Fugitive Dust Control Plan

Bureau of Land Management

El Centro Field Office

1661 S. 4th Street

El Centro, CA 92243

June 29, 2006
2

Table of Contents

Section Page No.

1.0 Introduction .....................................................................3

1.1 Purpose of Plan ........................................................3

1.2 Document Organization ................................................3

2.0 Actions Requiring Control ....................................................4

2.1 Off Highway Vehicle use .............................................4

2.2 Mining Operations ....................................................5

2.3 Geothermal Power Plants .............................................5

2.4 Miscellaneous Actions.................................................6

3.0 Dust Control Measures ........................................................6

3.1 Dust Control During OHV use ......................................11

3.2 Dust Control Within Mining Operations ...........................13

3.3 Dust Control Within Geothermal Power Plants ...................13

3.4 Dust Control During Miscellaneous Construction Projects......13
3

1.0 Introduction

Air quality is determined by many different factors, such as: landforms, amount of 

contaminants emitted into the atmosphere, and meteorological conditions. In the 

Imperial Valley, stable atmospheric conditions, low mixing heights, and light winds 

during the morning and evening hours provide opportunity for dust and other 

contaminates to accumulate on the low-lying Imperial Valley floor. As a result, the 

Imperial Valley, and all of Imperial County has been classified as a non-attainment 

area under the Environmental Protection Agency’s PM10 regulations as set forth in 

their Clean Air Act of 1990.

PM10 is defined as: Any material that exists as solid or liquid in the atmosphere. 

Particulate matter may be in the form of fly ash, soot, dust, fog, fumes, etc. Small 

particulate matter, or PM10, is less than 10 microns in size (about one-eighth the 

diameter of a human hair) and is too small to be filtered by the nose and lungs.

www.raqc.org/more/define.htm

The primary contributors of PM10 under jurisdiction of the Bureau of Land 

Management El Centro Field office are: OHV use, mining operations, geothermal 

energy operations and various short term construction projects such as installation of 

pipelines. 

1.1 Purpose of Plan

The purpose of the Bureau of Land Management El Centro Field Office dust 

control plan is to identify sources of PM10 emissions within our jurisdiction 

and identify dust control measures that can be implemented to help minimize 

or eliminate those emissions. 

1.2 Document Organization

The remainder of this Plan is organized into the following sections:

◦ Section 2.0 – Actions Requiring Controls

◦ Section 3.0 – Dust Control Measures
4

2.0 Actions Requiring Control

2.1 Off Highway Vehicle Use

Off highway vehicle use is a popular form of recreation in Imperial County. 

An off highway vehicle is defined as a self-propelled vehicle used for 

recreation or cross-country travel on public lands, trails, easements, lakes, 

rivers or streams (Code of Federal Regulations). Located within Imperial 

County is the Imperial Sand Dunes Recreation Area, one of the largest off 

highway vehicle recreation areas in the United States. With over 130,000 

acres open to OHV use, the Imperial Sand Dunes Recreation Area attracts 

thousands of off highway enthusiasts each year. 

There are three multiple use classes that the Bureau of Land Management 

employs in order to manage public Lands. Lands falling under Multiple Use 

Class C are closed to all motorized vehicle activity. These lands were 

classified by Congress and designated as Federal Wilderness Areas. Lands 

falling under Multiple Use Class L are classified as Limited Use areas. 

Travel in these areas is limited to existing open routes of travel only. In 

essence, only the trails or routes that are classified as open are allowed to be 

traveled on. The land in between these routes and trails is closed to vehicle 

use. Lands that fall under Multiple Use Class I are considered Open areas. 

This means that the entire area is open to all motor vehicles and all types of 

travel. 

