DRAFT: Spring Oceano Dunes Dust Mitigation Plan

STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY EDMUND G. BROWN JR.
, G OVERNOR
CALIFORNIA COASTAL COMMISSION

CENTRAL COAST DISTRICT OFFICE
725 FRONT STREET, SUITE 300
SANTA CRUZ, CA 95060
PHONE: (831) 427-4863
FAX: (831) 427-4877
WEB: WWW.COASTAL.CA.GOV
W18a
CDP 3-12-050 (ODSVRA DUST CONTROL)
CONDITION COMPLIANCE
FEBRUARY 7, 2018
EXHIBITS
Table of Contents
Exhibit 1: Project Location Maps

Exhibit 2: ODSVRA Aerial Photos
Exhibit 3: CDP 3-12-050 Adopted Summary of Commission Action
Exhibit 4: CDP 3-12-050 Conditions
Exhibit 5: DPR’s Proposed 2018 Annual Work Plan
Exhibit 6: APCD and CARB Concurrence with DPR’s Proposed 2018 Annual Work Plan
ODSVRA Location Maps
Exhibit 1 (Project Location Maps)

CDP 3-12-050 (ODSVRA Dust Control) Condition Compliance
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Pier Avenue Access
Interim Staging Area
La Grande Tract
Post Markers
Open Riding Area
Seasonal Exclosure Area

(Southern Exclosure)
Oso Flaco Access

(pedestrian only)
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Open Riding Area Fence/Boundary
Seasonal Exclosure Area Boundary
Park Boundary

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Interim Staging Area
Sand Highway
Seasonal Exclosure Area Boundary

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Open Riding Area
Approximate La Grande Tract Area
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Aerial Near Pier Avenue Access and
community of Oceano
Exhibit 2 (ODSVRA Aerial Photos)

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Image 2407. Copyright © 2002 Kenneth & Gabrielle Adelman. California Coastal Records Project. All rights reserved.
Aerial Near Interim Staging Area

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Aerial of Open Riding Area

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Aerial of the La Grande Tract

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Oso Flaco Lake Area

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SUMMARY OF COMMISSION ACTION
On September 14, 2017, the Commission approved with conditions the California Department of
Parks and Recreation’s (DPR) five-year program (Program) to implement a series of measures
aimed at controlling and minimizing particulate matter (or “dust”) emissions associated with
Oceano Dunes State Vehicular Recreation Area (ODSVRA, or Park). Such emissions have been
and are currently impairing air quality in downwind communities, including in some cases
through exceedances of State and Federal particulate matter emission standards. The Program is
meant to implement measures designed to comply with San Luis Obispo County Air Pollution
Control District (APCD) air quality requirements, including Rule 1001, which was adopted by
APCD in 2011 and requires DPR to minimize particulate matter emissions for ODSVRA. By
design, the approved Program represents a programmatic approach that broadly identifies a list
of potential measures that may be used to control dust emissions, whereas the final decision as to
the actual types and amounts of dust control measures to be used will be selected by DPR, in
consultation with the California Air Resources Board (CARB) and APCD, with authority of the
Executive Director to review and approve an Annual Work Plan and authority of the
Commission to concur with or modify the Executive Director’s determination. Broadly, these
measures are generally aimed at stabilizing dune structure and restoring dune surface properties
in a manner that can help to reduce potential dust emissions. Approved measures include
planting approximately 20 acres of native dune vegetation per year, both within and outside of
areas used for Off-Highway Vehicle (OHV) riding (for a total of approximately 100 acres of
dune vegetation by the end of year five); deploying approximately 40 acres of seasonal dust
control measures (e.g., wind fencing) during the windy season (i.e., roughly from March to
September each year) within the OHV riding area; and installing and operating monitoring
equipment to evaluate dust abatement effectiveness. In addition, the Program includes additional
related measures, including potentially planting trees on private property inland of ODSVRA
boundaries, and installing grooved concrete ‘track-out’ devices 1 to reduce inland sand transport
at the two vehicular Park entrances at West Grand Avenue and Pier Avenue. And finally, the
approved Program also authorizes dust control measures that were permitted under prior years’
emergency CDPs, including the installation of air quality monitoring equipment and the
restoration of dune areas used for dust abatement purposes. Again, DPR identifies the approved
Program measures as potential options, acknowledging that the actual measures employed would
be developed in conjunction with ACPD and CARB, including to meet Rule 1001 compliance
and objectives.
The Coastal Act states that air quality protection programs are the principal responsibility of
local air pollution control districts (APCD in this case) and CARB, and requires that
Commission actions be consistent with these entities’ air pollution control programs and
requirements. 2 That said, while the Act states that the Commission cannot establish or modify air
quality or emission standards, the Commission must still review development required to
implement air pollution control programs and requirements to ensure the development is
1
Track-out devices refer to grates and grooves and similar apparatuses designed to shake loose sand from vehicles
before it is taken further inland where it can contribute to potential dust problems.
2
Coastal Act Sections 30414 and 30253(c).
Exhibit 3 (CDP 3-12-050 Adopted Summary of Commission Action)

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consistent with Coastal Act requirements, including with respect to the protection of
environmentally sensitive habitat areas (ESHA), public views, public recreational access, and
other coastal resources. In other words, the Coastal Act does not provide an ‘override’ of Coastal
Act requirements on the basis of air quality protection, and the Commission must still evaluate
such proposed development for consistency with the Coastal Act.
In this case, DPR’s proposed project emanates from, is meant to implement, and is proposed
pursuant to APCD’s dust emission reduction programs, including Rule 1001. Therefore, a key
analytic question under the Coastal Act is whether DPR’s proposed Program is consistent with
APCD’s (and CARB’s) air pollution control programs and requirements, particularly Rule 1001,
or whether changes are necessary to ensure consistency and compliance with their programs and
requirements as the Coastal Act requires. In addition, the other key analytic question is whether
DPR’s proposed project, as well as any modifications necessary to ensure its consistency with
APCD/CARB programs and requirements, is consistent with Coastal Act policies, particularly
whether the methods to be used to abate dust comport with policies protecting and regulating
dunes and their associated habitats, which in this location are considered to be ESHA under both
the Coastal Act and the San Luis Obispo County LCP due to their rarity and especially valuable
ecosystem/habitat function, and with Coastal Act public access and recreation policies.
With respect to the former question, in terms of the proposed Program’s consistency with
applicable air quality protection programs and requirements, both APCD and CARB have
reviewed DPR’s proposed project and have written letters formally stating their evaluation on the
adequacy/efficacy of DPR’s proposed project to reduce particulate matter emissions in
accordance with applicable air quality protection requirements/programs, including Rule 1001
(see Exhibits 8 and 9). Notably, while both CARB and APCD agree that DPR’s proposed
programmatic approach appears to be generally broad enough to allow for an appropriate suite of
potential measures to control and reduce dust/particulate matter, APCD has expressed concerns
with some of the Program’s detailed parameters. Specifically, while DPR’s proposed project
limits dust control measures to a defined program area boundary, specifies limits on the amounts
of dust mitigation to be undertaken in any given year, and allows for dune vegetation planting to
be located in areas not used for OHV riding, APCD has expressed concerns about all of these
provisions. As more fully explained in this report, APCD is concerned that these provisions may
unnecessarily restrict the type, amount, and location of dust control abatement which may be
found, via further scientific study through ongoing air quality modeling being undertaken jointly
by CARB, APCD, and DPR, to be needed to sufficiently abate dust emissions. As such, to allow
for the measures that may be needed for consistency with applicable air quality requirements,
APCD indicates that DPR’s dust control Program needs to be modified to: ensure that dust
control measures are allowed in any areas shown to be highly emissive, and that specific
mitigation measures be based on scientific evidence and modeling, and not just within pre-
prescribed boundaries and limits; ensure that dune vegetation is planted within areas used for
OHV use due to these areas’ greater emissivity relative to non-riding areas; and ensure that
perimeter fencing around highly emissive areas is also a potential tool that could be used for dust
abatement.
With these changes, APCD indicates that the Program would be sufficiently encompassing to
allow the broad range of dust abatement measures that may be necessary to meet applicable air

