling are much stronger than the muscles lifting using a regular shovel. I have many other products that will be bringing to the market in the next few years all non-mining related, I just put the bucketdigger first to gain the experience in producing a product. The American dream.
    As for the unsubstatiated statements, for sure you don't have to beleive me, why should you. Also, don't think you can't find a bonanza in gold in modern times, because I know of 3 people in modern times that have found gold bonanzas. Isn't that the american dream 

  13. Scott says:

    Hi Bob, just read your post about when you used to prospect for gold. Let me tell you its not easy and it can get discouraging when you don't find any. But I can assure you there is a fantastic amount of gold still left out there in Calif. Many places you don't even have to work very hard. Thats why people file mining claims when they make a strike. Just like you have a talent in Ecology, I have a talent for finding gold. But this is for sure, a dredge is without doubt the most unimpactful method to mine for gold in a stream or river. I am sensitive to the water and environment. I've mined so many times when the stream was chocolate brown from natural erosion, even dredging in it blind, keeping my head above water. And I would not put all that hard work in, and beleve me its very hard work, if I was not getting a positive return, ie profit. When I was young, I had a paper route, and mowed lawns, washed cars, painted addresses and even worked at feed store for extra money, but never made more money than dredging for gold when I was a teenager. Maybe I'm the exception, but I can tell you this, I'm in excellent physical condition from gold mining, and would be in even better condition if I was dredging again.

  14. Rick says:

    I can assure you that although you don't feel that you leave more than a momentary impact, what about the fisherman which follows your same footsteps on the same day or following days? I live in a very popular trout fishing area and from my dining room I can see one of the most popular parts of our local trophy stream being trampled daily – different fishermen each day, wanting the "a river flows through it" experience and enjoying the serenity of the experience, yet they are following the well worn paths of the scores of other fishermen from month's before walking up and down the same trail, standing in the same pools, wading in the same spots- day in and day out. None of these people have an evil intent, and they are enjoying their experience as we the dredger enjoy ours. The main point is that the riverbeds are being trampled by the same people who feel my dredging my 10 foot diameter hole is bad for the environment. It is all too easy to push the blame on someone else, but the overall point is that if you are out in the wilderness and you are using an area that someone else has used, you are damaging the wildlife. We all are guilty- my concern is that the small scale dredgers are being singled out. If you are going to shut down small scale gold dredging, then shut down all reclaimation dredging and cull the fishermen from the sides of the rivers too. Let the fishermen fish from boats on lakes.
    Reclaimation dredgers use the same equipment- only bigger. They muddy up the rivers for miles, and yet the small scale gold miner is the one who is singled out as "destroying the environment".
    One of the big ironies of this whole experience is the Sierra Fund in Nevada City, CA has been responsible for a lot of the anti-gold dredging sentiment. They were instrumental in running the miners off the rivers because " the small scale gold dredgers ONLY recovered 98% of the mercury which went through their sluice boxes" – imagine that- only a recovery rate of 98%. Name ANY OTHER INDUSTRY which has a 98% recovery rate on ANYTHING. So they shut down small scale gold dredging and then they apply for a $9M taxpayer funded grant to dredge mercury from a local lake, using a dredge that is 85% efficient at recovering mercury. Now, explain to me the logic of this? They run the small miners out because we are destroying the environment, but when there is money to be made, a dredge is ok.
    I appreciate the fact that you lost interest in mining, as I lost interest in fishing. The difference is that I am not campaigning to end fishing because I don't do it. Rather than destroy some of the few locally owned businesses, it would be better received if you worked with the mining community to find a comprimise where it would be a win/win for everyone involved and rural businessmen wouldn't be thrown out of jobs.
    What happened to the environmental groups fighting the big polluting corporations? Why are you turning on the little guy? Could it perhaps be that the big guys are funding you to run the little guys out of town. Maybe time for some soul searching.

  15. bob says:

    I know the area as my family has visited the Tahoe region for 60 years and my parents still live in Auburn. There is a big difference between tromping with your feet and operating a machine that moves 16 cubic yards of material an hour. And although the Sierra Fund has done good work, I think that you will find that opposition to your activities is broader and deeper than you realize.

    Bob Ferris

  16. Joe Greeneg says:

    I do not want to spend a lot of time in details that your readers will not understand so I will do as you did and cite references so I can abbreviate my comments.
    First off, Bob, it is clear to me that you are not a biological scientist although you are well read in the subject of small-scale gold suction dredging.  There is nothing in your background (with a BA in environmental studies and M in zoology) that makes you better suited to advocate against suction dredge mining versus my 25+years of actual work in the field of aquatic and biological sciences. Let’s be honest Bob, your life career in building construction does not place you in any position to be an expert on the effects of dredging.
    With that out of the way let’s look at your first position under “There is not a single study that shows that suction dredging kills fish”.  You stated that this is misleading because “the issues are not primarily about adult fish but rather spawning beds, eggs, young fish……”.  I agree.  However, the miner that made that statement did so because that is the way the environmentalists frame the discussion. 
    I also agree that the study by Griffith and Andrews (1981) states that “un-eyed cutthroat trout eggs experienced 100% mortality.”  However, “eyed cutthroat trout eggs showed means of 29 and 35% for 1-hr and 36-hr mortalities, respectively.”  And, of course, the abstract goes on with more information.  I also agree with your statement that California has temporarily banned suction dredging while it is allowed, under permit, by Oregon, Washington, and Idaho.
    The problem I have with your position that suction dredging kills fish eggs, larvae, etc. is that it lacks analysis and appropriate interpretation. If you had shown minimal understanding of the subject you would have to conclude that your accusation that dredging kills fish is totally fallacious.  WHY YOU ASK!!!
    If you understood anything about the small-scale gold suction dredging permitting system, in all the states you listed, you would know that they are designed primarily to protect the salmonid species.  The States have designated in-water-work-periods (during spawning, incubation, swim-up and migration seasons) in which dredging is not allowed in order to protect these sensitive life stages.
    So, Bob, you misapplied sound science, out of context, to make a point that dredging kills fish that is entirely wrong.  Furthermore, you then attach a link to the CDFG site and page of the literature review developed for the purpose of preparing the $1.3 Draft Subsequent Environmental Impact Report.  A staff of contractors with multiple college degrees in appropriate scientific areas evaluated this literature (that you referenced) in regards to how these results might be influenced by the operation of a small-scale gold suction dredge’
    What did they find?
    Impact BIOFISH1: Direct Effects on Spawning Fish and their Habitat (Less than Significant)Draft Subsequent Environmental Impact Report 4.3-23
    Impact BIOFISH2: Direct Entrainment, Displacement or Burial of Eggs, Larvae and Mollusks (Less than Significant) Draft Subsequent Environmental Impact Report 4.3-25
    Impact BIOFISH3: Effects on Early Life Stage Development (Less than Significant) Draft Subsequent Environmental Impact Report 4.3-29
    Impact BIOFISH4: Direct Entrainment of Juvenile or Adult Fish in a Suction Dredge (Less than Significant) Draft Subsequent Environmental Impact Report 4.3-31
    Impact BIOFISH5: Behavioral Effects on Juvenile or Adults (Less than Significant) Draft Subsequent Environmental Impact Report 4.3-33
    Impact BIOFISH6: Effects on Movement/Migration (Less than Significant)
    Draft Subsequent Environmental Impact Report 4.3-35
    Impact BIOFISH7: Effects on the Benthic Community/Prey Base (Less than Significant) Draft Subsequent Environmental Impact Report 4.3-37

