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EIS FOR THE IMPERIAL SAND DUNES
RECREATION AREA MANAGEMENT PLAN
A CASE STUDY FOR PROFESSOR STEPHAN SCHMIDT,
CRP 5540 – CORNELL UNIVERSITY
December 1, 2010
Andrew Bruce
Andrew Bruce
Final Environmental Impact Statement for the Imperial Sand
Dunes Recreation Area Management Plan and Proposed
Amendment to the California Desert Conservation Plan 1980
Organization
Lead Agency:
U.S. Department of the Interior
Bureau of Land Management
California Desert District
El Centro Field Office
Involved Agencies:
The U.S. Fish and Wildlife Service
California State Historic Preservation Office
Native American Tribal Governments
Summary
The Bureau of Land Management (BLM) produced
this Environmental Impact Statement (EIS) to
investigate the potential environmental impacts
from the revision and updating of the Recreation
Area Management Plan (RAMP) for the Imperial
Sand Dunes Recreation Area (ISDRA). The
ISDRA is the largest mass of sand dunes in
California and is a world-renowned location for offhighway vehicle (OHV) recreation. The ISDRA
receives over 3 million OHV visitor-use days per
year and is one of the most popular OHV areas
west of the Mississippi. The ISDRA is also home
to several endemic and fragile plant and animal
species.
“To fulfill its obligations under the Federal Land
Policy Management Act (FLPMA) and under the
Endangered Species Act (ESA), the BLM
manages recreational use after considering the
effects of the recreational activities on the
conditions of special-status species, and other
unique natural and cultural resources” (BLM, 9).
The U.S. Fish and Wildlife Service (USFWS) is the
primary consulting agency for the EIS, because
they control federal agency activities with respect
to the ESA.
Increasing OHV use in the ISDRA has brought
about “minor occurrences of occasional
trespasses in the North Algodones Dunes
Wilderness and on private lands” by OHV users
(BLM, 10). This increasing level of use and number
of violations has created some user conflicts and
motivated the revision of the RAMP. Finding an
appropriate balance between these two values,
recreation and bio-diversity protection, is another
primary concern of the RAMP and the EIS. While
the EIS covers a number of environmental impacts,
this case study focuses on impacts to bio-diversity
and habitat.
Chronology
1976 - The Federal Land Policy Management Act
requires the BLM to create management plans for
all units managed by the Bureau.
1979 – The first RAMP for the ISDRA is completed.
1980 – The California Desert Conservation Area
Plan, which guides all BLM plans in the area
including the ISDRA RAMP, is completed.
1987 – The second RAMP for the ISDRA is
completed.
1994 – The California Desert Conservation Act
designates a portion of the ISDRA, the North
Algodones Dunes, as wilderness.
1998 – The BLM issues a Notice of Intent for the
new ISDRA RAMP and begins public planning
meetings.
2000 – The BLM conducts initial Public Scoping
Meetings.
2000 – The Center for Biological Diversity filed for
injunctive relief in U.S. District Court against the
BLM claiming the BLM violated the ESA because
they did not consult the USFWS. Camping and
OHV closures occurred in five areas of the ISDRA
during the interim.
2001 – The BLM conducts subsequent Public
Scoping Meetings.
2002 – The BLM provides the Draft EIS and RAMP
for public comment.
2003 – The Final EIS and RAMP are produced.
Andrew
Bruce
Andrew
Bruce
Project Description
The revised RAMP informs management
decisions about the land use and resources of the
Imperial Sand Dunes Recreation Area (ISDRA)
and seeks to find a balance between recreational
and ecological values, while promoting the health
and safety of visitors, employees, and nearby
residents. Under the new RAMP, the ISDRA is
divided into eight management areas:
1) Mammoth Wash Management Area, 2) North Algodones Dunes Wilderness Management
Area, 3) Gecko Management Area, 4) Glamis Management Area, 5) Adaptive Management
Area, 6) Ogilby Management Area, 7) Dune Buggy Flats Management Area and 8) Buttercup
Management Area (BLM, 2). Each management area provides different recreational
opportunities based on the Recreation Opportunity Spectrum (ROS) classification system. The
ROS system dictates the visitor supply and types of allowed activities based on users needs and
management area capacity and ecological sensitivity.
