How to Submit a Great Comment on BLM’s Draft Environmental Impact Statement

The BLM has issued its Draft Environmental Impact Statement (DEIS) for Burning Man. Unfortunately, the operational mitigations it outlines would fundamentally change the cultural fabric of Black Rock City. Read this post, which provides a high-level overview of the situation, highlighting that while Burning Man Project has been and will remain committed to its legacy of safety and strong environmental stewardship, many of these mitigations are unreasonable, untenable, arbitrary and capricious, attempt to solve problems that don’t exist, and/or create new (and worse) problems. We need your help.

We need everyone — particularly business owners, civic leaders, and subject matter experts — to provide substantive comments about these mitigations. By law, these comments must be taken into consideration by BLM in their drafting of the Final Environmental Impact Statement (FEIS), which will directly affect the future and survival of our event. Following are guidelines on how to submit high-quality, effective comments about the DEIS mitigations.

How to Submit a Comment

BLM has requested public comment and we encourage everyone to review the Draft EIS and submit informed, substantive comments through the BLM’s comment form OR email blm_nv_burningmaneis@blm.gov. Be sure to copy/cc us at eis@burningman.org. The deadline for public comment is April 29. You may submit multiple comments on different issues or include many issues in a single comment. More details are on the BLM website.

How to Submit an Effective Comment

The most effective comments provide useful information to the BLM. DEIS comments are not counted as votes, nor are they part of a referendum on BLM decisions. They’re used to improve the document and analyses, ensuring impacts are adequately determined before the BLM makes a final decision on the proposed project. So, avoid comments like “I am in favor of this project” or “I am opposed to this project.”

Remember: the more clear, concise, and relevant to the DEIS your comments are, the more effective they’ll be and the more likely it is that they’ll be utilized to improve the final documents and affect the agency’s decisions. The most effective comments should follow these guidelines:

  • Be as specific as possible with your comments and refer to sections, chapters, special studies, page numbers and paragraphs in the DEIS.
  • Back up your statements with explanations, facts, personal experience, and references, as appropriate.
  • Support statements with details. If, for example, you are concerned about impacts to the playa surface or traffic management, it is helpful to focus on a particular problem or issue, such as BLM’s recommendation for K-rail and jersey barriers around the Black Rock City perimeter: “It appears the Draft EIS failed to adequately consider the environmental impacts of the transportation and placement of millions of pounds of concrete and plastic barriers around the perimeter.” or
  • Comments can take the form of questions like: “I have not experienced problems with firearms or drugs at Burning Man. Did BLM consider the costs of running an increased search operation at the Gate, and the effects on wait times and individual rights?”
  • It’s important to look at the base assumptions that lead to BLM’s new requirements. For instance: “It appears BLM relied on very few observations in the Artificial Light at Night Assessment.”
  • You should include your experience. For example: “I have been to Burning Man seven times and my camp does everything we can to ensure our loads are secure and that we leave no debris. It seems the recommendation for dumpsters is extreme and not supported by enough evidence.”
  • You should state your qualifications, such as: “I am a biologist in Nevada studying bird migration and can tell you that the analysis in this respect is beyond reason. The extremely tiny level of risk to bird species posed by activity at Burning Man does not warrant BLM’s proposed monitoring or mitigations.”
  • Submit comments if you find:
    • an error in analysis that may affect the outcome
    • new information that would change the analysis and conclusions
    • something that should be clarified
    • a substantially different alternative that meets the purpose and need statement and has not been considered.

Comments that simply reflect an opinion about the project will not be as effective. For example, a comment that states, “I don’t like the idea of concrete barriers around the event,” or “ I oppose putting dumpsters on Gate Road on principle” typically result simply in a response of “Comment Noted.” An effective comment might start with: “Concrete barriers would be detrimental to the Burning Man event because ___,” or “The event would be negatively affected by dumpsters on Gate Road because ___.”

Substantive comments that are backed by factual support sometimes lead to changes in the Final EIS and in the project. The comments should be written in a manner that requires the lead agency that designed the mitigation to actually respond.

To have a significant impact on the Draft EIS process, comments should point out errors, inconsistencies, omissions of data or analyses, or conclusions not based on evidence.

The agency needs to respond adequately to such substantive comments prior to certification of the final EIS. Failure to do so would provide the basis for a legal challenge to a certified (approved) EIS, and if the court agreed with the challenge, the EIS would be found invalid. in Black Rock City, outlining a series of operational mitigations that ostensibly ensure our event remains in compliance with the National Environmental Policy Act (NEPA).

