11/12/01 ASA Activity Update
ASA's Position Regarding Comp Hill and the Sand Drags

To the ASA Membership and all sand dune enthusiasts,

As all of you know, the crowd gatherings at the Comp Hill area of the Imperial Sand Dunes Recreation Area (Glamis) have in recent years turned ugly, violent and unlawful. These crowd gatherings are not there for a legitimate OHV activity. Their purpose at Comp Hill is not to ride or show off their vehicles. These gatherings have been described as "rave parties", "mobs", "drunken brawls", "off-road revelers" etc. Many Duners have said that they no longer go to Comp Hill and are offended because of what is going on there.

While the overwhelming, vast majority of the OHV community does not participate in these activities they, inevitably, reflect upon the OHV community. Since this is occurring on an off-road recreation area it is inevitable that the off-roader is not only associated with it but also wrongly blamed for it.

Keeping the ISDRA open, as an OHV area is the very first priority of the ASA. The ASA encourages sound and prudent management of the ISDRA. The ASA has taken a pro-active role in working with the Bureau of Land Management in all aspects of managing the ISDRA. Environmental issues, such as the Peirson's MilkVetch plant, are not the only management issues that affect our OHV use of the ISDRA.

The outrageous behavior of the crowds gathering at Comp Hill must be dealt with. Sound and prudent management dictates that unlawful activities, outrageous behavior and conduct that offends public sensibilities not be allowed to occur on the ISDRA or any other OHV area.

This is a very serious matter that can affect our continued enjoyment of the dunes. Therefore the ASA board of directors has taken the following steps:

1. A letter, through the ASA law firm, has been sent to the IMPERIAL COUNTY SHERIFF and the CALIFORNIA STATE DIRECTOR OF BLM requesting them to curtail the unsafe and lawless behavior at the ISDRA.
(A meeting has been scheduled to hear what the responsible agencies plan to do to resolve this undesirable situation. ASA will take action to avoid capacity limitation or other solutions detrimental to OHV use at the ISDRA.)

2. The ASA has told the BLM that we would support a dusk to dawn curfew at Comp Hill.

3. The ASA has recommended to the BLM to enforce the existing rules and the California Off Road Vehicle laws.

4. The ASA has told the BLM that the ASA will support the enforcement of the new rule of no riding in the back of pickup trucks and unauthorized group activities.

Jerry Seaver
Chairman of the Board
ASA President

Keith Rosewitz
CFO, Director

Bob Mason
Public Safety and Education Chairman

Grant George
Biological Committee Chairman

Mark Harms
Legal Committee Chairman

ASA Letter to Imperial County Sheriff and BLM State Director

November 12, 2001

Sheriff Harold D. Carter
Imperial County Sheriff's Office
328 Applestill Road
El Centro, CA 92243

Mike Pool, State Director
Bureau of Land Management
California State Office
2800 Cottage Way, Suite W-1834
Sacramento, CA 95825-1886

Re: Safety Issues in the Imperial Sand Dunes Recreation Area

Dear Sheriff Carter and State Director Pool:

As legal counsel for the American Sand Association ("ASA"), I have been asked to review existing BLM rules and California OHV laws as applied to certain unsafe and potentially illegal activities in the Imperial Sand Dunes Recreation Area ("ISDRA"). I refer specifically to activities at Competition Hill and the impromptu drag races near Gecko Road and at Gordon's Well. Having completed my legal review, it is my opinion that the existing regulations could and should be strengthened, but are adequate to resolve this problem, so long as BLM and the Sheriff's Office provide adequate enforcement. Unfortunately, the ISDRA has long suffered from inadequate enforcement staff. This situation cannot continue if accidents are to be avoided.

ASA's correspondence with BLM indicates that the unsafe and unlawful activities at Competition Hill, Gecko Road, and Gordon's Well have grown steadily over the last few years and are now so prevalent as to create a significant public safety hazard, especially during holiday weekends. This is not an acceptable situation. During the last year, ASA has written several letters and emails to BLM requesting swift action to curtail these activities. But so far, no substantive action has been taken.

The current situation demands that sufficient enforcement staff be deployed at Competition Hill, Gecko Road, and Gordon's Well. The unauthorized activities at these locations not only endanger the physical well-being of those who recreate in the ISDRA, they expose the BLM and the Sheriff's Office to liability for failure to enforce the very rules designed to protect the safety of desert visitors. It is ASA's position that a serious accident will occur as a result of the activities at Competition Hill, Gecko Road, and Gordon's Well. It's not a matter of "if" - only a matter of "when." And ASA fears the "when" may be the upcoming Thanksgiving Weekend.

BLM has proposed additional rules to deal with safety problems in the ISDRA, and has submitted them to the Department of Interior in Washington. However, approval of the new rules may be months away. Further, while ASA believes the new rules are necessary, ASA is not convinced they will solve the problem completely. BLM and the Imperial County Sheriff's Office must work together to determine the appropriate course of action. For its part, the ASA Board is prepared to support a DUSK TO DAWN CURFEW at Competition Hill and NO PARKING RESTRICTIONS at the drag races.

Finally, the solution to this critical problem cannot be deferred until the proposed Resource Management Plan ("RMP") is finalized. Immediate action - preferably before the Thanksgiving Weekend - is required. ASA representatives would like to meet with both of you in El Centro during the week of November 12, 2001, to discuss a plan for addressing this serious issue. Please contact Jerry Seaver, President of ASA, to arrange such a meeting. If we do not hear from you by Thursday, November 8, we will contact your offices directly. Thank you for your time and attention to this matter.

Very truly yours,

David P. Hubbard

cc Jerry Seaver, ASA
Mark Harms, ASA
Bob Mason, ASA
Imperial County Board Of Supervisors
Sharon Housouer, Chief Deputy ICSO
Tim Salt, BLM
Ann Klee
Greg Thomsen, BLM, El Centro
Bob Zimmer, Chief Ranger
Dave Widell, Deputy Director