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RULE 8011 GENERAL REQUIREMENTS (Adopted November 15, 2001; Amended 

August 19, 2004) 

1.0 Purpose 

The purpose of Regulation VIII (Fugitive PM10 Prohibitions) is to reduce ambient 

concentrations of fine particulate matter (PM10) by requiring actions to prevent, reduce 

or mitigate anthropogenic fugitive dust emissions. 

The Rules contained in this Regulation have been developed pursuant to United States 

Environmental Protection Agency guidance for Serious PM10 Nonattainment Areas. 

The rules are applicable to specified anthropogenic fugitive dust sources. Fugitive dust 

contains PM10 and particles larger than PM10. Controlling fugitive dust emissions 

when visible emissions are detected will not prevent all PM10 emissions, but will 

substantially reduce PM10 emissions. 

2.0 Applicability 

The provisions of this rule are applicable to specified outdoor fugitive dust sources. 

The definitions, exemptions, requirements, administrative requirements, recordkeeping 

requirements, and test methods set forth in this rule are applicable to all Rules under 

Regulation VIII (Fugitive PM10 Prohibitions) of the Rules and Regulations of the San 

Joaquin Valley Unified Air Pollution Control District. The provisions of this rule 

adopted on November 15, 2001 shall remain in effect until October 1, 2004 at which 

time the amendments adopted on August 19, 2004 shall take effect. 

3.0 Definitions 

The following definitions shall be applicable to rules contained in Regulation VIII.

3.1 Agricultural Source: any activity or portion of land associated with the 

commercial growing of crops or the raising of fowl or animals. 

3.2 Annual Average Daily Vehicle Trips (AADT): annual average 24-hour total of 

all vehicles counted on a road. 

3.3 Anthropogenic: sources of pollution of, relating to, or resulting from the 

influence of human beings on nature. 

3.4 APCO: the Air Pollution Control Officer of the San Joaquin Valley Unified Air 

Pollution Control District or his designee. 

3.5 Blasting: any excavation or demolition conducted with the use of explosives. 
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3.6 Bulk Material: any unpackaged material with a silt content of more than 5%. 

3.7 Bulk Material Handling, Storage, and/or Transporting Operation: includes but is 

not limited to the use of equipment, haul trucks, and/or motor vehicles for the 

loading, unloading, conveying, transporting, piling, stacking, screening, 

grading, or moving of bulk materials at an industrial, institutional, commercial 

and/or governmental owned or operated site or facility. 

3.8 Carryout and Trackout: any and all materials that adheres to and agglomerates 

on vehicles, haul trucks, and/or equipment (including trailers, tires, etc.) and 

falls onto a paved public road or the paved shoulder of a paved public road. 

3.9 Chemical/Organic Stabilization/Suppression: means controlling PM10 emissions 

from fugitive dust by applying any non-toxic chemical or organic dust 

suppressant, other than water, which meets any specifications, criteria, or tests 

required by any federal, state, or local water agency and is not prohibited for 

use by any applicable law, rule, or regulations. 

3.10 Construction: any on-site mechanical activities preparatory to or related to the 

building, alteration, rehabilitation, or demolition of an improvement on real 

property, including, but not limited to, land clearing, excavation related to 

construction, land leveling, grading, cut and fill grading, and the erection or 

demolition of any structure. As used in Regulation VIII, a construction site may 

encompass several contiguous parcels, or may encompass only a portion of one 

parcel, depending on the relationship of the property boundaries to the actual 

construction activities. 

3.11 Disturbed Surface Area: an area in which naturally occurring soils, or soils or 

other materials placed thereon, have been physically moved, uncovered, 

destabilized, or otherwise modified by grading, land leveling, scraping, cut and 

fill activities, excavation, brush and timber clearing, or grubbing, and soils on 

which vehicle traffic and/or equipment operation has occurred. An area is 

considered to be disturbed until the activity that caused the disturbance has been 

completed, and the disturbed area meets the stabilized surface conditions 

specified in this rule. 

3.12 Dust Suppressants: includes water, hygroscopic materials and, chemical/organic 

stabilization/suppression materials. 

3.13 Earthmoving Activities: The use of any equipment for an activity that may 

generate fugitive dust emissions, including, but not limited to, cutting and 

filling, grading, leveling, excavating, trenching, loading or unloading of bulk 

materials, demolishing, blasting, drilling, adding to or removing bulk of 
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materials from open storage piles, weed abatement through disking, and backfilling. 

3.14 Emergency: any situation where immediate action on the part of a federal, state 

or local agency involved is needed and where the timing of such federal, state or 

local activities makes it impractical to meet the requirements of this Regulation, 

such as natural disasters, civil disturbances, or hazardous materials spills. Only 

an authorized official of a federal, state or local agency may declare an 

emergency when deemed necessary to protect the general public. 

3.15 Enclosed Structure: a building with walls on all sides covered with a roof. 

3.16 Event material: wind, storm, or water erosion and runoff resulting in the 

accumulation of mud, soil, or other material onto a public paved road surface 

travel lane or shoulder. 

3.17 Excavation: any digging, trenching, quarrying, extraction, or tunneling. 

3.18 Extraction: removal of minerals, aggregate, or fossil fuels from the earth by 

excavation; including mining, surface stripping, open pit excavation, or 

tunneling. 

3.19 Fallow Land: agriculturally productive land which has been developed and used 

for agricultural purposes in the past that is allowed to lie idle during the growing 

season, including agricultural land that has been plowed, harrowed, and broken 

up without seeding. 

3.20 Freeboard: the vertical distance between the top edge of a cargo container area 

and the highest point at which the bulk material contacts the sides, front, or 

back of a cargo container area. 

3.21 Fueling and Service: an activity that involves the transfer of fuel into a 

vehicle/equipment fuel tank, and/or the repair and maintenance activity 

performed on vehicles/equipment. 

3.22 Fugitive Dust: any solid particulate matter entrained in the ambient air which is 

caused by anthropogenic or natural activities which is emitted into the air 

without first passing through a stack or duct designed to control flow, including, 

but not limited to, emissions caused by movement of soil, vehicles, equipment, 

and windblown dust. This excludes particulate matter emitted directly in the 

exhaust of motor vehicles, from other fuel combustion devices, portable 

brazing, soldering, or welding equipment, and from pile drivers. 
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3.23 Gravel Pad: a layer of washed gravel, rock, or crushed rock located at the point 

of intersection of a paved public roadway and an unpaved work site exit, and 

maintained to dislodge mud, dirt, and/or debris from the tires of motor vehicles 

and/or haul trucks, prior to exiting the work site. 

3.24 Grizzly: a device (i.e., rails, pipes, or grates) used to dislodge mud, dirt, and/or 

debris from the tires and undercarriage of motor vehicles or haul truck prior to 

leaving the work site. 

3.25 Haul Truck: any fully or partially open-bodied, self-propelled vehicle including 

any non-motorized attachments used for transporting bulk materials, including, 

but not limited to, trailers or other conveyances which are connected to or 

propelled by the actual motorized portion of the vehicle. 

3.26 Hygroscopic Materials: any material that is readily capable of absorbing 

moisture from the air. 

3.27 Landfill Daily Cover: soil excavated and stockpiled from a landfill borrow site 

that is used for daily operations to cover solid waste, trash, garbage, or other 

waste at a landfill disposal site. 

3.28 Landfill Disposal Site: a site where solid waste, trash, garbage, or other waste is 

disposed of by burying between layers of earth. 

3.29 Land Preparation: any activity that disturbs the natural condition of land, 

including, but not limited to, brush or timber clearing, grubbing, scraping, 

ground excavation, land leveling, or grading. 

3.30 Limit Visible Dust Emissions to 20% Opacity: Visible Dust Emissions (VDE) 

of such opacity to obscure a certified observer’s view to a degree less than an 

opacity of 20 percent in accordance with the test methods in Appendix A, 

Sections 1 and 2 of this rule. 

3.31 Local Agency: a city, county, or special district with jurisdiction over public 

roads or having land use authority. 

