Fact-checking BLM: Draft Environmental Impact Statement Backgrounder

The Bureau of Land Management has published its Draft Environmental Impact Statement (DEIS) for the Burning Man Event in Black Rock City, outlining a series of operational requirements and mitigations that ostensibly ensure our event remains in compliance with the National Environmental Policy Act (NEPA).

While Burning Man Project remains committed to continuing our 30-year legacy of environmental stewardship and Leaving No Trace, many of the measures recommended by BLM are unreasonable, untenable, attempt to solve problems that don’t exist, and/or create new (and worse) problems. Altogether, these requirements would fundamentally change the operational integrity and cultural fabric of Black Rock City, and would spell the end of the event as we know it. This is not an exaggeration, and we need your help by April 29.

The best way to influence this outcome is for you — Burners, the general public, business owners, civic leaders, and in particular subject matter experts — to provide substantive comments to the BLM, challenging these proposed requirements on their merits. This post explains how and where to submit an effective comment. By law, these comments must be taken into consideration by the BLM in their drafting of the Final Environmental Impact Statement (FEIS), which directly affects the future of our event.

The Draft EIS does not adequately factor in the astronomical cost increases and beyond-excessive government oversight associated with BLM’s requirements. It does not adequately factor in our operational track record or expertise and proposes instead to increase federal government agency operations exponentially in order to take over or “monitor” our operations. Impacted operations would include gate and perimeter security, ticket sales, vehicle counts, population tracking, and use of light sources during the event. BLM measures would insert BLM agents into Burning Man Project pre-event and post-event operations on site, when our teams are building and removing infrastructure and performing playa restoration. The proposed level of government surveillance of and involvement in our everyday operations is unprecedented and unwarranted, and is unsupported by the EIS analysis.

This post provides background information for the most egregious mitigations and monitoring located in Appendix E of Volume 2 — giving you the context, history, facts, and operational realities of each — to help you address informed, substantive comments to the BLM about both the (devastating) direct and indirect impacts of the mitigations, as well as the (often faulty) premises and assumptions on which they were built (found in Chapter 3 and the Special Studies Supporting the EIS).

Send your own EIS comments (and lend support to ours) to the BLM at: blm_nv_burningmaneis@blm.gov. Send your questions, concerns, and ideas to us at eis@burningman.org, and be sure to cc: that email address when you submit your comments to BLM. We want to hear from you.  We will be publishing a FAQ soon to answer your most common questions. We also need experts in the following subjects to submit comments and to help us with our review of the DEIS Special Studies:

As you read through this analysis, and through the EIS itself, it’s important to consider the following:

  1. The most effective comments provide relevant information or a different perspective that was not fully analyzed or taken into account in the Draft EIS. Effective questions ask about things the EIS fails to adequately address.
  2. Fact-based, substantive comments are better than opinions or feelings. “I love Burning Man and this is terrible,” while quite possibly true, is not considered a substantive comment by BLM’s standards.
  3. Challenge the substance of the mitigation AND the assumptions underlying it.
  4. If you’d reconsider your participation in Burning Man should these mitigations be implemented, state that.
  5. Review all of the mitigations and monitoring — we need comments on every one of them — and ask your friends (subject matter experts in particular) to comment as well.
  6. Don’t copy and paste somebody else’s words exactly, or it’ll be considered a form letter, and will carry less weight.
  7. All comments must be submitted by April 29, 2019.

What follows is important background information about the mitigations and monitoring proposals from BLM that concern us most. We hope this information helps you understand the issues more clearly, and we hope you will help us explain to the BLM why they shouldn’t stand.

 

Migratory Birds, Wildlife, Special Status Species and Threatened and Endangered Species

Measure SPEC-2

Require Burning Man Project (hereinafter BRC or BMP) to reduce the amount of light pollution by banning the use of high-energy lasers and searchlights being pointed straight up, and requiring shields on sources of light at night where feasible.

Background:

The methodology used by the BLM’s subject matter experts  to determine the impacts of the Burning Man event on the night sky is essentially snapshots from a satellite, called VIIRS. Black Rock City asked independent experts to review the data. These experts found that the 2017 readings “were the most poorly sampled (at the Burning Man event) in the entire 2012-2017 satellite database. In the opinion of these experts, this single anomalously high data point is insufficient evidence to produce confidence in a new trend that warrants action by Black Rock City to be taken at this time.

The expert team explained that “[u]sable VIIRS data were obtained on only 4 nights of the 9-day [event] in 2017. Indeed, the VIIRS measure on 29 August 2017 is the highest seen that year, or for that matter, the highest seen in any year starting with 2012. The second highest value occurred in 2012… The high value on 29 August could reflect an unusual occurrence at [BRC] at the time the VIIRS ‘snapshot’ was taken, such as a very large combustion event occurring at the time the satellite measurement was made… Since there are no additional measures (such as a second satellite measure of the same night, or any simultaneous or near simultaneous ground-based observations), the WRC study provides no data to confirm and thus add credence to this high measure, or to otherwise provide insight into its nature.”