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quality requirements, with the specific type, amount, and location of measures to be ultimately
determined collaboratively among DPR, APCD, and CARB based on scientifically defensible air
quality modeling. The Program would continue to be undertaken in an adaptive management
framework where such measures are evaluated and modified for maximum dust abatement
efficacy. APCD indicates that the Program would allow for the measures necessary to be
consistent with applicable air quality requirements if it is modified in these ways. As such, and
pursuant to Coastal Act Section 30253(c), the Commission adopted conditions authorizing that
the suite of potential dust control measures be expanded as outlined by APCD, including that the
specific areas where these measures are applied be focused on the proposed Program area, but
that they can be applied wherever it makes the most sense for addressing APCD and CARB
requirements based on the ongoing collaboration between DPR, APCD, and CARB. This CDP
therefore authorizes the additional measures, locations, and amounts identified by APCD, but it
in no way requires DPR to implement such additional measures, as the specific measures to be
undertaken will be developed by DPR in conjunction with CARB and APCD. The CDP simply
ensures that the proposed project will be consistent with Section 30253(c) by authorizing the
type, amount, and location of dust abatement measures that may be needed to be consistent with
applicable air quality requirements and that are otherwise consistent with the Coastal Act. In
addition, the Commission required the annual work program, intended to identify the specific
measures to be applied for any particular year as proposed by DPR, to be submitted to the
Executive Director for review and approval, including with evidence that APCD and CARB have
reviewed the measures and consider them consistent with their requirements, if any, 3 related to
dust control at ODSVRA. As revised by the Commission at the September 14, 2017 hearing on
this matter, Special Condition 2 then requires the Annual Work Plan to be presented to the
Commission at a noticed public hearing for its concurrence as to the Executive Director’s
determination. If the Commission does not concur with the Executive Director’s determination,
the Commission shall have the authority to modify any portion of the Annual Work Plan to
ensure for that year effective implementation of dust control and monitoring measures consistent
with this CDP and with APCD and CARB requirements. This further ensures that the work
program will be consistent with Section 30253(c). The Commission also included a condition to
allow for the Commission to extend the program past the initial five years if there are no changed
circumstances that the Commission determines would require the proposal to be heard as a new
CDP or CDP amendment.
With respect to the Program’s consistency with other Coastal Act requirements, the project
(including as modified to meet applicable APCD requirements as required by the Coastal Act) at
its core is a comprehensive Program that seeks to stabilize dune structure, and protect and restore
dune surface properties so as to help reduce emissions, including within more emissive/disturbed
areas currently used for OHV riding activity. The project is thus inherently an allowed use within
dune ESHA and is designed not to significantly disrupt habitat values. Thus, as conditioned, the
project is consistent with Coastal Act habitat protection policies.
At the same time, it appears likely that the Program will lead to a decrease in areas available for
OHV recreation, some seasonally and some more permanent. Although this raises some Coastal
3
If APCD or CARB have not imposed any “requirements” related to specific dust control measures, then the
condition would not create such requirements.

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Act public recreational access concerns, the Commission found it is appropriate and Coastal Act
consistent in this case, including as the Act explicitly requires that its public access provisions
“be implemented in a manner that takes into account the need to regulate the time, place and
manner of public access” depending on, among other things, “the capacity of the site to sustain
use and at what level of intensity,” and the need to potentially limit access “depending on such
factors as the fragility of the natural resources in the area.” 4 In this case, it is appropriate to
implement measures that have the effect of limiting the ‘time, place, and manner’ of OHV use
associated with the fragile dunes in question to stabilize their structure, restore their surface
properties, and address applicable air quality requirements. In addition, while the Program may
result in limiting some areas currently open to OHV and camping recreational uses, significant
public recreational access representing several thousand acres will still be available at ODSVRA,
including some two square miles of dune and some three linear miles of beach available for
OHV riding. Thus, for all these reasons, the project will not result in significant adverse impacts
to public access and is consistent with these other Coastal Act policies.
As conditioned, DPR’s approach to restore dune surface properties, minimize dust emissions,
and meet applicable air quality requirements by, among other means, ensuring dune revegetation
is located within emissive areas subject to OHV activity, and by ensuring that all measures are
scientifically defensible and designed to comply with applicable APCD and CARB requirements,
can be found consistent with the Coastal Act. Again, the approval authorizes a broad program for
dust abatement and dune protection, with the specific measures to be deployed ultimately
determined through partnership and coordination among DPR, CARB, and APCD, submitted to
the Executive Director for review and approval, and ultimately approved by the Commission to
ensure their consistency with this CDP.
Commission staff has worked extensively and cooperatively with DPR, APCD, CARB, and
many interested members of the public over many years to address air quality in a manner that
responds to the various needs, goals, and interests of the many parties involved. The Program, as
modified, will allow for the flexibility and adaptability needed to abate what APCD has deemed
a significant and ongoing public health threat, while also ensuring the protection of sensitive
dune resources. As conditioned, the dust control Program is consistent with the Coastal Act, and
the Commission approved the CDP.
4
Coastal Act Section 30214.