We have some of the world’s most brilliant and creative minds in the Burning Man community — let’s go! Thank you for your time in supporting this effort.

This post contains our analysis of all of the mitigations proposed in Appendix E, as well as background context to help you understand the history behind each. This will serve as helpful background as you craft your comments, so keep an eye out for it.

For more detailed guidelines, see these resources:

[Editor’s Note: some of these guidelines are sourced directly from the BLM’s commenting tips.]


Top photo by Mark Hammon

About the author: Burning Man

Burning Man

The official voice of the Burning Man organization, managed by Burning Man's Communications Team.

63 Comments on “How to Submit a Great Comment on BLM’s Draft Environmental Impact Statement

  • Gio says:

    Might be time to purchase some land.

    Report comment

    • Watchitfall says:

      Then BMORG Execs will get a pay cut. Not to mention new land will dash the BMORG’s dreams of raising the event to 100k (like they have mentioned in the past)

      Report comment

    • LuxLupus says:

      Yes please. The BOrg spends millions in permit fees every year. Certainly that could go far (and above) toward purchasing land. It could likely even save money in the long term (and lower ticket prices).

      Report comment

      • Joshua says:

        Why? Why should we have to gather on private land? Why hand them that victory? Why can’t we gather on a pile of sand in the middle of nowhere without being fucking harassed or extorted? Fuck that. This is our public RIGHT.

        Report comment

      • sherlock says:

        If land was purchased but then placed into some form of trust or co-op, I would be open. Each person who participates by purchasing a ticket, or contributing in some as of yet in this comment unspecified manner, could be a co-owner.

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      • Dallas Shewmaker says:

        Why buy the land? Because it relieves the community from being under the thumb of the Federal Government whom does own the land and is using a Federal agency as a pundit to exploit the community. Burning Man has always been about community. What better way to permanently establish that by claiming ownership of the land it uses. All government land is available for a price. Purchase the land. Set up a post office. Establish the land as an unincorporated township of Washoe County, Nevada.

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  • Why don’t I see BMOrg making any suggestions that BURNER the shit out of their plans! Meaning flip the script on them. Think about it. 4th of JuPlaya, BLM comes out asking whose in charge. Seems like everyone answers no one because no one is. The groups can’t be bigger then what 11 people, and camps have to be 25 feet apart? Just follow the rules and DISPERSE ACROSS THE WHOLE THING! FREEEEEEBBBUUUUUURRRNNNN, by LynderSkynerd

    Report comment

    • Lady Diana says:

      4th of julplya…. Is the Queen to break new land with whom both pushed her broken heart back together again, she called them the devil and the lord savior. But he said he would never go there with the queen and the devil didn’t go down to Georgia, so anything is possible right? If the devil refuses his destiny what next? Do the French need to take measures so the Eiffel Tower man does not lean one way or another like the Tower of Piazza.

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  • Karl says:

    This is a retaliation move on the part of the BLM to get their way in unrelated areas

    Bring this tactic to light and publicly shame them for misuse, over exaggeration and out right lies to gain an advantage.

    Like the demand for flushing toilets and ice cream dispensers. They will back away from this shameful move ONLY when they are exposed

    Report comment

    • Sanfranissh!tcapitalofUSA says:

      You really think the public gives 2 flying f**ks that the government wants to end the drunken, 1%, white peoples party in the Desert? Watching BM go downhill is immensely satisfying. And I can’t wait until it gets worse!

      Report comment

      • HammeredOne says:

        San Fran – what are you so angry about? Can you be specific about why you believe BM is so terrible? ‘Content and context’, instead of simple rage, will allow interested and interesting people to address your concerns. Thanks, in advance, for your attention.

        Report comment

      • Bart says:

        Someone missed out in the ticketdrama..

        Report comment

  • TW Platz says:

    Not surprising with the current Federal Administration, comrade.

    Report comment

  • Xeno says:

    Or, you could comment on what you’ve seen that’s terrible. I’ve witnessed plug ‘n play camps dump black water and garbage all over their site. I’ve seen aircraft come in and crash, then leave the plane for others to clean up. I don’t think burningman is sustainable anymore. It should end. 4th of Juplaya is a much better model even though it makes mere participants out of all the office staff of BMorg. No one should be in charge.

    Report comment

  • Jomes says:

    BM needs to be relocated to Portland. Power to the people!

    Report comment

    • rekt says:

      Sure, we’ll substitute all of the productive art enclaves with homeless junkie compounds and deputize all of your antifa hooligans as rangers. Truly a model going forward.

