The U.S. Environmental Protection Agency is proposing to reissue its general permit for suction dredge mining throughout Idaho. We’ve discussed suction dredging in the past, often focusing on streams in Idaho. This general permit, under the National Pollutant Discharge Elimination (NPDES) program, is slightly different: it establishes the baseline criteria applicable throughout the state and dictates which rivers are open or closed to dredging. Any person wanting to suction dredge for gold in Idaho would need to apply for and receive this permit from the EPA.
The NPDES permit limits where dredges could operate, how large the dredges can be, when they’re allowed to operate during the year, and how long throughout the day they can be operated. These limits are based on experience and data that have identified effects to fish habitat, endangered species, clean water and public health. These limits are vital to protect the quality of our rivers and the aquatic life that rely on Idaho’s streams. The new permit would also maintain many protections that restrict dredging in endangered species habitat, streams where water quality is poor, and rivers designated as wild and scenic.
This Permit Needs Further Analysis
The EPA’s permit must protect Idaho’s water quality. To do this, the permit needs to be based on accurate and current information. This permit relies heavily on studies of polluted lakes and streams, known as total maximum daily loads or TMDLS, that stipulate how much additional pollution that water body can handle.
Unfortunately, the draft permit is relying on outdated TMDLs that haven’t been regularly reviewed and revised! That’s not what a protective permit should look like.
Another part of the permitting process requires the Idaho Department of Environmental Quality to do an antidegradation analysis. This analysis requires IDEQ to look at water bodies on an individual basis and ensure that clean streams are not harmed by any proposed project. In addition, the state agency must ensure that any other source of pollution within the same watershed is operating as effectively as possible. As you can imagine, this oversight takes a lot of work and requires a high level of site-specific knowledge.
The IDEQ has yet to do this analysis despite the explicit requirements laid out in our state rules on water quality. Rather than analyzing each water body individually, IDEQ is trying to make a blanket statement for all lakes and streams in Idaho. The state’s analysis also lacks any review of other discharges where people are suction dredging. IDEQ must fulfill its responsibilities before this permit gets final approval.
Finally, what’s the point of a permit if there’s no monitoring or enforcement? Over the five-year course of the current permit, only two citations have been issued despite widespread abuse in treasured waters like the Salmon and Boise rivers.