August 28, 2006


In Reply Refer To:

1703 (360) P



Information Bulletin No.2006-123


To:                   All Field Office Officials


From:               Assistant Director, Minerals, Realty, and Resource Protection


Subject:            Recommendations for Preventing Illegal Waste Dumps


Illegal dumping has been occurring on the BLM public lands for many years. State and Field Offices continue to encounter many illegal dumps within their jurisdictions.  Such dump sites often encourage or engender additional illegal dumping in the same area, in what has come to be called “promiscuous dumps”.  Illegal dumping involves mainly the dumping of solid waste such as white goods, yard wastes, household trash, vehicles, furniture, construction debris, and household hazardous waste.  Illegal dumps are often created along rail roads, dirt roads, routes, and in the deserts.   Illegal dumps also pose a tempting opportunity to dispose of hazardous waste in violation of the Resource Conservation and Recovery Act (RCRA).  A major type of hazardous waste found in illegal dumps is those generated by clandestine drug labs.


To prevent and reduce the occurrence of illegal waste dumping on the BLM public lands the Division of Engineering and Environmental Services provides the following recommendations for State and Field Offices to assist offices with their illegal waste dumping problems: 1) Community Outreach, Education, and Involvement, 2) Targeted Enforcement, 3) Creation of Legal Alternatives for Illegal Dumpers, and 4) Measurement.  These recommendations have been successful at a number of field offices in preventing illegal waste dumping.  State and Field Offices should consider using Special Cleanup Funding (Flexible Funding in Subactivity 1640) to implement these recommendations.


Community Outreach, Education, and Involvement – To prevent illegal dumping State and Field Offices can establish and implement a community outreach and education program. The focus of any community development involvement effort should be to teach residents why they shouldn’t take part in illegal dumping, what can be done to prevent illegal waste dumping, how and why they should get involved, and who to contact for assistance or to report an incident.  BLM can help educate the public on how to properly dispose of their household solid and hazardous waste by providing educational media such as brochures, handouts, and promotional items.


Such an initiative can be a collaborative effort with groups such as Take Pride in America, Keep America Beautiful Inc., State, County, and Local governments, and community organizations.  


As part of a prevention program, Field Offices can participate and get involved in their jurisdiction’s local community events such as state and county fairs and town hall meetings to publicize the impacts of illegal waste dumping. The BLM can also use media such as Public Service Announcements (PSAs) to educate the public on waste reduction and alternatives for disposing of wastes.


Targeted Enforcement – States and Field Offices can target illegal dumpers for Law Enforcement.  Law Enforcement is responsible for ensuring citizens on public lands are abiding by the laws and regulations. The Law Enforcement personnel can investigate citizens' complaints about illegal dumping and attempt to identify those responsible for the illegal activities.


The BLM Law Enforcement can obtain voluntary compliance and clean up, or may take civil or criminal enforcement action where necessary after those responsible are identified for illegally dumping on public lands.  To accomplish this task, the BLM Law Enforcement personnel can conduct targeted enforcement in association with community outreach.


A dedicated task force can be formed that consists of enforcement officials from different departments or agencies with the authority or responsibility for illegal waste dumping prevention.  Such collaborative efforts encourage cooperation and reduce the burden on State and Field Offices.  Task Forces with representatives from different levels of government (city, county, state, or federal) can be effective in working together to apply the strongest ordinance or law to an offender.


Create Legal Alternatives for Illegal Dumpers – State and Field Offices can create legal alternatives for the communities to prevent illegal waste dumping on public lands. State and Field Offices can organize events to collect and properly dispose of illegally dumped materials, such as tire collections, white goods, and abandoned vehicles. A successful pilot program for legal alternatives was implemented in Ely, Nevada for local residents to legally dispose of solid waste. The program used small amounts of money and partnered with local and county government to implement the pilot program.  The BLM Ely Field Office provided local residents a free service at the local municipal landfill.  Such a pilot program could also be part of a State or Field Office initiative.


Cleanup projects require a coordinated planning, resource acquisition, and implementation effort.  Sites must be cleaned up before a threat to public health, the environment, and safety develops.  State and Field Offices can develop a plan to remove illegal waste dumps and keep sites clean.  Such a plan should be developed before a cleanup to ensure the effort is not wasted.


Measurement – State and Field Offices should establish and implement a measurement initiative to calculate illegal waste dumps prior to cleanup and after cleanup.  The success of preventive measures can be measured by community feedback and by re-visiting the site within 6 to 9 months after cleanup to determine if illegal dumping has stopped or decreased.


Also all Field Offices are required to use project code DUMP (Instruction Memorandum No. 2004-075) to track costs associated with illegal waste dump cleanups.  Associated costs include volunteers, supplies, contracts, and employees’ labor hours.  This project code should be used when not in conflict with other mandated project codes (i.e. litigation, Indian Trust, and Recreation Fees). The program element used should be HQ.


Questions or comments concerning this information bulletin should be directed to Georgette A. Fogle at 202 557-3569 or Miyoshi Stith at 202 557-3578, Division of Engineering and Environmental Services.


Signed by:                                                                   

Authenticated by:

Bob Anderson                                                             

Robert M. Williams

Acting, Assistant Director                                            

Division of IRM Governance,WO-560

Minerals, Realty and Resource Protection