Alternatives
The EIS considers four alternatives: 1) No Action Alternative, 2) Recreation and Resource
Protection Alternative, 3) Natural and Cultural Resource Alternative and 4) Motorized Recreation
Opportunities Alternative. The names are accurate descriptions of the general approach of each
alternative, although alternative 2 does emphasize recreation more than natural resources.
Alternative 2 was preferred in the EIS and was ultimately implemented.
The primary difference between the alternatives is the number of recreational users allowed each
day, the type of OHV use allowed and the ROS classifications employed. All but the no action
alternative, provide for a dust control plan, new ranger stations, new law enforcement tools, the
implementation of fee-based programs and the provision of free use days.
The no action alternative does not place a limit on visitor supply, while alternatives 2, 3, and 4
allow 80,000, 20,000 and 274,000 visitors per day respectfully. The no action alternative allows for
unlimited OHV use in all areas except the wilderness zone. Alternatives 2 and 4 would allow for
unlimited OHV use in six areas with permit use in one area and none in the wilderness. Alternative
3 would allow unlimited use in five areas and close three areas to OHVs, including the wilderness.
Using the ROS, Alternative 2 would include one semi-primitive non-motorized area, two semiprimitive motorized areas, three roaded natural areas and two rural areas. Alternative 3 would
include three semi-primitive non-motorized areas, three semi-primitive motorized areas and two
roaded natural areas. Alternative 4 would include one semi-primitive non-motorized area, two
roaded natural areas, three rural areas and two urban areas.
Andrew Bruce
Impacts
Habitat
Three primary habitat types exist in the ISDRA: 1) Creosote Bush Scrub, 2) Psammophytic Scrub and 3)
Microphyll Woodland.
Creosote bush scrub is the most common habitat type in the Colorado Desert. It is found on well-drained
secondary soils of slopes, fans, and valleys. In the ISDRA, creosote bush scrub is found around the edge of
the major dune area. This habitat type consists of relatively barren ground interspersed with widely spaced
shrubs.
Psammophytic scrub is found in the interior of the dune system between active dunes in small valleys called
“bowls.” The soil in this habitat type is made up of fine sand. As the dunes shift, so do the bowls.
Psammophytic vegetation is adapted to high sand mobility and deep-water percolation and most species are
able to grow rapidly with favorable soil moisture conditions.
Microphyll woodland is found east of the dune system in a large alluvial fan that drains the Chocolate and
Cargo Muchacho mountains. The alluvial fan is crossed by many ephemeral washes. Microphyll woodland is
made up of dense stands of trees and occurs in the larger drainages around dry channels and the sinks
where they end. Vegetation in this habitat type is sparse in the open areas between the sinks.
Loss, degradation and fragmentation of habitat are expected in all habitat types open to OHVs. The EIS does
not elaborate further on how much loss, other than weakly stating a relative amount (more than alt. 1; less
than alt.3), and does not indicate the form of degradation or what degree of fragmentation is expected.
Impacts to habitat are expected from new facilities development, but the BLM determined that construction
would occur in areas that already have heavy OHV use, so the impacts were expected to be minimal. Indirect
impacts, such as soil erosion and dust generation, from increasing visitor use are also expected from facilities
expansion. No impacts are expected in the areas closed to OHVs. For this reason, the number of acres open
to OHV use, allowed by permit only and closed to OHV use are important indicators of the amount of
expected impacts. While alternative 2 and 4 have the same number of acres in these categories, there would
be more facilities built, more expected use and hence more expected impacts with alternative 4. The
following tables provide these indicators for each alternative.