3.32 Modified Road: any road that is widened or improved so as to increase traffic 

capacity or that has been reconstructed. This term does not include road 

maintenance, repair, chip seal, pavement or roadbed rehabilitation that does not 

affect roadway geometrics, or surface overlay work. 

3.33 New Paved Road: any paved road segment constructed or modified after May 

15, 2002. (See the definition of paved road in this rule). 
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Administrative Change 12/12/05

8011 - 5

3.34 Off-field Agricultural Source: any agricultural source that meets the definition 

of: outdoor handling, storage and transport of bulk material; paved road; 

unpaved road; or unpaved vehicle/equipment traffic area 

3.35 On-field Agricultural Source: any agricultural source that is not an off-field 

agricultural source, including: 

3.35.1 activities conducted solely for the purpose of preparing land for the 

growing of crops or the raising of fowl or animals, such as brush or 

timber clearing, grubbing, scraping, ground excavation, land leveling, 

grading, turning under stalks, disking, or tilling; 

3.35.2 drying or pre-cleaning of agricultural crop material on the field where it 

was harvested; 

3.35.3 handling or storage of agricultural crop material that is baled, cubed, 

pelletized, or long-stemmed, on the field where it was harvested, and the 

handling of fowl or animal feed materials at sites where animals or fowl 

are raised; 

3.35.4 disturbances of cultivated land as a result of fallowing, planting, 

fertilizing or harvesting. 

3.36 Open Area: any of the following described in subsection 3.36.1 through 

subsection 3.36.3 of this rule. For the purpose of this rule, vacant portions of 

residential or commercial lots and contiguous parcels that are immediately 

adjacent to and owned and/or operated by the same individual or entity are 

considered one open area. An open area does not include any unpaved 

vehicle/equipment traffic area as defined in this rule. 

3.36.1 an unsubdivided or undeveloped land adjoining a developed or a partially 

developed residential, industrial, institutional, governmental, or 

commercial area. 

3.36.2 a subdivided residential, industrial, institutional, governmental, or 

commercial lot, which contains no approved or permitted building or 

structures of a temporary or permanent nature. 

3.36.3 a partially developed residential, industrial, institutional, governmental, 

or commercial lot and contiguous lots under common ownership. 

3.37 Open Storage Pile: any accumulation of bulk material, stored outside a building 

or warehouse.
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3.38 Open-Pit Mine: an excavation for a mining operation which, excluding 

entrances and egresses, is encircled by a “high-wall” at least 10 feet high. A 

“high wall” is a berm or cut having a slope of at least 1:1. 

3.39 Operation: any activity, process, or project described in the applicability 

sections of the Rules under Regulation VIII. 

3.40 Outdoor Handling, Storage, and Transport: handling (including loading and 

unloading), storage, and transport, and any accumulation of bulk material, 

temporarily or permanently stored outside of an enclosed structure. 

3.41 Owner/Operator: includes, but is not limited to, any person who leases, 

supervises, or operates equipment, or owns/operates a fugitive dust source, in 

addition to the normal meaning of owner or operator. 

3.42 Particulate matter: any material emitted or entrained into the air as liquid or 

solid particles, with the exception of uncombined water. 

3.43 Paved Road/Area: any road/area that is covered by concrete, asphaltic concrete, 

asphalt, or other materials which provides structural support for vehicles. 

3.44 Person: any individual, public and private corporation, government agency, 

partnership, association, firm, trust, estate, or any other legal entity which is 

recognized by law as the subject of rights and duties. 

3.45 PM10: particulate matter with an aerodynamic diameter smaller than or equal to 

a nominal ten (10) microns as measured by the applicable State and Federal 

reference test methods. 

3.46 PM10-Efficient Street Sweeper: a street sweeper which has been certified by the 

South Coast Air Quality Management District (SCAQMD) to comply with the 

District's performance standards set forth in SCAQMD Rule 1186 utilizing the 

test methods set forth in SCAQMD Rule 1186, Appendix A. 

3.47 Private Road: any road not defined as public. 

3.48 Public Road: any road operated by a public road agency and maintained for 

unrestricted legal vehicle access. 

3.49 Road: any road or street, highway, freeway, alley, way, access easement or 

driveway. 
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8011 - 7

3.50 Road Length: the total centerline distance of all contiguous (connected) 

segments of an owner's road, regardless of change of direction, road name, or 

surface, or intersection with a road not owned or operated by the owner. 

3.51 Road Segment: the portion of a road between two intersections, or between an 

intersection and the road’s terminus. 

3.52 Roadmix: a mixture of tank bottoms from crude oil storage tanks, material from 

crude oil spills, or other crude-oil-containing soil mixed with aggregates and 

soils, that is used as a base or cover material for roads, parking lots, berms, 

tank and well locations, or similar applications. 

3.53 Rural: areas not classified as urban constitute “rural.” 

3.54 Shipping, Receiving, and Transfer: an activity that involves handling, 

processing, and movement of materials, supplies or equipment. 

3.55 Silt: any aggregate material with a particle size of less than 75 micrometers in 

diameter, which passes through a No. 200 Sieve. For the purpose of all Rules 

under Regulation VIII, the silt content level is assumed to be 5 percent or 

greater, unless a person can show, by sampling and analysis, using the test 

method in Section 6.1.4 of this rule, that the silt content is less than 5 percent.

3.56 Site: real property or land used or set aside for any specific use. 

3.57 Soil Stabilization: the process used to control PM10 emissions from fugitive 

dust for an extended period of time by applying dust suppressants or planting 

vegetative cover. 

3.58 Stabilized Surface: any disturbed surface area or open bulk material storage pile 

that is resistant to wind blown fugitive dust emissions. A surface is considered 

to be stabilized if it meets at least one of the following conditions specified in 

this Section and as determined by the test methods specified in Appendix B of 

this rule: 

3.58.1 A visible crust; or 

3.58.2 A threshold friction velocity (TFV) for disturbed surface areas corrected 

for non-erodible elements of 100 centimeters per second or greater; or 

3.58.3 A flat vegetative cover of at least 50 percent that is attached or rooted 

vegetation; or unattached vegetative debris lying on the surface with a 

predominant horizontal orientation that is not subject to movement by 

wind; or 
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3.58.4 A standing vegetative cover of at least 30 percent that is attached or 

rooted vegetation with a predominant vertical orientation; or 

3.58.5 A standing vegetative cover that is attached or rooted vegetation with a 

predominant vertical orientation that is at least 10 percent and where the 

TFV is at least 43 centimeters per second when corrected for nonerodible elements; or 

3.58.6 A surface that is greater than or equal to 10 percent of non-erodible 

elements such as rocks, stones, or hard-packed clumps of soil. 

3.59 Stabilized Unpaved Road/Unpaved shoulder: any unpaved road, unpaved 

shoulder, or unpaved vehicle/equipment traffic area surface which meets the 

definition of stabilized surface as determined by the test methods in Appendix B, 

Section 3 of this rule, and where VDE is limited to 20% opacity. 

3.60 Temporary Unpaved Road: any unpaved road surface which is created to 

support a temporary or periodic activity, and the use of such road surface is 

limited to vehicle access for a period of not more than six months during any 

consecutive three-year period. Temporary unpaved roads must also comply with 

the definition of section 3.59. 

3.61 Three-sided Structure: A building with walls on three sides with or without a 

roof. 3.62 Threshold Friction Velocity (TFV): is the corrected velocity 

necessary to initiate soil erosion as determined by the test method specified in 

Section 6.0 of this rule. The lower the TFV, the greater the propensity for fine 

particles to be lifted at relatively low wind speeds. 

3.63 Trackout Control Device: a gravel pad, grizzly, wheel wash system, or a paved 

area located at the point of intersection of an unpaved area and a paved road that 

prevents or controls trackout. 

3.64 Unpaved Road: any road that is not covered by one of the materials described in 

the paved road definition. 

3.65 Unpaved Access/Haul Road: any road or path that is not covered by one of the 

materials described in the paved road definition that is associated with any 

construction, demolition, excavation, extraction, and other earthmoving activity 

and used by vehicles, equipment, haul trucks, or any conveyances to travel 

within a site, to move materials from one part of a site to another part within the 

same site, or to provide temporary access to a site. 