      Report comment

  • Sparkle Bubbe says:

    This post asks too much of us. We don’t have the time or expertise to analyze this massive document and figure out what is wrong with it. Can Burning Man please publish an article that summarizes the main issues with this document and then we can tailor our comments to those concerns? Please help us help you.

    Report comment

  • Teresa says:

    IF we go this year, it would mark my 10th Burn. I’m disgusted at how many plug&plays have invaded the playa with total disregard to the 10 principles. I’ve camped directly across the street with very LOUD generators, wild amounts of garbage left behind (I’ve also stayed a day longer-NUMEROUS years to clean up the playa). I’m tired of supporting the BLM and law enforcement agencies with my ticket purchases only to worry on my way in that we could get pulled over and have our RV ransacked for no reason or our art car/trailer turned upside down. I’m also disgusted at the new rave crowd that’s only there for the party–and NOT giving anything back to the community before, during or after the burn. It’s very sad to see it all become SO political. I’m sure that what’s happening now was NOT in Larry’s vision for the future of the burn….RIP.

    Report comment

    • HammeredOne says:

      I believe that this article concerns the BLM permit. I am sure that there is an endlessly looping wormhole somewhere about how BM was much better 10 years ago.

      While opinions are educational I believe that this is a call to action on the question of permit/no permit and self governance/more regulation.

      Your opinions can never be addressed by BMORG if there is no event, so take that fire and apply it to fighting for the EVENT.

      Report comment

    • aFein says:

      Agree Teresa…however a lot of what you are concerned about was directly addressed by the cultural direction group that they are actively working on to fix these issues. I’m very curious how they can right the ship.

      Report comment

  • Understandable, predictable as art and BM mirrors the society zeitgeist. WE are in a Trump/Authoritarian nightmare also with new youth with a “whatever” clique and less than superior spiritual attitude overlay. WE always we there for the Party, “life is a party” 96 yr old dancer….. we work so we can party ! Yet the cooperative becoming competitive and the authorities becoming more hostile we must : Establish parameters and priorities for burners and fight back with lawyers for Env. Imp. Statement certification. Regroup ! Buy land in Amargosa Valley Nye county ! No building codes !

    Report comment

  • Sir Loin says:

    I used to care. But after the Facebook Like being allowed on the Playa and called “Art” I stopped attending. And reading about the camps like OverKill that are exclusive and operated by Serfs that are lied to about their experience there; I don’t regret my choice.
    Burning Man has sold out long ago to the mighty $$$. It’s already over. These are just symptoms of the death of BM.
    I’m sure it will continue despite all of this. But you won’t get any more of my valuable time and hard earned money.

    Report comment

    • Dougie Fresh says:

      So sad that your outlook is so sad!

      Report comment

      • Richard Quist says:

        So sad that you clearly DID NOT read the DEIS in entirety. This is about BMO asking the BLM for permission to increase the population to 100,000 a fact that has been conveniently left out of the latest JRS and all of these 47 comments. LNT? Theres a fucking aircraft on the playa and I walked down a very visible Esplanade three days ago. Pulling at liberal heart strings is all I see. Yeah I dont go to BM to find Skrillex

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    • Tres says:

      Apparently all empires eventually die but seldom gracefully.

      Burning Man had a good run.

      There is no need to cause retirement to be a death sentence. But they will, I have no doubt. Greed is seldom embellished with wisdom.

      Report comment

  • Future thinker says:

    It’s time for BM to buy land in California and move there. Nevada has shown their colors, and they are unworthy of our event. BMO needs to start thinking of the future of this event. It’s time to create something more sustainable. “Leave no trace” has always been a lie. We leave millions of tons of CO2 in the atmosphere, which could be offset by a year-round solar grid in CA. We have the means and the know-how. It’s time to get out of NV, and go to a state that deserves what we offer.

    Report comment

    • Charles Laines, S.E. says:

      I like your thinking Ft. We pulled of a pretty good replication of the Big Show with BEquinox in the Mojave desert; I was surprised how many people came from across the country, but I still want the original and certainly would not be unhappy with a move. I am in the process of writing my response to DEIS and I think BMorg has provide plenty of guidance.

      Report comment

    • David Maas says:

      I really don’t think the great state of california could have an event like BM on it’s soild without trying to rob it for what it’s worth. Ask literally any small business owner in california whether they trust the state government.

      Report comment

    • Dustbunny1.0 says:

      What Future Thinker said.

