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Redpaw
Oregon Water Resources Department (WRD)


• WRD grants water rights throughout the state, and is responsible for assuring that
the free flowing character of Scenic Waterways is maintained.
• The agency has determined that recreational mining, which it has defined in
regulation as suction dredging with a hose no larger than 4 inches in diameter,
does not create a diversion of water and therefore has no effect on water quantities
and flow.

WRD is responsible for granting water rights to various users; they are the body
responsible for permitting and prohibiting various uses of the state.s water. Under the Scenic Waterways Act, WRD (and the Water Resources Commission, which directs the activities of WRD) has multiple responsibilities. Within Scenic Waterways, WRD has the authority to deny a number of uses of water, including dams, impoundments, certain mining operations, and many other activities. Curbing these activities in certain parts of the state was, in fact, one of the primary reasons for establishing the Scenic Waterways System in the first place.

These types of activities are not eligible to receive water rights
on Scenic Waterways. This is true not only on stretches of rivers designated as scenic, but it can also be applicable to areas upstream as well. WRD must make determinations about the likelihood of an upstream activity to significantly affect water quantity. If an activity will ultimately affect the free-flowing character of a Scenic Waterway downstream, then WRD is not supposed to grant a water right for that activity.

WRD will grant new water rights until there is an effect on water quantity, and
there is a standard that has been developed to weigh the effects of new water rights. This standard is known as the Diack flow, which is the amount of water needed in a river to preserve its free-flowing character. The establishment of Diack flows resulted from a lawsuit brought against the state. The case established that WRD is required to limit water usage if such usage will diminish the free flowing character of scenic rivers. WRD has been routinely criticized for not meeting the goals of the Diack flows, and allowing too much water to be allocated.

WRD is also charged under the Scenic Waterways Act to work collaboratively
with other state agencies on actions that involve Scenic Waterways. WRD is to review and concur on management plans for adjacent lands, on land condemnation actions, and on new additions to the Scenic Waterway System, and the agency is given an opportunity to make comments whenever any of these actions take place.


WRD Considers Recreational Mining to Have Minimal Impact; It Does Not Divert or
Take Water

With respect to recreational placer mining, WRD has little to no involvement in
the day-to-day management of these activities. WRD wrote the regulation that defined the parameters of what is meant by the term recreational, and from this definition, DSL and DEQ have established their permitting guidelines and procedures. The definition of recreational as utilizing mechanized or hydraulic equipment, except a motorized surface dredge with a suction hose intake four inches or less in diameter has effectively meant that no recreational equipment is capable of moving enough water to divert or disrupt the free flowing character of any of the states designated Scenic Waterways. These waterways are not small streams and tributaries, but rivers whose flow cannot be significantly altered by a suction dredge with a four-inch hose.

Moreover, water pulled into a suction dredge for mining purposes stays in the river.

There is no taking of the resource out of the river. Thus WRD has determined that there is no diversion or taking of water by recreational placer miners, no water quantity issue at stake, and thus no affect on the free flowing character of the waterway. As far as the responsibility of WRD is concerned, recreational placer mining has de minimus effect. Therefore the agency has no permitting authority or responsibility for this activity, and has expressed no opposition to recreational placer mining in scenic waterways with respect to its responsibilities.
Redpaw
US Bureau of Land Management (BLM) and US Forest Service (USFS)


• Federal agencies manage significant amounts of land in Oregon.
• Mining is permitted on federal lands subject to applicable federal and state
regulation, though both agencies have found numerous examples of noncompliance.
• At times regulations are inconsistent across BLM and USFS lands, and are also at
times inconsistent with state regulations.
• Environmental impacts of recreational mining are considered to be small by
federal land managers, as long as regulations are adhered to. There are, however,
some concerns about ancillary activities . camping, getting access to mining sites and possible long-term cumulative effects of suction dredging.


The BLM and the USFS manage a significant portion of federal land in Oregon,
and have an especially strong presence in areas that are scenic, wild, forested, or
otherwise notable for their special features. As a result, these areas under federal
management are highly visited by various recreationists for these special qualities.

The BLM and the USFS maintain a significant presence on vast tracts of land
throughout the state, in contrast to state agencies that do not and often cannot. As a result, officials at OPRD and other state agencies often comment that federal agencies in many ways .carry. the state, taking responsibility for management and supervision of activities . recreation, fishing, boating passes, recreational mining, to name a few that should involve greater responsibility from Oregon state agencies. Without this federal presence and assistance, effective management of many lands and waterways throughout the state would be severely diminished.

There are opportunities for placer mining on some lands that BLM and the USFS
manage, and miners from both in and out of state will frequent available sites during the appropriate in-water work periods. Most active miners on BLM and USFS lands are not working in Scenic Waterways, but as both miners and land managers note, suction dredging is suction dredging no matter where it takes place. Land managers have provided comments and observations based on all lands and waterways they manage, not just areas that include designated state Scenic Waterways. In most cases, the observations and views are applicable across areas. (Most mining activities occur on mining claims made on federal lands under the 1872 Mining Law. This is not considered recreational mining and its permissibility is not at issue in the Scenic Waterways System.)


The Impacts of Recreational Mining Not Considered Significant

Both BLM and the USFS noted that recreational mining is exactly that: not for
making a living but indeed engaging in recreational activities. First of all, recreational miners are engaging in very small-scale operations (especially when compared to current and past large commercial mining operations on federal lands). Second, their activities do not involve any claims involving property rights. Third, there are no commodities coming out of recreational operations. People generally recover only very small amounts of gold, and this gold has no economic impact. These last two items are important distinctions for federal land managers in considering different types of mining operations.

It follows from this assessment that the impacts of recreational mining are not
usually significant. This seems to be especially true for larger rivers, which tend to be those that make up the Scenic Waterways System. (A suction dredge with a four-inch hose has a proportionally greater impact on a small stream or tributary than it does in a larger river.) Both BLM and the USFS are in the process of reviewing mining practices in areas they manage in southwest Oregon and in both cases their respective assessments suggest that if proper guidelines are followed, impacts can be kept at an acceptable level.

The USFS and BLM have both produced pamphlets describing the practices that suction dredgers need to follow in order to mine with acceptable impacts. (The USFS has also completed a Draft Environmental Impact Statement that will be reviewed in a later section.)

Acceptable in this case means evidence of mining that includes: minimal
sedimentation of the waterway, small tailings piles that are then redistributed if necessary to prevent dams or diversion of waters, and a hole where the suction dredge removed gravel from the riverbed. Operations which do not impact the waterway more than this are considered to have minimal environmental impact. These agencies also suggest that because the winter rains and spring runoff redistribute all tailings and move more gravel than recreational miners do, there is little to no evidence each new year that recreational mining has even taken place in areas where regulations have been followed.

In spite of this understanding, there are three major concerns: the level of
compliance with regulations, cumulative effects (which are harder to assess and almost impossible to measure) and ancillary impacts that accompany suction dredging. In northeastern Oregon, BLM reports that there is often very good compliance with regulations among suction dredgers. However, the USFS reports that in the southwestern part of the state compliance is not as good, especially on smaller waterways where most mining activity takes place, and this results in heavier environmental impacts.


Federal Agencies Are Doing Some Monitoring; The State Is Doing Much Less

As noted above, DSL and DEQ do not monitor the suction dredging activities
they permit, so when violations do occur they are not met with any penalties. This makes it more likely that the same violations, and thus the same impacts, will occur repeatedly.

BLM and the USFS are not required to enforce state permits on their lands, and for the most part they do not involve themselves with state requirements. They do, however, watch for abuses, and in parts of eastern Oregon, the BLM does in fact check to see that recreational miners are in compliance with state permitting requirements.


Cumulative Impacts Are a Concern

Federal land managers are also concerned about cumulative impacts of suction
dredging. These are very difficult to measure and quantify, and are nearly impossible to attribute to one type of activity or another. Considering that Scenic Waterways are open to multiple uses, making a definitive determination that recreational mining has a certain long-term impact seems to be beyond current scientific capabilities. Federal land managers note, however, that scientific certainty is not necessary to make qualitative assessments about the long-term health of waterways and riparian areas.

Recreational mining takes place at or near sites where mining occurred in decades past. The damage done from these large-scale commercial mines was often significant, and in many cases these areas are still recovering from the .insult.. Though the commercial operations had far greater an impact than could ever be caused by recreational miners, any additional mining in these same areas means that recovery from historic practices is likely to be weakened. Some officials submitted anecdotal evidence that there are noticeable differences in riparian areas where mining does and does not occur. There is less vegetation in mined areas, both in terms of density and diversity, making for a comparatively less healthy looking site.

Lastly, when recreational mining takes place, impacts result from more that just
suction dredging. Miners set up areas to camp, often for days at a time. The USFS has found evidence of lack of proper toilet facilities, improper garbage disposal, and use of soaps and detergents. In other instances, miners have developed new roads or trails, or cut logs and moved boulders to access a dredging site. There can be fuel spills as well.

All of these items can result in substantial impacts, as significant if not more so than those attributed directly to suction dredging, according to some officials. These impacts can be both immediate and cumulative.

The BLM and USFS, though large and diverse organizations, seem to be
expressing similar ideas to those found at state agencies: the impacts of recreational placer mining can be kept to a minimal, acceptable level provided that all applicable rules and regulations are adhered to and good stewardship is practiced. The extent to which these good stewardship practices are adhered to, however, is inconsistent. So in practice, the effects that regulators and managers seek to avoid still occur.


Public Lands Are to Support Multiple Uses

Another aspect of the recreational placer mining issue concerns social goals and
values. The BLM and USFS pointed out that they both manage their lands for multiple uses, and that a variety of activities should be able to take place on public lands. They reported that there is minimal direct conflict on federal lands between recreational miners and other river users. Conflict tends to be over social and political values, with respect to whether or not suction dredging should be allowed at all.