  17. Joe Greeneg says:

    I do not want to continually beat this dead horse.  But, you were critical of a miner’s comment regarding turbidity.  He raises this issue because, in Oregon, the small-scale gold dredging permit regulates turbidity not siltation.  Once again you are wrong.  The discussion was “Turbidity does not harm fish”.  I agree that siltation might be deleterious at some times.  However, when fish redds are present, and small-scale gold suction dredgers are not, the greatest siltation occurs through the natural movement of sediment by mother nature.  So, once again, what was the final analysis of the $1.3 study financed by the California Department of Fish and Game?  They follow:
    Impact WQ3. Effects of Turbidity/TSS Discharges from Suction Dredging (Less than Significant) Draft Subsequent Environmental Impact Report 4.2-28
    Impact GEO1: Erosion, Transport, and Deposition of Alluvial Material in Rivers and Streams Resulting in Dredge Potholes, Tailings Piles, and Other Suspension/Depositional Features (Less than Significant) Draft Subsequent Environmental Impact Report 4.1-13
    Impact GEO 2: Destabilization of the Streambanks (Less than Significant) Draft Subsequent Environmental Impact Report 4.1-21
    Impact GEO3: Destabilization of Channel Bed Forms such as Riffle and Bars (Less than Significant) Draft Subsequent Environmental Impact Report 4.1-22
    Impact GEO4: Destabilization of Channel Profile (Less than Significant) Draft Subsequent Environmental Impact Report 4.1-23
    Impact GEO5: Streamflow Channelization, Diversion, or Obstruction (Less than
    Significant) Draft Subsequent Environmental Impact Report 4.1-25
    And, remember the TSS in the “Impact WQ-3” refers to total suspended solids which in essence is a measure for the potential for siltation.
    Would you like me to go on? 
    You see Bob, I was truly concerned about the environmental consequences of small-scale gold suction dredging.  I set my biases and preconceived notions aside and investigated the subject in an unbiased fashion.  I am not a retarded old has been dragging myself out of retirement as you might wish.  Because of prejudiced and misguided folks like you I have never been able to retire.  If you want to test my resolve just keep throwing the misinformation and insults my way.  I have dealt with real scientists with disagreements that we discussed in an amicable conversation.  You are well spoken but you are not well informed and show no penchant for data analysis.  I hold that as my judgment of you so far because the alternate conclusion would not be flattering.  But, your cheap personal shot in lieu of respectable sound discourse has colored my opinion of you and your cohorts.
    Joseph C. Greene
    Research Biologist/Ecotoxicologist
    U.S. Environmental Protection Agency (retired)

  18. Rick says:

    Bob- it wouldn't let me reply on your last post as there was no "reply" button, so I have to start a new thread: Who's dredge moves 16 cu yards an hour? I am lucky to move a cubic yard a day. I guess in ideal dredging conditions where there is all sand, perhaps you could get those kind of numbers, but where I work, I literally spend hours just moving rocks out of the way so I can run the dredge for an hour or two to maybe (if I am lucky) move a cubic yard a DAY. Maybe the dredge manufacturers state those kind of numbers, but in real life situations, 1-2 yards a day is a norm and in my case, is a dream.
    So using my numbers of a cubic yard a day, vs 2 million foot steps in the rivers, who is doing the majority of the damage? It certainly isn't the small scale gold dredgers.
    I realize that the independent miner is fighting a David vs Goliath battle. The environmental non-profits have deep political connections, big money, and international support and the small independent miners have literally none of this. We have enough trouble trying to organize as all of us are individualists and we generally put our heads down and go to work- organizing to fight overwhelming odds is not something any of us have any experience with. But we have been backed into a corner and we are literally fighting for our livelihoods while you are battling us so you can have a quiet place to fish. Maybe that explains our passion.
    Look, in any other circumstance, you and I could probably be good friends. I read your linkedin page and it seems you have done a lot of good stuff in your past. It seems at one point in your life, you actually looked out for the little guys, but now for some reason, you are siding with entities which are dead set on destroying private property rights and the right for private property owners to use their property in an environmentally conscious way. Why is it that you feel compelled to drive a viable environmentally clean small business out of existence? For the last 150 years there has been other forms of river mining that were orders of magnitude larger than the small scale gold dredgers working in the rivers, and yet, none of the supposed damage you cite with the small dredgers has ever occured even with the likes of bucket dragging and commercial dredging operations. And might I (again) remind you that reclaimation dredging occurs EVERYWHERE, and yet there appears to be no issue with that, yet as soon as I put my 4" dredge in the water, the health of the whole watershed is at stake. Apparently the watershed knows the difference between my 4" dredge and all the devistation it causes, while a 16" cutterhead dredge causes no harm at all.
    If the evironmentalists are so sure about their scientific merits of their viewpoint, why do they have to resort to dirty politics to get bills passed? When the EIR (flawed as it was) was being worked on by an pro-environmental organization (Horizon Environmental) and the document was being written in such a way that it only highlighted the facts as the envionmental non-profits saw fit; why did the dirty politicians feel the need to float a bill which in one point demanded a arbitrary 5 year moratorium until the "facts were presented" AND at the same time sought to defund the completion of the EIR? Does that make any kind of sense? If you base your argument on facts, why would you want to defund the study which was exposing the facts?  And then again, most recently this year, again the environmental non-profits sent out a bill which arbitrarily chose to eliminate the sunset clause of the first bill? This was the "invisible bill" which was impossible to track, no representative ever saw it, no one knew where it was, it had no name, no number and it only surfaced in time for a yes vote, and then it disappeared again. Why are these sort of dirty tricks needed when an even-handed scientific review would have been enough? Especially considering that the industry you are set to destroy has ZERO pushback, no lobbyists, no money and was just a handful of small business people trying to make a living for themselves. If you environmental groups want to do something POSITIVE, maybe help rural america CREATE MORE SMALL BUSINESSES, rather than destroying them. You guys are really good at running small businessmen out of business, maybe it is time to try to improve the economy, rather than destroy it.

  19. bob says:

    And once again your comments are misleading about my comments re: turbidity.


  20. bob says:


    Dear Joe,
    Since I did not mention you by name in my 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 (Please see http://www.goldprospectors.org/Communication/ArticlesandInformation/tabid/153/EntryId/611/EPA-out-of-control-PLP-says.aspx)
    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 travelling power point presentation and advocacy (please see http://westernminingalliance.org/wp-content/uploads/2012/06/GREENE-2012-Small-scale-Gold-Suction-Dredging-Under-Attack-v.-07-1.ppt)  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, 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.  
  21. richard engstrand says:

    Hi Bob.
    I have an idea for a compromise, if you'd like to hear it.  Given the fact that we dredgers are operating legally as of now, and given that we, humans, are at least important as fish, how about mitigating the forceable
    removal of small scale suction dredge miners from YOUR watersheds.  I know mitigation is a common practice in environmental issues, and has been used to resolve conflicts for many years.  To mitigate the adverse economic impacts to suction dredgers, how about hiring them instead to accompany you and your fellow fishermen into your pristine wilderness watersheds when you decide to go kill some fish.  Although most do not possess advanced degrees in ecology, i'm sure they could still be useful.  For instance they could retrieve broken fishing line with lead weights.  They can carry bags/pouches of native riparian plants along with hoe and shovel to mitigate the compaction of pathways to the streambanks.  They can even be used as errand boys to get additional live fish from holding tanks in your  eco-vehicle.  These fish can replace the dead or tortured fish from your favorite hole; therefore nobody loses.  I know you'll have no problem paying these former miners minimum wage plus a pro-rating for their prior investment in valid mining claims, given your proven skill at accumulating other peoples money.  You surely have enough money in your budget to buy the legislative influence to make this happen.  Oh, and as an insigificant concession, how about paying them in gold, as they, foolishly, do not believe in the lasting value of paper money.  So, compromise on this issue can have beneficial conseqences for both parties, don't you think?
    P.S.  For an additional charge, former dredgers might be persuaded to carry along a boombox with tapes of John Denver singing "Rocky Mountain High" or the theme song from "Jeremiah Johnson" as well as audio tapes on the subject of how to return to a pre-industrial society.   