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Exhibit 4 (CDP 3-12-050 Conditions)
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Oceano Dunes State Vehicular Recreation Area
Proposed 2018 Dust Control Activities
January 19, 2018

The California Department of Parks and Recreation, Oceano Dunes District proposes to implement a
number of dust control efforts from January – October 2018 including:
1. Install Vegetation in approximately 18‐20 acres of open sand as identified in Figure 3. Note this
project was reviewed by the California Coastal Commission staff in December 2017 and it was
determined that this project could be completed pursuant to Condition #4 of CDP 4‐82‐300.
2. Install wind fencing in approximately 40 acres of open sand as identified in Figure 3. This
component would require approval from the California Coastal Commission under CDP 3‐12‐050
3. Install an experimental exclosure of 2‐3 acres to test the effectiveness of a vehicle closure in
reducing sand transport. This component would require approval under CDP 3‐12‐050
4. Install an array of sand flux, meteorological, and air quality monitoring equipment to test the
effectiveness of dust reduction strategies during the 2018 windy season and per Figure 3. This
component would require approval under CDP 3‐12‐050
5. Install Operational Mitigation Measures that would be emplaced in targeted areas of Oceano
Dunes SVRA. The precise location and placement of the Operational Mitigation Measures have
not been determined, but would be installed in locations and in a configuration that does not
restrict public access or require the closure of any area to public access and all forms of public
recreation. The Operational Mitigation Measures would not be subject to review by the
California Coastal Commission because they are within the Department’s operational authority
under the Public Resource Code or are consistent with existing permits, including CDP 4‐82‐300
as amended.
All of these projects have been developed in consultation with the California Air Resources Board and
the San Luis Obispo Air Pollution Control District and meet their regulatory requirements related to
Oceano Dunes SVRA.
Please refer to the Oceano Dunes Dust Control Project 2018 for a full description of the proposed
project and an analysis of information from previous dust control efforts.
Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

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Dust Control Projects ODSVRA, 2018 (DRAFT)
J.A. Gillies, V. Etyemezian, G. Nikolich
Division of Atmospheric Sciences, Desert Research Institute, Reno and Las Vegas, NV
Draft date: 01/19/2018
Introduction
Since 2014 California State Parks has installed control measures including sand fence and roughness
arrays to temporarily reduce, and planted vegetation in critical areas to eliminate, sand transport and
the associated dust emissions in areas of the Oceano Dunes State Vehicular Recreation Area (ODSVRA)
State Park. These control measures are emplaced to try and reduce the amount of particulate matter
≤10 µm aerodynamic diameter (PM10) originating from within the ODSVRA due to wind erosion that is
part of the overall PM10 burden measured at air quality monitors operated by the San Luis Obispo Co. Air
Pollution Control District (SLOCAPCD). The air quality management objectives that the mitigation
measures are trying to achieve are SLOCAPCD’s Rule Dust Rule 1001 and to reduce contributions of PM10
originating from within the ODSVRA to try and keep the 24-hour mean PM10 measurement below the
federal (150 µg m-3) and state (50 µg m-3) standards.
Arrays of sand fences of varying size (15 to 40 acres) have been installed each year within the ODSVRA
beginning in 2014. In 2014, 4 foot-high plastic sand fences of ≈50% porosity were emplaced into ≈30
acres of dunes. They were oriented approximately perpendicular to the prevailing direction of high wind
and spaced 10 fence heights apart (10h). In 2015 the same type of fencing was emplaced in ≈37 acres,
but the spacing was reduced to 7 fence heights apart (7h). Gillies et al. (2017) report on the
effectiveness of these arrays of porous fences to reduce sand flux and dust emissions. Measurements of
sand flux through the arrays indicated that it diminishes exponentially with increasing distance, reaching
equilibrium at ≈93 fence heights for the 10h spacing and ≈27 fence heights for the 7h spacing. Fences
spaced 7h apart reduced sand flux for the entire area by 78%, and 86% for the area that was a distance
of >27 h from the leading fence. Fences spaced at 10 h reduced sand flux for the entire area by 40%, and
56% for the area >93h downwind from the leading fence. PM10 monitoring upwind and downwind of
the array and in the absence of the array in 2015, indicated that the downwind PM10 concentration was
less than the upwind for the fence array, whereas in the absence of fences PM10 increased in the
downwind direction over the same fetch distance, suggesting the presence of the fences was reducing
the flux of PM10 from within the fence array. A reasonable estimate of the reduction in dust emissions
attributable to the fence arrays is that is equivalent to the reduction achieved in the sand flux, as for
sandy soils it has been observed that the ratio of dust flux to sand flux is relatively stable and
independent of wind speed (Gillette., 1999).
Information from the 2014 and 2015 studies (Gillies et al., 2016; 2017) was used to guide the dust
control approach for 2016. In spring 2016 an array of sand fences was re-established within the ODSVRA
with the fence-to-fence distance set at 7h that covered 40 acres. In 2016 the target for sand flux
reduction was expected to be close to that observed in 2015 (i.e., 73% [±22%] lower compared to sand
flux external to the array for entire array) as the fence spacing was the same. The 2016 sand flux data

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indicated that the sand transport reduction for the entire surface area defined by the perimeter of the
array was 73% (±80%), which is the same as the 2015 percent reduction in sand flux, but with a much
higher variability. There was also good evidence from the PM10 measurements that the dust plume
travelling over the array again showed quantifiable reductions in PM10 concentrations due to the
controls (Fig. 1). Based on the reported effectiveness of the 7h sand fence array to reduce sand
transport to levels >70% after the adjustment of sand flux to the presence of the fences, a sand fence
array was emplaced within the ODSVRA in 2017 at a different location than in previous years. The 2017
location was demarcated based on information gained from the dispersion modeling carried out by the
California Air Resources Board in 2016/2017 that identified the relative contributions of specified areas
of the ODSVRA to the PM10 measured at the CDF SLOCAPCD monitoring site. In 2017 the sand fence
array was emplaced within an area that the dispersion model suggested had a greater probability of
contributing PM10 at the CDF site than the areas targeted in previous years.
A brief overview of the data collected in 2017 to characterize the sand flux as modulated by the
presence of the sand fence array is provided below. The 2017 sand flux data indicate that the sand
transport reduction for the entire surface area defined by the perimeter of the array, when sand flux
measured upwind of the array resulted in sand catches in the single-height BSNE traps ≥10 g was 45%
(±100%), which characterized days with the highest sand flux rates. The mean normalized sand flux (i.e.,
NSF=sand flux interior the array/sand flux exterior to the array) plotted as a function of distance from
the front of the array shows that there were two positions that recorded NSF values that were much
greater than the flux exterior to the array (Fig. 2). The two positions represent ≈12% of the total.
Removing these two positions, the mean NSF becomes 0.24 (±0.25), which is a reduction in sand flux of
76% (25%) over 89% of the sand fence array, which matches quite closely the results of 2015 and 2016
for sand fence arrays spaced at 7h. A second set of multi-height BSNE traps (Gillies et al., 2013; Gillies et
al., 2018) were also set into the fence array in 2017 to provide a second measure of sand flux reduction
and to examine how the sand flux changes as a function of height above the sand surface. The multi-
height trap data for days in which the mass of the single height BSNE measurement was ≥10 g show a
similar pattern of changing flux with distance through the array, with a notable increase in flux at ≈110
m into the array (Fig. 2). The mean NSF for the all the multi-height BSNE traps was 0.46 (±0.48).
Removing the high NSF at the 110 m position changes the mean NSF to 0.29 (±0.10), which is a mean
sand flux reduction of ≈70% (±10%), which closely matches mean sand flux reduction value based on the
single height BSNE traps.
Another difference in the 2017 NSF data set compared to 2015 and 2016, is that there is a suggestion of
a trend of decreasing sand flux reduction with increasing distance into the array. This may be due to the
increasing elevation of the surface towards the downwind edge of the array, which is likely causing an
increase in wind speed that increases the sand flux. As the wind streamlines are compressed as the flow
moves over the array towards the east, wind speed would increase. This can be evaluated further using
the 2017 E-BAM data that is not yet available.
The objective to demonstrate that these control measures can reduce the PM10 at downwind monitoring
sites to the desired air quality standards has not been unambiguously demonstrated at this time. The
SLOCAPCD 2016 Annual Air Quality Report, based on their analyses of PM10, wind speed and wind

