ICSAC Coalition

9,271-Acre Access Restoration Initiative

Advancing Data-Driven Land Management in the Imperial Sand Dunes Recreation Area


Executive Summary

In 2013, approximately 9,271 acres located south of Highway 78 within the Imperial Sand Dunes Recreation Area (ISDRA) were placed under closure following designation of critical habitat for the Peirson’s milk-vetch (PMV). These areas had historically remained open to public use prior to 2000, when litigation resulted in the temporary closure of approximately 49,300 acres south of Highway 78. Areas north of Highway 78 designated as wilderness had already been closed to off-highway vehicle use prior to that time.

While the U.S. Fish and Wildlife Service designated critical habitat, the closure itself was implemented by the Bureau of Land Management as part of its land management approach to support a no-jeopardy Biological Opinion associated with the 2013 Recreation Area Management Plan (RAMP).

This approach incorporated areas that had historically remained open, including the Patton Valley Corridor (PVC), and established a 9,271-acre restricted area that continues to guide current management.

The ICSAC Coalition is advancing a structured, evidence-based effort to support reevaluation and reopening of this closure area, grounded in over a decade of BLM monitoring data and aligned with current federal law and policy direction emphasizing scientific rigor, economic consideration, and administrative accountability.


Closure Background - Critical Habitat and Implementation Decisions

The 9,271-acre closure reflects the interaction between critical habitat designation and subsequent land management decisions.


The resulting management approach applied a one-to-one alignment between critical habitat designation and access restrictions, with the closure encompassing the full extent of designated habitat without differentiation at a sub-area or site-specific level.

In doing so, BLM incorporated areas that had remained historically accessible, including the Patton Valley Corridor.

As currently structured, this closure:


The uniform application of closure across the entire designated habitat area underscores the opportunity for a more tailored, data-driven reassessment based on site-specific conditions now reflected in the administrative record.

It is also noted that portions of designated critical habitat extend into areas north of Highway 78 that are managed as wilderness, where separate statutory constraints apply and where off-highway vehicle use had already been restricted prior to 2000.

The presence of multiple land-use designations within the broader critical habitat area further underscores that management approaches may vary by location and that a uniform application of access restrictions across the entire 9,271-acre area may not reflect site-specific conditions or management requirements.


Scientific Record - Bureau of Land Management Monitoring Data

The Coalition’s position is grounded in more than eleven years of monitoring data conducted by the Bureau of Land Management related to the Peirson’s milk-vetch (PMV).

Findings reflected in this federal dataset include:

This long-term dataset provides an empirical foundation for evaluating whether the scope of the 2013 closure remains aligned with observed environmental conditions.


Regulatory Framework and Policy Alignment

This initiative is grounded in existing federal law, including the Endangered Species Act and the National Environmental Policy Act.

Recent policy direction further emphasizes data-driven and accountable decision-making. This includes:


In parallel, updated NEPA implementation introduces more structured timelines and clearer expectations for agency coordination and documentation. While these changes do not eliminate review requirements, they reinforce a framework centered on efficiency, transparency, and evidence-based outcomes.


Strategic Considerations - Why Reevaluation Is Warranted

The current 9,271-acre closure reflects a management approach established in 2013 under different data conditions.

Since that time:


The question is no longer what was appropriate in 2013, but whether the current scope of closure remains justified based on eleven years of federal data.

This creates a basis for reassessing whether the existing closure:


Administrative Pathways for Reassessment

Established mechanisms exist to evaluate and potentially adjust the current designation:


Each pathway is governed by defined evidentiary standards and administrative procedures and would be evaluated by the appropriate federal agencies.


ICSAC Coalition

The ICSAC Coalition represents a broad and growing network of stakeholders committed to responsible land use, scientific integrity, and constructive engagement.

The Coalition’s role is to:


Path Forward

The Coalition supports a structured and transparent review of the 9,271-acre closure area based on:


This approach is intended to improve alignment between land use designations and observed environmental conditions while supporting durable, defensible outcomes for long-term management of the ISDRA.