3.66 Unpaved Vehicle/Equipment Traffic Area: any nonresidential area that is not 

covered by asphalt, recycled asphalt, asphaltic concrete, concrete, or concrete 
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Administrative Change 12/12/05

8011 - 9

pavement that is used for fueling and servicing; shipping, receiving and transfer; 

or parking or storing equipment, haul trucks, vehicles, and any conveyances. 

3.67 Urban Area: an area within an incorporated city boundary or within 

unincorporated areas completely surrounded by an incorporated city 

3.68 Vehicle: A device by which any person or property may be propelled, moved, 

or drawn, including mobile equipment, excepting aircraft or watercraft or 

devices moved exclusively by human or animal power or used exclusively upon 

rails or tracks. 

3.69 Vehicle Daily Trips (VDT): The 24-hour total (midnight to midnight) count of 

all vehicles traveling over a survey point on a road segment or unpaved 

vehicle/equipment traffic area. The survey point must represent the most heavily 

traveled portion of the road segment or unpaved vehicle/equipment traffic area. 

3.70 Visible Dust Emissions (VDE): dust emissions that are visible to an observer. 

3.71 Wind Barrier: a fence or structure constructed, or row of trees planted, to 

reduce the shearing effects caused by wind thereby reducing or eliminating the 

amount of entrained fugitive dust.

3.72 Wind Generated Fugitive Dust: visible emissions from any disturbed surface 

area which are generated by wind action alone. 

3.73 Wheel Wash System: a system that uses water to dislodge mud, dirt and/or 

other debris from the tires and undercarriage of vehicles and/or haul trucks, 

prior to exiting the work site. 

3.74 Workday: a day on which work is performed as distinguished from a day off. 

For the purposes of this Regulation, a workday may be any period of hours or 

shift within a 24-hour period. 

4.0 Exemptions 

4.1 Emergency activities performed to ensure public health and safety are exempt 

from Regulation VIII. Emergency activities lasting more than 30 days shall be 

subject to this regulation, except where compliance would limit the effectiveness 

of the emergency activity performed to ensure public health and safety. 

4.2 Active operations conducted by essential service utilities to provide electricity, 

natural gas, telephone, water and sewer during periods of service outages and 

emergency disruptions. Within one hour of completion of active operations, a 
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person/owner must immediately comply with the requirements of Regulation 

VIII. 

4.3 Activities conducted at an elevation of 3,000 feet or higher above sea level. 

4.4 On-field agricultural sources. 

5.0 General Requirements 

5.1 Materials used for chemical/organic stabilization of soils, including petroleum 

resins, asphaltic emulsions, acrylics, and adhesives shall not violate State Water 

Quality Control Board standards for use as a soil stabilizer. Materials accepted 

by the California Air Resources Board (ARB) and the United States 

Environmental Agency (EPA), and which meet State water quality standards, 

shall be considered acceptable to the APCO. 

5.2 Any material prohibited for use as dust suppressant by EPA, the ARB, or other 

applicable law, rule, or regulation is also prohibited under Regulation VIII. 

5.3 Use of hygroscopic materials may be prohibited by the APCO in areas lacking 

sufficient atmospheric moisture of soil for such materials to effectively reduce 

fugitive dust emissions. The atmospheric moisture of soil is considered to be 

sufficient if it meets the application specifications of the hygroscopic product 

manufacturer. Use of such materials may be approved in conjunction with 

sufficient wetting of the controlled area. 

5.4 Any use of dust suppressants or gravel pads, and paving materials such as 

asphalt or concrete for paving, shall comply with other applicable District 

Rules. 

6.0 Administrative Requirements 

6.1 Test Methods 

The test methods specified in this section shall be used to determine compliance 

with the requirements of all rules under Regulation VIII. 

6.1.1 Determination of VDE Opacity 

Opacity observations to determine compliance with VDE standards shall 

be conducted in accordance with the test procedures for “Visual 

Determination of Opacity” as described in Appendix A of this rule. 

Opacity observations for sources other than unpaved traffic areas (e.g., 
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roads, parking areas) shall be conducted per Section 2 of Appendix A 

and shall require 12 readings at 15-second intervals. 

6.1.2 Determination of Stabilized Surface 

Observations to determine compliance with the conditions specified for a 

stabilized surface, in any inactive disturbed surface area, whether at a 

work site that is under construction, at a work site that is temporarily or 

permanently inactive, or on an open area and vacant lot, shall be 

conducted in accordance with the test methods described in Appendix B 

of this rule. If a disturbed surface area fails all of the specified tests, 

then the surface shall not be considered stabilized. 

6.1.3 Determination of Soil Moisture Content 

Soil moisture content shall be determined by using ASTM Method 

D2216-98 (Standard Test Method For Laboratory Determination Of 

Water [Moisture] Content of Soil and Rock By Mass), or other 

equivalent test methods approved by the EPA, ARB, and the APCO. 

6.1.4 Determination of Silt Content for Bulk Materials 

Silt content of a bulk material shall be determined by ASTM Method C 

136a (Standard Test Method For Sieve Analysis Of Fine and Coarse 

Aggregates), or other equivalent test methods approved by EPA, ARB, 

and the APCO. 

6.1.5 Determination of Silt Content for Unpaved Roads and Unpaved 

Vehicle/Equipment Traffic Areas 

Silt Content for unpaved roads and unpaved vehicle/equipment traffic 

areas shall be determined by using Section 3 of Appendix B of this Rule 

or other equivalent test methods approved by EPA, ARB, and the 

APCO. 

6.1.6 Determination of Threshold Friction Velocity (TFV) 

TFV shall be determined according to the sieving field procedure 

contained in “Determination of Threshold Friction Velocity (TFV),” as 

described in Appendix B of this rule. 
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6.2 Recordkeeping Requirements 

A person or owner/operator shall maintain records and any other supporting 

documents to demonstrate compliance with the requirements of the rules under 

Regulation VIII only for those days that a control measure was implemented. 

Such records shall include the type of control measure(s) used, the location and 

extent of coverage, and the date, amount, and frequency of application of dust 

suppressant, manufacturer’s dust suppressant product information sheet that 

identifies the name of the dust suppressant and application instructions. Records 

shall be kept for one year following project completion that results in the 

termination of all dust generating activities. An owner/operator subject to Rule 

2520 (Federally Mandated Operating Permits) shall keep the records for five 

years. Records shall be made available to the APCO upon request. 

7.0 Fugitive PM10 Management Plan for Unpaved Roads and Unpaved Vehicle/Equipment 

Traffic Areas 

As a compliance alternative for Rule 8061 section 5.2 and Rule 8071 section 5.1, an 

operator may implement a Fugitive PM10 Management Plan (FPMP) that is designed to 

achieve 50% control efficiency and has been approved by the APCO. The FPMP shall 

be implemented on all days that traffic exceeds, or is expected to exceed, the number of 

annual average daily vehicle trips or vehicle trips per day as specified in Rules 8061, 

8071, and 8081. The owner/operator remains subject to all requirements of the 

applicable rules of Regulation VIII that are not addressed by the FPMP. It should be 

noted that the FPMP is not a compliance option for any requirement for a stabilized 

surface as defined in Rule 8011. The requirements for FPMPs for agricultural sources 

are specified in Rule 8081 (Agricultural Sources) section 7.0. 

7.1 An owner/operator shall provide the proposed FPMP to the APCO or his/her 

designee via fax, mail, or in person. The APCO shall approve, disapprove, or 

conditionally approve each proposed FPMP. An FPMP shall not be considered 

APCO-approved until the operator has received written approval from the 

APCO. 

7.2 An owner/operator may submit one FPMP covering multiple unpaved roads and 

unpaved vehicle/equipment traffic areas. 

7.3 An owner/operator shall retain a copy of an APCO-approved FPMP at the 

operators place of business and make it available for inspection by the APCO or 

his designee during normal business hours. The APCO-approved FPMP shall 

remain valid until notification by the APCO that it is no longer valid, or until 

the owner/operator notifies the APCO that the owner/operator has permanently 

discontinued implementing the FPMP. 
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7.4 Failure to comply with the provisions of an APCO-approved FPMP is deemed 

to be a violation of this rule. 