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3000 1800
1600
2500 Downwind E-BAM E-BAMD = 0.008 WS4.99 R2=0.98
1400 Upwind E-BAM E-BAMU = 0.027 WS4.45 R2=0.95
Down-wind E-BAM E-BAMD= 0.011 WS4.80 R2=0.99
Up-Wind E-BAM E-BAMU = 0.018 WS4.91 R2=0.99
PM10 (µg m-3)
2000 1200
PM10 (µg m-3)

1000
1500
800
1000 600
400
500
200
0 0
0 2 4 6 8 10 12 14 0 2 4 6 8 10 12 14
Wind Speed Bin (m s-1) Wind Speed Bin (m s-1)
Figure 1. Mean hourly PM10 (µg m-3) concentration plotted as a function of mean hourly wind speed (m
s-1) for upwind PM10 measurements (brown squares) and immediate downwind measurements past the
sand fence array (gold diamonds) (left panel). Upwind PM10 measurements (gold triangles) and
downwind measurements (brown circles) across approximately the same horizontal distance in the
absence of fences (right panel). In all cases the data have been filtered for wind direction range 230°-
310°), May through September, 2016. Best fit regression lines are for wind speed ≥5.5 m s-1 and the
error bars represent the standard deviation of the mean for the data that fall into the 1 m s-1 wind speed
bins.
8
Single-H BSNE
Multi-H BSNE
7
Normalized Sand Flux, NSF
0
0 20 40 60 80 100 120 140 160
Horizontal Distance (m)
Figure 2. The normalized sand flux as a function of distance through the sand fence array for 2017
based on the measurement of sand using single-height and multi-height BSNE traps. Error bars
represent the standard deviation of the mean based on multiple samples.

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direction data measured at the CDF monitoring site does suggest that the 2016 dust control projects
were “indeed somewhat effective in reducing PM10 at CDF”, which is based on analysis using their filter
days methodology, but they do not endorse this as being a definitive demonstration of an observable
downwind effect. To achieve a demonstrable effect on downwind PM10 concentrations in the vicinity of
the Nipomo Mesa may require an increase in the size of the area placed under control and a further
optimization of the placement of the controls with respect to the areas of emission that have the
highest probability, based on modeling, to be contributing to the PM10 burden downwind of the
ODSVRA.
In 2018 California State Parks plans to initiate another combination of 1) a temporary dust control
project within the ODSVRA using an array of sand fences placed 7h apart for two areas, one ≈30 acres
and the other ≈10 acres (Fig. 3), 2) a vegetation planting project that will place plants in two areas
totaling ≈18 acres (Fig. 3), and 3) an Operational Mitigation (OM) project that would use a combination
of administrative controls on the camping area to achieve dust control. The objective being to reduce
emissions that impact the downwind areas that experience high dust concentrations as a result of
windblown emissions from the ODSVRA.
Metrics for gauging how well the 2018 control areas reduce PM10 at the scale of the control measures
will be evaluated based on the amount of sand flux reduction that is observed between the uncontrolled
upwind side and that observed within the area controlled. As a measure of the effect of the control
measures on PM10 in their immediate vicinity, measurement of PM10 will be made on their upwind and
downwind edges to evaluate change associated with the presence of the controls. A second pair of
PM10 measurements will be made over a similar length of dune area in the absence of controls for
comparison. In addition, a network of seven PM10 samplers will be operated, as they were in 2017, to
measure PM10 in the ODSVRA, near the eastern park boundary, in the Conoco-Philips property upwind
of the CDF site and at the CDF site. This network will provide insights into the spatial and temporal
patterns of PM10 during wind dust emission events in 2018 that can be compared and contrasted with
the patterns observed in 2017 that had a different amount and configurations of dust control measures.
To determine if there is an observable effect on PM10 due to the presence of the controls downwind of
the ODSVRA, and at the kilometer scale of resolution, the number of exceedances of the 24-hour PM10
standard at the CDF monitoring site will be monitored and compared to previous years taking into
account how the meteorology in 2018 compares to other available years. In addition, SLOCAPCD will
carry out their filter day analysis method (SLOCAPCD, 2017) that evaluates the effect of the control
measures on PM10 concentrations at CDF for specific ranges of wind speed, wind direction and durations
of time for these conditions to last at a measurement position within the ODSVRA (i.e., the S1 tower)
and at CDF. This method also requires that the data used have been validated by the APCD. The CDF
site exhibits some of the highest concentrations of PM10 on the Nipomo mesa during windy periods and
serves as an important indicator of the general air quality of the region.
In addition to using sand fences and vegetation to control sand movement, in 2018, a new strategy
termed Operational Mitigations (OM) developed jointly by Parks and SLOCAPCD leadership will be
evaluated as a dust control measure. OM will involve emplacing single (or multiple) rows of sand

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fencing in a strategic arrangement in areas where Park users prefer to camp. It is expected that the
fencing and the camping accommodations will combine to provide a demonstrable reduction in sand
flux and the accompanying dust emissions from areas that have been identified as being of high
emission potential.
Dust Control Plan for 2018