From the Report: “The overall assessment methodology depends too heavily on VIIRS satellite measurements. There is inadequate ground-based data to investigate directly sky glow impacts of the [BRC], particularly those events during the festival that could cause significant increases in sky glow and VIIRs radiance measures. Such data during the future events would address the issue of potential ALAN changes raised by the WRC [BLM’s experts] report.

Back on Earth, Burning Man has a robust nightlife which, combined with the artists’ technical creativity and the darkness of the playa, heavily features light-based artwork. Due to daytime temperatures and compressed construction schedules, artists, Black Rock City Operations, and Department of Public Works (DPW) necessarily work at night, and require light towers and other lighting for safety. The nighttime Black Rock City skyline has become a hallmark of the Burning Man experience, including innumerable LEDs, lasers, and searchlights throughout the city. Previous environmental studies have shown the migration pattern of birds isn’t in fact impacted by light pollution emanating from the Black Rock Desert … in fact, birds are rarely encountered on the playa in hot summer months. This could be the reason why the EIS doesn’t provide sufficient data about the species and quantity of birds affected by this alleged problem. (It’s also worth noting that by far the brightest light cluster on playa is to be found at the BLM compound.)

 

Wetlands and Riparian Areas

Mitigation WET-1

BRC must ascertain with the ACOE if a Clean Water Act Section 404 Nationwide Permit 33, and/or Nationwide Permit 18 is needed. If so, the proponent must obtain those permits and provide copies to the BLM 30 calendar days before the start of the Closure Order.

Background:

BLM has taken the position that the Black Rock Desert playa during August and September is a wetland and that BMP needs to get a permit from the US Army Corps of Engineers. BMP has researched this issue and determined that no permit is required. If you have special knowledge on this issue, we would appreciate your opinion as well.  

Mitigation NAT-2

To reduce litter and trash in the PLPT Reservation and along SR 447, the proponent must place a sufficient number of dumpsters in the city and along Gate Road before its intersection with Highway 34. This is intended to reduce adverse impacts on the PLPT Reservation and SR 447. These dumpsters must be placed by 12:01 a.m. on the Friday before Labor Day and must be kept in place until Exodus is completed. To prevent overflow, BRC will be required to maintain the dumpsters during the time they are in place.

Background:

Burning Man is the largest and most successful Leave No Trace event in the world. Leaving No Trace has been one of our core principles for over 30 years, and is the bedrock of our ethos of Radical Self-reliance: we pack everything in and pack everything out. Our community’s resounding success in this area is largely due to the fact that there are no trash cans (or dumpsters) on playa, so participants must rely on themselves to Leave No Trace. Our history has proven that if you emphasize the LNT ethic and don’t offer on-site waste removal support resources, people won’t come to expect the organizing entity to handle their other needs as well. This is part of what pulls community together.

Also, this requirement would be logistically and financially crippling to Black Rock City’s operations and would create significant detrimental environmental impacts including increased traffic on Highway 447 and CR34, increased greenhouse gas emissions from hundreds of flatbed trucks transporting large, heavy loads, and increased fuel consumption. Offering dumpsters for trash disposal would undermine the core principles of Burning Man’s culture and cause environmental degradation.

According to BLM, this solution is meant to address trash falling off of cars from poorly secured loads. The fact is that after each Burning Man event concludes, Black Rock City’s Highway Cleanup Team conducts (and BRC pays for) exhaustive trash sweeps of not only of Routes 447, 446 and 34 (which are required), but we go beyond and include RT 445 and Jungo Road, as well as investigating trash complaints in Reno. Not only do we pick up after traveling Burners, our team picks up trash and debris discarded by residents, land owners, truck drivers, businesses, law enforcement, tourists, tribes, ranchers, and nature lovers year-round. This is our duty and our gift to nearby communities and the users of these public roads. Our organization works closely with the Pyramid Lake Paiute Tribe and Nevada Department of Transportation year-round to support tribally permitted operators and after the event to respond to any location where trash has been accidentally or intentionally dumped.

Additionally, members of the Pyramid Lake Paiute Tribe enjoy a thriving business of accepting and disposing of participants’ trash and recycling at post-event waste stations along SR 447, and this lucrative annual revenue source would be decimated by implementation of BLM’s plan.

BLM’s analysis fails to adequately contemplate impacts to the playa itself from the additional driving and infrastructure required for this dumpster operation.

Lastly, not only would this create significant carbon emissions from transportation of the approximately 1,500 30-yard dumpsters (weighing 5 tons each for a total of 7,500 tons, or 15 million pounds) to and from the playa, further stressing the road system, it’s estimated that this would also cost over $5M to implement, causing prohibitively higher ticket prices. This is, of course, assuming that dumpsters are even available in the region. If they are not, which is highly likely, the financial and logistical costs rise even higher. This mitigation would also require the creation, management, 24×7 monitoring, and cleanup of an approximately 360,000 square foot (that’s roughly seven football fields) transfer station (1500 8’x20’ dumpsters with 4’ between each for access) plus space for 30,000 vehicles to pull over in turn and dispose of their trash — in the middle of a National Conservation Area.