Along with the Imperial Sand Dunes, the El Centro Field office also oversees 

lands in the East Mesa, West Mesa and Yuha Desert in BLM’s, Western 

Colorado (WECO) planning unit and the Indian Pass area in BLM’s North 

Eastern (NECO) planning unit. WECO and NECO are both limited use areas 

that fall under BLM Multiple Class L. Designated routes of travel and open 

riding areas are found in all of these regions and these are also popular areas 

for off highway enthusiasts to recreate. Three open riding areas are found 

within El Centro Field office jurisdiction that also fall within Imperial 

County. These open areas are: Imperial Sand Dunes Recreation Area, 

Plaster City Open Area and Superstition Open Area. An open area, or BLM 

Multiple Use Class I is defined as: “Intensive Use.” Its purpose is to provide 

for concentrated use of lands and resources to meet human needs (California 

Desert Conservation Area Plan, 1980). These open areas fall within Multiple 

Use Class I, which means that the entire area is open to all motor vehicles and 

all types of travel. Several closed areas designated as Wilderness areas by 

Congress that are managed by the BLM are also found in Imperial County. 

The Wilderness Areas fall under BLM Multiple Use Class C, which means 

that they are closed to all motorized vehicle activity. 

Off highway vehicle use contributes to PM10 emissions in a number of ways. 

Travel in open areas and along designated routes can produce particulate 
5

matter from wind-blown dust. Travel in open areas also causes a reduction in 

vegetation cover, which leaves soils vulnerable to wind erosion and makes 

them more likely to be spread in the event of a wind occurrence. 

2.2 Mining Operations

The BLM oversees roughly 30 sand and gravel mining operations of various 

sizes, several small recreational mining claims, and it is possible that one 

open-pit gold mine may be developed on BLM managed land within Imperial 

County. Occasionally the El Centro Field Office receives applications for 

mineral exploration activities for mining, geothermal and geophysical 

exploration. 

Excavation, hauling and processing activities associated with mining, such as 

digging, loading trucks, crushing and screening, all have the potential to 

produce fugitive dust, including PM10 emissions, unless adequate mitigation 

techniques are employed. Dust suppression measures, such as the application 

of water or fixatives, are generally employed as standard operating 

procedures, under the approved Plan of Operations required by the BLM. 

State law requires that all vehicles licensed for highway use be in compliance 

with specified vehicle emissions standards. Other emission controls may be 

required for off-highway equipment, such as loaders and bulldozers, and 

point sources of emissions such as diesel generators. Activities associated 

with exploration include construction and maintenance of temporary roads 

and drill pads, and minor excavation activities. Fugitive dust and emissions 

controls for exploration activities are similar to those required for mineral 

production. Larger permanent and semi-permanent operations may be 

required to have a separate dust control plan approved by the county. 

Smaller, temporary operations, such as sand and gravel sales of a few 

thousand cubic yards may not need an emissions control plan approved by the 

county, but are required to employ dust control techniques on an as-needed 

basis. 

2.3 Geothermal Power Plants

The El Centro field office oversees the lease for one Geothermal Power Plant 

Complex, the Ormesa Geothermal Energy Plant, located on the East Mesa. 

There are several unsurfaced access roads in the vicinity of the Ormesa 

Geothermal Power Plant. These roads are used to access pumps, pipelines 

and other geothermal facilities. Travel across these unsurfaced roads has the 

potential to produce fugitive dust and vehicle emissions. Likewise, other 

activities central to geothermal operations such as well pad construction and 

excavation, have the potential to produce fugitive dust emissions, including 

PM10, unless mitigation measures are taken. 
6

There are also several applications for geothermal energy leasing on BLM 

administered lands. BLM has not approved development of any of these 

leases at this point in time. If developed is approved, the development would 

require analysis of potential air quality impacts and possibly the development 

of a dust control plan.

2.4 Miscellaneous Actions

Fugitive dust emissions may also be derived from miscellaneous actions that 

occur on public lands such as: driving to private property via BLM managed 

lands, right of ways for maintenance of power pole lines and canals, and new 

construction of pipelines. 

These activities produce particulate matter mainly through the use of unpaved 

roads and use of heavy equipment and machinery during construction and 

maintenance projects. 

