Dredgers are supposed to work inside the work windows specified in the Fish and Gold pamphlet and those windows were calculated to avoid the spawning periods of fish. But dredgers can and often do apply for exceptions to those work windows (so-called Hydraulic Project Approvals or HPAs), and these are routinely granted. In fact, based on our count of HPAs issued by the WDFW from 2009 to September 2013 (we have obtained them from the WDFW), more than 1,000 were issued in that short time period. (As I recall, the exact number was 1,019.) The HPAs carry detailed provisions for how this "exceptional" dredging is to be carried out to avoid or minimize damage, but the WDFW has NO ability to actually monitor those projects for compliance. And these HPAs, which, once again, are exceptions to the specified work windows, can be issued for a period of years. And there is no charge or license needed to get an HPA, so the WDFW has no funds to monitor the work. That's an obvious problem. What the dredgers fear most is an outright ban on dredging; almost as bad, in their view, is a system that exposes their dredging projects to actual monitoring for compliance with the rules by the WDFW. The dredgers don't want anyone actually inspecting their sandboxes.