7.5 A FPMP shall contain all of the following information: 

7.5.1 Name(s), address(es), and phone number(s) of person(s) responsible for 

the preparation, submittal, and implementation of the FPMP, and of 

person(s) responsible for the unpaved road or traffic area. 

7.5.2 A plot plan or map which shows the location of each unpaved road or 

traffic area to be covered by the FPMP, and the total length (miles) of 

unpaved roads, and the total area (acres) of the unpaved traffic areas. 

7.5.3 The months (and weeks, if known) of the year that vehicle traffic is 

expected to reach or exceed the number of vehicle trips as specified in 

Rules 8061, 8071, and 8081, and the types of vehicles (e.g., passenger 

vehicles, trucks, mobile equipment) expected on each road or traffic 

area. As stated above, the FPMP shall be implemented on all days that 

traffic exceeds, or is expected to exceed, the number of vehicle trips as 

specified in Rules 8061, 8071, and 8081. 

7.5.4 Dust suppressants, gravel, and/or vegetative materials to be applied, 

including: product specifications; manufacturer’s usage instructions 

(method, frequency, and intensity of application); type, number, and 

capacity of application equipment; and information on environmental 

impacts and approvals or certifications related to appropriate and safe use 

for ground application. 

7.5.5 A description of the condition of the treated surfaces to be achieved as a 

result of the use of the suppressant or other dust control material. 
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APPENDIX A 

Visual Determination of Opacity 

SECTION 1 Test Method For Unpaved Roads and Unpaved Traffic Areas 

SECTION 2 Test Method For Time-Averaged Regulations 

SECTION 3 Qualification and Testing 

______________________________________________________________________________ 

SECTION 1 TEST METHOD FOR UNPAVED ROADS AND UNPAVED TRAFFIC 

AREAS 

1.0 Opacity Test Method. The purpose of this test method is to estimate the percent opacity 

of fugitive dust plumes caused by vehicle movement on unpaved roads and unpaved 

traffic areas. This method can only be conducted by an individual who has received 

certification as a qualified observer. Qualification and testing requirements can be 

found in Section 3. of this appendix. 

a. Step 1: Stand at least 16.5 feet from the fugitive dust source in order to provide 

a clear view of the emissions with the sun oriented in the 140° sector to the 

back. Following the above requirements, make opacity observations so that the 

line of vision is approximately perpendicular to the dust plume and wind 

direction. If multiple plumes are involved, do not include more than one plume 

in the line of sight at one time. 

b. Step 2: Record the fugitive dust source location, source type, method of control 

used, if any, observer's name, certification data and affiliation, and a sketch of 

the observer's position relative to the fugitive dust source. Also, record the 

time, estimated distance to the fugitive dust source location, approximate wind 

direction, estimated wind speed, description of the sky condition (presence and 

color of clouds), observer's position to the fugitive dust source, and color of the 

plume and type of background on the visible emission observation form both 

when opacity readings are initiated and completed. 

c. Step 3: Make opacity observations, to the extent possible, using a contrasting 

background that is perpendicular to the line of vision. Make opacity 

observations approximately 1 meter above the surface from which the plume is 

generated. Note that the observation is to be made at only one visual point upon 

generation of a plume, as opposed to visually tracking the entire length of a dust 

plume as it is created along a surface. Make two observations per vehicle, 

beginning with the first reading at zero seconds and the second reading at five 

seconds. The zero-second observation should begin immediately after a plume 

has been created above the surface involved. Do not look continuously at the 

plume but, instead, observe the plume briefly at zero seconds and then again at 

five seconds. 
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d. Step 4: Record the opacity observations to the nearest 5% on an observational 

record sheet. Each momentary observation recorded represents the average 

opacity of emissions for a 5-second period. While it is not required by the test 

method, EPA recommends that the observer estimate the size of vehicles which 

generate dust plumes for which readings are taken (e.g. mid-size passenger car 

or heavy-duty truck) and the approximate speeds the vehicles are traveling when 

readings are taken. 

e. Step 5: Repeat Step 3 (Section 1 c) of this appendix) and Step 4 (Section 1 (d) of 

this appendix) until you have recorded a total of 12 consecutive opacity 

readings. This will occur once six vehicles have driven on the source in your 

line of observation for which you are able to take proper readings. The 12 

consecutive readings must be taken within the same period of observation but 

must not exceed 1 hour. Observations immediately preceding and following 

interrupted observations can be considered consecutive. 

f. Step 6: Average the 12 opacity readings together. If the average opacity reading 

equals 20% or lower, the source is in compliance with the opacity standard 

described in Rule 8011 of this rule. 

SECTION 2 TEST METHOD FOR VISUAL DETERMINATION OF OPACITY OF 

EMISSIONS FROM SOURCES FOR TIME-AVERAGED REGULATIONS 

2.0 Applicability. This method is applicable for the determination of the opacity of 

emissions from sources of visible emissions for time-averaged regulations. A timeaveraged regulation is any regulation that requires averaging visible emission data to 

determine the opacity of visible emissions over a specific time period. 

2.1 Principle. The opacity of emissions from sources of visible emissions is 

determined visually by an observer qualified according to the procedures of 

Section 3 of this appendix. 

2.2 Procedures. An observer qualified, in accordance with Section 3 of this 

appendix, shall use the following procedures for visually determining the 

opacity of emissions. 

 

a. Position. Stand at a position at least 5 meters from the fugitive dust 

source in order to provide a clear view of the emissions with the sun 

oriented in the 140° sector to the back. Consistent as much as 

possible with maintaining the above requirements, make opacity 

observations from a position such that the line of sight is 

approximately perpendicular to the plume and wind direction. The 

observer may follow the fugitive dust plume generated by mobile 
SVJUAPCD 8011 - 16 8/19/04

earthmoving equipment, as long as the sun remains oriented in the 

140° sector to the back. As much as possible, if multiple plumes are 

involved, do not include more than one plume in the line of sight at 

one time. 

b. Field Records. Record the name of the site, fugitive dust source type 

(i.e., pile, material handling (i.e., transfer, loading, sorting)), 

method of control used, if any, observer's name, certification data 

and affiliation, and a sketch of the observer's position relative to the 

fugitive dust source. Also, record the time, estimated distance to the 

fugitive dust source location, approximate wind direction, estimated 

wind speed, description of the sky condition (presence and color of 

clouds), observer's position relative to the fugitive dust source, and 

color of the plume and type of background on the visible emission 

observation from when opacity readings are initiated and completed. 

 

c. Observations. Make opacity observations, to the extent possible, 

using a contrasting background that is perpendicular to the line of 

sight. For storage piles, make opacity observations approximately 1 

meter above the surface from which the plume is generated. For 

extraction operations and the loading of haul trucks in open-pit 

mines, make opacity observations approximately one meter above the 

rim of the pit. The initial observation should begin immediately after 

a plume has been created above the surface involved. Do not look 

continuously at the plume, but instead observe the plume 

momentarily at 15-second intervals. For fugitive dust from 

earthmoving equipment, make opacity observations approximately 1 

meter above the mechanical equipment generating the plume. 

d. Recording Observations. Record the opacity observations to the 

nearest 5% every 15 seconds on an observational record sheet. Each 

momentary observation recorded represents the average opacity of 

emissions for a 15-second period. If a multiple plume exists at the 

time of an observation, do not record an opacity reading. Mark an 

“x” for that reading. If the equipment generating the plume travels 

outside of the field of observation, resulting in the inability to 

maintain the orientation of the sun within the 140° sector or if the 

equipment ceases operating, mark an “x” for the 15- second interval 

reading. Readings identified as “x” shall be considered interrupted 

readings. 

e. Data Reduction For Time-Averaged Regulations. For each set of 12 

or 24 consecutive readings, calculate the appropriate average opacity. 

