Fugitive Dust Control Plan Bureau of Land Management

El Centro Field Office

1661 S. 4 th Street El Centro, CA 92243

June 29, 20062

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 Miscell aneous Actions.................................................6

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

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

3.2 Dust Control With in Mining Operations ...........................13

3.3 Dust Control Within G eothermal Power Plants ...................13

3.4 Dust Control During Miscellaneous Construction Projects ......133

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 Impe rial 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 PM 10 regulations as set forth in

their Clean Air Act of 1990.

PM 10 is defined as: Any material that exists as solid or liquid in the atm osphere.

Particulate matter may be in the form of fly ash, soot, dust, fog, fumes, etc. Sm all particulate matter, or PM 10 , 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 PM 10 under jurisdiction of the Bureau of Land
Management El Centro Field office are: OHV us e, 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 sour ces of PM 10 emi ssions 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 Measures4

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 o ff 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 o ff 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 L and 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 Multip le 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 route s 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

la nds 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 Mult iple 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 off ice 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 conc entrated 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.

O ff highway vehicle use contributes to PM 10 emissions in a number of ways.
Travel in open areas and along designated routes can produce particulate5

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 claim s, 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 explorat ion.

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 PM 10 emissions, unless adequate mitigation

techniques are emp loyed. 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 expl oration 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 se mi

- 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.

The re 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 ce ntral to geothermal operations such as well pad construction and excavation, have the potential to produce fugitive dust emissions, including

PM 10, 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 impact s 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 Requi rement:

◦ 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 th e 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 ann ual 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 and7

episodic (e.g. event) usage; describe plans fo r control of PM

- 10 emissions from

these areas.

Summary of Roads and Routes of Travel

B LM 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, paralle l to Interstate 8 (see map ). Gecko Road is appro ximately 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

- highw ay trails, or routes of travel in two distinct management areas known as the Northern and Eastern Colorado (NECO)

management are a and the Western Colorado (WECO) management area. These areas are known as Limited Use areas, or Multiple Class Use L. In the se 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. Th ere are approximately 1,116 mi les 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 vehicl es) 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 miles8

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.

Th e 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 avail able.

Plans for Control of PM

- 10

Many d ust 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 veh icle traffic during the cooler months of the year, the fact that they are paved will reduce dust emissions that may have aris en if they had not been paved. There are speed limit signs on both of these roads, which are rigorously enforced. Speed limits ar e 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 approxima tely 49,127 acres. While in place, these closures will also help to redu ce 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 Imp erial 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

allow ed in Wilderness areas. A significant amount of land that may h ave 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).

Tabl e 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

A nother mitigation measure to help control fugitive dust emissions from BLM lands is a seasonal closure on all routes within the Painted Gorge area f rom January 1 of each year to June 30 th 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 lowe rs PM

- 10 emissions in the area. The Painted G orge 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 min imized when well

- worn trails are restored to their natural state. Name of Closure Approxi mate 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 ISDRA10

Areas of Critical Environmental Concern are also areas where travel is lim ited to street legal vehicles only. The BLM El Centro Field Office manages 14 Areas of

Critical Environmental Con cern 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 emi ssions from certain roads and routes as per the Wilderness

Classification in the California Desert Protection Act.

As stated above, t here are no authorize d roads in BLM Wilderness Areas. All

BLM Wilderness Areas are closed to all motor vehicle traff ic. 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 pe r 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 PM 10 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 mor e 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 publi c educational information on PM 10 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 t o “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 road s 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 Duneb uggy 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 identifi es OHV use on Ted Kipf Road as a significant source of

PM 10 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 Reclamati on 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 PM 10 emissions, then BLM will meet with Imperial Irrigation District, the

Coach ella 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

vehi cle 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 recrea tional 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 Ca mping 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 Des ignation (these are also true for the Northern and Eastern Colorado Routes of Travel

Des ignation) :13

There would be fewer roads designated as open than the current situation. There would be less miles of routes than existing

conditions....T he 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 rou te 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 redu ction 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 Des ert and West Mesa management areas. This resto ration 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 With in 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

Ai r 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 construction14

projects, BLM will require the project coordinator to obtain a permit from the Imperial County Air Pollution Control District.