3.0 Dust Control Measures

The following measures will be used singularly or in combination to prevent 

conditions conducive to fugitive dust emissions or to suppress airborne dust should it 

occur. Dust control measures are those measures that will be taken by the Bureau of 

Land Management, its lessees, and permit holders, for any activity occurring on 

BLM owned and managed lands. 

Potential dust control measures include, but are not limited to: 

◦ Non-toxic stabilization of heavily used areas.

◦ Enforceable and posted speed limits in heavily used areas.

◦ Restoration of closed routes per BLM standards.

Imperial County Air Pollution Control District Requirements and BLM’s Plan to 

address the Requirement:

◦ Stipulate that all new authorizations for stationary emission sources obtain all 

 necessary permits and satisfy all applicable SIP provisions, including project- or

 activity- specific BACM.

 BLM will advise applicants to contact the County APCD for appropriate permits.

◦ A summary that: describes the total miles of BLM roads that are paved, paved with 

unpaved shoulders, and unpaved, including length and level of usage of each road; 

prioritize control of road segments based on annual and episodic (e.g. event) usage; 

describe the location and extent (e.g. acreage) of open areas disturbed by legal and 

illegal recreational use; prioritize control of these open areas based on annual and 
7

episodic (e.g. event) usage; describe plans for control of PM-10 emissions from 

these areas.

Summary of Roads and Routes of Travel

BLM currently manages only two paved roads, Gecko Road and Gray’s Well Road. 

Each of these roads are located within the Imperial Sand Dunes Recreation Area 

(ISDRA). Gecko Road is located in the Northern portion of the ISDRA, 

perpendicular to Highway 78, on the Western edge of the dunes (see map). Gray’s 

Well Road is located in the Southern portion of the ISDRA, parallel to Interstate 8 

(see map). Gecko Road is approximately 6.8 miles long, and Gray’s Well Road is 

approximately 4.7 miles long. 

Table 3.1 – Paved Roads Managed by BLM – El Centro Field Office

BLM currently manages many off-highway trails, or routes of travel in two distinct 

management areas known as the Northern and Eastern Colorado (NECO) 

management area and the Western Colorado (WECO) management area. These 

areas are known as Limited Use areas, or Multiple Class Use L. In these areas, travel 

is limited to open routes of travel only. Cross-country travel is not prohibited in 

these areas. For this reason, the BLM considers the areas between open routes of 

travel to be closed to vehicle travel. There are approximately 1,116 miles of open 

routes in the WECO management area and more than 600 miles of open routes in the 

NECO management area. There are approximately 279 miles of limited use routes 

(open only to street legal vehicles) in the WECO management area, and over 100 

miles of limited use routes in the NECO management area. Approximately 880,000 

acres of the NECO management area falls within Imperial County, and 

approximately 475,000 acres of the WECO management area falls within Imperial 

County.

In addition to the limited use areas in Multiple Use Class L, BLM also manages 

several areas designated as Multiple Use Class I, which are designated as open riding

areas. BLM manages three Open Areas: Imperial Sand Dunes, Plaster City and 

Superstition (see map). 

The location and extent of the Open Areas located within the El Centro Resource 

Area are as follows:

Name of Road Mileage

Gecko Road 6.8 miles

Gray’s Well Road 4.7 miles
8

 Table 3.2 – Acreage of Open Areas managed by BLM El Centro Field Office

Open Area Name Approximate Acreage

Imperial Sand Dunes 130,000 acres

Plaster City 41,000 acres

Superstition 13,000 acres

Total 184,000 acres 

Unfortunately, there is no way to differentiate between or monitor legal and illegal 

recreational use. Therefore, we assume that all three Open Areas in their entirety 

are disturbed. 