The idea is that some public lands are considered especially valuable and thus are
provided with special protections that do not apply to other .normal. public lands.

For example, some areas are off limits to mineral withdrawal, or to motorized activities, or even to certain recreational uses. Special management guidelines of this type apply on a considerable amount of land managed by the BLM and USFS. It may very well be the case that additional restrictions on use should be considered in the Scenic Waterways System, which was designed to offer extra protection to particular sites recognized by the public as especially valuable.
Redpaw
US Army Corps of Engineers (COE)

COE has authority to issue permits under the Clean Water Act in order to
protect water quality.
• COE no longer issues permits for recreational mining in Oregon, having
determined that effective state regulation sufficiently mitigates impacts on water
quality.


Until the recent past, the Army Corps of Engineers issued permits for recreational
placer mining in Oregon.

Under Section 404 of the Clean Water Act, the Corps is responsible for determining what activities will affect water quality and issuing permits to regulate these activities. The Corps has now determined that small-scale suction dredging in Oregon involves no more that an incidental discharge of dredged material into waterways.

Therefore the Corps has decided that recreational placer mining does not
require a permit provided the activity is conducted with intake nozzles 4 inches or less and operated with a 10 horsepower engine or less
.

While it continues to maintain the authority to regulate recreational placer mining, the Corps has effectively gotten out of the business of issuing permits to recreational miners in the state of Oregon, based upon the determination that the activity is effectively regulated in the state by DSL and DEQ and thus has minimal impact on water quality and is not inconsistent with federal water quality standards.

GO BACK AND READ THAT AGAIN.
Redpaw
Oregon Department of Geology and Mineral Industries (DOGAMI)


• DOGAMI maintains responsibility for commercial mining operations in the state
and has no regulatory authority over recreational placer mining.

DOGAMI is the agency that maintains regulatory responsibility for all
commercial mining in the state of Oregon. The agency deals only with commercial
operations and is prohibited by law from regulating recreational mining. Recreational mining occurs on a much smaller scale and thus it falls below the threshold established for determining DOGAMI’s regulatory authority.

The agency did note that while a distinction is made among size of activities
because bigger operations have bigger impacts and smaller operations have smaller impacts, this is not always the case. DOGAMI maintains strict requirements for commercial operations in order to minimize the impact of mining on the surrounding environment, but small-scale recreational miners do have the capacity to have significant impacts if the activity is not done properly and according to permitting requirements.
Redpaw
National Marine Fisheries Service (NMFS) and US Fish and Wildlife Service (FWS)


• NMFS and FWS maintain responsibility for protecting fish and wildlife .
especially threatened or engendered species . as applicable under federal law.
• These agencies have very little interaction with the Oregon Scenic Waterways
program, but have at times considered the impacts of suction dredge mining.
• Compliance with regulations will significantly mitigate environmental impacts,
however, there is concern over long-term cumulative effects, which have not been
addressed by scientists to date.

These federal agencies cooperate with Oregon state agencies in managing and
protecting fish and wildlife resources where federal law or money is involved. Usually their involvement stems from issues arising over the Clean Water Act or Endangered Species Act, or if federal funding goes to the state to administer rules or a program. These agencies are not involved with the Oregon Scenic Waterways Program, but they do address recreational placer mining in their responsibilities. The views they expressed were similar to others: compliance with appropriate regulations minimizes impact, but there are concerns and uncertainty. Even when following the permitting rules individuals have the capacity to do harm if they are not careful stewards of the land.


FWS did point out two related additional concerns. First, while the scientific
literature often echoes the conventional wisdom about the efficacy of effective
regulations, it also tends to focus on short-term impacts, not long-term effects, and so the science may be overlooking important developments in the rivers. Second, there is some concern about the long-term homogenization of waterways and the loss of complexity in an ecosystem where suction dredging takes place. It will be extremely difficult to study this and attribute exact causes to particular effects.

Cumulative effects result from a mix of activities, but mining is a significant part of the mix as it entails the movement of rocks, logs, and boulders, holes being filled, vegetation being cut. The result may be that the idiosyncrasies of a stream get washed away, while uniformity increases.
Redpaw
Oregon State Police


• The State Police patrol Scenic Waterways, though they generally are not involved
in enforcing DSL and DEQ regulations pertaining to recreational placer mining.

The Oregon State Police maintain a significant presence on Oregon Scenic
Waterways. Like many agencies, the police make no distinction between Scenic
Waterways and others in carrying out their enforcement responsibilities, as the laws and regulations they enforce are not so narrowly applicable, but rather are applicable statewide. The State Police point out that a significant part of enforcement consists of education so that river users know the rules that they need to comply with, and monitoring to make sure those in compliance stay that way.


The State Police keep reports on their activities on Oregon rivers, though they do
not keep a systematic database regarding enforcement actions. To provide one example, however, the State Police reported that in 2001 officers spent about 1000 hours on the Rogue River from the mouth up to the town of Galice. Out of more than 1500 contacts with river users, 130 people were found to be in non-compliance with some type of law, regulation, or permit. Of these 1000 hours spent on the Rogue, approximately five hours were spent on activities that would involve DSL, and monitoring suction dredgers would be included in this number.

Considering that DSL and DEQ do not monitor compliance with their permits, this indicates that there is very little attention paid to recreational placer mining on Scenic Waterways, though BLM, USFS and the police noted that if there were serious violations by suction dredgers, they would most likely hear about it
and respond.


Other Agencies


The Oregon Department of Agriculture, the Oregon Department of Forestry, the
Oregon Marine Board, and the Department of Land Conservation and Development all maintain some interest in or responsibility for some aspect of the Scenic Waterways Program. None of these interests and responsibilities, however, involves recreational placer mining and the questions at issue in this report. (See The Oregon Scenic Waterways System: A Program Review and Assessment, for a discussion of these agencies and those mentioned above with respect to the Oregon Scenic Waterways Program.)
Redpaw
WHAT THE RESEARCHERS SAY


A considerable amount of research has been conducted in both social science and
physical science fields that bears on issues associated with Oregon Scenic Waterways and
recreational suction dredge mining. We reviewed relevant academic literature in order to
summarize the current state of knowledge and assess how research findings might assist
in decision-making. A review of relevant research on wildland recreation conflict,
crowding and visitor capacity is discussed first, followed by a review of scientific
literature pertaining to suction dredging.


Social/Recreational Impacts: Wildland Recreation Conflict, Crowding and Capacity

• Conflict between recreationists can arise from interference with visitor goals for
participating in a recreation activity, or from differences in social values.
• Conflict between motorized and non-motorized use is the most pervasive conflict
found in recreation settings.
• Perceptions of recreation areas as crowded are influenced by expectations, prior
experiences, and the number, similarity and behavior of other visitors
encountered.
• A single.conflict. encounter can have more pervasive negative effects than a
larger number of non-conflict. encounters.
• Available space, ecological impacts and the activities and behavior of different
visitors all influence the capacity of a recreation setting to support visitation.
• Visitor capacity may be reduced if managers are trying to accommodate
recreation activities that are incompatible.
• Dredge mining is likely to be in conflict with non-motorized recreation,
decreasing the quality of these experiences. Because these conflicts are probably
asymmetric, miners are not negatively affected in a like manner and may be
unaware of their impact on other recreationists.

Prompted by problems associated with rapidly rising and diversifying outdoor
recreation in the 1970s, researchers responded with studies designed to help public land
managers better understand and manage factors that affect recreation settings and
experience quality. Among these factors are conflict among recreationists, crowding at
heavily used sites, and the capacity of wildland recreation areas to accommodate
visitation. These topics are interdependent to some degree, but distinctions between them
can help in understanding recreation management challenges, and considerable literature
exists on each. This section presents a review of relevant studies and discusses how the
research applies to issues facing managers of Oregon Scenic Waterways. It concludes
with a brief note on socioeconomic impacts of recreational mining in the state.


Recreation Conflict

Recreation conflict is one of the most pervasive problems faced by public land
recreation managers. There is evidence that conflicts may be increasing as wildland
recreation continues to increase (Manning 1999). Conflicts typically arise when
individuals or groups attempt to use the same recreation area for different activities, but
can also be an issue when conditions for visitors engaging in the same activity become
crowded. Most simply, conflict occurs when the recreation experience of a person or
group is negatively impacted by the presence or activities of another person or group.
Conflict may or may not be outwardly manifested. In fact, most instances of conflict do
not result in negative verbal or physical exchanges between recreationists, although these
can sometimes result.

Recreation conflict is an important issue for land managers, so it has been studied
to identify potential causes and mitigation strategies. Recreation conflict can be difficult
to differentiate as a separate construct from crowding and personal norm violations
(Schneider 2000), but research has provided a better understanding of the issue. Based
on the assumption that people recreate to meet various goals, recreation conflict is
defined as goal interference attributed to another.s behavior, with four principal
contributing factors. These are activity style . the various personal meanings assigned to
an activity; resource specificity . the significance attached to using a specific recreation
resource for a given recreation experience; mode of experience . varying expectations of
how the natural environment will be perceived, and lifestyle tolerance . the tendency to
accept or reject lifestyles different from one.s own (Jacob and Schreyer 1980).

Several propositions concerning contextual factors make conflict more likely, including:

• The more specific the expectations of what constitutes a quality experience, the
greater the potential for conflict.
• Conflict results when users with a possessive attitude toward the resource
confront users perceived as disrupting traditional uses and behavioral norms.
• When a person who views a recreation place as unequaled confronts behaviors
indicating a lower evaluation, conflict results.