  22. Gabe says:

     I appreciate the way you are defending your lifestyle, and doing your best to apply the science to the situation. You are suffering from one false assumption though that I want to clear up. By way of disclosure, I'm Cascadia's Alaska rep, have been since 1998 (with some breaks for school). Two things about us you should know:
    1. There has never been, and never will be, any "big money" involved in our work. Not even close. We scrap and scrape for every dime, and every bit of money we raise goes directly back into our work on the ground. Any idea you have that our positions are motivated by wealth-generation for ourselves is dead wrong. 
    2. We have no interest per se in running people or industries out of business. Be they loggers, miners, fishermen, or oilfield workers. We respect what you do and who you are. What our agendia IS is to conserve the wildlands of our bioregion. Period. And it so happens that suction dredge mining, based on the science, looks to be incompatible with the wild fisheries that are the foundation of sustainability on the forest. We take zero pleasure (and derive zero money) from the negative effect banning it would have on folks like you. If you know of some compromise that would allow for coexistence, then we'd love to hear your idea. But spouting off about how dredging has zero effect on fisheries, when the science tells us otherwise, isn't going to change our stance. That line reminds me of the loggers who used to insist that clearcutting old-growth trees was good for wildlife and had no impact on fisheries. What that signals to us is someone who is locked in to a perspective and isn't listening to evidence, and the policy response to such an industry needs to be banning it. 
    P.S. – I have a little different perspective than Bob and think you make a reasonable point that millions of fishermen on the creeks aren't a totally benign presence. If some evidence & science emerged that something or other about recreational fishing is having an unsustainable impact on our wildlands, then that is something that we'd absolutely pay attention to. Haven't seen it though. Another difference is that anglers seem to have a great deal of respect for the natural systems they interact with, and tend to adapt their activity to tread lightly.

  23. bob says:

    Hey Gabe,

    We likely see eye-to-eye on the fisheries impact of anglers.  And where impacts have been demonstrated, I am totally in support of taking actions to improve or correct those situations.  While working on the Chesapeake Bay I took some unpopular positions on seasonal fisheries restrictions as well as gear restrictions.  

    Bob Ferris

  24. Rick says:

    Gabe- finally a voice of reason.
    1. To wit- no money in your business? You are a non-profit, I know Bob probably draws a salary, and do you too? My guess it is enough to live on and as chasing down the "big polluters" dwindles or perhaps you tire of fighting their well-funded defense attorneys, perhaps you are lowering your sights to focus on battles you can easily win, to show your supporters that you are accomplishing something and to assure the donations keep coming in.
    2. You respect us? Really? You're the first environmental representative who hasn't looked down their nose at us in sheer distain. Your agenda is to conserve the wildlands? To what end? You and I both agree that there may be possible damage caused by fishermen walking up and down the creeks- any yet, (by your thinking foisted upon the small scale dredgers) that should appear to be ample evidence enough to run the fishermen off the creeks unless THEY PROVE they AREN'T damaging the ecosystem, isn't it? Small scale gold dredging has be occuring for over 100 years, and I ask you to show me one shred of evidence of the supposed damages caused by the un-interrupted assault on the environment by the dredgers. Where is the evidence? Where are all the dead fish? The destroyed benethic ecosystems? They don't exist, because dredging doesn't damage them. Show me the evidence of damage, not just assumptions. You guys are turning the justice system around- where up is down and down is up-  in the justice system I grew up in, you were innocent until proven guilty. Now the environmentalists suspect damages which MAY, COULD, SHOULD happen- but alas there is no evidence of IT HAPPENING; but because it is suspected, the small scale dredgers are gulity until we prove ourselves innocent. And with a little political back room dealing, we are un-ceremoniously legislated off the rivers without a shred of evidence of damages (just suspicions). Maybe the same sort of justice ought to levied upon the rafters, fishermen, kayakers, and day users too. Like it or not EVERYONE who enters the wilderness has a negative affect. If you are hiking across a stream, you are disturbing benethic insects, and thus you are killing wildlife and damaging the ecosystem. Yet, Mt Saint Helens blows and destroys millions of acres of forest, and it is accepted as nature at its finest.  So to follow your premise of protecting the environment, where do you stop accusing innocent people of environmental damages and then making them prove they aren't harming anything? The irony of this whole thing is that while the small scale dredgers are singled out, reclaimation dredging which uses essentially the same equipment, on a much larger scale, and not having the high mercury recovery rate that small dredgers have, are somehow immune from the "guilty until proven innocent" assault and thus are allowed to work away un-impeded. Apparently the environment, itself knows that when suction dredge miners are working, they are destroying it, and when reclaimation dredgers are working they are improving the environment. I get it. It makes perfect sense to me. 
    What REALLY needs to happen (and the dredgers cannot afford to pay for it & the environmentalists won't pay for it) is there needs to be a multi-year study of a region of river where for a year or so a baseline is created studying populations of assorted species. In the following year, let a small scale dredger come in and do his business, with no restraints and while and after he finishes the study is recorded to see what REALLY is happening. So far all the studies SIMULATE what MAY or COULD happen, but don't actually show what REALLY HAPPENS. The State of California wouldn't allow that study to take place, although it was planned for Humbug creek. But what it did find was the amount of mercury coming off a 3" dredge was insignificant.
    So here the miner has been run off the rivers on the assumption that there is damage (because studies show it should, could or may cause damage- not because it DID cause damage). So far the environmental movement has been very effective of accusing industry of damages and running them out of town on a rail because they cannot prove they don't cause damage- so where does this end? When you run out of donations by the private foundations who have something to gain by reduced rural populations? The way you guys are going, you are going to shut down all small businesses in the rural communities in the near future. In order to begin to fight this onslaught on the rural businesmen, there are groups forming (Defend Rural America, for one), consisting of small businessmen, farmers, ranchers, and other outdoor users who are getting tired of environmental organizations suing to have regulations changed to the point that the new regulations  mandate what we do every minute of our lives, to the point of insanity. This problem isn't only the small dredgers problem, it is the problem of all small business people in rural communities. Your organization may not be responsible for all the lost business and ruined rural economies, but there are many more of you who are accomplishing the deed across the country. Where does it end? Will you stop when you run everyone out of the wilderness? Will the wilds become the King's forest, where only the king and his friends (Bob and his fisher-friends) are allowed to sling lead and slay fish? Inquring minds want to know.
    What is difficult to get through your thick environmentalist heads is EVERYONE who works in the wilds does it because they enjoy the outdoors. We ALL want to see clean watersheds and abundant wildlife. But you need to realize that we all impact the outdoor environment. When you are driving your Prius and it has a small oil leak, that oil ultimately ends up in some watershed somewhere- you are damaging the environment. The only answer you guys spout is the run everyone out of the back country.
    Your views are very passionate, but in my opinion, very myoptic. Your passion over-rules your sense of reasoning and logic. You have become religious zealots for the religion of the environment and nothing will stand in your way until you destroy all rural industry in order to achieve your idyllic view.