Sets must consist of consecutive observations, however, readings 
SVJUAPCD 8011 - 17 8/19/04

immediately preceding and following interrupted readings shall be 

deemed consecutive and in no case shall two sets overlap, resulting in 

multiple violations. 

SECTION 3 QUALIFICATION AND TESTING. 

3.1 Certification Requirements. To receive certification as a qualified observer, a 

candidate must be tested and demonstrate the ability to assign opacity readings 

in 5% increments to 25 different black plumes and 25 different white plumes, 

with an error not to exceed 15% opacity on any one reading and an average 

error not to exceed 7.5% opacity in each category. Candidates shall be tested 

according to the procedures described in section 3.2 of this appendix. Any 

smoke generator used pursuant to section 3.3 of this appendix shall be equipped 

with a smoke meter, which meets the requirements of section 3.1 of this 

appendix. Certification tests that do not meet the requirements of sections 3.2 

and 3.3 of this appendix are not valid. The certification shall be valid for a 

period of 6 months, and after each 6-month period the qualification procedures 

must be repeated by an observer in order to retain certification. 

3.2 Certification Procedure. The certification test consists of showing the candidate 

a complete run of 50 plumes, 25 black plumes and 25 white plumes, generated 

by a smoke generator. Plumes shall be presented in random order within each 

set of 25 black and 25 white plumes. The candidate assigns an opacity value to 

each plume and records the observation on a suitable form. At the completion of 

each run of 50 readings, the score of the candidate is determined. If a candidate 

fails to qualify, the complete run of 50 readings must be repeated in any retest. 

The smoke test may be administered as Section of a smoke school or training 

program, and may be preceded by training or familiarization runs of the smoke 

generator, during which candidates are shown black and white plumes of known 

opacity. 

3.3 Smoke Generator Specifications. Any smoke generator used for the purpose of 

section 3.2 of this appendix shall be equipped with a smoke meter installed to 

measure opacity across the diameter of the smoke generator stack. The smoke 

meter output shall display in-stack opacity, based upon a path length equal to the 

stack exit diameter on a full 0% to 100% chart recorder scale. The smoke meter 

optical design and performance shall meet the specifications shown in Table A 

of this appendix. The smoke meter shall be calibrated as prescribed in section 

3.3.a of this appendix prior to conducting each smoke reading test. At the 

completion of each test, the zero and span drift shall be checked, and if the drift 

exceeds plus or minus 1% opacity, the condition shall be corrected prior to 

conducting any subsequent test runs. 
SVJUAPCD 8011 - 18 8/19/04

The smoke meter shall be demonstrated, at the time of installation, to meet the 

specifications listed in Table A of this appendix. This demonstration shall be 

repeated following any subsequent repair or replacement of the photocell or 

associated electronic circuitry, including the chart recorder or output meter, or 

every 6 months, whichever occurs first. 

a. Calibration. The smoke meter is calibrated after allowing a minimum of 

30 minutes warm-up by alternately producing simulated opacity of 0% 

and 100%. When stable response at 0% or 100% is noted, the smoke 

meter is adjusted to produce an output of 0% or 100%, as appropriate. 

This calibration shall be repeated until stable 0% and 100% readings are 

produced without adjustment. Simulated 0% and 100% opacity values 

may be produced by alternately switching the power to the light source 

on and off while the smoke generator is not producing smoke. 

b. Smoke Meter Evaluation. The smoke meter design and performance are 

to be evaluated as follows: 

(1) Light Source. Verify, from manufacturer's data and from voltage 

measurements made at the lamp, as installed, that the lamp is 

operated within plus or minus 5% of the nominal rated voltage. 

(2) Spectral Response Of Photocell. Verify from manufacturer's data 

that the photocell has a photopic response (i.e., the spectral 

sensitivity of the cell shall closely approximate the standard 

spectral-luminosity curve for photopic vision which is referenced 

in (b) of Table A of this appendix). 

(3) Angle Of View. Check construction geometry to ensure that the 

total angle of view of the smoke plume, as seen by the photocell, 

does not exceed 15°. Calculate the total angle of view as follows: 

Total Angle Of View = 2tan -1 d/2L 

Where: 

d = The photocell diameter + the diameter of the limiting 

aperture; and 

L = The distance from the photocell to the limiting aperture. 

The limiting aperture is the point in the path between the 

photocell and the smoke plume where the angle of view is most 

restricted. In smoke generator smoke meters, this is normally an 

orifice plate. 
SVJUAPCD 8011 - 19 8/19/04

(4) Angle Of Projection. Check construction geometry to ensure that 

the total angle of projection of the lamp on the smoke plume does 

not exceed 15°. Calculate the total angle of projection as follows: 

Total Angle Of Projection = 2tan -1 d/2L 

Where: 

d= The sum of the length of the lamp filament + the diameter of 

the limiting aperture; and 

L = The distance from the lamp to the limiting aperture. 

(5) Calibration Error. Using neutral-density filters of known opacity, 

check the error between the actual response and the theoretical 

linear response of the smoke meter. This check is accomplished 

by first calibrating the smoke meter, according to section 3.3(a) 

of this appendix, and then inserting a series of three neutraldensity filters of nominal opacity of 20%, 50%, and 75% in the 

smoke meter path length. Use filters calibrated within plus or 

minus 2%. Care should be taken when inserting the filters to 

prevent stray light from affecting the meter. Make a total of five 

nonconsecutive readings for each filter. The maximum opacity 

error on any one reading shall be plus or minus 3%. 

(6) Zero And Span Drift. Determine the zero and span drift by 

calibrating and operating the smoke generator in a normal manner 

over a 1-hour period. The drift is measured by checking the zero 

and span at the end of this period. 

(7) Response Time. Determine the response time by producing the 

series of five simulated 0% and 100% opacity values and 

observing the time required to reach stable response. Opacity 

values of 0% and 100% may be simulated by alternately 

switching the power to the lightsource off and on while the smoke 

generator is not operating. 

Table A. Smoke Meter Design And Performance Specifications 

Parameter Specification 

a. Light Source: Incandescent lamp operated at nominal rated voltage. 

b. Spectral response of photocell: Photopic (daylight spectral response of the human eye). 

c. Angle of view: 15° maximum total angle. 

d. Angle of projection : 15° maximum total angle. 

e. Calibration error: Plus or minus3% opacity, maximum. 

f. Zero and span drift: Plus or minus 1% opacity, 30 minutes. 

g. Response time: Less than or equal to 5 seconds 
SVJUAPCD 8011 - 20 8/19/04

APPENDIX B 

Determination of Stabilization 

SECTION 1 Test Methods for Determining Stabilization 

SECTION 2 Visible Crust Determination 

SECTION 3 Determination of Silt Content for Unpaved Roads and Unpaved 

Vehicle/Equipment Traffic Areas 

SECTION 4 Determination of Threshold Friction Velocity 

SECTION 5 Determination of Flat Vegetative Cover 

SECTION 6 Determination of Standing Vegetative Cover 

SECTION 7 Rock Test Method 

______________________________________________________________________________ 

1. Test Methods For Determining Stabilization. 

The test methods described in Section 2 through Section 7 of this appendix shall be 

used to determine whether an area has a stabilized surface. Should a disturbed area 

contain more than one type of disturbance, soil, vegetation, or other characteristics, 

which are visibly distinguishable, test each representative surface separately for 

stability, in an area that represents a random portion of the overall disturbed conditions 

of the site, according to the appropriate test methods in Section 2 through Section 7 of 

this appendix, and include or eliminate it from the total size assessment of disturbed 

surface area(s) depending upon test method results. 

2. Visible Crust Determination. 

2.1 Where a visible crust exists, drop a steel ball with a diameter of 15.9 

millimeters (0.625 inches) and a mass ranging from 16-17 grams from a 

distance of 30 centimeters (one foot) directly above (at a 90° angle 

perpendicular to) the soil surface. If blowsand is present, clear the blowsand 

from the surfaces on which the visible crust test method is conducted. Blowsand 

is defined as thin deposits of loose uncombined grains covering less than 50% of 

a site which have not originated from the representative site surface being 

tested. If material covers a visible crust, which is not blowsand, apply the test 

method in Section 4 of this appendix to the loose material to determine whether 

the surface is stabilized. 