For 2018 we propose that an array of sand fences with 7 fence height (7h) separation be established
within the ODSVRA in the areas shown in Fig. 3. The areas selected for control are based on the
available dispersion modeling carried out by the ARB, which attributes areas within the defined dust
control areas as being significant sources of dust that contribute to the PM10 measured at CDF. As best
as construction allows the bottom of the sand fence should initially be (a few inches) below the level of
the sand surface to avoid flow acceleration under it, which reduces its effectiveness. If gaps in a row are
required due to topography affecting placement of the fencing, the gap should be spanned with fencing
placed downwind immediately as surface conditions allow, thus restricting fetch length between two
sequential rows to the highest degree possible.
Sand Fence Array Location and Dimensions
Based on previous results that define sand fence effectiveness to reduce sand transport and the
associated dust emissions it is recommended that the size of the sand fence array as shown in Fig. 3 be
as large as is logistically feasible, with the assumption being that a larger size is better for two reasons:
1) more surface area in the ODSVRA is controlled, and 2) for larger areas the edge effect is reduced.
Recall that sand fence effectiveness at the upwind part of the array requires a distance of ≈27 h, when
sand fences are spaced at 7h, to become fully adjusted to the presence of the fences. The larger the
array, the smaller is the ratio of edge to equilibrium control area (Gillies et al., 2015). The same
argument holds for horizontal gaps in the fences due to topographic constraints, these need to be a
small as possible as they are less effective in reducing sand transport. To minimize edge effects, and the
lower sand flux reduction associated with the equilibrium flux area, the shape of the array should be
maintained to be as rectangular as possible.
Monitoring Effectiveness to Control Sand Flux in the Control Areas in 2018
In 2018 we recommend the monitoring of sand flux interior and exterior to the areas with controls
applied using the 1-height self-orienting BSNE traps (Fryrear, 1986) for the sand fence array and
vegetation areas, and the multi-height BSNE traps only in the sand fence array due to their limited
number. If resources permit data collection should occur after each (assumed) daily transport event. All
sand flux measuring instruments should be put in place as soon as possible after installation of the
controls.
We recommend that for each area that receives controls, the BSNE traps be positioned through the
array to determine the sand flux reduction levels as a function of distance through the controlled area.
In each prior year of controls multiple measurements have been useful for defining the zone in which
the sand flux adjusts to the presence of the roughness and the mean sand flux reduction in the zone
where flux is adjusted to the presence of the roughness. In 2017, a new pattern of flux adjustment was

Page 6 of 25
Figure 3. The proposed locations for the sand fence array (orange polygons with orange lines) and the
two areas for vegetation planting (green stippled areas) in 2018. The underlying colors (blue to rose)
identify the degree of fractional attribution of PM10 from a cell to the PM10 receptor at CDF.

Page 7 of 25
observed, with one part of the array showing a noticeable increase in sand flux compared to the flux
measured upwind and external to the array and the suggestion of a trend of increasing flux with
increasing distance into the array at a distance >100 m. The flux increase at this position in the array
(Fig. 2) we suspect is due to topographic forcing that has accelerated the wind speed.
If resources permit, we recommend that Parks make use of un-manned aerial vehicle (UAV) technology
to repeatedly map the surface relief of the fence array using Light Detection and Ranging (lidar)
techniques as attempts to use the photogrammetric technique in 2017 were found to be of limited use
probably due to the weak color contrast across the dune surface. The acquisition of highly-resolved
digital elevation models (DEM) of the control area made at the time of installation and during the period
of emplacement will provide data to evaluate the total sand trapping potential of the array and provide
information on the sedimentation processes that result from the fence position. Repeated mapping of
the surface will allow for the determination of the patterns of erosion and deposition through the fence
array. These can be linked with the sand trap measurements to provide a better understanding of the
modulation of the sand flux by the fence array. These data are needed to guide engineering
considerations to improve fence array performance as well as provide data to inform models that
predict how porous fences affect airflow and sediment transport. Data from 2015 and 2016 suggest
that sand transport and sand transport variability are greatest between consecutive fences at a distance
of 3h behind the forward fence, which coincides with the transition at the surface from a zone of low
turbulence to higher turbulence in McAneney and Judd’s (1991) equilibrium flow model. Woodruff and
Zingg (1955) observed a zone of maximum velocity fluctuations between successive fences at the 6h
position, which doesn’t match our observations. Neither McAneney and Judd (1991) nor Woodruff and
Zingg (1955) measured sand transport.
In addition to these BSNE measurements, we propose to deploy 2 DRI-developed SANTRI™ saltation
sensors that resolve sand flux using optical gate sensors (Etyemezian et al., 2017) at 1 Hz resolution and
also resolve which direction the sand is coming from. We propose these stand-alone units be deployed
between successive fences deep in the array to provide new information on the directional variability of
sand flux with respect to the measured wind direction upwind and downwind of the array.
Sand Fence Array and Planted Vegetation Effect on Local PM10
E-BAMs to measure PM10 should be positioned upwind and immediately downwind of the locations
where controls are placed, and mounted so their collection orifices are all at the same height above the
surface. The E-BAMs should be, as near as possible, along the center line of the controlled areas. The
relationship shown in Fig. 1, suggests that PM10 immediately downwind of the fence array was ≈47%
lower than measured at the upwind position. It is recommended that the E-BAMs be emplaced into
their positions before the fences are installed, which would provide an opportunity to acquire
measurements of the PM10 gradient across the space without controls, which could subsequently be
compared to that gradient in the presence of the controls.
We also recommend that two E-BAMs be used in 2018 to measure the change in PM10 across a
horizontal distance approximately equivalent to the length of the fence array in the absence of the
fences. This will provide additional information how the presence of the fences affects the gradient of
PM10 and the emission of PM10 from within the controlled area. In the absence of fencing over a similar