      Report comment

    • Dallas Shewmaker says:

      This is not the doing of the State of Nevada. This is the BLM. A federal government agency that is clearly overstepping the boundary of their influence. Should BMORG decide to purchase a ton of dead, unincorporated acreage in the Nevada desert, you might find that the state would be more than forgiving. BLM wants to play money wars? All government land is available for a price. Purchase the land. Set up a post office. Establish the land as an unincorporated township of Washoe County, Nevada.

      Report comment

  • Burnt says:

    Maybe BM should take the show on the road.
    If BLM and the surrounding community of BM doesn’t appreciate the cash influx, because the millions of dollars spent in the area isn’t worth the hassle. Offer it out to the other states and communities, see who wants the business, see who wants to be put on the map. Does BM have to be held in a barren, windy, dust bowl? Not that there is anything wrong with that. New Mexico is taking nuclear waste from Canada, Michigan is taking household waste from Canada, WHY?? MONEY!!! and lots of it. Don’t think someone else wouldn’t welcome the event. Nevada BLM is just getting greedy. Offer enough money and all the fences and searches go away.

    Report comment

  • Moaboy says:

    As a former Federal lobbyist at a law firm I can assure u that while comments “must be taken into consideration “ the agency in question does not have to adopt, or abide by any comments. If the resulting Final regulation is so egregious, it could be challenged in court, but that is a long and expensive process.
    Good luck.

    Report comment

  • Katydid says:

    To those who posted asking why the BMorg doesn’t just some land, they did. Fly Ranch. Just north of where BM is currently held. My question is, why did they buy it?

    Report comment

  • Capt Wade says:

    This whole thing smacks of BLM actually looking for a way to legally remove having to deal with the BM event from their job description. They really don’t want an organization that has the money power to sue them back into compliance if they try to do something outside of their legal authority. Public lands are there for public use. They are supposed to help manage it in a fashion that allows for public use, not sit around figuring out ways to create rules and regs that prevent the use.
    I can’t help but wonder if this is simply an attempt to find a way to generate untenable “rules” as a way to cause the event to fail, thereby getting rid of it. They obviously cannot just say, “You can’t have here anymore” because their job is managing the land, making it available so we CAN have public events on it. The truth is, they are just trying to harrass BM off the Playa. Plain and Simple.

    Report comment

  • Yr says:

    Be careful, the blm comment page resets itself!!!

    Write your comment offline and then paste it, I just wasted 30mins :(((

    Report comment

  • Dan Steinberg says:

    I just submitted my comments successfully. you should see a notice similar to this:
    Submission Successful
    Your Submission ID is: BM-SRP-EIS-1-477303

    Report comment

  • Badger says:

    I’m not sure how best to write a good public comment given my generally contentious temper, ornery disposition and contempt of authority and all but… here are a few points I’m submitting that I’d genuinely like to see answered.

    On the issue of the barrier proposal (ie Jersey barriers) I want to know to what extent they’ve actually considered the following:

    Cost: what are the economics? Are they suggesting that these barriers be purchased or rented?
    Weight considerations. Standard cement Jersey barriers weigh ~8200 lbs/ea. That’s FOUR tons apiece!
    Availability. As has been pointed out the encircling perimeter area is appx 9 miles. I’m not sure if the DEIS is demanding a perimeter around the entirety of the proposed closure area or just the event area (ie the pentagon area marked by the orange trash fence that so many are familiar with. In either case the number of barrier sections is substantial and reasonable questions have been asked if 1) even if BM acquiesced to this blunderous exercise in stupidity would there even be an enough barriers available in the state of Nevada, Idaho, California, Oregon?
    Storage: assuming barriers are purchased would they be rented long term or annually? In either case where would such a massive number of barrier sections be stored or staged?
    Installation and removal: what would the impact be as a result of barrier installation on the playa? Logistically speaking what would the impact be of the traffic generated by flatbed trucks hauling such barriers in and off the playa. How many vehicles? How much traffic disruption? How much fuel consumed? What impact would the delivery vehicles have on the ancient Lahontan lake bed. How much dust would be generated? What would the weight of such vehicles making multiple deliveries a day to drop the barrier inventory off? How much damage would the weight of said vehicles have and how would such degradation of the playa affect dust both during and post-event?
    Impact: How degraded would current county and state infrastructure become as a result of delivery on state and county highways?
    What is the *real* purpose of the BLM digging their heels in with this absurd demand? Is it *really* concern for a mass casualty scenario as the BLM has suggested via Homeland Security. Are recommendations being made to ‘protect’ other high volume tourist areas? Have barriers been proposed at (or around) Yosemite? Yellowstone? Kings Canyon? Arches? What about the Grand Canyon? Where does the disingenuous protect-the-public posturing end?

