is impossible to justify any so-called “recreational” activity that requires a general or even individual NPDES permit. Discharging pollutants into the waters of Idaho or our national is not a recreational activity; suction dredging is simply not a legitimate recreational activity
Furthermore, the distinction between so-called “recreational” suction dredging and commercial dredges is rather arbitrary. In any case, it is not an activity of vital economic importance to our state or nation. As such, we urge you to issue no permits, general or individual, for suction dredging. It is an activity that has far too many negative impacts without any societal benefit.
Dredging affects benthic invertebrates (especially mollusks which disperse slowly and mussels whose populations are currently unstable) and fish habitat (downed woody debris and spawning beds) (see Effects of Suction Dredging on Streams: a Review and an Evaluation Strategy, Harvey and Lisle 1998 in Fisheries, Vol. 23 No. 8). Little research has been done on any aspect of dredging. There is almost no mention in the literature on extremely sensitive species like bull trout, which have even narrower tolerances than salmon, steelhead, and Westslope cutthroat. All of those fish, however, need clear, clean water, but the bull trout is most sensitive.
Dredging also has other impacts. This include but are not limited to impacts on riparian areas form human activity associated with dredging, impacts from long-term camping at dredge sites, displacement of terrestrial wildlife and displacement of other recreationists. Species such as the harlequin duck, wolverine, fisher, and northern leopard frog use riparian areas. Those species need water and the duck and frog are dependent upon riparian habitats. This suggests an EIS is needed to look at all impacts from suction dredging in Idaho. Indeed, compliance with NEPA is needed as public land owned by all Americans makes up about 2/3rds of the land base in Idaho.