  25. bob says:


    In addition, USGS scientists found that present-day suction dredging can be problematic if used as a management tool to remove mercury from the environment.
    “The use of suction dredging to remove mercury at the South Yuba River and Humbug Creek confluence area would likely result in more mercury-laden particles moving downstream,” said USGS research scientist Charles Alpers, a co-author of the two USGS reports.  
    Although a typical suction dredge may be effective in capturing larger sand-sized particles of mercury and gold-mercury amalgam, Alpers said it is ineffective in capturing finer-grained sediment particles that carry the most mercury. Instead, these smaller particles and the mercury in them, if mobilized by dredging, stay suspended in the water for days and may be carried great distances downstream, increasing the possibility of methylmercury entering the food web.
    Please stop with the mercury myth…
  26. Joe Greeneg says:

    Hi Bob,
    As time allows I will get back to you on the comments in this section.
    I see you just cannot let go of the cheap assaults on me personally.
    You stated," 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".
    I think you would find that USEPA researchers are very interactive with their peers and work very diligently outside the laboratory supporting and disseminating the fruits of their efforts.  That is just good "bang for the buck" spent on the research by the taxpaying citizens.  When you chose the term “notoriety” I assume you referred to the definition of “the character of being widely known”.  Thanks for your concern about my lack of notoriety, but it is un-necessary. 
    I have over 30-years of national and international professional experience, including consulting, research and teaching, for both government regulatory agencies and industry.  Throughout my career I was busy with some of the following.  Sorry to disappoint you that I was not sitting in a deep dark hole of a laboratory for 30-years.  I was busy with…………..
    Technical Advisor to Environment Canada

    Member Environment Canada’s External Advisory Committee on Development of Guidance Document for Environmental Toxicological Data Interpretation and Application;
    External reviewer for the “Toxicity Data Interpretation and Application Guidance Manual in support of the Environment Canada Steering Committee;
    Provide an International Review of toxicity bioassay protocols for use in the assessment of contaminated sites under the Canadian Governments National Contaminated Sites Assessment Program;
    Member, Canadian Intergovernmental Aquatic Toxicity Group Subcommittee, Microplate Growth Inhibition test Using Selenastrum capricornutum, Environment Canada;
    Waste Management Division, Ottawa, Ontario. Participation led to an agreement to include a waste extraction procedure for hazardous wastes with a biological testing component included;
    Oil, Gas and Energy Division, Ottawa, Ontario, Technical advisor to Environment Canada and the Canadian Petroleum Association, Participation led to a procedure for determining the character and environmental hazard of natural gas processing industrial waste sludge which includes a biological testing component;
    Technical advisor to Environment Canada and the Canadian Petroleum Association, Participation led to a procedure for determining the character and environmental hazard of natural gas processing industrial waste sludge which includes a biological testing component.

    Committees. Commissions and Boards

    Joint Task Group Chairman, American Public Health Association, Standard Methods for the Examination of Water and Wastewater, Committee on Part 8111, Biostimulation (Algal Productivity);
    Scientific Advisory Group Member, Canadian Association of Petroleum Producers, Testing of Toxicity Based Methods to Develop Site-Specific Cleanup Objectives;
    Member, Middle Snake River (Idaho) Nutrient Management Technical Advisory Committee;
    Chairman, American Society for Testing and Materials, Task Group for a Proposed Standard Guide for Conducting Static Chronic 96-h Toxicity tests on Hazardous Chemical Wastes Using the Freshwater Alga Selenastrun capricornutum;
    Co-Chairman, American Society for Testing and Materials, Task Group for a Proposed Standard Guide for Conducting Seed Germination and Root Elongation Soil Elutriate Chronic Toxicity Bioassays;
    Co-Chairman, American Society for Testing and Materials, Task Group for a Proposed Standard Guide for Conducting Seedling Emergence Toxicity Tests in Soils or Sediments from Hazardous Waste Sites;
    Member, Organization for International Standards (ISO), Technical Advisory Group for the United States, International Standards Committee, Technical Committee 147 for Water Quality, Subcommittee 5 for Aquatic Toxicology;
    Chairman, American Society for Testing and Materials, Task Group for A Standard Guide for Conducting Static 96-H Toxicity Tests with Micro algae;
    Reviewer, Journal of the Society of Environmental Toxicology and Chemistry (SETAC;
    Reviewer, Acute Lethality Test Method Documents, Environment Canada, Conservation and Protection, Ottawa, Ontario, Canada;
    Reviewer, Archives of Environmental Contamination and Toxicology;
    Reviewer, Journal of Water, Air and Soil Pollution;
    Chairman, American Society for Testing and Materials, Committee on A Standard Practice for Algae Growth Potential Testing with Selenastrum capricornutum;
    Chairman, American Public Health Association, Standards for the Examination of Water and Waste Water, Task Committee on Part 802, Biostimulation (Algal Productivity);
    Chairman, American Public Health Association, Standards for the Examination of Water and Waste Water, Task Committee on Part 803, Toxicity Testing with Phytoplankton.

    Professional Societies

    Society of Environmental Toxicology and Chemistry (Charter member);
    American Society for Testing and Materials;
    Pacific NW Society of Environmental Toxicology and Chemistry (Charter Member);
    Hazardous Materials Control Resources Institute;
    Water Environment Federation.

    Professional Recognition

    Sigma Xi, the Scientific Research Society;
    Intergovernmental Personnel Act (IPA) exchange with Oregon State University, Department of Civil Engineering, Western Regional Hazardous Substance Research Center;
    Courtesy Faculty Appointment, Adjunct Professor, Oregon State University, Department of Civil Engineering.


    Technical Contribution Award, U.S. Environmental Protection Agency, Environmental Research Laboratory, Corvallis OR;
    Nomination for the Scientific and Technological Achievement Award for the research publication “Comparative Toxicology of Laboratory Organisms for Assessing Hazardous Waste Sites,” U.S. Environmental Protection Agency, Office of Research and Development, Washington, DC;
    Nominated for The Gold Medal for Scientific Achievement, U.S. Environmental Protection Agency, Office of the Administrator, Washington. D.C;
    Special Achievement Award for Noteworthy Contribution in the Environmental Protection Agency, Environmental Research Laboratory, Corvallis, OR;
    Special Service Award for Special achievement in the Environmental Protection Agency, Environmental Research laboratory, Corvallis, OR;
    Special Achievement Award, U.S Environmental Protection Agency, Environmental Protection Agency, Corvallis, OR.