Page 8 of 25
horizontal distance the downwind measurement of PM10 is 22% higher than the upwind measurement.
Upwind and immediate downwind monitoring of PM10 should also be carried out at both of the
vegetation planting locations.
We recommend that the E-BAMs to be deployed within the ODSVRA be collocated with a BAM,
preferably at the CDF site before and after the temporary controls are emplaced in 2018.
Additional PM10 Monitoring within and exterior to the ODSVRA
We also propose that the Met One monitoring network be re-established in 2018. The data collected by
the network in 2016 and 2017 was of very high quality and will be quite helpful when data are needed
for comparison to model results. We propose that the network be replicated in 2018 for complete
spatial compatibility with the 2016 and 2017 network (Fig. 4), with the addition of a monitoring location
added at the downwind edge of the 30 acre fenced area co-located with the E-BAM. Ideally, the
network would be emplaced early in the dust season so that a longer record of data would be available.
We recommend that all the monitors of the network be collocated with one another for a comparison
prior to installation and at the end of the sampling season as was done in 2017. This colocation should
again be carried out under controlled, indoor conditions at DRI’s Southern Nevada Science Center facility
in Las Vegas, NV, where we can be assured of a homogeneous aerosol concentration over a wide range
and under relative humidity (RH) conditions similar to those that exist during windy season dust
emissions events (≈70%).
As the uncertainty in the attribution of an observable effect of the control measures on the PM10
concentration at CDF was high in 2016, care should be taken to have a much more complete data set on
wind speed, wind direction, and PM10 for the control areas as well as at positions at other strategic
locations within and exterior to the ODSVRA that are contemporaneous with the measurements at CDF.
This will increase our ability to look at the links between the emissions from the Park during saltation
and dust emission events.
Operational Mitigations (OM)
Operational Mitigations are based on the concept of incorporating sand fences to reduce sand flux into
camping areas used by Park visitors, with the objective being that the physical presences of the fences
and the camping vehicles will result in a sequestration of sand that becomes unavailable for driving dust
emissions further downwind. The concept is based on the use of sand fences to reduce sand flux in the
shelter zone of their lee and the camping units (tents, trailers, RVs) to act as roughness elements to aid
in reducing wind speed. This method can be considered as being in the first phase of development and
there is no a priori knowledge its effectiveness potential.
To evaluate the effectiveness of OM on an area of the ODSVRA, we suggest that the above mentioned
lidar technique be used to estimate if sand is being sequestered in the area by determining if there is a
net positive gain in surface elevation due to sand deposition following the lifetime of the OM. A lidar-
acquired DEM would be needed prior to the establishment of the OM followed by a second
measurement at the end of its temporary lifetime. This would require essentially excluding use of this
area for a period of time to acquire the post-OM DEM. A measure of effectiveness could be estimated

Page 9 of 25
• Windfence 2018
Figure 4. MetOne Particle Profiler stations 2016 & 17 marked as red circles. The stations positions
should be the same for 2018 and a new position is recommended that is downwind of the 30 acre fence
array (Fig. 3) shown as a purple circle.

Page 10 of 25
from the mass of sand per unit area added (or lost) from the designated control area. If a loss of
elevation was observed, this would suggest that OM had enhanced erosion, and dust emission. If there
was a net gain of elevation and sand mass, this would indicate that sand was trapped within the OM
area. The OM effectiveness, i.e., tons of sand added/acre, could be compared with the tons/acre added
within the sand fence array. If the sand fence array added 10 tons per acre and the OM resulted in an
addition of 5 tons/acre, the OM would be 50% less effective than the sand fence array at sequestering
sand. If the sand fence array was demonstrated to reduce sand flux by ≈70%, as in previous years, then
it could be inferred that, in this case, the OM reduced sand flux by 35%.
The ODSVRA Technical Team composed of personnel from Parks, DRI, SLOCAPCD, SLOCAPCD contractor,
and California Air Resources Board are working to define the OM configuration and establish a
measurement program to determine effectiveness for 2018. Installation of the OM will follow the
completion of the installation of the 40 acres of sand fencing and the exclosure pilot test area.
PI-SWERL® Measurements 2018

PI-SWERL (Etyemezian et al., 2007, 2014) has been used extensively at the ODSVRA to characterize
emission potential of the dust source areas. This has proved invaluable for generating a gridded
emissions data base that can be used in dispersion models to generate predictions of downwind PM10
concentrations at specified receptors, and identify source areas that preferentially impact receptor sites.
We propose to carry out measurements of dust emissions potential using PI-SWERLTM prior to the
installation of the sand fence array, one month after full installation, and just prior to removal. We
recommend, as has been done in previous years, that we measured emissions in the Plover exclosure
area before it is closed to riding, and again subsequent to the re-introduction of driving.
New Opportunities
Moisture effects on PI-SWERL Measurements
One uncertainty that remains regarding the PI-SWERL measurements and related data is how much
moisture affects the results of the measurement. Water is never too far beneath the surface of the sand
dunes, but under certain conditions, the sand is moist even at a depth of one centimeter. We propose
that a systematic evaluation of the effect of wetness be undertaken in DRI’s environmental chamber.
The intent would be to determine and separate the effect of ambient relative humidity from the effect
of moisture content in the sand on the PI-SWERL measurement. This would be used to establish clear
guidelines on when PI-SWERL testing should be conducted in the field and when it should be postponed
until the sand is drier or the ambient relative humidity is lower.
Fencing an area to examine the effect of vehicle exclusion on sand transport
If it is logistically feasible, it would be instructive to fence off a section of the ODSVRA to OHV activity
without emplacement of any other controls during the 2018 dusty season. At a minimum, the fenced
off area would encompass 2 to 3 acres (Fig. 5). Lidar scanning of the area at the beginning of the windy
season and near the end would provide significant insight into whether the absence of riding alone has
afforded any dust control. Optionally, 1) one or both SANTRI devices could be emplaced within the
10

Page 11 of 25
Figure 5. The proposed location of the OHV exclosure pilot test (red hexagon, not to scale of actual size
to be created) with respect to the proposed locations for the sand fence array (orange polygons with
orange lines) and the two areas for vegetation planting (green stippled areas) in 2018. The underlying
colors (blue to rose) identify the emissivity of PM10 from a cell based on the interpolation/extrapolation
of the 2013 PI-SWERL emission data.
11

