Recent calls to dredge the silt from the Rappahannock River have cast light on a similar but failed 2009 proposal. A letter from the Army Corps of Engineers to Terra Producs LLC, the company which sought to dredge the river in 2009, sheds light on the regulatory hurdles which a commercial dredging operation may be subject to. This letter, and the regulatory framework which it lays out, is the part of the basis for City Manager Beverly Cameron's recent proposal that city leaders replace initiatives to dredge the river with a push to stabilize the shoreline and work on erosion control. 

The letter states that the project, as proposed in 2009, would have been a "very complex project creating probably substantial environmental impacts." The letter goes on to say that the proposal would probably have been denied a permit because of the "magnitude of adverse environmental and cultural impacts"

In March 2009, representatives from five federal and state regulatory agencies and representatives from Stafford County and the City of Fredericksburg attended a meeting with the Army Corps of Engineers to discuss Terra Products proposal to dredge 300,000 cubic yards of material from the Rappahannock River. The attendance list reads like a who's-who of agencies which a dredging project would have to contend with: Virginia Marines Resources Commission, Virginia's Department of Mines, Minerals and Energy, Virginia's department of Game and Inland Fisheries, and the National Park Service. 

After the meeting, Hal Wiggins, chief of the Northern Virginia Regulatory Section of the Army Corps of Engineers, wrote a letter reviewing Terra Products proposal and laying out a map of guidelines and procedures for the company to follow if it decided to apply for a mining permit. 

The letter says that Terra Products initial proposal was to dredge the river for environmental restoration and flood control. But after meeting with representatives from Terra Products during a site visit, Hal writes that "it appears that the projects primary purpose is commercial mining." 

The letter was critical of Terra Products proposal, saying that it required more details on any mining activities proposed, more details on how wastewater runoff was to be treated and better mapping of the project area, which included a three mile stretch of the river downstream of the Falmouth bridge. 

Due to the risk that dredging may suck up historic artifacts and damage archaeological sites the proposal would also be subject to the Historic Preservation Act. The letter strongly suggested that Terra Products conduct an archaeological inventory of the entire project area. 

Representatives from Terra Products were unable to be reached as of this posting, with their listed phone numbers being out of service. 

I am also trying to get in contact with Hal Wiggins, as this letter leaves some questions up in the air. For instance, would the regulatory framework be any different or easier if the dredging was conducted for the sole purpose of flood control and environmental restoration?