U.S. Army Corps of Engineers Regulatory Division
1455 Market Street 16th Floor
San Francisco, CA 94103-1398
RE: Comments on Proposed Letters of Permission Procedure for Gravel Mining in Humboldt County (LOP 2015-1)
Dear Mr. Mazza,
On behalf of the Environmental Law Foundation (“ELF”) and Friends of the Eel River (“Friends of the Eel”), we submit the following comments on the Letters of Permission Procedure (“LOP”) for Gravel Extraction in Humboldt County proposed by the U.S. Army Corps of Engineers (“Corps”). Please include ELF on the notice and distribution list for any future communication, documentation, or hearings regarding this matter.
We have several concerns related to gravel mining in general, and with the LOP specifically. First, we are concerned that the LOP ignores the significant damage that California’s drought has inflicted on local biological conditions. Secondly, we disagree with the application of a LOP procedure to gravel mining. Thirdly, we believe that the required biological and environmental analyses are taking place too late to be useful in the Corps’ decision making process and that their absence robs the public of the opportunity to submit meaningful comments on this draft. Finally, the LOP potentially violates the Wild and Scenic Rivers Act.
As a result of these deficiencies, we respectfully request that the Corps significantly revise its approach to gravel mining to take account of its potentially severe environmental impacts. At a minimum, we request that the Corps reopen public comment on the LOP once the required consultations have been completed so that the public may be fully informed about the project’s effects.