Recent research has refined this definition of conflict, adding the distinction
between interpersonal conflict and social values conflict (Vaske, Donnelly, Wittman and
Laidlaw 1995). Interpersonal conflict occurs when the physical presence or activities of a
group interferes with the goals of another group, such as problematic encounters between
snowmobilers and cross-country skiers, or mountain bikers and equestrians on the same
trail. Interpersonal conflict can also occur among groups engaged in the same activity,
although this is less common.

Social values conflict arises between individuals or parties of recreationists that
do not share the same norms and values, and can occur independently of actual contact
between groups. This type of conflict is rooted in differences of lifestyle and opinion
about the kinds of activities and behavior that are appropriate in wildland recreation
areas. A tent camper may have plenty of space, but have a worse experience because of
proximity to RV campers. Similarly, a recreational suction dredge miner might not be
physically impeding a person flyfishing fifty yards upriver, but that person could still be
affected. In these instances, visitors may not be physically interfering with each other,
but conflict occurs because one sees or hears the other engaged in some activity they did
not expect and do not like. This in turn can degrade recreation experience quality.
A study summarizing 30 years of conflict research reports some consistent
findings (Manning 1999). It is well established that the degree to which recreationists see
themselves as like or different from those encountered is often related to conflict.
Variation in motives for participating in a recreation activity has also been found to
influence conflict. For example, a rafting party may seek excitement and adventure while
a person fishing may seek undisturbed river conditions that enhance the likelihood of
catching fish. These motives differ, which increases the chances for conflict when the
rafting group encounters an angler. Research has also shown that conflict can result from
both direct and indirect contact between recreationists. Indirect contact includes the mere
presence of undesirable groups or even simply evidence of such groups, including
environmental impacts.

Use of motorized recreation equipment is an issue that often divides outdoor
recreationists into two distinct ideological camps and causes significant conflict in a
broad range of contexts. Conflict between motorized and non-motorized recreationists is
rising in the Pacific Northwest, and outdoor recreation continues to increase while the
amount of available public land does not (Robinson 2001). These trends are expected to
intensify as population and recreation use in western Oregon and Washington continue to
grow. Discord between motorized and non-motorized recreationists has long been an
issue for public land managers, and nearly half of the conflict studies reviewed by
Manning involved conflict between these groups. Many such conflicts are asymmetrical,
i.e., motorized recreation affects non-motorized recreation more than the reverse. Such
conflicts may result from actual encounters as well as social value differences, making
them particularly difficult to address.


Differences also exist in views toward resource development and preservation
among participants in three types of outdoor recreation: .appreciative. activities (crosscountry
skiing, hiking, and canoeing); .consumptive. activities (fishing and hunting); and
.mechanized. activities (motorboating, snowmobiling and trail biking) (Jackson 1987).
A strong preservationist orientation is exhibited among participants in appreciative
activities, while generally stronger pro-development views are found among participants
in consumptive and mechanized activities. The main differences occurred between
people who partake in human-powered activities and those who prefer motorized
activities.


When asked why they recreate in wildlands, people commonly cite the restorative
or regenerative effects of experiencing esthetically pleasing natural environments. They
also note that it helps them recover from stresses of modern life. Natural environments
do appear to possess intrinsic mental restoration capacities (Kaplan 1995; Kaplan and
Kaplan 1989; Ulrich 1993). Scholars frequently point out that nature-based experiences
and their restorative effects may be impacted by factors that affect the perceived
naturalness of outdoor settings (Bacon 1996; Gobster 1996; Kaplan 1987; Kaplan 1995;
Parsons, Daniel and Tassinary 1994). Ulrich (1983) notes that although scenes described
as natural are not restricted to wilderness, people are more likely to respond to a scene as
natural if human built features are absent or not prominent. McCool (1979) notes that
motorized use may disrupt other recreation experiences and interfere with humanpowered
activities. Wohlwill and Harris (1980) showed that people find human elements
in a predominantly natural landscape more acceptable if these elements are perceived to
.fit. into the setting.


Conflict between motorized and non-motorized recreationists appears to result
primarily from impacts on human-powered visitors. ability to experience solitude and
natural quiet. Conflict occurs when natural esthetic conditions that many visitors expect
in wildland recreation areas are not available or are degraded by concurrent motorized
use. The effect of motor noise on esthetic attributes of recreation settings seems obvious,
but has rarely been studied by means other than field observation and visitor surveys.
However, Mace, Bell and Loomis (1999) studied how helicopter noise affects perceptions
of natural landscapes in a controlled laboratory simulation. Subjects viewed 68 slides of
scenic vistas and assessed them for naturalness, preference, and scenic beauty and
evaluated dimensions of freedom, annoyance, solitude and tranquility. When the slides
were viewed with helicopter noise in the background (as opposed to sounds of birds or
streams), the assessments of these scenes suffered. The finding was that noise interferes
with experience quality and even affects the perceived esthetic quality of landscapes.
Similar findings could be inferred in situations involving other motorized recreation
equipment.


Hammitt and Patterson (1991) investigated coping behaviors that wildland
recreationists use to avoid conflict and achieve or maintain privacy and solitude. They
note three kinds of responses described by research. Displacement occurs when those
who are dissatisfied with encounter levels or activities of other recreationists move to less
crowded areas or choose not to visit in the first place. Product shift involves redefining
the encounter (and broader recreation) experience. For example, a rafter may expect a
wilderness experience, but upon visiting an area, decide that maybe this was an
unreasonable expectation on a busy summer weekend, and rather than leave the area, reevaluate
her expectations. Rationalization occurs when a person voluntarily selects an
area, then rationalizes conditions found as satisfactory.


