A proposed 86-mile transmission line between Arizona and California is raising concerns about potential effects on OHV access, existing desert routes and recreational connectivity across public lands in California’s Imperial Valley.
Don Amador, president of Quiet Warrior Racing LLC and a longtime advocate for responsible OHV recreation and public-land access, brought the proposed Ironwood Transmission Line Project to the attention of OHV stakeholders in an August 11 briefing memorandum.
Amador emphasized that his review remains preliminary. He is not calling for categorical opposition to the transmission project. Instead, he wants existing OHV routes, public access and route connectivity identified, mapped and fully analyzed before project-level decisions are made.
“The immediate objective should not be to oppose transmission infrastructure categorically,” Amador wrote. “Rather, it should be to ensure that existing OHV access, route connectivity, and the public’s established use of BLM lands are identified, mapped, analyzed, and protected before project-level decisions are made.”
What Is the Ironwood Transmission Line Project?
Horizon West Transmission LLC is proposing an approximately 86-mile, 500-kilovolt transmission line connecting Arizona Public Service Company’s North Gila Substation in Yuma County, Arizona, with San Diego Gas & Electric Company’s Imperial Valley Substation in Imperial County, California.
Approximately 80 miles of the project would be located in California. The proposed alignment would cross a combination of federal, state and private lands, including property administered or managed by the Bureau of Land Management, Bureau of Reclamation and California State Parks.
Horizon West would acquire a new 250-foot-wide right-of-way for the project. Construction would involve transmission structures and foundations, conductor and fiber-optic lines, temporary and permanent access roads, staging and pulling sites, work areas, grading, excavation and the movement of heavy equipment.
According to the California Public Utilities Commission’s Ironwood project page, Horizon West intends to use existing access roads and trails associated with the Southwest Powerlink transmission line, pipelines, highways and county roads whenever possible.
That proposed reliance on existing roads and trails is at the center of the OHV access concerns identified by Amador.
Why Existing Roads and Trails Matter
The potential impact is not limited to whether a transmission tower would physically occupy a formally designated OHV trail.
Many roads across the California Desert serve more than one purpose. A road originally constructed for utility or land-management access may also function as a public recreation route. Primitive roads and two-tracks can connect highways, staging areas, dispersed campsites, riding areas and other portions of the BLM motorized travel network.
A route that appears minor when considered by itself may be essential to a much larger recreational network.
This type of connectivity is what allows riders to travel between destinations without loading their UTVs back onto trailers. The importance of connected routes can also be seen in the recently established Needles OHV route network, which connects staging areas and surrounding BLM trails with local services.
Amador argues that the Ironwood environmental review should therefore examine routes individually and determine how each one functions within the broader transportation and recreation network.
“The value of a route is not necessarily determined by its individual mileage or designation,” Amador explained. “Its importance may instead be determined by what other public lands, recreation areas, staging areas, camping areas, and routes it connects.”
Potential Construction and Access Conflicts
The project’s official environmental-review documents acknowledge that temporary construction activities could disrupt or limit access to recreational resources and public lands within portions of the project area.
Potential sources of disruption include:
- Construction traffic and heavy equipment
- Temporary road or access restrictions
- Tower construction sites and work areas
- Material staging and conductor-pulling sites
- Safety zones surrounding active construction
- Improvement or modification of existing roads
- Permanent utility access and maintenance requirements
None of this confirms that a particular OHV route will be closed. Detailed comparisons between the proposed alignment, construction-access plans and the existing BLM motorized route network are still needed.
Amador’s concern is that a road currently open to the public could be treated in project documents primarily as a construction or utility-access road without adequately recognizing its existing recreational function.
Temporary Closures Can Have Larger Consequences
A temporary closure does not have the same effect as permanently eliminating a route, but it can still substantially disrupt recreation—especially if the affected road is the only legal or practical connection between two areas.
Amador recommends that the environmental review identify:
- Which public routes would be used for construction
- Which routes could be temporarily restricted or closed
- When restrictions would occur and how long they would last
- Whether construction traffic and public OHV use could safely coexist
- Whether legal and practical alternate routes would be available
- How public access would be handled after construction
A nearby road should not automatically be considered an equivalent replacement. A proposed detour may be substantially longer, too narrow or difficult for some vehicles, seasonally impassable, legally closed to OHVs or incapable of reconnecting riders with the same destinations.
Any replacement route should be evaluated for legality, safety, terrain, vehicle accessibility, seasonal availability and its ability to provide substantially equivalent access.
Relationship to the Imperial Sand Dunes
The project crosses a region that includes one of the country’s most important OHV recreation landscapes. The Imperial Sand Dunes Recreation Area—commonly known as Glamis—extends across a large portion of southeastern California and includes riding and camping areas accessed from Highway 78 and Interstate 8.
Amador’s memorandum does not establish that the project will close the Imperial Sand Dunes or eliminate one of its primary entrances. Rather, it raises a broader concern about roads, staging access and connector routes within the surrounding Imperial Valley public-land network.
The distinction is important. This is an early opportunity to identify potential conflicts, not evidence that specific trail closures have already been approved or proposed.