2.2 A sufficient crust is defined under the following conditions: once a ball has been 

dropped according to section 2.1. of this appendix, the ball does not sink into 

the surface, so that it is partially or fully surrounded by loose grains and, upon 

removing the ball, the surface upon which it fell has not been pulverized, so that 

loose grains are visible. 
SVJUAPCD 8011 - 21 8/19/04

2.3 Drop the ball three times within a survey area that measures 1 foot by 1 foot and 

that represents a random portion of the overall disturbed conditions of the site. 

The survey area shall be considered to have passed the Visible Crust 

Determination Test if at least two out of the three times that the ball was 

dropped, the results met the criteria in section 2.2 of this appendix. Select at 

least two other survey areas that represent a random portion of the overall 

disturbed conditions of the site, and repeat this procedure. If the results meet the 

criteria of section 2.2 of this appendix for all of the survey areas tested, then the 

site shall be considered to have passed the Visible Crust Determination Test and 

shall be considered sufficiently crusted. 

2.4 At any given site, the existence of a sufficient crust covering one portion of the 

site may not represent the existence or protectiveness of a crust on another 

portion of the site. Repeat the visible crust test as often as necessary on each 

random portion of the overall conditions of the site for an accurate assessment. 

3. Determination of Silt Content for Unpaved Roads and Unpaved Vehicle/Equipment 

Traffic Areas 

The purpose of this test method is to estimate the silt content of the trafficked parts of 

unpaved roads and unpaved vehicle/equipment traffic areas. The higher the silt content, 

the more fine dust particles that are released when vehicles travel on unpaved roads and 

unpaved vehicle/equipment traffic areas. 

3.1 Equipment: 

a. A set of sieves with the following openings: 4 millimeters (mm), 2mm, 

1 mm, 0.5 mm and 0.25 mm, a lid, and collector pan. 

b. A small whisk broom or paintbrush with stiff bristles and dustpan 1ft. in 

width (the broom/brush should preferable have one, thin row of bristles 

no longer than 1.5 inches in length). 

c. A spatula without holes. 

d. A small scale with half-ounce increments (e.g., postal/package scale). 

e. A shallow, lightweight container (e.g., plastic storage container). 

f. A sturdy cardboard box or other rigid object with a level surface. 

g. A basic calculator. 

h. Cloth gloves (optional for handling metal sieves on hot, sunny days). 

i. Sealable plastic bags (if sending samples to a laboratory). 

j. A pencil/pen and paper. 

3.2 Step 1: Look for a routinely traveled surface, as evidenced by tire tracks [Only 

collect samples from surfaces that are not damp due to precipitation or dew. 

This statement is not meant to be a standard in itself for dampness where 

watering is being used as a control measure. It is only intended to ensure that 
SVJUAPCD 8011 - 22 8/19/04

surface testing is done in a representative manner.] Use caution when taking 

samples to ensure personal safety with respect to passing vehicles. Gently press 

the edge of a dustpan (1 foot in width) into the surface four times to mark an 

area that is 1 square foot. Collect a sample of loose surface material into the 

dustpan, minimizing escape of dust particles. Use a spatula to lift heavier 

elements such as gravel. Only collect dirt/gravel to an approximate depth of 3/8 

inch or 1 cm in the 1 square foot area. If you reach a hard, underlying 

subsurface that is <3/8 inch in depth, do not continue collecting the sample by 

digging into the hard surface. In other words, you are only collecting a surface 

sample of loose material down to 1cm. In order to confirm that samples are 

collected to a 1cm depth, a wooden dowel or other similar narrow object a least 

one-foot in length can be laid horizontally across the survey area while a metric 

rule is held perpendicular to the dowel. (Optional: At this point, you can choose 

to place the sample collected into a plastic bag or container and take it to an 

independent laboratory for silt content analysis. A reference to the procedure the 

laboratory is required to follow is at the end of this section) 

3.3 Step 2: Place a scale on a level surface. Place a lightweight container on the 

scale. Zero the scale with the weight of the empty container on it. Transfer the 

entire sample collected in the dustpan to the container, minimizing escape of 

dust particles. Weight the sample and record its weight. 

3.4 Step 3: Stack a set of sieves in order according to the size openings specified 

above, beginning with the largest size opening (4 mm) at the top. Place a 

collector pan underneath the bottom (0.25 mm) sieve. 

3.5 Step 4: Carefully pour the sample into the sieve stack, minimizing escape of 

dust particles by slowly brushing material into the stack with a whiskbroom or 

brush. (On windy days, use the trunk or door of a vehicle as a wind barrier.) 

Cover the stack with a lid. Lift up the sieve stack and shake it vigorously up and 

down and sideways for at least 1 minute. 

3.6 Step 5: Remove the lid from the stack and disassemble each sieve separately, 

beginning with the top sieve. As you remove each sieve, examine it to make 

sure that all of the material has been sifted to the finest sieve through which it 

can pass (e.g., material in each sieve (besides the top sieve that captures a range 

of larger elements) should look the same size). If this is not the case, re-stack 

the sieves and collector pan, cover the stack with the lid, and shake it again for 

at least 1 minute. (You only need to reassemble the sieve(s) that contain 

material, which requires further sifting.) 

3.7 Step 6: After disassembling the sieves and collector pan, slowly sweep the 

material from the collector pan into the empty container originally used to 

collect and weight the entire sample. Take care to minimize escape of dust 
SVJUAPCD 8011 - 23 8/19/04

particles. You do not need to do anything with material captured in the sieves – 

only the collector pan. Weigh the container with the materials from the collector 

pan and record its weight. 

3.8 Step 7: If the source is an unpaved road, multiply the resulting weight by 0.38. 

If the source is an unpaved vehicle/equipment traffic area, multiply the resulting 

weight by 0.55. The resulting number is the estimated silt loading. Then, divide 

by the total weight of the sample you recorded earlier in Step 2 (section 3.3) and 

multiply by 100 to estimate the percent silt content. 

3.9 Step 8: Select another two routinely traveled portions of the unpaved road or 

unpaved vehicle/equipment traffic area and repeat this test method. Once you 

have calculated the silt loading and percent silt content of the 3 samples 

collected, average your results together. 

3.10 Step 9: Examine Results. If the average silt loading is less than 0.33 oz/ft2

, the 

surface is STABLE. If the average silt loading is greater than or equal to 0.33 

oz/ft2, then proceed to examine the average percent silt content. If the source is 

an unpaved road and the average percent silt content is 6% or less, the surface is 

STABLE. If the source is an unpaved parking lot and the average percent silt 

content is 8% or less, the surface is STABLE. If your field test results are 

within 2% of the standard (for example, 4%-8% silt content on an unpaved 

road) it is recommended that you collect 3 additional samples from the source 

according to Step 1 (section 3.2) and take them to an independent laboratory for 

silt content analysis. 

3.11 Independent Laboratory Analysis: You may choose to collect samples from the 

source, according to Step 1 (section 3.2) and send them to an independent 

laboratory for silt content analysis rather than conduct the sieve field procedure. 

If so, the test method the laboratory is required to use is: 

“Procedures For Laboratory Analysis for Surface/Bulk Dust Loading Samples”, 

(Fifth Edition, Volume 1, Appendix C.2.3 “Silt Analysis”, 1995), AP-42, 

Office of Air Quality Planning & Standards, U.S. Environmental Protection 

Agency, Research Triangle Park, North Carolina. 

4. Determination Of Threshold Friction Velocity (TFV). 

For disturbed surface areas that are not crusted or vegetated, determine threshold 

friction velocity (TFV) according to the following sieving field procedure (based on a 

1952 laboratory procedure published by W. S. Chepil). 