Alt. 1
Habitat
C. B Scrub
P. Scrub
Woodland
Alt. 2 & 4
Closed aand
Open
3,144 48,687
15,983 91,702
7,075 57,831
Alt. 3
Habitat
C. B Scrub
P. Scrub
Woodland
Habitat
C. B. Scrub
P. Scrub
Woodland
Closed
Closed
3,144
15,983
7,075
Permit
30,019
24,726
37,749
Open
34,678 17,153
47,705 59,980
47,927 16,979
Special-Status Plants
Potential impacts to special-status plants as a result of OHV use are expected to occur under each
alternative. Special-status plants that are expected to be impacted are: Peirson’s milk-vetch, Algodones
dunes sunflower, Wiggins’ croton, giant Spanish needle, and sand food. Each of these species is dependent
on psammophytic scrub habitat. Under Alternative 1, about 85 percent of this habitat would be open to OHV
use. Under alternatives 2 and 4, 63 percent would be open to OHV use, but the impacts are expected to be
lower in alternative 2 because some of the open area would be adaptively managed. Alternative 3 would
protect the more of this habitat, allowing only access to only 56 percent of the area; however, degradation
within the areas OHVs are allowed is expected to be greater because of more intensive use.
Open
18,668
66,976
20,082
Special-Status and Endemic Wildlife
As with habitat types and special-status plants, potential impacts to special-status and endemic wildlife are
expected under each Alternative. “Primary impacts to special-status and endemic wildlife include direct
mortality from recreational vehicles. Secondary impacts include destruction of forage and habitat; crushing
of burrows; attraction of predators due to improper disposal of food and litter; harassment and illegal
collection of wildlife; harassment by unleashed pets; dust, noise, lights associated with OHV and camping
activities; and increased potential for invasion of non-native plants” (BLM, 252)
OHV use is generally concentrated within the psammophytic scrub and some special-status wildlife species
like the Colorado Desert fringe-toed lizard, the flat-tailed horned lizard and endemic dune beetles would be
killed or injured by OHVs. Also, OHV routes through microphyll woodland habitat and open desert wash
areas are expected to impact the desert tortoise by running them over or crushing their burrows. OHVs may
also affect Couch's spadefoot toad habitat by disrupting small ephemeral pools on which this species
depends. Couch's spadefoot toad often group up during breeding season, placing them in greater risk if
there is high OHV use.
Measurement and Reporting of Impacts
Interestingly, no measurements other than OHV use in habitats are provided for the impacts on biodiversity.
No population numbers, expected deaths, quantifiable indicators of disturbance or expected injuries are
discussed. Perhaps this data was unavailable, but it seems as though this would be necessary information
for assessing impacts to special-status species. It is noted throughout the document, however, that specialstatus species “were considered in detail” and that the USFWS was consulted about these species (BLM,
255).
Mitigation
Mitigation for impacts to biodiversity is not expressly discussed in this EIS. In fact, this is the only sentence
under the mitigation measures section for biological resources: “No additional mitigation measures are
required beyond those management actions incorporated into the action alternatives” (BLM, 259).
Within the action alternatives, reductions in impacts from the baseline are often touted as positive qualities
of the various options. The document repeatedly emphasizes the expected effectiveness of the adaptive
management area, making statements such as “impacts to special-status and endemic wildlife within the
Adaptive Management Area and limited use area surrounding ISDRA are expected to substantially
decrease” (BLM, 255).
Restricting and prohibiting OHV use is also discussed as a method to reduce impacts, but no mitigation
measures for OHV impacts on biodiversity in open areas are discussed. I would expect mitigation measures
could include special-status species awareness and education campaigns for OHV users or improved
signage in critical habitat areas, but no options were covered in the EIS at all. Also, increased law
enforcement and the construction of law enforcement facilities in the ISDRA are proposed in the EIS, but
this is completely disconnected from biodiversity protection despite the recognition that many of the
expected impacts are related to unlawful activities.
References
United States. Department of the Interior, Bureau of Land Management, El Centro Field Office. Final
Environmental Impact Statement for the Imperial Sand Dunes Recreation Area Management Plan and
Proposed Amendment to the California Desert Conservation Plan 1980. Washington: GPO, 2003.
CRP 5540 – CORNELL UNIVERSITY
Andrew Bruce
MRP, 2010
341 Ferguson Rd Apt 2A
Freeville, NY 13068
Anb55@cornell.edu
P: 303-859-2370
M: 555-555-5555
F: 555-555-5555