BILL ANALYSIS                                                                                                                                                                                                    



                                                                  SB 670
                                                                  Page  1


          SENATE THIRD READING
          SB 670 (Wiggins)
          As Amended  June 26, 2009
          2/3 vote.  Urgency 

           SENATE VOTE  :31-8  
           
           WATER, PARKS & WILDLIFE      11-0                    
          APPROPRIATIONS      12-0        
           
           ----------------------------------------------------------------- 
          |Ayes:|Huffman, Fuller,          |Ayes:|De Leon, Ammiano, Coto,   |
          |     |Arambula,                 |     |Davis, Fuentes, Hall,     |
          |     |Tom Berryhill,            |     |Harkey, John A. Perez,    |
          |     |Blumenfield, Caballero,   |     |Skinner, Solorio, Audra   |
          |     |Fletcher,                 |     |Strickland, Torlakson     |
          |     |Bonnie Lowenthal, John A. |     |                          |
          |     |Perez, Salas, Yamada      |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |     |                          |     |                          |
           ----------------------------------------------------------------- 
           SUMMARY  :   Places a statewide temporary moratorium on the use of  
          any vacuum or suction dredge equipment in any river, stream or  
          lake until the director of the Department of Fish and Game (DFG)  
          completes a court ordered environmental review of its existing  
          suction dredge regulations and updates the regulations.   
          Specifically,  this bill  :

          1)Prohibits the use of any vacuum or suction dredge equipment in  
            any river, stream or lake of this state until the director of  
            DFG certifies to the Secretary of State (SOS) that all of the  
            following have occurred:

               a)     DFG has completed the environmental review of its  
                 existing suction dredge mining regulations as ordered by  
                 the court in the case of Karuk Tribe of California v.  
                 DFG.

               b)     DFG has transmitted for filing to the SOS new  
                 regulations, as necessary, pursuant to the Administrative  
                 Procedures Act, and the new regulations are operative.

          2)Declares that the issuance of permits to operate vacuum or  
            suction dredge equipment is a project pursuant to the  








                                                                  SB 670
                                                                  Page  2


            California Environmental Quality Act (CEQA), and permits may  
            only be issued and vacuum or suction dredge mining may only  
            occur as authorized by any existing permit, if DFG has caused  
            to be prepared and certified completion of an environmental  
            impact report (EIR) for the project as ordered by the court.

          3)Provides that this bill applies solely to vacuum and suction  
            dredging activities conducted for instream mining purposes,  
            and does not expand or provide new authority for DFG to close  
            or regulate suction dredging conducted for regular maintenance  
            of energy or water supply management infrastructure, flood  
            control, or navigational purposes.

          4)States that this section does not prohibit or restrict  
            nonmotorized recreational mining activities, including panning  
            for gold.

          5)States that it is necessary for this bill to take immediate  
            effect for the reason that suction or vacuum dredge mining  
            results in adverse environmental impacts to protected fish  
            species, the water quality of the state, and the health of the  
            people of the state.

           EXISTING LAW  :
          1)Prohibits the use of vacuum or suction dredges in any river,  
            stream or lake except as authorized under a permit issued to  
            that person by DFG in compliance with regulations adopted by  
            DFG.

          2)Requires DFG to adopt regulations governing use of vacuum and  
            suction dredge equipment, including the maximum size of  
            dredges and time of year when dredges may be used.  Authorizes  
            DFG to close streams otherwise open to dredging if there is an  
            unanticipated water level change and DFG determines that  
            closure is necessary to protect fish and wildlife.

          3)Requires DFG to issue a suction dredge permit to an applicant  
            if DFG determines, pursuant to the regulations, that the  
            operation will not be deleterious to fish.  Operation of a  
            suction dredge without a permit, or in waters or at times not  
            authorized by permit, is a misdemeanor.

           FISCAL EFFECT :  According to the Assembly Appropriations  
          Committee, loss of approximately $175,000 in annual revenue each  








                                                                  SB 670
                                                                  Page  3


          year the moratorium is in effect, resulting from loss of suction  
          dredge permit fees (Fish and Game Preservation Fund).   
          Currently, fee revenue pays for suction dredge permit  
          enforcement at the cost of approximately $50,000 per year,  
          activity which will presumably continue during the moratorium.

           COMMENTS  :  Vacuum and suction dredge mining is a process by  
          which power equipment is used to vacuum up sediment from the  
          streambeds of rivers, creeks or other water bodies to search for  
          gold.  DFG issues permits for use of motorized suction dredge  
          equipment for recreational gold mining in California streams.   
          Existing regulations governing the use of suction dredges for  
          instream gold mining were last updated in 1994.  In 2005 the  
          Karuk Indian Tribe sued DFG over the adequacy of the regulations  
          in protecting fish and wildlife.  DFG filed declarations with  
          the court stating that in the opinion of DFG and other fishery  
          biologists, suction dredge mining is resulting in deleterious  
          effects on Coho salmon, a species listed under the Endangered  
          Species Act.  A court order entered in December 2006 as part of  
          a settlement agreement ordered DFG to complete an environmental  
          review of its existing permitting program and to promulgate new  
          regulations, as necessary, to protect Coho salmon and other  
          listed species.  The court required DFG to complete the  
          environmental review and regulatory update by July of 2008.  DFG  
          has yet to comply with the order, citing a lack of funding,  
          which was not provided until this year.  DFG now indicates it  
          will take until the end of 2010 for the environmental review to  
          be completed.