  27. bob says:

    Both the U.S. Environmental Protection Agency and the State Water Resources Control Board expressed serious misgivings about the new regulations and suggested that an ongoing moratorium was the policy best supported by science. (See http://articles.latimes.com/2012/apr/05/opinion/la-ed-gold-mining-dredge-20120405) Joe, There is no doubt that you have accomplished some milestones in your thirty year career. Does that make you a remarkable and noteworthy scientist? No. And does that excuse your current unethical and contrarian activities? No. None of your past is relevant. What is relevant is that you are Treasurer and Membership Coordinator for the Millennium Diggers (http://www.millenniumdiggers.com/us.shtml) and are serving as the de facto scientific spokesperson for the dredging industry. Your former EPA affiliation means little because your agency disagrees with your position (see above quote). So you are arguing a view not held by an array of experts in a field where you are not currently and never have been a player and you have this conflict of interest which further compromises all that you say and claim. It is not a pretty picture. Can you honestly say that you could take the amateurish and politically laced power point presentation (see http://westernminingalliance.org/wp-content/uploads/2012/06/GREENE-2012-Small-scale-Gold-Suction-Dredging-Under-Attack-v.-07-1.ppt) that you are currently using to a meeting of scientists and not get laughed out of the room? Have you forgotten in your 10 years of retirement so much about how scientific debates are conducted and defended and what constitutes ethical behavior? I continue to stand by my earlier critique of your behavior (see http://www.cascwild.org/general-response-to-joe-greene/) and nothing that you have said here changes that opinion an iota. –Bob Ferris

  28. Joe Greeneg says:

    Hi Bob,
    You start out, "Both the U.S. Environmental Protection Agency and the State Water Resources Control Board expressed serious misgivings about the new regulations.  This is just a line from a newspaper.  Would you by any chance have knowledge of where we could actually read these statements and see who said them?  I would like to see them in their full context to understand the specific issues that they have raised.
    My response to your statement, " 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" were totally appropriate because you questioned my notoriety as a "federal bureaucrat.  That is why you received the that answer.
    I am a member of small family oriented recreational group, the Millennium Diggers, that enjoys rockhounding, metal detecting and gold mining.  We have in the neighborhood of about 30 members.  So what?
    You recall some time back I said, “So let us get past all this crap and get back to the science of the issue”. I guess you just cannot resist attacking me personally rather than discussing the specific issues.
    You continually charge me with being “unethical and having contrarian activities” and a “conflict of interest”.  Let’s examine that accusation.  Since you just throw out the accusations without explanation.
    OBJECTIVITY may be understood as synonymous with neutrality.  I explained that back in early 2000 I was hearing charges from the environmental community that suction dredging was harming fish and the environment.  I had been an environmentalist for years. And, I was very concerned about what I might be doing that was harmful.  (By-the-way, at this time I was a member of the Sierra Club, Nature Conservancy, National Parks Association and many other environmental organizations).  As a research scientist I was in the enviable position of having knowledge and resources to investigate these claims.  To my surprise, and relief, I found these claims against small-scale gold suction dredging to be false by misrepresentation of the data.  Just as you are doing on your site today. 
    I believed that there was a misunderstanding of the data in the environmental community.  I felt if I could sit down and discuss the data with the proclaimed environmentalists we could come do a reasonable understanding.  It actually took me years to accept the fact that the attack on suction dredging had nothing to do with science, protecting the environment, or saving the salmon.  This attack is all about removing a segment of society from the environment that certain individuals have chosen to attack.
    At this time I was completely neutral and objective.  I still strive to maintain that objectivity in all reviews of the mining and fisheries literature and how the data might be analyzed to understand if and how it could be used to understand the environmental effects of small-scale gold suction dredge mining. 
    Where I lose all objectivity is when I have to listen to you and others in your anti-mining community when you charge that suction dredging kills fish.  We have already discussed this you clarified that you meant not adult fish, but eggs, fry, and sensitive early life stages.  When I point out to you that the State’s small-scale gold suction dredging permitting systems prevent that by defining in-water-work-periods down to specifically named streams and rivers you just ignore the fact.  The fact is that small-scale miners are not mining during the seasons when sensitive salmonid life stages are present.
    Transparency as used in science, in a social context more generally, implies openness, communication, and accountability. Transparency is operating in such a way that it is easy for others to see what actions are performed,  There are no secrets that I try to support the small-scale gold suction dredging against attacks by environmental organizations.  That issue was so open and clear that the California Department of Fish and Game invited me to be a member of the Public Advisory Committee on Suction Dredging.
    A conflict of interest situation may occur when an individual tries to accomplish personal goals as a result of being in a certain profession.  I am retired and no longer associated with the USEPA or Oregon State University.  If I wanted I could choose to be a paid consultant for either side that would like to hire me. I chose not to go that route. After seeing all the distortions and misinformation regarding the effects of suction dredging on fish I choose to support the small-scale mining community.  I am not paid for what I do.
    Integrity In ethics, integrity is regarded as the honesty and truthfulness or accuracy of one's actions.  When I am analyzing an issue I make every effort to accumulate all relevant data.  I do my best to synthesize the information and let the chips fall where they may.  If I had found serious effects caused by small scale-gold suction dredgers I would have informed them of that finding.  There are a lot of smart miners out there that would view any such issue as a challenge to determine if they could find a solution and still dredge.  The environmentalists choose to characterize these miners as crazy wild men and women bent on destroying nature.  The fact is these folks are taxpayers like you, environmentalists like you, and fishermen like you.  We are all not all that different.
    Respectfulness gives a positive feeling of esteem or deference for a person.  Rude conduct is usually considered to indicate a lack of respect.  It seems we may both be guilty of a failure here.  Sorry.  My goal in this discussion has always been to discuss our differences in how or why we perceive the same data differently.  When I presented all the results from the $1.3 million dollar (sorry did not get that fully written out previously) Subsequent Environmental Impact Statement on Suction dredging you essentially ignored the facts and continued your personal attack on me.
    You stated, “So you are arguing a view not held by an array of experts in a field where you are not currently and never have been a played….”  I will just repeat my answer that I stated previously. 
    The State of California, California Department of Fish and Game spent $1.3 million dollars for an analysis of the effects of small-scale gold suction dredging on the environment. A staff of contractors (array of experts as you said)with multiple college degrees in appropriate scientific areas evaluated this literature (that you referenced) in regards to how these results might be influenced by the operation of a small-scale gold suction dredge.  What did they find?
    Impact BIOFISH1: Direct Effects on Spawning Fish and their Habitat (Less than Significant) Draft Subsequent Environmental Impact Report 4.3-23
    Impact BIOFISH2: Direct Entrainment, Displacement or Burial of Eggs, Larvae and Mollusks (Less than Significant) Draft Subsequent Environmental Impact Report 4.3-25
    Impact BIOFISH3: Effects on Early Life Stage Development (Less than Significant) Draft Subsequent Environmental Impact Report 4.3-29
    Impact BIOFISH4: Direct Entrainment of Juvenile or Adult Fish in a Suction Dredge (Less than Significant) Draft Subsequent Environmental Impact Report 4.3-31
    Impact BIOFISH5: Behavioral Effects on Juvenile or Adults (Less than Significant) Draft Subsequent Environmental Impact Report 4.3-33
    Impact BIOFISH6: Effects on Movement/Migration (Less than Significant)
    Draft Subsequent Environmental Impact Report 4.3-35
    Impact BIOFISH7: Effects on the Benthic Community/Prey Base (Less than Significant) Draft Subsequent Environmental Impact Report 4.3-37
    Bob, it is not me that “cherry picks” and continues to turn a blind eye to the published facts.
    Your opinion of the PowerPoint presentation is what it is.  I cannot change that.  I will point out that any slide that contains published data has the reference printed at the bottom so anyone can check out the source.  Anyone willing to take the time can go and check the whole publication.
    You stated, “And your quoting of water chemistry conclusions from a nearly 75-year old study is pretty much laughable—what professional scientist would do that?” In regards to the 1938 comment by Ward that I included.  I thought it was very interesting and informative.  I believe that many folks would be surprised to learn that salmonids swam through and survived the mud flows that, back then, were still called rivers.  For clarification, the rivers were running full of mud at this time because mining by water cannon (monitors) was allowed.
    Again you mischaracterize this citation.  Ward was not reporting a measured chemical concentration.  He was stating a physical fact which I have been led to believe are constants.  Ward merely stated that the salmonids could survive in such extremely sediment polluted waters because the sediments were inert and did not steal the essential oxygen from the water.
    Your suggestion that the Powerpoint presentation does not meet the requirements of scientific debate.  That is ridiculous.  Of course it doesn’t meet the requirements of scientific debate.  It is a presentation of an opinion supported by cited scientific information.
    Relative to scientific debate…I have been trying to get you to stop jumping all over and denigrating my professional career so we could get to the subject at hand.  You have chosen not to do so.  In a debate you can usually determine the individual that cannot defend their position because they will change the subject and attack the messenger.