4.1 Obtain and stack a set of sieves with the following openings: 4 millimeters 

(mm), 2 mm, 1 mm, 0.5 mm, and 0.25 mm or obtain and stack a set of 

standard/commonly available sieves. Place the sieves in order according to size 
SVJUAPCD 8011 - 24 8/19/04

openings, beginning with the largest size opening at the top. Place a collector 

pan underneath the bottom (0.25 mm) sieve. Collect a sample of loose surface 

material from an area at least 30 cm by 30 cm in size to a depth of 

approximately 1 cm using a brush and dustpan or other similar device. Only 

collect soil samples from dry surfaces (i.e. when the surface is not damp to the 

touch). Remove any rocks larger than 1 cm in diameter from the sample. Pour 

the sample into the top sieve (4 mm opening) and cover the sieve/collector pan 

unit with a lid. Minimize escape of particles into the air when transferring 

surface soil into the sieve/collector pan unit. Move the covered sieve/collector 

pan unit by hand using a broad, circular arm motion in the horizontal plane. 

Complete twenty circular arm movements, ten clockwise and ten 

counterclockwise, at a speed just necessary to achieve some relative horizontal 

motion between the sieves and the particles. Remove the lid from the 

sieve/collector pan unit and disassemble each sieve separately beginning with 

the largest sieve. As each sieve is removed, examine it for loose particles. If 

loose particles have not been sifted to the finest sieve through which they can 

pass, reassemble and cover the sieve/collector pan unit and gently rotate it an 

additional ten times. After disassembling the sieve/collector pan unit, slightly tilt 

and gently tap each sieve and the collector pan so that material aligns along one 

side. In doing so, minimize escape of particles into the air. Line up the sieves 

and collector pan in a row and visibly inspect the relative quantities of catch in 

order to determine which sieve (or whether the collector pan) contains the 

greatest volume of material. If a visual determination of relative volumes of 

catch among sieves is difficult, use a graduated cylinder to measure the volume. 

Estimate TFV for the sieve catch with the greatest volume using Table 1 of this 

appendix, which provides a correlation between sieve opening size and TFV. 

Table 1. Determination Of Threshold Friction Velocity 

Tyler Sieve No. ASTM 11 Opening TFV 

 Sieve No. (mm) (cm/s) 

5 5 4 135 

9 10 2 100 

16 18 1 76 

32 35 0.5 58 

60 60 0.25 43 

Collector Pan --- -- 30 

4.2 Collect at least three soil samples which represent random portions of the 

overall conditions of the site, repeat the above TFV test method for each sample 

and average the resulting TFVs together to determine the TFV uncorrected for 

non-erodible elements. Non-erodible elements are distinct elements, in the 

random portion of the overall conditions of the site, that are larger than 1 cm in 

diameter, remain firmly in place during a wind episode, and inhibit soil loss by 
SVJUAPCD 8011 - 25 8/19/04

consuming Section of the shear stress of the wind. Non-erodible elements 

include stones and bulk surface material but do not include flat or standing 

vegetation. For surfaces with non-erodible elements, determine corrections to 

the TFV by identifying the fraction of the survey area, as viewed from directly 

overhead, that is occupied by non-erodible elements using the following 

procedure. For a more detailed description of this procedure, see Section 6 (Test 

Methods For Stabilization-Rock Test Method) of this appendix. Select a survey 

area of 1 meter by 1 meter that represents a random portion of the overall 

conditions of the site. Where many non-erodible elements lie within the survey 

area, separate the non-erodible elements into groups according to size. For each 

group, calculate the overhead area for the non-erodible elements according to 

the following equations: 

Average Dimensions = 

(Average Length) x (Average Width) 

Eq. 1

Overhead Area = 

(Average Dimensions) x (Number Of Elements) 

Eq. 2

Total Overhead Area = 

Overhead Area Of Group 1 + Overhead Area Of Group 2 (etc.) 

Eq. 3

Total Frontal Area = 

Total Overhead Area/2 

Eq. 4

Percent Cover Of Non-Erodible Elements = 

(Total Frontal Area/Survey Area) x 100 

Eq. 5

Note: Ensure consistent units of measurement (e.g., square meters or square 

inches when calculating percent cover). 

Repeat this procedure on an additional two distinct survey areas that represent a 

random portion of the overall conditions of the site and average the results. Use 

Table 2 of this appendix to identify the correction factor for the percent cover of 

non-erodible elements. Multiply the TFV by the corresponding correction factor 

to calculate the TFV corrected for non-erodible elements. 

Table 2. Correction Factors For Threshold Friction Velocity 

Percent Cover Of Non-Erodible Elements Correction Factor 

Greater than or equal to 10% 5 

Greater than or equal to 5% and less than 10% 3 

Less than 5% and greater than or equal to 1% 2 

Less than 1% None 
SVJUAPCD 8011 - 26 8/19/04

5. Determination Of Flat Vegetative Cover. 

Flat vegetation includes attached (rooted) vegetation or unattached vegetative debris 

lying on the surface with a predominant horizontal orientation that is not subject to 

movement by wind. Flat vegetation, which is dead but firmly attached, shall be 

considered equally protective as live vegetation. Stones or other aggregate larger than 1 

centimeter in diameter shall be considered protective cover in the course of conducting 

the line transect test method. Where flat vegetation exists, conduct the following line 

transect test method. 

5.1 Line Transect Test Method. Stretch a 100 foot measuring tape across a survey 

area that represents a random portion of the overall conditions of the site. 

Firmly anchor both ends of the measuring tape into the surface using a tool such 

as a screwdriver, with the tape stretched taut and close to the soil surface. If 

vegetation exists in regular rows, place the tape diagonally (at approximately a 

45° angle) away from a parallel or perpendicular position to the vegetated rows. 

Pinpoint an area the size of a 3/32 inch diameter brazing rod or wooden dowel 

centered above each 1 foot interval mark along one edge of the tape. Count the 

number of times that flat vegetation lies directly underneath the pinpointed area 

at 1 foot intervals. Consistently observe the underlying surface from a 90° angle 

directly above each pinpoint on one side of the tape. Do not count the 

underlying surface as vegetated if any portion of the pinpoint extends beyond the 

edge of the vegetation underneath in any direction. If clumps of vegetation or 

vegetative debris lie underneath the pinpointed area, count the surface as 

vegetated, unless bare soil is visible directly below the pinpointed area. When 

100 observations have been made, add together the number of times a surface 

was counted as vegetated. This total represents the percent of flat vegetation 

cover (e.g., if 35 positive counts were made, then vegetation cover is 35%). If 

the survey area that represents a random portion of the overall conditions of the 

site is too small for 100 observations, make as many observations as possible. 

Then multiply the count of vegetated surface areas by the appropriate conversion 

factor to obtain percent cover. For example, if vegetation was counted 20 times 

within a total of 50 observations, divide 20 by 50 and multiply by 100 to obtain 

a flat vegetation cover of 40%. 

5.2 Conduct the line transect test method, as described in section 5.1 of this 

appendix, an additional two times on areas that represent a random portion of 

the overall conditions of the site and average results. 

6. Determination Of Standing Vegetative Cover. 

Standing vegetation includes vegetation that is attached (rooted) with a predominant 

vertical orientation. Standing vegetation, which is dead but firmly rooted, shall be 
SVJUAPCD 8011 - 27 8/19/04

considered equally protective as live vegetation. Conduct the following standing 

vegetation test method to determine if 30% cover or more exists. If the resulting 

percent cover is less than 30% but equal to or greater than 10%, then conduct the test 

in Section 4 (Determination Of Threshold Friction Velocity (TFV)) of this appendix in 

order to determine if the site is stabilized, such that the standing vegetation cover is 

equal to or greater than 10%, where threshold friction velocity, corrected for nonerodible elements, is equal to or greater than 43 cm/second. 

6.1 For standing vegetation that consists of large, separate vegetative structures 

(e.g., shrubs and sagebrush), select a survey area that represents a random 

portion of the overall conditions of the site that is the shape of a square with 

sides equal to at least 10 times the average height of the vegetative structures. 

For smaller standing vegetation, select a survey area of three feet by three feet. 