Shindler and Shelby (1995) explain how product shift can confound the ability of
managers to detect impacts on recreation experience quality. Visitors become tolerant of
declining environmental or social conditions in order to obtain any experience at all,
especially in scarce recreation settings like wild and scenic rivers. Over time the most
tolerant visitors come to define acceptable resource conditions. Managers may become
complacent, or simply not realize conditions are declining because changes in experience
quality occur over time. Managers may also have difficulty gaining support for
management actions to mitigate factors that are degrading experience quality because
visitors are apparently still satisfied.
Redpaw
Recreation Crowding
Crowding is an important and widely studied social variable that affects
recreation experience quality. It has often been assumed that increases in density equal
increases in crowding, but Shelby, Vaske and Heberlein (1989) conclude that this is
overly simplistic. Density and crowding are separate constructs. Density is a numerical
description of the actual number of people in an area, and is thus objectively neither good
nor bad. Crowding, on the other hand, is explicitly defined as a negative evaluation of a
particular level of density (Shelby and Heberlein 1986).
Social norms – widely shared standards for what constitutes crowded conditions –
can be identified using visitor surveys and are strongly affected by context (Shelby and
Heberlein 1986). People are less likely to feel crowded by other people in an urban park
than by the same number of people in a wildland area. People are also less likely to feel
crowded by others perceived as similar to themselves, and engaged in similar activities
(Manning 1999). Visitor preferences, prior expectations and experience in the area,
commitment to the activity, characteristics of other visitors encountered, and an array of
situational variables can all influence how crowded people feel (Graefe, Vaske and Kuss
1984; Manning 1999).
Notwithstanding this complexity, use level is a practical, easily measured, and to
some extent manageable indicator of recreation quality, particularly at sites where
activity types are relatively homogeneous. The causes of crowding can be harder to
identify when different activities occur concurrently. In any case, however, density and
crowding are related to the concept of visitor capacity, an idea borrowed from the
biological sciences and expanded to include (in addition to physical constraints) the
psychological dimension of perceived crowding (Manning, Lime and Hof 1996).
59
Visitor Capacity
Two fundamental responsibilities of public land recreation managers are to
protect lands under their charge from unacceptable impacts resulting from overuse or
misuse, and to maintain and enhance the quality of recreation experiences for visitors.
How these responsibilities are met varies greatly because of the diverse landscapes,
management goals, and activity types available on public lands. In all cases, however,
balancing resource protection with public access and recreation requires managers to
understand something about the capacity of the area to support visitation.
Visitor capacity is defined as “…a prescribed number and type of [recreationists]
that an area will accommodate given the desired natural/cultural resource conditions,
visitor experiences, and management program” (Haas 2002). Biophysical aspects of
visitor capacity include cumulative ecological impacts and physical space available.
These categories are referred to as ecological capacity, such as plant, animal, soil or
water impacts, and physical capacity, such as number of sites available at a campground
(Shelby and Heberlein 1986).
Visitor capacity also has social components, for example, the number of people
visible, the number of encounters with other parties per hour or day, or encounters with
parties of a different type or size (Shelby and Heberlein 1986). Social variables such as
the activities and behavior of other visitors can influence perceptions of crowding and
conflict, so they are important to consider when assessing visitor capacity. This is
especially true in wildland settings, where interaction with nature and solitude are
essential attributes of many visitors’ experiences, and contacts with other people can
affect experience quality as much or more than biophysical factors.
When developing visitor capacity guidelines in areas with heavy demand,
managers must first define types of activities and experiences that are appropriate there.
This is a critical step, because biophysical and social aspects of visitor capacity, and
strategies to manage them, will vary widely with the type of visitor experience being
targeted. Moreover, overall capacity may be lower if managers are trying to
accommodate recreationists with diverging goals or a history of incompatibility and thus
more likely to conflict than visitors who generally share similar goals and activities.
Defining appropriate experiences and setting visitor capacity standards are
difficult because of the variable and contextual nature of how humans perceive and
experience the natural environment. This is contentious because these decisions directly
affect who gets to do what, when and where. These recreation allocation issues can be
value laden and controversial, so experts consistently stress the importance of explicitly
spelling out the types of recreation opportunities the area in question will be managed for,
and why. Professional judgment is an appropriate basis for making visitor capacity
determinations, but such decisions must be principled and reasoned (Haas 2002).
60
Recreation Conflict, Crowding and Capacity in Oregon Scenic Waterways
Academic distinctions between conflict, crowding and capacity help us
understand them, but in the real world these issues are closely related and often
interdependent. The crux of the matter for managers of popular waterways is how to
accommodate heavy visitation while meeting goals for resource protection and
experience quality. This usually means allowing visitors as much freedom as possible
while mitigating the factors that exacerbate conflict, crowding and resource degradation
which (other than being denied access to a site) are the most common the most common
factors that degrade recreation experience quality.
Conflict arising from the presence of recreational placer mining in Oregon Scenic
Waterways seems to be based on both goal interference and social value differences. The
goal of non-motorized recreationists to experience the natural characteristics of a
waterway may be compromised by motor noise, turbidity or visible evidence of mining or
miners’ campsites. But there is also considerable evidence that divergence of social
values seems to play a significant role in these conflicts. Actual blockage of boaters’
routes downstream does occur and is a potentially serious safety issue, but this is not the
source of most boater-miner conflicts.
Differences between miners’ and other river recreationists’ views about
“appropriate” recreation were consistent with Jackson’s typology. Many visitors seem to
fit the category of “appreciative” recreationists, while miners have characteristics of both
“consumptive” and “mechanized” recreationists and held more utilitarian views about
human-environment relationships. Thus miners saw nothing wrong with recreational
mining, while other visitors often held that recreation activities with a lighter “ecological
footprint” are most appropriate in waterways protected for their natural qualities.
People are more likely to feel crowded and perhaps also more likely to experience
conflict when they encounter other visitors engaged in a different activity. This is
especially true if they feel the activity is inconsistent with the primary recognized
attributes and qualities of the area. Thus, overall visitor capacity may be affected if an
agency is trying to accommodate an activity that some groups feel is inappropriate and is
leading to conflict.
For example, visitors to popular Oregon Scenic Waterways such as the Rogue
may perceive conditions as crowded at lower visitor densities when use includes
recreational placer mining than if such use did not occur. A single miner may be
encountered by several boaters, who might reasonably have expected natural conditions
and thus may find the activity inappropriate and intrusive. This increases perceptions of
crowding more than an additional boater or riverside hiker might. When setting visitor
capacity, managers must consider a range of factors, any one of which might limit
capacity in a different situation. Capacity for overall use will depend on how well
individual uses co-exist, and how much impact they have on biophysical resources.
61
Heavy recreation use is an increasingly important issue on several Oregon Scenic
Waterways, and managers believe rivers such as the Rogue and Deschutes may be
reaching visitor capacity. This places pressure on managers to look critically at
recreation activities with the highest potential to impact other river visitors and riparian
conditions. Recreational suction dredgers are not a large group, and many recreationists
contacted statewide indicated they had never encountered the activity. However, where
mining and non-motorized recreation occur together, conflict attributed to the presence
and actions of miners is fairly common. Safety can be an issue for boaters, but most
conflicts relate to noise, level of development, degraded ecological conditions, and
differences in social values.
For various reasons, these types of social conflicts usually do not lead to official
complaints, but miners do appear to have a larger impact on other visitors, rather than
vice versa. Managers report few complaints on rivers where recreational mining occurs
with boating, but as described previously, this is somewhat inconsistent with what boaters
reported, as would be expected with an asymmetric conflict. Staff and budgetary realities
limits consistent monitoring of recreation conditions, and product shift hinders managers’
ability to detect changes in experience quality over time. For these reasons, manager
perceptions do not necessarily indicate that boater-miner conflicts are inconsequential.
There is a good probability that some level of conflict will occur when boaters,
hikers or other non-motorized recreationists encounter a recreational suction dredge
miner. Because of the disproportionate effects that one miner can have on other
recreationists, such conflicts may increase if current trends of rapid growth in recreational
rafting and kayaking continue, even if mining itself does not grow.
Socioeconomics
One additional item to be briefly mentioned involves socioeconomic impacts of
recreational mining. Oregon mining organizations have suggested that one of the impacts
of recreational mining is significant economic activity in particular parts of the state.
This was discussed earlier in this report, and while this claim is often made, there is no
solidly reliable data available to say with certainty what the economic impact of
recreational placer mining is in the state of Oregon. As mentioned previously, a 1994
State of California environmental impact report on suction dredging estimated that a
typical dredger spends around $9,000 per person per year on equipment, gasoline, repairs
and maintenance, motels, groceries and restaurants, other forms of recreation and
occasionally on medical services. The Waldo Mining District in southwest Oregon
surveyed its members in 2001, and came up with similar results. These estimates,
however, are not considered to be hard statistical data regarding exactly how much
economic activity recreational placer mining generates for local communities.
Redpaw
Biological and Ecological Impacts


The scientific literature reviewed here consists of academic journals and
government reports, including environmental impact statements. The literature covers
biological and ecological impacts that can result from small-scale suction dredging
(studies looking at larger operations were excluded because of their inapplicability to the
issue at hand), and the effects of various mining practices in different types of stream
conditions. This does not imply that all of these impacts always occur in every mining
area.

Different levels of compliance with regulations, varying degrees of land
stewardship, and other contingencies that depend on individual behavior determine
exactly what will occur in a given case. These contingencies, however, are not what the
scientific literature is supposed to reveal -- that is the purpose of monitoring.


Highlights of the scientific literature on environmental affects of dredging include the following:

• There are only a small number of peer-reviewed scientific studies that directly
address the impacts of suction dredge mining. However, there are several
environmental impact statements, government reports and articles (both peerreviewed
and non-peer reviewed) that address the issue, either directly or
indirectly.
• The long-term impacts of suction dredging, tested over large areas and large
populations of fish and wildlife, have yet to be systematically addressed, partly
because of cost and partly because of the limitations in designing and executing
controlled experiments over large times and spaces. Therefore, knowledge
regarding total impacts, especially cumulative impacts, is very limited.
• Scientific literature suggests that there is a high likelihood of some damage from
suction dredging, but it also concludes that with proper regulation and adoption of
certain best management practices, harmful effects can largely, though not
entirely, be mitigated.
• In rivers and streams with high natural fluctuation of waterflows, most evidence
of suction dredging is washed away. Rivers and streams in the region are typified
by high natural, seasonal waterflows. Therefore, most effects of suction dredging
are short term because these high winter flows recruit and redistribute sediment,
recreating natural habitats.


It is important to note that the scientific studies and assessments that have been
done to date, especially peer-reviewed scientific studies, are relatively small in number.
The work that has been done has been generally well-received and well-regarded, but in
spite of the this, scientists in this field are quick to point out that with respect to the
impact of suction dredging, they are much more in a state of ignorance than they are in a
state of knowledge. This is because the studies done to date have looked only at a small
part of what scientists and policymakers may wish to know. They have thus far looked at
impacts over the short-term in localized areas. This in an important area of research, but
it represents only a segment of the possible areas of study. The longer-term impacts over
larger areas and larger fish and wildlife populations have yet to be systematically
addressed, partly because of cost and partly because of the limitations in designing and
executing controlled experiments at large temporal and spatial scales.


Due to the fact that there have not been numerous studies on suction dredging
done in Oregon waterways, and because the characteristics of each river and stream can
be different, this report cannot conclusively state what impacts will be found in Oregon
waterways. However, conditions in streams and rivers throughout much of the
northwestern United States are considered by researchers to be sufficiently similar to
conclude that their results are generally applicable to other waterways.
The literature does suggest, based on studies and assessments done throughout
various parts of the western United States, that there is a high likelihood of some damage
from suction dredging, but it also concludes that with regulation and adoption of certain
best management practices, these harmful effects can largely, though not entirely, be
mitigated.


The scientific literature looks at several aspects of suction dredging and a variety
of potential impacts the practice may have. There are several steps in the process that
may impact the rivers and surrounding areas. They include:

• Access . in order to gain entry to a site, miners may need to drive or walk into
an area without established roads or trails. Also, in order to access a particular
spot in the riverbed to mine, it may be preferable for miners to move large
boulders or logs, or cut or remove vegetation.
• Entrainment . when operating a suction dredge, fish, eggs, fry, or invertebrate
may be sucked into the dredge. This is referred to as entrainment of the
organisms.
• Turbidity . suction dredges, in the process of pulling gravel and sediment up
from the riverbed, may cause a plume that clouds the water, sometimes over a
great distance as water is moved downstream by the current.
• Tailings . during the operation of a dredge, the gravel pile that is formed,
called a tailings pile, can consist of a pile of loose gravel that is not stable
and/or diverts waters from their natural course in the river.
• Sedimentation . fine particles released into the stream by a suction dredge
will not immediately fall to the riverbed and are likely instead to be deposited
elsewhere in the stream in calmer areas where currents are light. This can
potentially cause a buildup of sedimentation in areas where this would
otherwise not have occurred.

Each of these parts of the process may have effects on various aspects of the
ecology and health of the stream and the organisms living in it. The scientific literature
reviewed discusses this and potential cumulative effects of several operations with
respect to fish, invertebrates, riparian habitat, water quality, and cumulative impacts.
Three studies in particular have included a substantial review of other work done
on the question of suction dredge mining. Harvey and Lisle (1998) looked at other peerreviewed
investigations of suction dredging to evaluate the literature and propose
strategies for further study and management of streams and rivers. This study concluded
that the effects of dredging commonly appear to be minor and local, but that effects can
actually vary widely among stream systems and reaches within systems. It is therefore
very important for natural resource managers to take into account the life cycles of fish
and other organisms to tailor regulations to mitigate potentially serious effects. The
authors also noted that there has been relatively little peer-reviewed work done on the
effects of dredging, and the result is that a great deal of uncertainty about its effects
remains, especially long-term effects. Given the current state of knowledge, the authors
suggest that .fisheries managers would be prudent to suspect that dredging is harmful to
aquatic resources.. They further concluded from their review that additional study and
management of streams and rivers was necessary.