  29. Joe Greeneg says:

    That is not much to work with.  Please clarify tour comment.  I am willing to discuss it.

  30. Joe Greeneg says:

    Since I did not mention you by name in my 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.
    Your reply is very disingenuous and down right dishonest.  On September 21 both Claudia Wise and I introduced ourselves and indicated we would like to join the conversation.  We also added comments We both told you that we were retired and former USEPA employees.  On September 26 (because you were out of town for a couple of days) you stated”… a handful of slide-rule era-educated, contrarian scientists who pull themselves up from the depths of retirement…”  Of course you were directing an insult towards us.  Attaching names is not necessary.  An examination of the details and timing is sufficient to explain what you had done. 
    All of this and you had not addressed any of the scientific issues that we had raised.

  31. bob says:

    Please. You and Claudia both presented yourselves as scientists without disclosing that you were officers in a mining group or that you participated in process and were an “avid dredger.” All of those facts were material to me and would be to anyone reading your post. It is a little like your presentations of the section cites of the DSEIR that indicate lack of significant impact without also disclosing that those fundings are conditional on a number of requirements and come after lists and lists of impacts associated with suction dredging.

    Bob Ferris

  32. Joe Greeneg says:

    Good Morning Bob,
    In the final analysis the individuals with all the education and credentials in the specific areas you desire, and after full analysis of the data, have concluded that small-scale gold suction dredging is LESS-THAN-SIGNIFICANT.
    It is impossible to give any other reply because your generalities are impossible to address.
    Joe Greene

  33. bob says:

    I love this quote of yours: “To my surprise, and relief, I found these claims against small-scale gold suction dredging to be false by misrepresentation of the data.”

    Then clearly you did not read the DSEIR thoroughly because each section basically starts with a listing of the impacts and they are myriad. They then have a rather tortured list of restrictions and directives (most of this physically unenforceable) that could lead to a finding of “less than significant,” but the USEPA, the state water folks, and the Court all disagreed with these findings. That is why you have a ban in California.

    And quit trying to play the pity card. I have given you credit for your career and past professional activities. That said, I am critical of current unprofessional behavior. You are purposely being misleading. Take, for instance, one of your open statements of being an invited member of the public advisory committee. To someone not familiar with the facts that would lend credibility to your statements because a scientist who is an “invited” member generally get there because they bring science chops to the table (i.e., the work in or publish in the area in question). Your invitation came because the New 49ers whined so loudly about the bias of the scientists already on the committee (those who had earned a right to be there through standing or achievements) that they insisted on having a scientist or two from their camp. So your participation hinged on your opinion and not your qualifications–to imply otherwise is professionally dishonest. You and Claudia, therefore, should have been listed as suction dredgers and not by your former affiliations.

    –Bob Ferris

  34. Rick says:

    Alpers must have a clouded memory (or clouded  enough to attack only the miners and not the Sierra Fund, for whom he is a consultant) as he was consulting on a mercury dredging operation at Combie Resevoir in Nevada County, utilizing a Canadian dredge (they didn't shop locally) which had an 83% recovery rate of mercury. Now gold dredgers have recovery rates of 98%, so explain to me how the 83% recovery rate (in a lake where methylization occurs) is better for the environment than a 98% recovery rate (in a highly oxygenated river) where gold dredging occurs? I'm sure Dr Alpers knows……of course, EVERYONE ELSE knows there is more environmental damage done by the gold dredgers because of their intent vs the less efficient, but more (not-so) alturistic environmental non-profits and their taxpayer funded substantially less-efficient mercury recovery dredges. And let us not leave out reclaimation dredges too.
    One other thing Bob; according to your website, your "vision" is " We envision old growth forests…and vibrant communities…." Tell me Bob, how are those communities doing, which you envision to be vibrant when your main tactic is to shut down small businesses in those same rural communites? (sarcasm on) I guess forcing people on the government dole makes the communities more vibrant (sarcasm off)? Many of the environmental non-profits talk about sustainability and vibrant communities, but how can communities be vibrant when you are constantly suing everyone in sight over what you "evision" as an ideal environment- all that does is enrichen your lawyers and bankrupt your opponents. I guess if a group of people don't exactly share your specific viewpoint, it is time to ruin them economically- which in turn causes vast community resources to be wasted to protect local (already vibrant) community businesses which you have trained your sights on. Bob, rather than tell me how many jobs and small businesses you have destroyed in our rural communities (in the pursuit of "vision of Cascaida Wildlands"), can you tell me how many economic opportunites you have actually CREATED in your pursuit of your vision(other than enrichening your attorneys)? Tell me about your economic successes for rural communities where you have "protected the environment"? What percentage of your donations come from the areas away from the areas where you engage in economic warfare?  If your mandate is to protect the environment, why don't you roll up your sleeves and put some time on the ground cleaning up rivers on a daily basis like the dredgers do? If you have been in any river recently, I am sure you know there are many that need to be cleaned from all sorts of garbage. Maybe rally all your members to spend a day a week, every week cleaning rivers…. nah, that won't work, because they'd rather pay you to do the dirty work. Rather than destroying economic opportunity, don't you think it would be better for all involved if you worked to achieve your goal, working WITH the people you have focused upon economically destroying? What ever happened to Win/Win situations? Maybe approach the miners to work with them to create  some ideas where we can work together to have a SHARED VISION, where all groups are working to the beneift of everyone involved? Or would you rather mess with people's lives by pitting one group of people against another?  (it probably pays better). To my knowledge no one has made a SINGLE effort to contact the mining claim owners to see if we could work together- it has been an all out assault from the beginning. It kinda makes you wonder what the agenda is…….

  35. bob says:

    Except that I did not use the Alpers report I used another that said basically the same thing about the re-suspension mercury. As to your economic arguments, I have yet to see a study that indicates that the loss of dredging with have a significant impact on the economy or the Ma and Pa sector. Certainly monies are expended on this hobby but hobbies are easily replaced and that spending does not drop out of the economic it just gets redistributed. That said, all economic arguments that have seen from the dredgers only look at the benefits side of this equation and not the costs.