    On the issue of Private Security: Not only do I demand assurances but I want specificity in how the BLM will guarantee my Constitutional rights against unreasonable search and seizure by demanding a private security agency to ‘screen’ attendees coming to the event.

    What is meant by screening and what is the difference between what BM Gate staff do and what a private security firm would do.
    What exactly *are* the envisioned responsibilities of a private security and will they be seen as an entity also set up to augment the Black Rock Rangers? What legal authority do they have? Can they make arrests?
    What if attendees submit to a vehicle search by Gate staff but not this private firm.
    Is the idea of this firm to replace the Gate staff? If so, why?
    How will BLM handle formal complaints against such an entity both on site and post-event?
    Have organizations such as the ACLU weighed in with their expertise

    As to other Environmental Impact Statements (EIS):

    What other EIS have been issued by the Winnemucca BLM office to other groups seeking permits and are they held to the same strict requirements as those suggested by the BLM in their DEIS?
    How are permits issued to groups like the Rocketeers? Land speed record attempts? car commercials and other non-profit entities?
    Is there a list of other permits issued on which a reasonable comparison of restrictions can be compared to?
    What other regional BLM offices in the west have issued similar a EIS reports?

    Finally, what is the entity (contractor) who was tasked with writing the DEIS and how was that contract approved? How much experience and expertise is behind such a group? How many other DEIS have they assembled and submitted? are the portions of the DEIS weighted on cultural, environmental, ecological considerations peer reviewed?

    When citizen input is submitted using the written public comment format who evaluates (i.e. weighs) the concerns and the points made by both proponents and opponents? Are those concerns and considerations passed off to an objective, impartial group? If not, why not?
    Are questions submitted to the BLM required to be answered by the BLM within a reasonable amount of time or before the issuance of the final EIS? Are questions regarding specificity and accuracy of data placed in the DEIS and EIS answered or review by the contractor who writes the draft?

    I’d appreciate people’s comments and input as to where I might be on target and where I might have run off the rails. I’d also ask that you forgive ypos and grammatical trespasses seeing as I’m hammering this out as quick as I can during my lunch. more than a little evasive given the two public comment meeting held in Nevada this month.
    I’d appreciate people’s comments and input as to where I might be on target and where I might have run off the rails in cobbling this together. I’d also ask that you forgive ypos and grammatical trespasses seeing as I’m hammering this out as quick as I can during my lunch. Thanks.

    Any direct comments can find their way to me at

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  • abcdefgh jkwse says:

    Hahaha, I love how a bunch of anti-establishment, free-love, one-with-the-universe hippies can’t figure out how to organize themselves to deal with the government. “Can someone please tell me what the problem is and what to write? Why can’t we all get along?” Good luck, losers!

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  • ActionRequiresYourVotesWhenItMatters says:

    I can see why this won’t work in our favor. The plans are so extreme and environmentally destructive I don’t see how this could pass an EIS. All that aside, reading through the comments I can also see why we can’t make this work. So many people moving in so many different directions creates a weak argument for anything. Part of me wants BM to cease completely because it would remove the wasteful element from the Playa. If it were to go away, perhaps in years to come under a different administration we would not need to waste our time and money talking to a wall. If you can’t see how they are playing you, you must be blind. This is all political theater to punish Burners because we disagree with the policies of this administration. Put your time and money where your mouths are and go vote. That is what makes the biggest difference. See you in 5 years on Playa or somewhere else. And F$*# the Plug n’ Plays on Playa.

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  • Richard Quist says:

    BMorg is lying through their teeth. The org wants to increase the population to 100,000 people. They want more money for their “nonprofit”. I was on playa two days ago and BRC is still clearly visible. I read the entire DEIS and the best option is to reduce the population. If the BMorg wants to protect the playa they need to dial it back and remove the connivence culture that leads to 4 miles of trenching for cabling.

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  • You note that “The most effective comments provide useful information to the BLM.” That is patently false. No useful info will be of any use to them, since they are obviously intent on crushing the Burning Man event regardless of useful info to the contrary. We do have private land, no? It is not under the control of BLM, right? Maybe that’s what BLM is thinking about? I said before, and I say again: We need to get the fuck out from under the foot of BLM to survive, so let’s do it.

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  • Igostem says:

    No useful info will be of any use to them, since they are obviously intent on crushing the Burning Man event regardless of useful info to the contrary. We do have private land, no? It is not under the control of BLM, right? Maybe that’s what BLM is thinking about?

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