Page 12 of 25
fenced off area for data collection, 2) use a transect of single height BSNE sand traps to measure the
sand flux from upwind (riding influenced) to the downwind edge of the exclosure. We also recommend
that PM10 emissivity measurements be made with the PI-SWERL immediately following the construction
of the exclosure and immediately prior to the exlosure being removed to determine if there has been
any measureable change in emissivity that could be attributed to the restriction of OHV riding.
References
Etyemezian, V., G. Nikolich, W. Nickling, J.S. King, J.A. Gillies (2017), Analysis of an optical gate device for
measuring aeolian sand transport, Aeolian Research, 24, 65-79, doi: 10.1016/j.aeolia.2016.11.005.
Etyemezian, V., J. A. Gillies, M. Shinoda, G. Nikolich, J. King, A. R. Bardis (2014), Accounting for surface
roughness on measurements conducted with PI-SWERL: Evaluation of a subjective visual approach
and a photogrammetric technique, Aeolian Research, 13, 35-50.
Etyemezian, V., G. Nikolich, S. Ahonen, M. Pitchford, M. Sweeney, J. Gillies, H. Kuhns (2007), The
Portable In-Situ Wind Erosion Laboratory (PI-SWERL): a new method to measure PM10 windblown
dust properties and potential for emissions, Atmospheric Environment, 41, 3789-3796.
Fryrear, D. W. (1986). A field dust sampler. Journal of Soil and Water Conservation 41, 117-120.
Gillette, D. A. (1999). A qualitative geophysical explanation for "hot spot" dust emitting source regions.
Contributions to Atmospheric Physics, 72 (1): 67-77.
Gillies, J.A., V. Etyemezian, G. Nikolich (2016). Analyses of Environmental Data Associated with the Sand
Fence Array ODSVRA, 2016. Report Submitted to California State Parks, ODSVRA, Pismo Beach,
CA.
Gillies, J.A., V. Etyemezian, G. Nikolich, W.G. Nickling, J. Kok (2018). Changes in the saltation flux
following a step-change in macro-roughness. Earth Surface Processes and Landforms (submitted).
Gillies, J.A., V. Etyemezian, G. Nikolich, R. Glick, P. Rowland, T. Pesce, M. Skinner (2017). Effectiveness of
an array of porous fences to reduce sand flux: Oceano Dunes, Oceano CA. Journal of Wind
Engineering and Industrial Aerodynamics, 168, 247-259, doi: 10.1016/j.weia.2017.06.015.
Gillies, J. A., W. G. Nickling, M. Tilson (2013), Frequency, magnitude, and characteristics of aeolian
sediment transport: McMurdo Dry Valleys, Antarctica, Journal of Geophysical Research: Earth
Surface, 118, 1-19, doi: 10.1029/2012JF002473.
Gillies, J. A., W. G. Nickling, M. Tilson, E. Furtak-Cole (2012), Wind-formed gravel bed forms, Wright
Valley, Antarctica, J. Geophys. Res.-Earth Surf., 117 (F04017), doi: 10.1029/2012JF002378.
McAneney, K. J., M. J. Judd (1991), Multiple windbreaks: An aeolean ensemble, Boundary-Layer
Meteorology, 54 (1-2), 129-146.
SLOCAPCD (2017). Annual Air Quality Report 2016. Air Pollution Control District San Luis Obispo
County, 3433 Roberto Court, San Luis, California, 93401.
Woodruff, N. P., A. W. Zingg (1955), A comparative analysis of wind-tunnel and atmospheric airflow
patterns about single and successive barriers, Trans. Am. Geophys. Union, 36 (2), 203-208.
12

Page 13 of 25
,BBQ
&
b ,Lagrande
&
b
,bWindfence
& 2018
b
b
,Windfence
&
, S1
& Wind Tower
,Haybale
&
,Phillips66
&
,CDF
&
0 1,000 2,000
Source: CDPR, Desert Research Institute, MIG, Inc
Feet
4,000
´ 01/23/2018
&
, S1 Wind Tower Existing vegetation fencing Nesting exclosure 2017
,
& Windfence 2018 Sand Highway, approximately Least tern buffer 2017
,
& MetOne Particle Profiler Station ! Marker post EIR Project Area
b eBAM Boundary Fence
Fence proposed 2018
Vegetation installed in early 2018
Conceptual First Year Dust Control Plan
Oceano Dunes SVRA Dust Control Program
Page 14 of 25
Emission Rate
0.1240-0.4166
"
0.4166-0.7092
"
0.7092-1.0018
"
1.0018-1.2944
"
1.2944-1.587
"
1.587-1.8796
30 acres
"
1.8796-2.1722
"
2.1722-2.4648
"
9.08 acres 2.4648-2.7574
"
2.7574-3.05
"
9.27 acres
10 acres
0 300 600
Source: CDPR, Desert Research Institute, MIG, Inc
Feet
1,200
´ 01/23/2018
Fence proposed 2018 Existing vegetation fencing Nesting exclosure 2017

Vegetation installed in early 2018 Sand Highway, approximately Least tern buffer 2017
Area east of the fence (1 acre) PrivatelyOwnedParcel EIR Project Area
Conceptual First Year Dust Control Plan

Oceano Dunes SVRA Dust Control Program
Page 15 of 25
OPERATIONAL MITIGATIONS
Fugitive Dust Emission Strategies
Oceano Dunes District

Off-Highway Motor Vehicle Recreation Division
District Staff
January 18, 2018

Page 16 of 25
Page 2 of 4
Issue
What fugitive dust air emission mitigation measures (operational mitigations) could Oceano Dunes District
implement and incorporate into on-going park operations, which will enhance our project specific, seasonal,
San Luis Obispo County Air Pollution Control District mitigation measures, in an effort to address and improve
upon fugitive dust emission strategies and compliance?
Potential Costs
Costs will be dependent upon multiple factors including, but not limited to, amount of operational mitigations
identified, staff and labor required for installation, materials and equipment required for installation, staff and
labor required for on-going maintenance and material and equipment required for on-going maintenance.
Background
Oceano Dunes implements temporary, seasonal, fugitive dust emission projects to address air emission
compliance as identified by the San Luis Obispo County Air Pollution Control District. The California Coastal
Commission recently (September 2017 and October 2017) approved a Coastal Development Permit (CDP 3-12-
050) for Oceano Dunes District Dust Control projects. Oceano Dunes District identifies significant additional
benefits by implementing and incorporating mitigation measures into on-going park operations (operational
mitigations) which would provide additional emission benefits, beyond planned seasonal projects.
Discussion
Oceano Dunes District believes implementing specific operational mitigations, incorporated as part of our on-
going park operations, will provide for additional air emissions compliance benefits. To achieve these benefits,
Oceano Dunes District has identified a number of potential operational mitigation strategies for consideration.
Proposed activities and strategies may be evaluated independent of one another, or collectively, in an effort
to identify feasibility and success of proposed operational mitigations (wind fencing).

Page 17 of 25
Page 3 of 4
Proposed Operational Mitigations

Strand Way-
1,400 linear feet of wind fencing
Cost of installation (labor and materials) approximately $4,620.00
Time of installation approximately 4 days
Concession Corrals-
Cost of on-going maintenance approximately $4,000.00
Dune Preserve (Post 3 to Open Area)-

Alley Way(s)-
Open Area Camping-

Post 4 ½ - 5 Camping-
1500 linear feet of wind fencing
All operational mitigation measures implemented


Page 18 of 25
Page 4 of 4
Project Execution
Phase 1- Installation February 6-8, 2018
Dune Preserve perimeter fence
Open Area camping array
Search and Rescue (SAR) Base
If time allows
Post 4 – Post 6 camping arrays
Phase 2- Installation March 6-15

Post 4 – Post 6 camping arrays
Concession Corrals
Arroyo Grande Creek/ south Strand Way array
Appendix
Maps

Page 19 of 25
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Page 20 of 25
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Page 21 of 25
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Page 22 of 25
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Page 25 of 25
From: Gary Willey
To: Carl, Dan@Coastal
Cc: Glick, Ronnie@Parks; Fuzie, Mat@Parks; Karperos, Kurt@ARB; Raymond A. Biering; "Mitchell Rishe
(Mitchell.Rishe@doj.ca.gov)"; Kahn, Kevin@Coastal
Subject: RE: Annual Workplan
Date: Thursday, January 25, 2018 5:42:42 PM
Dan,

The projects proposed are consistent with our requirements and a step towards compliance. As you
are aware, the District’s Hearing Board is currently holding meetings on a Nuisance abatement
petition which might add further projects for Coastal Commission review later this year.