The BLM estimates that none of the routes of travel located in Imperial County on 

public lands receive more than 50 vehicle trips per day. Certain unpaved areas 

located in the Imperial Sand Dunes, including the Dunebuggy Flats access road 

receive more than 50 vehicle trips per day during holiday weekends (Halloween, 

Thanksgiving, New Year’s and President’s Day) that fall between the months of 

October and March. BLM will continue to water these areas on an as-needed basis 

when funding and equipment are available.

Plans for Control of PM-10 

Many dust control measures are employed within the El Centro Resource Area. As 

referenced above, Gecko Road and Gray’s Well Road, located in the ISDRA, are 

paved roads. Since these roads receive high amounts of vehicle traffic during the 

cooler months of the year, the fact that they are paved will reduce dust emissions 

that may have arisen if they had not been paved. There are speed limit signs on 

both of these roads, which are rigorously enforced. Speed limits are also rigorously 

enforced within the entire ISDRA “within 50 feet of any campground, campsite, or 

concentration of people or animals” to 15 miles per hour. These measures also help 

to keep dust down, as they keep vehicle traffic decelerated. 

Certain unpaved areas located in the Imperial Sand Dunes, including the 

Dunebuggy Flats access road receive more than 50 vehicle trips per day during 

holiday weekends (Halloween, Thanksgiving, New Year’s and President’s Day) 

that fall between the months of October and March. BLM will continue to water 

these areas on an as-needed basis when funding and equipment are available.

Five administrative closures are currently in place in the Imperial Sand Dunes 

Recreation Area (see map). These closures total approximately 49,127 acres. 

While in place, these closures will also help to reduce PM-10 emissions in the 

ISDRA by limiting the area where vehicles are allowed.
9

Table 3.3 – Administrative Closures at Imperial Sand Dunes Recreation Area

The BLM El Centro Field Office manages eight Wilderness areas within Imperial 

County. These Wilderness areas were designated by Congress and can be found on 

both the East and West sides of Imperial County. Travel within Federal Wilderness 

areas is limited to foot traffic and horseback riding. No motorized vehicles are 

allowed in Wilderness areas. A significant amount of land that may have produced 

PM-10 emissions is closed to vehicle traffic, since a total of approximately 196,082 

acres of BLM managed lands in Imperial County are closed as Wilderness areas 

(see map).

Table 3.4 – Federal Wilderness Areas in Imperial County managed by BLM

Wilderness Area Name Total Acres Closed

Fish Creek Mountains 20,575

Coyote Mountains 18,574

Jacumba 31,171

Palo Verde Mountains 21,149

Indian Pass 31,922

North Algodones Dunes 25,811

Picacho Peak 8,828

Little Picacho 38,052

Total 196,082 acres closed as Wilderness in 

Imperial County

Another mitigation measure to help control fugitive dust emissions from BLM lands 

is a seasonal closure on all routes within the Painted Gorge area from January 1 of 

each year to June 30th of each year. This seasonal closure takes place each year to 

protect the Federally Threatened Peninsular Bighorn Sheep (Ovis canadensis), and 

is an action that also lowers PM-10 emissions in the area. The Painted Gorge area 

is located West of the Plaster City Open area and North of Evan Hewes Highway. 

BLM has also performed route restoration on closed routes within the WECO 

management area in the Yuha Desert and the West Mesa. A total of approximately 

17.3 miles of routes have been closed and restored to their natural state. The 

closure and restoration of these routes should help reduce PM-10 emissions in the 

area by limiting the number of trails that vehicles are allowed to travel on. Wind 

erosion is also minimized when well-worn trails are restored to their natural state. 

Name of Closure Approximate Acreage

Northern Closure 3,802

Central Closure #1 2,000

Central Closure #2 43,345

Patton Valley Closure 310

Southern Closure 160

Total 49,617 total acres closed at ISDRA
10

Areas of Critical Environmental Concern are also areas where travel is limited to 

street legal vehicles only. The BLM El Centro Field Office manages 14 Areas of 

Critical Environmental Concern within Imperial County (see map). These areas 

were set aside as areas that are valuable because of unique cultural, biological or 

scenic resources. PM-10 emissions are reduced in these areas due to the restriction 

of off-highway vehicles. 