A second study was the State of California.s Final Environmental Impact Report
for the Adoption of Regulations for Suction Dredge Mining (California FEIR), issued in
1994 and revised in 1997 to account for some amendments to the regulations. This report
reviewed the relevant literature and discussed several harmful impacts from unregulated
suction dredge mining. The report recommended that proposed regulations would be
sufficient to mitigate these impacts.


A third study, a Draft Environmental Impact Statement (DEIS) completed by the
US Forest Service in 2001, reviewed the relevant literature completed to date for the
purpose of assessing suction dredging activities in the Siskiyou National Forest in
southwest Oregon. The DEIS looked at three alternatives involving varying degrees of
restrictions on suction dredging. It found that the alternative proposed in the draft .
which is generally consistent with the types of regulations currently in effect . would
provide considerable protection to fish, wildlife and habitat through proper regulation,
and that more stringent regulation would offer increased protection.
These and other studies will be addressed below in discussing the potential
impacts on fish, invertebrates, riparian habitat and water quality, as well as cumulative
impacts.


Fish

• Destruction of habitat, entrainment of fish, fry and eggs, loose tailings piles, and
sedimentation can all significantly impact fish populations.
65
• Activities of miners must be limited by regulation in order to reduce or eliminate
these impacts.


Suction dredging can affect fish in several ways. Regulations in Oregon allow
mining to occur only in defined in-water work periods, generally in the summer months,
to limit the direct effects of mining on spawning fish, eggs, or embryos. This type of
limitation has a significant effect on preventing harmful impact to fish (California 1994;
USFS DEIS 2001; Harvey and Lisle 1998). In some places, salmonids and nonsalmonids
have spawning and incubation periods that extend into the summer months, so
there is often some overlap and thus potential for impacts (Harvey and Lisle 1998). With
respect to impacts from entrainment, effects are greatest on eggs and fry (Griffith and
Andrews 1981; USFS DEIS 2001; Harvey and Lisle 1998; California 1994).
One study in particular tested this and found that mortality among the eggs of
cutthroat trout sucked through a dredge ranged from 29% to 100% (Griffith and Andrews
1981). The same study also found that sac fry of rainbow trout suffered greater than
80% mortality resulting from entrainment. Mortality rates among sac fry not passed
through a dredge were only 9% (Griffith and Andrews 1981). Other fish that produce
equally small larvae are likely to suffer the same mortality rate from being passed
through a dredge, and eggs from all types of fish would have high mortality rates as well
. resulting not only from the mechanical disturbance, but also predation after passing
through a dredge and other physical/chemical conditions. The State of California.s FEIR
suggested that mortality would be close to 100% for all eggs and fry. Once they were
removed from their protective in-gravel environment they would be available and
attractive food sources that would not be likely to survive for long. By contrast, most
juvenile and adult fish would be likely to avoid being sucked into a dredge, and those that
were would be likely to survive (Harvey and Lisle 1999; Griffith and Andrews 1981;
California 1994).


Suction dredge tailings piles are also believed to have potential impacts on the
survivability of fish eggs, or redds (Harvey and Lisle 1998; USFS DEIS 2001; California,
1994). This may not consistently be the case, as some evidence suggests that gold
dredging in certain streams and rivers increases the availability of spawning gravel by
loosening up compacted gravels (Badali 1988; Hassler et al. 1986). However, impacts
from tailings piles are often considered to be significant. Impacts can result even outside
the work period when miners are permitted to dredge. Dredging does not usually occur
when most fish species of special concern tend to spawn. And many fish spawn in the
spring after dredge tailings from summer and fall mining activities have been moved by
currents resulting from high water flows in the winter. However, dredging during the
summer can affect the reproductive success of fish that spawn in the fall such as chinook
salmon and coho salmon because some of these fish choose tailings as their spawning
habitat, and these piles are typically less stable during high winter flows (Harvey and
Lisle 1999).


The reasons are as follows. During the summer and fall, there is generally low
streamflow. Tailings piles that were created in the summer months are more likely to
retain their original form through the fall, just when chinook and coho are spawning.
Tailings often contain the materials appropriate for redds, although the extent to which
they will be used depends on the amount of suction dredging in an area and the
availability of other suitable sites for spawning. These piles tend to be less stable than
the rest of the riverbed, so when high water flows occur, tailings piles are more likely to
be washed away, resulting in the death of the eggs. Consequently these sites are
considered undesirable spawning grounds (Hassler et al. 1986). The literature suggests
that natural resource managers could reduce or eliminate these potential harmful effects
through regulations that require tailings piles to be redistributed (flattened) in order to
restore the riverbed to conditions more like they were before dredging occurred.
Sedimentation can also pose a problem for fish populations. This can occur
during the period when sediments are suspended in the water and moving downstream .
the problem of turbidity in the water . and after the sediments have resettled in the
riverbed. The impacts of suspended sediment vary with the amount of time sediments are
in the water and the size of the particles. While extremely high levels of sediment can be
lethal, or at least very harmful, it is believed that lethal concentrations of suspended
sediments will rarely be produced by small suction dredges because fish can usually
avoid those concentrations (Newcombe and Jensen 1996; Harvey 1986). Research has
also found that when water is made turbid by dredges, this does not appear to affect the
feeding abilities of many species (Hassler et al. 1986; USFS DEIS 2001). Moreover,
suspended sediments are usually quick to resettle to the riverbed allowing the water to
return to normal levels of turbidity. Dredging is done during low flow periods, usually in
areas where the ability of the stream to carry sediment is low, thus silt is usually
deposited nearby dredging activities. By way of comparison, it has been noted that as
long as multiple dredges are not operating simultaneously, suction dredging cannot
mobilize nearly as much sediment as naturally occurring high water flows (Harvey and
Lisle 1998).


Sediment may also have an impact once it resettles. The concern is that since
suspended sediments tend to fall to the riverbed in areas where waterflow is
comparatively slow, they tend to accumulate in the same places (Keller 1971). When
pools and other habitat are present in these areas, they can be filled in by the sediment,
which has the effect of removing sites fish may normally use (Thomas 1985; Harvey
1986; Harvey et al. 1982). The effects of sediment deposition can also suffocate eggs
and reduce the production of important invertebrates, which are part of the food chain.
However, in streams with larger flushing flows, fish are less likely to be highly sensitive
to dredging, most likely because these same variations in sediment levels occur naturally
(Harvey 1986). The state of California and the US Forest Service concluded that the
effects related to turbidity and sedimentation appear to be measurable at the site level, but
they are localized and temporary in most cases, especially in areas with large natural
fluctuations in stream flow (California 1994; USFS DEIS 2001).


Other impacts can result from movement of boulders and woody debris to permit
access to mine a particular spot. Large items such as these create pools; they also block
the force of the flow, creating feeding and resting areas. Dislodging them can result in
adverse impacts (California 1994, Harvey and Lisle 1998; USFS DEIS 2001). However,
it is also the case that such effects will generally be localized when they do occur. Better
still, they can be mitigated through strict regulation prohibiting the movement of boulders
and woody debris, although the Forest Service has acknowledged that educational efforts
would be required to make sure these efforts were successful (California 1994; Harvey
and Lisle 1998; USFS DEIS 2001).


Some positive impacts of suction dredging have also been noted. In streams
carrying significant amounts of sediment, the riverbed can become embedded and
compacted, providing fish with poor spawning ground. Suction dredging may be able to
break up compacted gravel, particularly on reaches below dams where there are no high
flushing flows (Badali 1988; California 1994). Also, deeper areas left by dredgers may
be occupied by fish once dredging has been completed (Harvey and Lisle 1998;
California 1994).


Invertebrates


• Invertebrate colonies situated in the riverbeds are almost entirely destroyed by
suction dredging.
• The effects of dredging are localized . they do not extend beyond the immediate
area dredged. In addition they are temporary . most invertebrates recolonize
dredged areas within 1-2 months after dredging has occurred.
Invertebrates in streams consist of various types of insects and other organisms
than live in the sediment of the riverbed (these organisms are also referred to as benthic
invertebrates, the benthic zone being the bottom sediment). Several studies have
examined the impacts of suction dredging on invertebrates, investigating whether or not
they are substantially impacted while dredging occurs, and the extent to which benthic
communities recover over time. These studies have shown that the impacts on
invertebrates are significant, destroying invertebrate populations in immediate dredging
area. However, it has also been found that these impacts are generally localized to the
specific dredging area and short-term, with recovery taking place within 1-2 months
(Harvey 1986; Thomas 1985; Hassler et al. 1986; Harvey et al. 1982; EPA 1999).
Griffith and Andrews (1981) found that while fish eggs and fry suffered from
high mortality rates upon passage through a suction dredge, mortality (and injury) rates
for insects were less than 1%. Lewis (1962) found mortality rates of more than 7%,
which is still considered a small number. These results, however, may represent a low
estimate of survival. Observations by both scientific investigators and recreational
miners confirm that fish tend to readily feed on invertebrates dislodged by a suction
dredge, so survival from entrainment may not mean survival through the normal lifecycle
(Thomas 1985; California 1994).