          The delay in conducting the environmental review prompted the  
          Karuk Tribe, Caltrout, Friends of the North Fork, and the Sierra  
          Fund in January of this year to petition DFG to adopt emergency  
          regulations to limit dredging in certain salmon spawning streams  
          while the new EIR is developed.  DFG denied the petition,  
          indicating that while they agree that deleterious harm is  
          occurring to listed species, they do not believe they have  
          authority to stop issuing the permits, which they interpret as a  
          ministerial act.  The petitioners, on the other hand, believe  
          issuance of the permits is a discretionary act, that development  
          of the regulations is a project under CEQA, and that no permits  
          should be issued until the new regulations are in place.  The  
          existing statute requires DFG to issue the permits only if DFG  
          determines, pursuant to the regulations, that the operation will  
          not be deleterious to fish.








                                                                  SB 670
                                                                  Page  4



          This bill seeks to prohibit suction dredge mining in streams  
          that provide critical habitat to spawning salmon until DFG  
          completes its court-ordered review and update of regulations.   
          The author notes the state's salmon fisheries are in crisis,  
          with salmon fishing banned along the California coast for the  
          second year in a row, affecting the livelihoods of thousands of  
          commercial fishermen and others, while status quo has been  
          allowed for recreational gold mining.  The author asserts these  
          conditions warrant use of the precautionary principle to protect  
          endangered fish.     

          Studies conducted by DFG, the U.S. Forest Service and others  
          indicate that suction dredging can degrade fish habitat and  
          water quality, and have a deleterious impact on native aquatic  
          species.  Declarations filed by DFG's chief fisheries biologist  
          and Dr. Peter Moyle of the University of California at Davis in  
          the 2005 Karuk lawsuit cite to scientific peer-reviewed studies  
          on the effects of suction dredging issued since the DFG  
          regulations were last amended in 1994.  The declaration of DFG's  
          chief fisheries biologist filed in the case acknowledged that  
          DFG's existing regulations are inadequate and that harm is  
          occurring to listed species including Coho salmon.  Dr. Moyle in  
          his declaration also explained that "suction dredging represents  
          a chronic disturbance of natural habitats that are already  
          likely to be stressed by other factors and can therefore have a  
          negative impact on fish?suction dredging through a combination  
          of disturbance of resident fishes, alteration of substrates, and  
          indirect effects of heavy human use of small areas, especially  
          thermal refugia, will further contribute to the decline of the  
          fishes."       
           
           Some proponents of suction dredging have asserted that suction  
          dredgers help recover mercury from hot spots.  A 2003 pilot  
          study conducted by the State Water Resources Control Board found  
          that motorized suction dredging exacerbates rather than  
          alleviates mercury contamination of rivers and streams.  The  
          study found that instream suction dredge mining is an  
          unacceptable means of recovering mercury lost to the environment  
          from gold mining because the dredges release too much mercury  
          back into the environment.  Mercury concentrations in the  
          sediment released by the dredges were more than ten times higher  
          than that needed to classify it as a hazardous waste.  By  
          "flouring" the mercury and releasing it back into the stream,  








                                                                  SB 670
                                                                  Page  5


          dredging may also distribute the mercury more broadly and  
          contribute to methylation of mercury and bioaccumulation in fish  
          making it toxic for human consumption. 

          Supporters of this bill note the affect of the salmon fishery  
          closure on thousands of commercial, recreational and tribal  
          fishermen and businesses, and the risk salmon face from the  
          effects of suction dredging.  Supporters note DFG's  
          acknowledgement in court in sworn statements that suction dredge  
          mining is harming fish, including Coho salmon which is on the  
          brink of extinction, and also note many other endangered fish  
          and amphibian species are also in decline.  Several tribal  
          organizations point to the cultural, traditional, and religious  
          tribal practices that revolve around the annual returns of  
          salmon, steelhead and other species, and note many tribal  
          members rely on subsistence fishing to provide food for their  
          families.  Other supporters also emphasize concerns over water  
          quality impacts, particularly mercury.       

          Opponents reject claims that suction dredging is harmful to fish  
          or has contributed to the decline of salmon fisheries, note the  
          prior EIR found that suction dredging can have positive impacts,  
          creating additional salmon spawning habitat by loosening  
          concretized river gravels, and assert further restrictions on  
          suction dredge mining will violate the property rights of those  
          with mining claims.  Rural counties also cite concerns regarding  
          the economic impact of the proposed restrictions on local  
          communities, believe the existing regulatory permitting process  
          is adequate, and argue this bill circumvents the CEQA process.    
                       


           Analysis Prepared by  :    Diane Colborn / W., P. & W. / (916)  
          319-2096                                                 FN:  
          0001749