    Bob Ferris

  36. Rick says:

    Bob- Let's talk about economic impacts of communities and dredging. But first let's get something straight- suction gold dredging is not a "hobby", it is an industry. Probably the reason you think it is a hobby, is because the two largest voices in the industry are recreational mining clubs (that is also why I helped starte Western Mining Alliance, which represents those miners who think of this industry as work, and NOT a hobby). Some of the miners who belong to the clubs are claimowners, but most of those club members don't have mining claims (nor do they pay property taxes on mining claims as claim owners do), and yet they want to share the enrichning family experience of taking the kids out and share the experience of being in a wild natural environment, as I am sure you can agree, is good for building good strong family bonding. The recreational miners can mine in a social atmosphere, while getting instruction from seasoned "real" miners, just as I am sure your fishing clubs do- the pros showing the novices what to do.  However, MOST of the miners don't belong to social clubs, and spend anywhere from a few hours a week to fulltime work mining. 
    Back to the main point- to call professional miners "hobbyists" is like calling a commercial fisherman, a flyfisherman- to wit, one works for a living and another does it recreationally, as something you would do on a vacation FROM work. Mining is HARD WORK, no if's and's or but's. It is the most satisfying hard work you will ever do (don't ask me why, as I am not sure I can put it in words, why) and your body will be talking to you for days after you do it.
    Now back to economics- when the environmentalists in California were talking about forcing the miners off the rivers because what MAY happen when the miners mine, they also sold the lie that the fishing community had enough members who spent money at the local rural shops and stores where the mining used to occur, that they would pick up the slack from the displaced miners. Well, sir, it didn't exactly work out that way. I was talking to a county representative at a recent event in Downieville, CA (the center of the Northern Sierra Mining areas) and her comment was "we never really understood how much our community depended upon the miners. In effect, a lot of our economy was based upon these guys who came in and shopped, bought food and gas and left to go back to their claims. Apparently, we didn't really know how many miners there were out there". Downieville's store closed up and there are many vacant business locations now. Apparently the mountain bikers and fisherman just drive through to go to their mountain bike trails or fishing holes, and they don't spend the kind of  money in the town, like the miners did. I guess that is the difference between depending on someone who is visiting your town, vs someone who is actually living there while working. Duh.
    Another aspect of this whole economic thing that everyone overlooks is mining claim owners are taxed as property owners. The USFS owns the land, but the mining claim owners have to pay a yearly tax on the land. If the claims are made commercially unminable, then the counties lose a lot of potential tax revenue. When was the last time you paid taxes on your favorite fishing hole? Who is the hobbyist and who is the property owner? My guess is the taxpayer who is paying to work his land should have a bit higher standing in the economic pecking order. And even though the local counties make property taxes from the miners, it would also be in their best interest to ensure the miners are creating an ecological nightmare for other local industries which similarly use the river. So I would think the FIRST government agency to notice any ecological damage would be the local counties, as their economic livelyhood depends upon the rivers. And don't you find it curious that all of the local community governments fully SUPPORT THE MINERS? Why would a government agency which monitors the health of the community, support an industry which devistates the local rivers? Bob, do you see just a little disconnect here? Just a little disconnect?
    I encourage you to contact ANY local county officials in any rural mining town on ANY California river to see what ANY of them think about the dredging ban. Stores are closed, people who used to be producing members of society are now on public assistance and a lot of the "charm" of the towns are now gone as are some of the population (the enviromental movement did the same thing with logging) has moved on to where they could find good paying jobs.
    From the outside looking in, it appears you're (collectively stated to all environmental groups) ambition to create pristine wilderness also encompasses destroying the economic viability of those same areas. Maybe the intent is to make sure there is no economy at all in those towns, so everyone has to either be on public assistance or move away to the cities to get work. That's ONE WAY to ensure you (and your elitist friends who can afford to flyfish, rather than work to make a living) can have the "river runs through it" experience. I hope you sleep well at night, as the environmental movement has thrown a lot of good folks out of their livelihoods and homes all under the pretense of saving the environment. Job well done.

  37. bob says:

    You and others do not have the economic analyses to make these claims you are making. All tourism in Northern California is declining—even in places where gold in not a factor (see http://mtrc.asu.edu/barometer/northern-california). Downieville (population 282 people) is an interesting situation and example. This is a small, remote area that has always been economically marginal. Gold panning is part of their economic fabric but certainly not the main driver. I would suspect that they and other outlying areas are more a victim of their remoteness during a time with high gasoline prices and high unemployment, that the loss of gold dredgers.
    I think we would also disagree on whether or not dredging on any scale is something that we really need to teach the next generation. Gold dredging is not a celebration of wilderness or an appreciation of nature. In reality, they compromise wildness and destroy nature. These strike me as less than optimal values to emphasize on a planet that is becoming more populated and more impacted.

    –Bob Ferris

  38. Scott says:

    How does dredging Compromise Wilderness and destroy Nature more than the following.
    Lightning strikes
    Fires from lightning strikes
    10 to 20 foot deep snow,
    Avalances of snow.
    Avalances of dirt gravel and trees
    Trees that have died, fallen into the creek, making the entire stream buried in dead trees, this is the true scene on an untouched watershed.
    Golf courses, herbicides and pesticides and futilizers for the grass.
    Farms using herbicides and pesticides and futilizers
    Boat propellers chopping up small fish in the lakes and rivers, theres no season set for this either.
    Fishing, the act of intentionally killing a fish for food.
    Commecial fishing kills fish in mass.
    Suntan lotion while people swim in the rivers and lakes.
    Cars, and car exhaust.
    Cars on Roads, they kill animals. literally 100's per day (maybe more) in Calif.
    Herbicides the government sprayed in the 1950's and 60s on the forests of CA in an attempt to reduce the underbrush and help reduce the damage when forest fires occur.
    Winter storms, rain and erosion.
    Volcanic activity, the ever changing earth on a very large scale.

  39. Scott says:

    Sorry I forgot a couple more to the list above.
    People killing and hunting Grizzly bears, Mountain Lions and Wolves. According to your belief we should bring back the Grizzly bear and Wolves to California so we can say we have a celebration of wilderness and a true appreciation of nature.
    Man I'm going into the fencing business, everyone is going to want one since the Grizzly and wolves are coming back to California.

  40. bob says:

    Some of these are natural occurrences and should be struck, but the rest are EDI arguments or "everyone is doing it." Is that really your argument for continuation? A child's taunt? –Bob Ferris

  41. Rick says:

    Who said anything about gold panning? Did I mention gold panning? I think you read what you want out of a post and then post a response completely out of context from my responses. That is part of your problem (which you ought to  have someone look at);  you read what you want from what another is saying and don't listen to what other's say. That has been happening throughout our "discussion" and it confused me and took me a while to figure out what you were doing. 
    Unemployment: and for some reason you don't equate the high unemployment due to the dredging ban- that is curious, since that was the point I was making.
    Again, I reference your myoptic view; if it doesn't fit your reality, it doesn't exist. Personally, part of the draw to the whole gold dredging activity is the ability to go to amazing places and to experience extreme beauty. I emailed you photos of my claim (and asked you who to contact to find a dredge where I can move 16 cu yards of material an hour, instead of my measly 1 cu yard a day- on MY claim), and I cannot think of a more beautiful and scenic place I want to be while working. And when I am moving a cubic yard a DAY, on bedrock, in a bedrock lined canyon, very little is being impacted.
    You say I am destroying, and I am saying that everyone who goes into the wilderness has an effect- it is a matter of scale (a point that I have made a bunch of times, and yet you still don't get it). My point to you was there is one of me per several miles and there may be dozens of fishermen or other outdoor users- my comment to you was asking you who REALLY has a bigger impact? Me and my moving a cubic yard a DAY or dozens of fishermen and outdoor users also enjoying the wilderness or perhaps the reclaimation dredger who is muddying up the rivers for miles (and his activity is not outlawed). Sounds like selective enforcement to me.
    As the planet is becoming more populated and impacted, the only way to decrease the affect on the environment is to outlaw corporate personhood (where the bottom line justifies the means- don't get me started on that) and practice eugenics. Any volunteers? Instead, both of us need to recognize that change happens and BIG CHANGES have been happening for BILLIONS of years, and yet still the earth survives. The last asteroid impact probably did a bit more damage than my dredge does, and yet look at the beautiful planet we live on. On an order of scale, the planet will do what the planet needs to do to survive, and I think what the human race does to "save the environment" has the same effect as a single flea on your body wanting to save its environment- not one iota – and yet the planet always survives. The difference is you are promoting yourself as a protector of the planet, and that makes you feel like you have god-like powers and do everything in an alturistic manner, when in fact, you are just a working stiff like me, making a living agitating people (like it says on your website). I do marketing and you get your supporters frothed up into an angry rage to stop others from doing what they do, so you can feel good about what you do. Who am I to say what you do is right or wrong- it is what it is. But the realization needs to sink in- exactly what you do.
    Hey Bob, it has been fun- hope you think so too. This thread is getting old and we probably have bored everyone who is reading it to tears. Some day, maybe I will meet up with you and we can talk about Natural Building- something we both can agree upon- have you seen any earthbag homes?  (otherwise we may be arguing all night). You've been a good sport and have allowed the posts to be un-edited, and I appreciate that.