Thomas (1985) found that after dredging, the abundance of insects and other
species at the site was significantly reduced, though these effects were localized. The
numbers of invertebrates downstream were not affected. In addition, recolonization by
insects and other species at the dredge sites were .substantially complete. one month
after dredging. This was determined by comparing numbers of insects at sites that were
dredged with numbers at sites not dredged. Only one type of insect had not fully
recovered in that time. Harvey (1986) looked at sites that had been dredged multiple
times for purposes of his study. He reached similar conclusions to Thomas, noting that
the effects were highly localized, and that insects tended to fully recolonize dredged areas
45 days after dredging took place. He also found that there were no cumulative effects
on invertebrate populations. Similar recolonization took place after each instance of
dredging.


Riparian Habitat


• Riparian habitat can be impacted by three types of practices: by suction dredging
outside permitted areas, such as under the edge of the riverbank and outside the
wet perimeter of the waterway; by cutting or removing vegetation to gain access
to mining sites; and by activities associated with placer mining, such as camping
and blazing trails.


• If these practices are neither prohibited nor mitigated by regulation and good
stewardship, the impacts can last for years before natural processes erase them.
The condition of riparian zones and riverbanks are closely linked to the quality of
habitat for both fish and wildlife. When damage is done to these resources, it can take a
very long time for natural processes to make the needed repairs (Harvey and Lisle 1998;
California 1994). Streambeds and riparian habitat can be most significantly affected in
three ways. The first occurs when suction dredges are used outside the wet perimeter of
the stream, or are used underneath the edge of the stream bank. In these instances miners
can cause significant long-term damage to riparian areas that can last several years.
Suction dredging outside the wet perimeter in the riparian zone impacts habitat used by
many species, large and small. In addition, observations by stakeholders and the
scientific literature both make the point that high water flows remove much of the
evidence that suction dredging has occurred, redistributing gravel, filling or
reestablishing pools. Therefore, areas outside the wet perimeter are not nearly as likely to
be .flushed. by high streamflows when the winter rains arrive, leaving behind a lasting
impact.


When suction dredges are used under the edge of a stream bank, it can undercut
the bank, destabilizing it and sometimes causing it to collapse into the water (Hassler et
al. 1986; McCleneghan and Johnson 1983; California 1994). This destroys habitat for
invertebrates and other organisms that depend on habitat at the water.s edge, and it
removes cover used by some fish species. Undercutting banks also changes the structure
and shape of the waterway, which affects waterflows (Harvey and Lisle 1998; California
1994; Badali 1988). Three assessments done in California found that even though
compliance with regulations was relatively high, some suction dredgers were
undercutting banks in various areas, and the impacts from these violations could be quite
significant (Hassler et al. 1986; Stern, 1988, McCleneghan and Johnson 1983). Though
it is unclear what the compliance rates are throughout Oregon, these results suggest that
significant impacts may be occurring.


Second, cutting or removing vegetation or large woody debris to provide better
access to a particular spot to be mined can have a large impact on the ability of the
riparian zone and streambanks to support fish and wildlife dependent on these areas. The
roots of riparian plants provide banks with stability against flowing water and allow for
non-uniform surfaces along the wet perimeter. Overhanging banks and other irregular
features along the bank can also provide important cover for fish (California 1994; USFS
DEIS 2001; Harvey and Lisle 1998). In addition, vegetation that blocks sunlight from the
river may help maintain cooler water temperatures during the summer, providing better
habitat for salmonid species.


Third, riparian areas can suffer degradation independently of the actual suction
dredging process. Other activities associated with suction dredging such as camping,
blazing trails to dredging sites, and anchoring equipment may impact riparian zones.
Dredge operators camp in areas adjacent to streams and rivers, with campsites sometimes
occupied by families or small groups, and some sites are often camped at for extended
periods (California 1994; USFS DEIS 2001; Harvey and Lisle 1998). In addition, miners
will often camp at sites that are not maintained by land management or resource agencies.
Therefore responsibility for keeping up the site or removing garbage or other traces of
use is left entirely to the miners (Harvey and Lisle 1998). When miners engage in these
practices, which may be a necessary part of getting access to a site or remaining there,
they can cause damage to the riparian zone, which may be home to many species of
plants and animals (McCleneghan and Johnson 1983; Harvey and Lisle 1998; California
1994; USFS DEIS 2001; EPA 1999).


Impacts to riparian areas are thought to be considerable if there is not adequate
control and/or stewardship. In fact, in several instances it was surmised that the
destruction or removal of vegetation and boulders . whether for suction dredge mining or
associated activities . can present a more serious potential environmental threat than the
operation of suction dredges.


Water Quality

• Turbidity is often thought to cause significant impacts to water quality, but this is
not usually the case.
• Suction dredging is more likely to harm water quality from gasoline and oil spills,
from runoff out of adjacent campsites or, to a lesser extent, from mobilization of
heavy metals left by historical mining activities.
• Removal of heavy metals such as lead and mercury by recreational miners can
improve water quality, but may also simply mobilize toxins and reintroduce them
into the water and the riverbed surface.


Water quality is usually unlikely to be significantly affected for a long period of
time by turbidity, which is affected by factors such as the volume of water in a waterway,
rate of waterflow, and the number of dredgers in an area. Turbidity is often thought to be
a significant contributor to diminished water quality. However, larger particles quickly
return to the riverbed, and turbidity caused by fine sediments usually lasts for only a short
time before sediments resettle (Harvey 1986; Badali 1988; USFS DEIS 2001). In Alaska,
the US Geological Survey found on the Fortymile River that turbidity from dredging
causes no significant changes to water quality (USGS 1997). However, the applicability
of assessments on this river to Oregon conditions has been questioned because of
differences in the physical conditions in the river systems.


The water quality of a stream or river may be most significantly affected by
suction dredging as a result of two things in particular. The first of these is that dredges
require gasoline to operate. They also require oil and grease to lubricate parts and keep
the engine in proper working order. Since fuel sources are most likely to be kept within
close range of the dredge, it is likely that there will be periodic spillage of gasoline, oil or
grease into the water and that the impact would be detectable at the site level (USFS
DEIS 2001). With dredges that use 2-stroke engines, this type of spillage into the river is
likely to be even greater. The state of California differs with this conclusion, noting that
while some spillage would be likely to occur, the environmental impacts would not be
significant (California 1994).


Suction dredging can benefit the environment by removing lead and mercury
from waterways (California 1994). As was pointed out previously, Oregon miners
recently turned in ten pounds of mercury. However, suction dredging does not only
result in the removal of these heavy metals. Sometimes it only dislodges them and moves
them around. This mobilization of heavy metals, which reintroduces them into the water
and the riverbed surface, may be toxic to aquatic species (California 1994).


Cumulative Impacts


• Cumulative impacts from multiple dredges operating at once, or from dredging in
the same spot year after year have not been adequately studied.
• This absence represents a significant gap in the literature, and leaves scientists
unsure about the long-term impacts of suction dredging. In the absence of
evidence, scientists advise caution to regulators and land managers.


Cumulative impacts are those that result from either a) multiple dredges operating
in the same area, or b) the same segments of streams and rivers being dredged year after
year. A number of people contacted for this review conveyed their sense that the
cumulative impacts from either of these circumstances may be significant, but also noted
that some cumulative impacts can be subtle and generally undetectable in the short-term.
Harvey and Lisle (1998) have pointed out that no research has been done involving the
impacts of multiple dredges that are closely spaced and operating at the same time, and
that this is likely to be an important consideration, especially in reaches that are dredged
year after year. Badali (1988) suggests differently, however. Using data gleaned from
previous studies not specifically designed to observe cumulative impacts, he notes that
the effects of multiple dredges operating over a relatively limited area of 11 to 15
kilometers are insignificant.