Access decisions have shaped recreation at the Imperial Sand Dunes for decades. The BLM’s 2013 Recreation Area Management Plan, for example, changed the status of substantial areas and required new maps and route signing as implementation moved forward. UTVGuide covered both the implementation of the dunes management plan and the subsequent reopening of previously closed areas.
ASA Proposes Alternative Route Near Dune Buggy Flats
The American Sand Association has also been working directly with the project proponent and reviewing potential transmission-line alignments through the Imperial Sand Dunes and surrounding OHV recreation areas.
ASA says it has not endorsed the project’s current preferred alignment through the dunes. Instead, the organization has proposed an alternative route near Dune Buggy Flats, which it identifies as one of the most significant areas of concern.
According to ASA, the suggested diversion is intended to avoid active dune areas where practical, reduce conflicts with OHV traffic and camping, minimize safety concerns associated with fixed transmission structures, and shift the line toward areas with less intensive OHV use where feasible.
The project proponent has indicated that it will evaluate ASA’s proposed alternative.
That development provides a concrete example of the type of early involvement Amador is encouraging: identifying potential access and recreation conflicts while project routing can still be evaluated rather than waiting until major decisions have already been made.
Cumulative Loss of Desert Route Connectivity
Amador also wants the Ironwood project evaluated alongside other land-use changes occurring across the California Desert.
Transmission infrastructure, renewable-energy development, mining, transportation projects, conservation designations and other decisions can each affect a relatively small portion of the motorized route network. Their combined effect, however, can gradually fragment access across a much larger landscape.
Recent Western Mojave trail closures demonstrate how the loss of individual roads can affect access to destinations, memorials, businesses and communities across an entire recreation network.
For OHV recreation, the cumulative impact cannot always be measured simply by calculating the number of acres occupied by each project. It also requires determining whether riders can continue traveling legally and practically between staging areas, campsites, riding areas and public-land destinations.
Questions the Environmental Review Should Answer
Amador recommends that the California Public Utilities Commission and BLM conduct a route-by-route analysis that addresses several key questions:
- Which designated routes, primitive roads, utility roads and public connectors are located within or adjacent to the project corridor?
- Which existing roads would be used, widened, improved or modified for construction?
- Would any public routes be temporarily closed or subject to safety restrictions?
- Could construction vehicles conflict with recreational traffic?
- Would proposed detours provide legal and functionally equivalent OHV access?
- Would any existing public routes become restricted utility-access roads after construction?
- How would future maintenance, emergency access and vegetation management affect public use?
- How would the project contribute to cumulative fragmentation of the California Desert motorized route network?
The CPUC has already identified recreation and transportation as subjects requiring environmental review. Its preliminary recreation checklist asks whether the project could reduce or prevent access to a designated recreation area, change the character of a recreation area or damage recreational trails and facilities.
Amador believes that analysis must extend beyond formally named trails and include the less obvious connector and access routes that make the larger OHV network functional.
Public Comments Due September 21
The CPUC is currently accepting comments to help determine the scope and content of the project’s Environmental Impact Report. The Ironwood Transmission Line proceeding is Application No. A.25-09-008.
Two virtual public scoping meetings are scheduled for August 27, 2026:
- 3:00 p.m. – virtual public scoping meeting
- 6:30 p.m. – virtual public scoping meeting
Written scoping comments must be submitted by 5:00 p.m. on September 21, 2026. Comments may be emailed to CEQA@IronwoodTransmissionProject.com.
Comments should identify specific routes, staging areas, campsites, access points or connections that could be affected whenever possible. Useful submissions can also request route-level mapping, continued public access during construction, advance notice of temporary restrictions and legally usable detours.
Public comments will become part of the public record and will be summarized in the project’s scoping report.
CEQA and NEPA Reviews Will Be Separate
The CPUC is the lead agency for the California Environmental Quality Act review. The BLM will conduct a separate federal review under the National Environmental Policy Act for portions of the project crossing federal land.
Although the two agencies are expected to coordinate where possible, CEQA and NEPA will remain separate decision-making processes with separate documents, notices and public-comment periods.
The current deadline applies to the CPUC’s CEQA scoping process. OHV stakeholders will need to watch for a future BLM notice and participate in the federal review as well.
The CPUC anticipates releasing the Draft Environmental Impact Report during the third quarter of 2027, followed by a Final EIR during the first quarter of 2028.
An Opportunity to Address Access Before Decisions Are Made
The Ironwood Transmission Line Project remains in the early stages of environmental review, and no specific OHV route closures have been confirmed. That makes the current scoping period especially important.
Waiting until construction plans are finalized could make it much more difficult to preserve a route, alter an access plan or require a functional detour. Identifying the recreational importance of existing roads now gives agencies an opportunity to include those routes in the environmental analysis from the beginning.
Amador is continuing to review the revised Proponent’s Environmental Assessment, alignment maps, proposed construction access, routing study and recreation analysis. He plans to develop more detailed technical recommendations and formal CEQA scoping comments as that work progresses.
His message to the OHV community is measured but clear: place the Ironwood Transmission Line Project on the radar, document how the affected route network is used and participate while there is still an opportunity to shape the environmental review.
Visit our Land Use & Access section for additional public-comment opportunities and proposed actions affecting motorized recreation.