6.2 Count the number of standing vegetative structures within the survey area. 

Count vegetation, which grows in clumps as a single unit. Where different types 

of vegetation exist and/or vegetation of different height and width exists, 

separate the vegetative structures with similar dimensions into groups. Count the 

number of vegetative structures in each group within the survey area. Select an 

individual structure within each group that represents the average height and 

width of the vegetation in the group. If the structure is dense (e.g., when 

looking at it vertically from base to top there is little or zero open air space 

within its perimeter), calculate and record its frontal silhouette area, according 

to Equation 6 of this appendix. Also, use Equation 6 of this appendix to estimate 

the average height and width of the vegetation if the survey area is larger than 

nine square feet. Otherwise, use the procedure in section 6.3 of this appendix to 

calculate the frontal silhouette area. Then calculate the percent cover of standing 

vegetation according to Equations 7, 8, and 9 of this appendix. 

Frontal Silhouette Area = 

(Average Height) x (Average Width) 

Eq. 6 

Frontal Silhouette Area Of Group = 

(Frontal Silhouette Area Of Individual Vegetative Structure) x 

(Number Of Vegetation Structures Per Group) 

Eq. 7 

Total Frontal Silhouette Area = 

Frontal Silhouette Area Of Group 1 + Frontal Silhouette Area Of 

Group 2 (etc.) 

Eq. 8 

Percent Cover Of Standing Vegetation = 

(Total Frontal Silhouette Area/Survey Area) x 100 

Eq. 9 
SVJUAPCD 8011 - 28 8/19/04

Percent Open Space = 

[(Number Of Circled Gridlines Within The Outlined Area Counted 

That Are Not Covered By Vegetation/Total Number Of Gridline 

Intersections Within The Outlined Area) x 100] 

Eq. 10 

Percent Vegetative Density = 

100 - Percent Open Space 

Eq. 11 

Vegetative Density = 

Percent Vegetative Density/100 

Eq. 12 

Frontal Silhouette Area = 

[Max. Height x Max. Width] x [Vegetative Density/0.4]0.5 

Eq. 13 

Note: Ensure consistent units of measurement (e.g., square meters or square 

inches when calculating percent cover). 

6.3 Vegetative Density Factor. Cut a single, representative piece of vegetation (or 

consolidated vegetative structure) to within 1 cm of surface soil. Using a white 

paper grid or transparent grid over white paper, lay the vegetation flat on top of 

the grid (but do not apply pressure to flatten the structure). Grid boxes of 1 

inch or 1/2 inch squares are sufficient for most vegetation when conducting this 

procedure. Using a marker or pencil, outline the shape of the vegetation along 

its outer perimeter, according to Figure B, C, or D of this appendix, as 

appropriate. (Note: Figure C differs from Figure D primarily in that the width 

of vegetation in Figure C is narrow at its base and gradually broadens to its 

tallest height. In Figure D, the width of the vegetation generally becomes 

narrower from its midpoint to its tallest height.) Remove the vegetation, count 

and record the total number of gridline intersections within the outlined area, 

but do not count gridline intersections that connect with the outlined shape. 

There must be at least 10 gridline intersections within the outlined area and 

preferably more than 20, otherwise, use smaller grid boxes. Draw small circles 

(no greater than a 3/32 inch diameter) at each gridline intersection counted 

within the outlined area. Replace the vegetation on the grid within its outlined 

shape. From a distance of approximately 2 feet directly above the grid, observe 

each circled gridline intersection. Count and record the number of circled 

gridline intersections that are not covered by any piece of the vegetation. To 

calculate percent vegetative density, use Equations 10 and 11 of this appendix. 

If percent vegetative density is equal to or greater than 30, use an equation (one 

of the equations-Equations 16, 17, or 18 of this appendix) that matches the 

outline used to trace the vegetation (Figure B, C, or D) to calculate its frontal 

silhouette area. If percent vegetative density is less than 30, use Equations 12 

and 13 of this appendix to calculate the frontal silhouette area. 
SVJUAPCD 8011 - 29 8/19/04

Figure B. Cylinder 

Frontal Silhouette Area = Maximum Height x Maximum Width Eq. 16 

Figure C. Inverted Cone 

Frontal Silhouette Area = Maximum Height x 1/2 Maximum Width Eq. 17 
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Figure D. Upper Sphere 

Frontal Silhouette Area = (3.14 x Maximum Height x 1/2 Maximum Width)/2 Eq. 18 

7. Rock Test Method. 

The Rock Test Method, which is similar to Section 4 (Test Methods For StabilizationDetermination Of Threshold Friction Velocity (TFV)) of this appendix, examines the 

wind-resistance effects of rocks and other non-erodible elements on disturbed surfaces. 

Non-erodible elements are objects larger than 1 centimeter (cm) in diameter that remain 

firmly in place even on windy days. Typically, non-erodible elements include rocks, 

stones, glass fragments, and hardpacked clumps of soil lying on or embedded in the 

surface. Vegetation does not count as a non-erodible element in this method. The 

purpose of this test method is to estimate the percent cover of non-erodible elements on 

a given surface to see whether such elements take up enough space to offer protection 

against windblown dust. For simplification, the following test method refers to all nonerodible elements as “rocks”. 

7.1 Select a 1 meter by 1 meter survey area that represents the general rock 

distribution on the surface. (A 1 meter by 1 meter area is slightly greater than a 

3 foot by 3 foot area.) Mark-off the survey area by tracing a straight, visible 

line in the dirt along the edge of a measuring tape or by placing short ropes, 

yard sticks, or other straight objects in a square around the survey area. 

7.2 Without moving any of the rocks or other elements, examine the survey area. 

Since rocks >3/8 inch (1 cm) in diameter are of interest, measure the diameter 

of some of the smaller rocks to a get a sense for which rocks need to be 

considered. 
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7.3 Mentally group the rocks >3/8 inch (1 cm) diameter lying in the survey area 

into small, medium, and large size categories. Or, if the rocks are all 

approximately the same size, simply select a rock of average size and typical 

shape. Without removing any of the rocks from the ground, count the number of 

rocks in the survey area in each group and write down the resulting number. 

7.4 Without removing rocks, select one or two average-size rocks in each group and 

measure the length and width. Use either metric units or standard units. Using a 

calculator, multiply the length times the width of the rocks to get the average 

dimensions of the rocks in each group. Write down the results for each rock 

group. 

7.5 For each rock group, multiply the average dimensions (length times width) by 

the number of rocks counted in the group. Add the results from each rock group 

to get the total rock area within the survey area. 

7.6 Divide the total rock area, calculated in section 7.5 of this appendix, by two (to 

get frontal area). Divide the resulting number by the size of the survey area 

(make sure the units of measurement match), and multiply by 100 for percent 

rock cover. For example, the total rock area is 1,400 square centimeters, divide 

1,400 by 2 to get 700. Divide 700 by 10,000 (the survey area is 1 meter by 1 

meter, which is 100 centimeters by 100 centimeters or 10,000 centimeters) and 

multiply by 100. The result is 7% rock cover. If rock measurements are made in 

inches, convert the survey area from meters to inches (1 inch = 2.54 

centimeters). 

7.7 Select and mark-off two additional survey areas and repeat the procedures 

described in section 7.1 through section 7.6 of this appendix. Make sure the 

additional survey areas also represent the general rock distribution on the site. 

Average the percent cover results from all three survey areas to estimate the 

average percent of rock cover. 

7.8 If the average rock cover is greater than or equal to 10%, the surface is stable. 

If the average rock cover is less than 10%, follow the procedures in section 7.9 

of this appendix. 

7.9 If the average rock cover is less than 10%, the surface may or may not be 

stable. Follow the procedures in Section 1.3 (Determination Of Threshold 

Friction Velocity (TFV)) of this rule and use the results from the rock test 

method as a correction (i.e., multiplication) factor. If the rock cover is at least 

1%, such rock cover helps to limit windblown dust. However, depending on the 

soil’s ability to release fine dust particles into the air, the percent rock cover 
SVJUAPCD 8011 - 32 8/19/04

may or may not be sufficient enough to stabilize the surface. It is also possible 

that the soil itself has a high enough TFV to be stable without even accounting 

for rock cover. 

7.10 After completing the procedures described in section 7.9 of this appendix, use 

Table 2 of this appendix to identify the appropriate correction factor to the TFV, 

depending on the percent rock cover.