It is also the case that no research has been done looking at the long-term
cumulative impacts of suction dredge mining on areas that are worked every year. (This
may have some relevance for the state of Oregon, where some stretches are mined year
after year with multiple dredges simultaneously. Some mining organizations sponsor
group trips to particular areas, and so more than one dredge may in operation at a time.
This circumstance, however, appears to be more common in areas where an organization
has a mining claim, and less common on specifically designated Scenic Waterways.)
The lack of studies addressing cumulative impacts of multiple dredges and
cumulative impacts over long periods of time represents a significant gap in the literature
about what the impacts and potential impacts suction dredging may be. The unknowns
contributing to such a state are many: the intensity of use on particular waterways,
effects from mining conducted decades ago vs. those resulting from current practices, the
difficulty in tracking whole fish populations, and the difficulty of attributing particular
effects to suction dredging when waterways are subject to multiple uses, to name a few.
Moreover, the cost of turning these elements of ignorance into useful knowledge can be
prohibitive.
Redpaw
Summary of Findings
The scientific literature supports the assertion that small-scale suction dredging
has the potential to significantly impact the overall health of waterways by impacting
fish, wildlife, habitat, and water quality, both in the short and long-term. Scientists can
speak with much greater authority about short-term, localized impacts, as that has been
the focus of most studies. However, with respect to riparian areas, the threat of potential
long lasting impacts is better understood.
While it is the case that significant impacts can and do occur, the literature has
pointed out that most observed impacts are local and temporary. However, this is partly a
function of observation bias, that is, the studies done thus far have not systematically
addressed long-term effects of dredging. Moreover, impacts can be substantially
mitigated, according to the literature, if regulations are implemented (and enforced) that
72
address those practices that can do serious harm. This part is essential, because only if
best management practices are followed can the impacts be significantly mitigated. This
is dependent upon the good stewardship of individual miners and effective enforcement
of compliance with regulations. The US Forest Service and the State of California found,
in their respective environmental assessments, that regulations are not consistently
followed, and so it is sometimes the case that the impacts that scientific researchers have
concluded can occur, actually do occur.
In the event that regulators and land managers can achieve high rates of
compliance with regulation, then the chances that nature will be better able to repair itself
are greatly increased. Harvey pointed this out, stating that in streams where there is a
natural and substantial fluctuation in water levels, then winter water flows are likely to
flush the system and reduce the long-term impacts of dredging. By contrast, streambed
alterations will be more long-lived on rivers and streams with controlled flows (Harvey
1986; Harvey et al. 1982), but these streams are already impacted because their natural
disturbance patterns have been affected.
Finally, the question of multiple impacts from different activities should be
addressed. There are no studies that compare biological and ecological impacts from
various uses on waterways – recreational mining, camping, hiking, boating. A number of
stakeholders, regulators, land managers and scientists did point out that suction dredging
can cause significantly less impact than campers, or jet boats, or other activities in which
river users do not practice good stewardship of the land. By the same token, a single
miner who acts without regard for nature can cause a great deal of harm that takes years
to repair through natural processes. Therefore, it is difficult to say with assurance which
activities are best or worst for fish, wildlife and habitat. In looking at ecology, so many
variables come into play, all activities have to be taken in the context of understanding
the physical setting and the practices of the river user. This is why so many of the
questions posed by scientists yield an answer of “it all depends.”
GOALS AND USES: ARE THEY COMPATIBLE?
There are two types of issues to consider when discussing the compatibility of
suction dredge mining with the goals and objectives of the Scenic Waterways Program.
These are environmental/biological, and social/recreational considerations.
Environmental and Biological Considerations
The first of these – environmental and biological considerations – are the easier to
address. Peer-reviewed scientific literature that speaks to the subject, though to some
extent limited, suggests that most impacts can be kept at a level that does not do
widespread or long-term harm to fish, wildlife, habitat, or water quality. The
environmental impact statements from Oregon and California suggest the same thing. In
all cases, however, these determinations are based upon the understanding that suction
dredge mining is strictly regulated, with rules developed that take into account the
73
specific conditions of each river and stream, and most importantly, that miners carefully
observe all regulations and best management practices. This is key to interpreting the
literature, as the science also claims, again and again, that unregulated, unimpeded
dredging practices can and will be very harmful.
The government agencies dealing with recreational mining generally have come
to conclusions similar to and often based upon the scientific literature: that proper
regulation of mining activities can keep the environmental impacts at an acceptable level.
The definition of acceptable is certainly subject to dispute, but among the various
agencies involved, acceptable environmental impacts do not require that there be no
evidence of impact. Instead they tend to focus on practices that are abusive, destructive
and/or have the potential to cause long-term environmental damage.
What appears to be very clear from addressing the literature, the stakeholders, and
the government agencies is that the most effective control to be placed on suction dredge
miners is self-control. If individual miners refuse to follow regulations, then any
suggestions of compatibility are not applicable. A handful of suction dredgers, or even a
single person, who refuses to respect the law and to make the effort to protect his or her
surroundings can do more short-term and long-term damage than dozens of suction
dredge miners (or other river recreationists for that matter) who practice good
stewardship of the land and natural resources.
The scientific considerations then, while concluding that suction dredging does
not, by definition, cause irreparable harm to natural resources, comes with a big if: that
is, these conclusions can only be true if the practitioners of suction dredge mining play a
significant role in making them true.
Social and Recreational Considerations
The issues surrounding recreational conflict, multiple uses, and the clash of
competing social values present a more varied picture than the science does in
considering the compatibility of recreational placer mining with the goals and objectives
of the Scenic Waterways Program.
The most serious incompatibilities are those that reflect a sharp difference in the
values attached to the state’s natural resources. Among individuals and organizations
that maintain a clear preference for activities, uses, and non-uses that enhance resource
preservation and protection, there is a strong understanding that mining for gold with a
motorized dredge is entirely incompatible with the Scenic Waterways Program. (This
view would also hold true for other parts of the state as well.) The argument is that at a
time when pressures on natural resources are increasing, when the damage done from
historic mining operations has not been completely repaired by natural processes, and
when social values have shifted in recent decades from favoring resource extraction to
resource conservation, there can be no accommodation for an activity such as suction
dredge mining, even on a small-scale, recreational basis.
74
Among river recreationists throughout the state of Oregon, the issue is not so
clear-cut. There appears to be recurring recreational conflict between miners and other
river users. Motor noise, turbidity and the condition of miners’ camps interfere with
goals of non-motorized boaters, hikers and campers to enjoy an experience in a quiet,
natural river setting. Recreationists also reported being intimidated and displaced by
encamped miners who seemed to believe they had certain rights to occupy the area.
Conflict can also be partially attributed to differences in social values about what
constitutes “appropriate” recreation in Scenic Waterways and perceptions that any form
of mining is inconsistent with the attributes scenic rivers were protected for.
At the same time, boaters and other recreationists reported seeing few dredgers on
Scenic Waterways, and especially less now than in years past. Miners indicated there is
some correlation between number of miners and gold prices, which are currently low. If
this is accurate and represents a general trend, recreation conflict might be expected to
decrease because boaters would encounter fewer miners. However, the overall number of
boater-miner contacts might also actually increase because non-motorized boating is
growing so rapidly in popularity. Boaters might see fewer individual miners on a given
day, but many more boaters may encounter the miners that are still active.
In spite of reports of significant recreational conflict, state and federal land
managers who administer recreation in Scenic Waterways indicated that the impact of
recreational mining on other recreationists was not serious and did not warrant taking
action. Based on this assessment, it would be reasonable to conclude that recreational
conflict between recreational miners and other river users is widespread but perhaps not
tremendously serious.
However, some recreationists often described the situation differently, arguing
that managers downplay the impact of recreational mining because they are understaffed
and the issue is complicated and controversial. Conflicts between recreational miners
and other visitors are viewed as less pressing than recreation access, crowding, site
maintenance, and capacity issues. Several boaters stated that they disapproved of
recreational suction dredging and thought it should not be allowed, but they had not made
this case to river managers. Taking time to voice complaints was viewed by some as “a
waste of time” because mining was still legal, and river managers were seen as
uninterested or unable to really do anything about it.
Perceptions that recreational mining causes conflict are also not pronounced
among most state and federal agencies responsible for permitting the practice. OPRD, as
a recreation-oriented department, expressed a concern that recreational mining is
fundamentally different from other types of recreation and is therefore not appropriate in
Scenic Waterways. However, most other state agencies did not share this view. The
suite of agencies with a significant role in dealing with Scenic Waterways do so from a
regulatory and often utilitarian standpoint. Each of them focuses on a particular resource
75
– riverbeds, fish and wildlife, water quality or quantity – and the effects on it from a
particular activity.
The net effect of each agencies’ focused efforts is accommodation of a range of
uses and activities on the state’s rivers and streams. Federal agencies with significant
interests in recreational mining, the BLM and the US Forest Service, tend to have a
multiple use focus to begin with. Although the federal Wild and Scenic and state Scenic
Waterways programs share similar goals, agencies responsible for administering Wild
and Scenic rivers have a history of facilitating several uses, including resource extraction.
Thus the dominant philosophy that affects Scenic Waterway management is that multiple
uses, including recreational mining, can and should be accommodated unless significant
harm is shown. To they extent that harm is done, an activity must be banned or
controlled so that impacts are acceptable, but these agencies may be disinclined to
monitor rigorously with a focus on fish, wildlife and human-powered “appreciative”
forms of recreation.
OPTIONS
All permits for recreational placer mining in Scenic Waterways are set to expire
under current law on December 31, 2003. The State Legislature has placed similar sunset
dates on this practice in the past, only to extend them. Unless the Legislature wishes to
further extend the deadline by another two years (or some other limited timeframe), it has
a few options to consider.
• Option 1 is to continue to allow recreational placer mining on Scenic Waterways.
This would provide for recreational mining to continue as it has for many years,
with the crucial difference that there would be no sunset date at which time all
recreational placer mining would have to cease on Scenic Waterways.
• Option 2 is to allow the sunset date on recreational placer mining, as provided for
in Senate Bill 606, to go into effect. This will have the effect of banning the
activity on Scenic Waterways by declaring all permits issued by DSL for
recreational placer mining on Scenic Waterways invalid after December 31, 2003.
• Option 3 is to further refine the situation and adopt a watershed-specific approach
to regulation of recreational placer mining. This would be similar to the type of
limitations currently embodied by ODFW’s in-water work periods tailored to
particular waterways. A decision tree that considers relevant parameters such as
stream size, value as fish habitat, natural fluctuation in water levels, mining use
levels, cumulative impacts, and demand from other recreationists could aid in
decisions about where recreational mining is likely to entail relatively higher or
lower risks of ecological and social impacts. Such an approach could serve to
reduce these risks and conflicts short of an outright ban on recreational mining.
This option would also necessarily entail greater data collection, monitoring and
enforcement than is currently employed in order to be effective.
76
Impacts
The impacts of the legislature’s decision may very well be small, no matter how
the legislature decides this matter. The issue most directly involves a small number of
people (about 125 permits are currently in effect in Scenic Waterways), in limited areas
of the state (Oregon Scenic Waterways comprise 1% of all Oregon river miles, and
comparatively few of these site are mined), with regulations stipulating when and how
recreational mining can take place. The number of people and total area under
consideration are not sizable portions of the state’s population or territory.
However, those people and places that are impacted by this decision face real
gains or losses. Recreational miners can potentially be affected more directly and
immediately than other stakeholders may be. And while the direct impacts are not likely
to be as significant to other stakeholders, any changes will be noticed, even if such
changes impact them only indirectly. By the same token, a portion of the state’s natural
resources will be affected, either in the form of continued mining impacts or their
elimination, and impacts will vary by river conditions and the behavior of individual
miners.
Moreover, the value of precedent may bring about additional impacts as well.
Scenic Waterways comprise only a small part of the state’s waterways, but the decision
to be rendered by the State Legislature could be significant in that Scenic Waterways are
considered to be some of the most highly prized rivers in the state for their scenic,
ecological and recreational values. Therefore, policies set for them may be likely to have
added significance for establishing new statewide priorities or reaffirming current
practices.
Option 1: Continuing to allow recreational suction dredging will impact fish,
wildlife, habitat and water quality adversely, but perhaps not significantly or in
measurable ways. A suction dredge simply cannot be operated without causing some
disturbance to the natural environment, and the scientific literature and environmental
organizations have pointed out these impacts. At the same time, these impacts are
mitigated in several ways: recreational miners are subject to multiple regulations; they
do not generally move large amounts of gravel because of the size of their equipment; inwater
work periods are limited; some mining organizations try to ensure that their
members obey all regulations; and winter rains tend to flush most rivers and get rid of
most evidence of suction dredging. To the extent that long-term and cumulative impacts
may be occurring but cannot be easily determined, Option 1 disregards this consideration
and shows a preference for addressing any future unacceptable impacts after they occur
rather than taking a precautionary approach.
Recreational miners will, of course, not be adversely impacted and thus would
strongly prefer this option, while interests most concerned with resource protection and
non-motorized river recreation would likely oppose it. Boaters, campers and sportfishers
are not likely to be significantly impacted unless they happen to encounter recreational
77
placer mining, which seems to happen less frequently now than in years past. River users
do occasionally come into contact with recreational miners. Only a small portion of these
visitors voice complaints about recreational mining, but this may not represent an
accurate measure of conflicts. Future encounters between miners and boaters may
increase if the trend of rapid growth in non-commercial river floating continues, but this
may be counterbalanced if the apparent gradual decline in recreational mining continues.
Option 2: A ban on recreational suction dredging would have the greatest impact
on miners, because several gold-bearing sites would be made off-limits to dredging. The
vast majority of such sites in Oregon are not on Scenic Waterways, and even some
mining organizations admit that a ban would not stifle all recreational mining in the state.
Many available sites that can be visited are not on Scenic Waterways, and some
organizations have mining claims that their members or tourists can use. Nonetheless,
this would represent a curtailment of where recreational miners can operate. While far
from a death-blow to the practice, it would be an inconvenience, especially to miners who
have come to expect access to mining areas in Scenic Waterways. A ban might force
people to drive further to engage in suction dredging, or discourage some people
altogether who may not wish to drive farther to access mining areas other than their
preferred locations. The extent to which either of these scenarios would occur is
uncertain.
Fish, wildlife, habitat and water quality would likely benefit from a ban on
suction dredging on Scenic Waterways. While regulation and natural flushing of
waterways can mitigate the potential harmful impacts of suction dredging, they cannot
completely eliminate all impacts, especially when best management practices are not
followed. Since the absence of unnatural disturbance to the natural environment is
considered to be better that some disturbance, even a small one, this option would be best
for protecting natural resources. At the same time, this ban would cover only a small
percentage of waterways, enhancing protections for only a small proportion of the state’s
fish and other natural resources.
Environmental interests would, of course, be pleased with a ban on recreational
mining, because it would provide additional legal restrictions on human activities for
some of the state’s most valued waterways. Recreationists other than miners could
benefit, though in many cases not significantly. To the extent that boaters, campers and
hikers do come into contact with recreational miners on Scenic Waterways, these
encounters would be eliminated. Any recreational conflicts that result from noise,
turbidity, miners’ behavior and campsites, or other aspects of suction dredging would
cease.
Option 3: Expanding the parameters of a context and watershed-specific
management approach to recreational placer mining, including greater data collection and
monitoring, could serve to balance multiple interests, taking into account competing
values, uses, and benefits. It would also, however, require additional agency resources.
Tracking where and when miners and other river recreationists go, monitoring their
78
activities, and ensuring compliance with regulations can be labor intensive and timeconsuming.
This option would address concerns that suction-dredge regulations are not
being consistently followed, and increased monitoring in the late 1990’s apparently
enhanced compliance considerably. However, in light of current limitations in Oregon’s
state budget, as well as the fact that there are only 125 permitted miners on Scenic
Waterways, refining regulations and increasing monitoring of the relatively small number
of currently active miners may not be economically sensible. In addition, regulations
more specific to conditions in each waterway would probably not be well received by
miners, who often call for a simpler, more consistent permitting process.
Redpaw
ADDITIONAL STAKEHOLDER RECOMMENDATIONS


