Here's the answer to your question, Jerry. A first-cut review of the 1,019 mining HPAs issued by the WDFW from 2009 to September 2013 (a 45-month period) showed that one was for a restoration project. Maybe there are a few other outliers. But we can safely say that roughly 1,000 HPAs for mining were issued in those 45 months, an average of about 22 a month. The part of the WDFW's website on mining and prospecting states the following about an HPA:

"If the Gold and Fish pamphlet does not cover the location, equipment, or work time you want to use, you can request an individual, written HPA."

So each of the 1,000 HPAs issued in that relatively recent 45-month period represents some kind of exception to the rules detailed in the Gold and Fish pamphlet -- for example, a request to work outside the work window specified for a particular stream in the pamphlet. These new dredging projects (again, a monthly average of 22 new ones) are, of course, in addition to the "normal" dredging that occurs inside the established work windows or that ostensibly complies with the pamphlet's operating rules. And an individual HPA can be valid for a period of several years. That's a LOT of repetitive dredging.

What concerns me and other opponents of suction dredging is that the large number of authorized dredging projects outstrips the ability of the WDFW's already overtaxed biologists to give individual projects anything other than cursory attention. And, as I've said here repeatedly, the WDFW has no funds for a dedicated monitoring and enforcement capability for suction dredging. The purpose of Representative Gael Tarleton's proposal to charge dredgers a fee of $150 is to fund effective monitoring and enforcement, not to deprive small miners of the opportunity to do their thing. (Maybe the fee should be $100 or some other amount, but if you can afford to buy and operate a suction dredge, it seems as if you could afford to pay a licensing fee of $100 or so.) Right now, the system is vulnerable to abuse. Based on the scientific literature by fisheries biologists that I've read, suction dredging at the very least is potentially harmful to streams, so giving the WDFW the money to fund a genuine monitoring and enforcement capability is sensible. Dredgers pay nothing to dredge fish-bearing streams whereas taxpayers already have shelled out hundreds of millions of dollars to restore wild salmon and steelhead and fishing opportunities are ever more restricted. I don't think that makes sense, which is why I'm an advocate for changing our state's permissive dredging regulations.