Table 3.5 – Acreages of Areas of Critical Environmental Concern in Imp. County

Name of ACEC Approximate Acreage

Chuckwalla 262,202

Coyote Mountains Fossil Site 5,861

East Mesa 42,768

Gold Basin/Rand Intaglios 1,884

Indian Pass 1,764

Lake Cahuilla – A 1,231

Lake Cahuilla – B 2,528

Lake Cahuilla – C 5,592

Lake Cahuilla – D 4,723

North Algodones Dunes (also a 

Wilderness Area)

25,811

Pilot Knob 869

San Sebastian Marsh 7,680

West Mesa 20,294

Yuha Basin 71,847

Total 455,054

 

 

◦ Control dust emissions from certain roads and routes as per the Wilderness 

 Classification in the California Desert Protection Act.

As stated above, there are no authorized roads in BLM Wilderness Areas. All 

BLM Wilderness Areas are closed to all motor vehicle traffic. Foot traffic and 

horseback riding are the only modes of transportation allowed in BLM 

Wilderness Areas.

◦ Control dust emissions from certain roads and routes as identified through general

 BLM planning.

Certain unpaved areas located in the Imperial Sand Dunes, including Wash Road 

and the Dunebuggy Flats access road receive more than 50 vehicle trips per day 

during holiday weekends (Halloween, Thanksgiving, New Year’s and President’s 

Day) that fall between the months of October and March. BLM will continue to 

water these areas on an as-needed basis when funding and equipment are 

available.
11

◦ Implement those PM10 control measures required to manage organized off-road

 events and/or competitions on public lands.

BLM has considered the level of dust related to racing events to be of short 

duration and at low levels. If more than 300 riders participate in any single event, 

BLM may require water to be applied to staging areas and the beginning only of 

race routes. If ICAPCD notifies BLM that it considers racing generated dust to be 

of concern, BLM will refer race organizers to the ICAPCD for a permit. 

◦ Use BLM-standard road design and drainage specifications when maintaining 

 existing roads or authorizing road maintenance and new road construction.

BLM will require this for new road construction and existing road maintenance.

◦ Include public educational information on PM10 emissions with BLM open area 

 literature and on information signs in heavily used areas.

BLM will post flyers provided by ICAPCD in all open area kiosks.

 

3.1 Dust Control During Off Highway Vehicle Use

In May of 2003, the Bureau of Land Management drafted its Imperial Sand 

Dunes Recreation Area Management Plan in order to provide a framework 

for how the ISDRA would be administered. The RAMP includes certain 

control measures that the BLM may perform in order to “improve the health 

and safety of visitors.” 

As stated in the Bureau of Land Management Imperial Sand Dunes 

Recreation Area Management Plan (RAMP) the BLM has agreed to consider 

the following dust control measures:

◦ “Treat the following access roads for dust control to reduce the impact of

 OHV activities on air quality: Ted Kipf Road (from South of Glamis and 

North of the Adaptive Use Area), the Canal Road adjacent to the 

Coachella Canal, Wash Road adjacent to the Union Pacific Railroad (from 

South of Glamis to the Clyde Over crossing), the entry road to Dunebuggy 

Flats campground.”

Ted Kipf Road –

Since Ted Kipf Road is a road that belongs to Imperial County, 

BLM has no authority to perform dust control or maintenance. If the 

APCD identifies OHV use on Ted Kipf Road as a significant source of 

PM10 emissions, then APCD and BLM may meet to develop a plan to 

address this concern.
12

Canal Road –

Since the Canal Road is managed by the Coachella Valley 

Water Authority, Bureau of Reclamation and Imperial Irrigation District, 

BLM has no authority to implement dust control measures on this road. If 

the APCD identifies the Canal Road as a significant source of PM10

emissions, then BLM will meet with Imperial Irrigation District, the 

Coachella Valley Water Authority and the Bureau of Reclamation in order 

to develop a plan to comply with APCD standards.