While the purpose of this report is to inform the State Legislature to assist it in
making a determination on recreational placer mining in Scenic Waterways, two
additional recommendations, pertaining to the entire state, were made by several
respondents, and these suggestions deserve mention.


Monitoring and Enforcement.


Several individuals and organizations suggested that no matter what is decided on
Scenic Waterways, the state should make a stronger effort at monitoring compliance with
regulations and enforcing DSL and DEQ permits on all Oregon Scenic Waterways and
Essential Salmon Habitat. DSL did do this for a few years and found that its efforts
resulted in greater adoption of best management practices among suction dredge miners.
Currently DSL and DEQ devote little attention to monitoring compliance with their own
permits. BLM and the Forest Service do monitor all kinds of activities on their lands, and
mining is included in this. So some monitoring and enforcement does take place, though
it can be inconsistent and uneven throughout the state.


In spite of these federal efforts, previous DSL efforts, and of the efforts of mining
organizations to encourage compliance, state and federal agencies, mining organizations,
and most of all, environmental organizations have stated that there are a number of
people around the state who do not fully comply with regulations, and therefore are more
likely to have an adverse impact as a result of their activities. Increased monitoring and
enforcement can help to further mitigate such impacts, not only through the coercive
power of government, but also through educational efforts. This practice does not have
to be pervasive and time consuming to be effective, as DSL has demonstrated in the past.
Getting state personnel out on some rivers sometimes can have a significant effect.
Perhaps members of the state.s mining organizations can accompany DSL in these efforts
to help reinforce the idea that it is important to comply with regulations and that miners
themselves are supportive of this.


Uniform Regulation and Enforcement Practices Throughout the State.
Miners and staff from several different agencies commented on the fact that
depending upon where one was in the state, he or she could be subject to different
regulations with respect to placer mining. BLM may allow one type of activity but not
others, but the Forest Service may require different practices, even in different National
Forests in Oregon. Each agency has a degree of control over its lands that allow it to set
certain conditions for suction dredging or other mining activities. These conditions may
be more stringent than standards set by the State of Oregon, which has led to complaints
of inconsistency and confusion.
One recommendation is to bring together all the different land managers and
regulators from around the state . both federal and state agencies . and ask them to come
to an agreement on a set of acceptable practices for recreational and small-scale mining
that would be applicable throughout the state. It may be the case that one set of standards
may need to be applied for small streams and tributaries, while slightly different practices
can be permitted on larger bodies of water. The lack of consistency has been described
as frustrating . individuals may not differentiate among different levels of governmental
jurisdiction when they are outdoors, and it should not be made difficult to determine if
one is in violation or in compliance with regulations. Intergovernmental cooperation
should not be insurmountable to accomplish this task.
Redpaw
Organizations Contacted


Oregon State Senate

Oregon State House

Oregon Parks and Recreation Department

Division of State Lands

Department of Environmental Quality

Oregon Department of Fish and Wildlife

Oregon Watershed Enhancement Board

Water Resources Department

Oregon Department of Forestry

Oregon Department of Agriculture

Oregon Marine Board

Oregon State Police

Department of Land Conservation and
Development

Oregon Department of Geology and
Mineral Industries

Commission on Indian Affairs

Bureau of Land Management

US Forest Service

National Marine Fisheries Service

US Fish and Wildlife Service

US Army Corps of Engineers

Oregon Independent Miners

Waldo Mining District

Eastern Oregon Mining Association

Willamette Valley Miners

Armadillo Mining Shop

Defenders of Wildlife

Native Fish Society

Siskiyou Regional Education Project.

Willamette River Keepers

Oregon Environmental Council

Pacific Rivers Council

Nature Conservancy

Sierra Club

World Wildlife Fund

Blue Mountains Biodiversity Project

1000 Friends of Oregon

Oregon Natural Resources Council

Audubon Society

Water Watch of Oregon

Conservation Biology Institute

Rogue Flyfishers

Southern Oregon Flyfishers

Oregon Trout

Northwest Steelheaders

Central Oregon Flyfishers

For the Sake of the Salmon

American Rivers

Northwest Rafters Association

Willamette Kayak and Canoe Club

Oregon Whitewater Association

Cascade Canoe Club

Rogue Wilderness Adventures

Orange Torpedoes, Inc.

Oregon Guides and Packers

OSU Fisheries and Wildlife Department

OSU Forest Science Department

Deschutes County

Josephine County

Wallowa County

City of Maupin

City of Redmond

City of Grants Pass

City of Gold Beach

City of Bend

City of Wallowa

Confederated Tribes of Warm Springs

Confederated Tribes of Umatilla

Burns Paiute Tribe

Confederated Tribes of Siletz

Coquille Indian Tribe

Confederated Tribes of Coos, Lower

Umpqua, and Suislaw

Cow Creek Band of Umpqua Indians

Klamath Tribe

Lower Rogue Watershed Council

McKenzie Watershed Council

Umpqua Watershed Council

Upper Rogue Watershed Council

Elk/Sixes River Watershed Council

Mid Deschutes Watershed Council

Mid Rogue Watershed Council

North Fork John Day Watershed Council

Upper South Fork John Day Basin

Upper Deschutes Watershed Council

Oregon Farm Bureau

Water for Life

Oregon Cattlemen’s Association

Oregon Water Resources Bureau

Oregon Forest Industries Council

Oregon Small Woodlands Association

Associated Oregon Loggers

Individual Landowners
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