Gary

From: Carl, Dan@Coastal [mailto:Dan.Carl@coastal.ca.gov]
Sent: Thursday, January 25, 2018 5:18 PM
To: Gary Willey <gwilley@co.slo.ca.us>
Cc: Glick, Ronnie@Parks <Ronnie.Glick@parks.ca.gov>; Fuzie, Mat@Parks
<Mat.Fuzie@parks.ca.gov>; Karperos, Kurt@ARB <kurt.karperos@arb.ca.gov>; Raymond A. Biering
<Biering@ammcglaw.com>; 'Mitchell Rishe (Mitchell.Rishe@doj.ca.gov)'
<Mitchell.Rishe@doj.ca.gov>; Kevin.Kahn_coastal.ca.gov <Kevin.Kahn@coastal.ca.gov>
Subject: RE: Annual Workplan

Thanks Gary, I take this to mean that APCD has reviewed the measures in DPR’s proposed
2018 Annual Work Plan dated January 19, 2018 and considers them consistent with APCD
requirements related to dust control at ODSVRA. Please confirm. Thanks!

From: Gary Willey [mailto:gwilley@co.slo.ca.us]
Sent: Thursday, January 25, 2018 5:12 PM
To: Kahn, Kevin@Coastal <Kevin.Kahn@coastal.ca.gov>; Carl, Dan@Coastal
<Dan.Carl@coastal.ca.gov>
Cc: Glick, Ronnie@Parks <Ronnie.Glick@parks.ca.gov>; Fuzie, Mat@Parks
<Mat.Fuzie@parks.ca.gov>; Karperos, Kurt@ARB <kurt.karperos@arb.ca.gov>; Raymond A. Biering
<Biering@ammcglaw.com>; 'Mitchell Rishe (Mitchell.Rishe@doj.ca.gov)'
<Mitchell.Rishe@doj.ca.gov>
Subject: Annual Workplan

Dan and Kevin,

The annual work plan submitted to the Coastal Commission by State Parks has been reviewed by the
APCD. We request that the measures contained in the plan be allowed to proceed as soon as
possible.

If you have any question, please feel free to contact me.

Exhibit 6 (APCD and CARB Concurrence with DPR’s Proposed 2018 Annual Work Plan)
Page 1 of 3

Sincerely,

Gary E. Willey
Air Pollution Control Officer
San Luis Obispo County APCD

slocleanair.org
805.781.5912

Page 2 of 3
From: Carl, Dan@Coastal
To: Kahn, Kevin@Coastal
Subject: FW: ODSVRA Annual Work plan
Date: Friday, January 26, 2018 1:01:52 PM
Attachments: image003.png
From: Karperos, Kurt@ARB [mailto:kurt.karperos@arb.ca.gov]

Sent: Friday, January 26, 2018 12:58 PM
To: Carl, Dan@Coastal <Dan.Carl@coastal.ca.gov>; Fuzie, Mat@Parks <Mat.Fuzie@parks.ca.gov>;
Gary Willey <gwilley@co.slo.ca.us>
Cc: Rabinowitsh, Nicholas@ARB <Nicholas.Rabinowitsh@arb.ca.gov>
Subject: ODSVRA Annual Work plan

Dan Carl:

The California Air Resources Board (CARB) staff has reviewed the proposed 2018 Dust Control
Project for Oceano Dunes State Vehicular Recreation Area (ODSVRA). CARB is the state agency
charged with coordinating efforts to attain and maintain ambient air quality standards. CARB has not
developed requirements specifically relating to dust control at ODSVRA. The San Luis Obispo Air
Pollution Control District (SLOAPCD) is responsible for regulating dust emissions at ODSVRA and has
developed requirements related to dust control at ODSVRA. Based on our review, CARB concludes
that the proposed 2018 measures are consistent with progress toward compliance with SLOAPCD
requirements related to dust control at ODSVRA.

Kurt Karperos

Kurt Karperos
Deputy Executive Officer
916.322.2739

Page 3 of 3

DRAFT: Spring Oceano Dunes Dust Mitigation Plan

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STATE OF CALIFORNIA—NATURAL RESOURCES AGENCY EDMUND G. BROWN JR.

CALIFORNIA COASTAL COMMISSION

Exhibit 1: Project Location Maps

Exhibit 1 (Project Location Maps)

Interim Staging Area

Open Riding Area

Seasonal Exclosure Area

Oso Flaco Access

Seasonal Exclosure Area Boundary

Exhibit 1 (Project Location Maps)

Seasonal Exclosure Area Boundary

Exhibit 1 (Project Location Maps)

Exhibit 2 (ODSVRA Aerial Photos)

Exhibit 2 (ODSVRA Aerial Photos)

Exhibit 2 (ODSVRA Aerial Photos)

Exhibit 2 (ODSVRA Aerial Photos)

Exhibit 2 (ODSVRA Aerial Photos)

Exhibit 3 (CDP 3-12-050 Adopted Summary of Commission Action)

Exhibit 3 (CDP 3-12-050 Adopted Summary of Commission Action)

Exhibit 3 (CDP 3-12-050 Adopted Summary of Commission Action)

Exhibit 3 (CDP 3-12-050 Adopted Summary of Commission Action)

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

PM10 (µg m-3)

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Dust Control Plan for 2018

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

PI-SWERL® Measurements 2018

Moisture effects on PI-SWERL Measurements

Fencing an area to examine the effect of vehicle exclusion on sand transport

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Fence proposed 2018 Existing vegetation fencing Nesting exclosure 2017

Conceptual First Year Dust Control Plan

Oceano Dunes District

January 18, 2018

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Proposed Operational Mitigations

Dune Preserve (Post 3 to Open Area)-

Open Area Camping-

All operational mitigation measures implemented

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Phase 2- Installation March 6-15

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

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Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

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Exhibit 5 (DPR's Proposed 2018 Annual Work Plan)

From: Karperos, Kurt@ARB [mailto:kurt.karperos@arb.ca.gov]

Das könnte Ihnen auch gefallen

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