Certain unpaved areas located in the Imperial Sand Dunes, including 

Wash Road and the Dunebuggy Flats access road receive more than 50 

vehicle trips per day during holiday weekends (Halloween, Thanksgiving, 

New Year’s and President’s Day) that fall between the months of October 

and March. BLM will continue to water these areas on an as-needed basis 

when funding and equipment are available.

 

 ◦ “Install air meters for ozone and PM-10 in the ISDRA, if requested by 

Imperial County Air Pollution Control District or the U.S. EPA. 

Implement actions to mitigate for contributions to the non-attainment due 

to activities at the ISDRA, as requested by Imperial County Air Pollution 

Control District.”

BLM agrees to meet with ICAPCD to discuss this stipulation, if needed. 

◦ “Maintain, post and enforce the following speed limitations: all sand 

highway segments near zones of recreational use concentration, the Wash

Road and the road entering Dune Buggy Flats, Gecko Road and Grays 

Well Road. Establish, post and enforce a speed limitation in Gecko Loop

Campground, Key Hole Campground, Midway Campground and 

Buttercup Key Hole Camping Area.”

BLM has posted these speed limit signs and is enforcing these speed 

limits. 

In October of 2002, the BLM drafted a plan for the Western Colorado Routes

of Travel Designations. In this plan, BLM set forth control measures to help 

curb PM-10 emissions. The BLM has also drafted a plan for the Northern 

and Eastern Colorado Routes of Travel. The dust control measures to help 

curb PM-10 will be the same for both of these plans.

As stated in the Western Colorado Desert Routes of Travel Designation 

(these are also true for the Northern and Eastern Colorado Routes of Travel 

Designation):
13

There would be fewer roads designated as open than the current 

situation. There would be less miles of routes than existing 

conditions....The vehicle use limitation to street legal vehicles in 

the Yuha (and other areas) should result in a decrease in the use of 

this area. In addition to the designation of roads and the 

enforcement of the designation and land use should result in less 

off route travel. The off route travel creates new roads which 

increases the particulate matter emissions due to vehicular use and 

wind. This alternative also includes the mitigation requirement to 

restore closed roads to a natural desert landscape. This will result 

in fewer emissions due to the inability to easily use closed roads 

and the reduction in emissions due to wind.

 BLM is currently implementing this plan and BLM has restored 

 approximately 17.3 miles of closed routes in the Yuha Desert and West Mesa 

management areas. This restoration has returned the closed trails / routes to 

natural habitat and reduced the wind erosion for these areas.

 

3.2 Dust Control Within and During Mining Operations

BLM will require each commercial mining operation to work with the 

Imperial County APCD to develop a dust control plan that is specific to each 

mining operation. BLM requires compliance with all applicable air pollution 

laws in the approved Plan of Operations for all mining operations. This gives 

BLM the authority to order the operator to come into compliance. If this does 

not happen, BLM may issue a Notice of Non-Compliance, and may 

ultimately shut down all or part of the operation, and revoke the operator’s 

bond. 

3.3 Dust Control Within Geothermal Power Plants

The BLM will require the geothermal power plant to work with the Imperial 

County Air Pollution Control District to develop a dust control plan that is 

specific to the geothermal power plant, as required by the Imperial County 

Air Pollution Control District. Highway legal vehicles are required to 

employ appropriate state-mandated emissions controls.

3.4 Dust Control During Miscellaneous Construction Projects

Miscellaneous construction activities and general access activities tend to 

produce minimal fugitive dust emissions. Due to this, BLM will not request 

actions be made for private citizen right of ways, unless the Imperial County 

Air Pollution Control District requests that they do so. For major construction 
14

projects, BLM will require the project coordinator to obtain a permit from the 

Imperial County Air Pollution Control District.