  42. bob says:

    I see gold panning but not suction dredging in the activities…



  43. bob says:

    Boy it is nice to have fans in the treasure hunting community.  I am not sure that I see anything here that directly address the science or facts that are relevant to this important issue.  Lots of name calling, finger pointing and frustration.  http://www.treasurenet.com/forums/gold-prospecting/315378-bob-ferris-guy-full-bs.html  I particularly liked the Bob Ferris…Sucks part of this.  Thanks, Hefty.

    –Bob Ferris

  44. Mark H says:

    You are very welcome bobby!
    Must be really nice to be able to pick the comments that you and your org. wants your fans to see from the internet side.
    So why are the comments from Oct, 2 thru Oct, 5 not able to be veiwed from the internet side? Hiding something? They can be viewed on the GPAA and Tnet.
    Bobby you really need to get off your your "Im mightier than all" BS!  And go back to your gig at the jailhouse in Merion County recycling garbage that you do so well. (Award given for)
    Take care Sheriff Bobby Ferris.

  45. Mark H says:

    Well then.

  46. Mark H says:

    My bad…two different blogs.

  47. bob says:

    I get confused as to where I am as well sometimes. And this thread limitation is a shortcoming of Word Press.

    –Bob Ferris

  48. Mark says:

    All the stuff you state is bunk science or just opinion.  You are childish in your beliefs and ignore common scense.  You quote studies and reports created from nothing more than opinion.
    Where did the mercury go in the three inch dredge that was ran in the highest mercury contaminated site in California in the Humbug/Yuba study?????  Come on.  It was ran in contaminated streambed material, contaminated water and yet the turbid water discharge contained no detectable level of mercury in all but one sample and that one sample was the lowest reading that the best mercury scientists at USGS can detect.  An amount that is not an illegal discharge.  Come on Bob????????
    Where did the mercury go???????  The dredge caught it, that is where it went.  Yet the scientists involved in that study refuse to admit it in their biased conclusions.
    Read the entire study BOB, Where did the mercury go????? I guess it must have just disappeared.  No mercury in the turbid water discharge or in the collection dishes of fall out sediment.
    So spew forth your garbage and corrupt innocent minds with your biased one sided preaching but know this, your intention is to ban dredging.  You cannot agree with any valid point made by anyone who disagrees with your stated goal.
    Therfore comon scense says that you are biased and it is obvious you refuse to even consider that this entire attack against dredging is being based on emotion, lies and innuendo.
    One other fact I know.   Mr Green is recognized by the courts as an expert in this field, are you?  I only ask because you keep proclaiming yourself as one of the leading experts on this subject by your nonstop attacks, so spit it out, are you recognized in a court of law as a scientific expert on the environmental impacts of suction dredging or are you just full of hot air?
    I don't care how much you have read on this subject, it in no way makes you an expert.  How many years have you worked in the water with suction dredges studying them? 
    You can read volumes of books on sheetrock, how to install it, watch untold videos, you can even go to college and get a degree, but until you can install and finish it to a level five smooth wall finish, you are just a wannabe. 
    Is that your story? 
    When have you been professionally employed to study the impacts of suction dredging as a biologist or scientist or recognized professional in this field?  Have you recieved any financial compensation at a professional level that would qualify you as a person who is at the top of the leading scientific study and research on this subject.  Do you admit that using proper scientific methods and methodology to perform real studies of operating suction dredges is neccessary to determine if the multitude of hypothesis that the environmentalists keep spewing forth are based on proven scientific facts or are just emotional opinions based on possibilities is what should lead dredging regulations?
    The CDF&G 2009 study did not study one single operating suction dredge in any California water way.  It is a compilation of nothing but unproven scientific hypothesis, excuse me, you would cal it expert opinion. 
    I am sorry, but if you were half the scientists and expert on this subject as you proclaim yourself to be, you would have to agree an opinion is nothing more than that, it is not a scientific proven fact.
    So I would ask you do perform some serious thought on this question, if your stated goal is to ban suction dredging, how unbiased is your opinion on any of this and what prevents you from just picking out the printed unproven opinions of others who share your goal to ban dredging. 
    A printed scientific study, even with peer review is not scientific proof.  If it is only based on a professional opinion and there were no properly conducted unbiased scientific studies performed to prove the hypothesis was valid, then it is bunk science.
    And as for your statement about being responcible to the fish first, if there were hundreds, no, let me make this easy, if there were one dead fish found floating below every running dredge, then I would agree that  a ban would be in order. 
    Lets look at this in a rediculous way.  Even if every single dredger killed one salmon a year in Oregon, that would have the combined effect of removing 3000 spawning salmon from the return.  The reality is that environmental zealots still can not proove that suction dredging as it is regulated today to protect reds and fry and returning spawning salmon has even killed a single fish.  You can try to belittle that fact but it is true.
    Yet every year fishermen are legally able to kill hundreds of thousands of these protected fish.
    What is your problem?  How can you sleep at night trying to outlaw a recreational activity that as currently regulated, you can not prove has killed one single fish, destroyed one red, killed one fry, or released one single illegal water discharge into an Oregon waterway ?
    What if the cause of the salmon decline is the thousands of pounds of lead from fishermen and hunters and it's effects on salmon reproduction??? Dredging is the only thing removing this lead garbage from the rivers.
    Go ahead, justify your attack while fishermen keep legally killing hundreds of thousands of these protected fish.
    You are a hypocrit, period.

  49. bob says:


    You and other hopeful dredgers seem to want to take the “does not always happen there” piecemeal rebuttal approach. While that might be appropriate in high school debate, it is not when natural resources and human health concerns are at stake. Yes the worse case scenario was used on mercury because mercury hotspots exist and if we have reason to believe–as we do–that dredging in hotspots will result in re-suspension and flouring then the prudent thing to do would be to make absolutely sure that does not happen. That closes out waterways that have high mercury content already or where mercury was used historically. But suction dredge use is not hinged only on mercury there is also evidence of fisheries or food web impacts in other areas. At the end of the day the social and biological rationale for the enterprise collapses under the collective weight of likely risk which is based upon opinion–as you suggest–because it is always better when dealing with these sensitive systems to take that best guess rather than perform in situ testing and jeopardize what you are trying to protect. Whine all you want and hold your breath but this the best option we have and your friend Joe knows this because the US EPA regulations and practices are all based on risk.

    –Bob Ferris

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