 

Public Health & Safety

Mitigation PHS-1

At all portals of entry into the Event, beginning 14 days before Labor Day, BRC will be required to contract a BLM-approved, independent, third-party, private security to screen vehicles and participants, vendors and contractors, and staff and volunteers entering the Event. Third-party, private security will report Closure Order violations, to include weapons and illegal drugs, directly to law enforcement as violations are observed so that law enforcement can respond. Third-party, private security will provide an Event summary report to the BLM within 30 days of the end of the Event.

Background:

This BLM requirement constitutes search and seizure without just cause — the “probable cause” in this case is solely and exclusively the fact that a participant is going to Burning Man, and we believe this would constitute a violation of the 4th Amendment of the U.S. Constitution.  

For many years, BRC has published and widely publicized a list of prohibited items that are not allowed into Black Rock City, including weapons, narcotics and fireworks. We enforce these restrictions when items are discovered in vehicles during entry.

Operationally, this recommendation would require dozens more lanes on Gate Road to process people in a timely manner while private security agents stop and search every single vehicle and each passenger, unpacking belongings onto the playa as BLM does now, tripling or quadrupling the area of impacted playa surface. With the current number of lanes on Gate Road, the delay from this private security operation would cause entrance times to be extended by days. Not hours, days.

We currently estimate this operation, if it were feasible and legal, would cost well over $3 million.

From the data available in the Draft EIS, it appears BLM’s experts failed to adequately consider the increased detrimental environmental impacts of this recommendation. Deleterious impacts to the environment would include increased tailpipe emissions of greenhouse gases caused by idling vehicles and additional staff transportation, increased traffic, dust, and massive playa surface disturbance. The Draft EIS speaks about the risk of civil unrest, which has not happened in Black Rock City, but does not consider at all the potential for frustrations to boil over when event entry is impeded by a private security force reporting to the federal government and the delays it will cause.

Also of great concern to Burning Man Project and the Burning Man community are the serious cultural impacts this recommendation would have. Black Rock City is a participatory environment, and a key part of that participation is volunteering. Requiring a private company to perform this unnecessary and analytically unfounded function at the event would damage this shared value within the community, and it would negatively alter the experience of thousands of visitors to public lands, since the first experience people would have upon arrival to the National Conservation Area would be an unconstitutional search of their person and belongings.

Mitigation PHS-3

BRC will be required to implement physical perimeter barriers (e.g., Jersey barriers and K-rail fence) to reduce the risk of unauthorized entry to the Event. This will be done concurrent with city and perimeter fence construction.

This proposal from BLM is not supported by the analysis, logistically onerous, environmentally irresponsible, unnecessarily redundant, prohibitively expensive, and a clear demonstration that the proposed mitigation was not sufficiently thought through. It shows a clear lack of on-the-ground institutional knowledge or full spectrum logistical understanding of the event and the environmental impact that the delivery and installation of the barriers would have on the site in question. In fact, this lack of any reasonable consideration calls into question the integrity of the whole EIS document.

Burning Man Project currently installs a nine-mile orange trash fence around the event site, which serves as our visual perimeter and is heavily monitored and patrolled by the Black Rock City Gate, Perimeter, and Exodus Staff 24 hours a day using sophisticated radar, night vision, and patrol intercept trucks in coordination with BLM Rangers. This type of fencing allows the wind to blow through but catches MOOP (Matter Out Of Place).

BLM’s barrier mitigation would dramatically increase the Burning Man event’s carbon footprint, a paradoxical recommendation for an Environmental Impact Statement. The added irony is that this “solution” would create unprecedented environmental impacts on the playa surface itself, a concern so great that BLM brought in NASA to study it. The barrier would create a massive, 10-mile-long set of dunes that would eclipse by huge margins any past dunes and need to be remediated with heavy machinery, which should not be a recommendation in an EIS. The impact to the playa surface created by 1,900 separate 10-ton loads being driven over repeatedly would create a new restoration project for both Burning Man Project and BLM to mitigate. Increased fuel consumption, greenhouse atmospheric emissions, and damage to local roads leading into the event are all results that will negatively affect the environment of Northern Nevada.

This closure area is monitored by radar capable of detecting the shape signature of anything larger than a jackrabbit both within the perimeter fence and for several miles outside or approaching the perimeter fence. Simply put, the BMP Gate, Perimeter, Exodus team has the ability to pinpoint any human being from several miles away, and can radio an intercept vehicle instantly to the exact location of any person or vehicle headed toward the city from outside the perimeter fence. It is a remarkably efficient system. It is near impossible under the current paradigm for a person or vehicle to breach the trash fence undetected, and no life threatening event has occurred or even “almost occurred” because of such a breach.

That being the case, the erection of a massive concrete or plastic barrier around the event could only generously be described as an incoherent solution completely unsupported by the Draft EIS analysis. We did some initial calculations on the logistics of such an undertaking, principally to illustrate that it appears to be unlikely that that same due diligence was done before the mitigation was suggested, and to illustrate the potential impact to our operations.

For the sake of our example, we contacted the closest available vendor to the event site that manufactures and/or provides standard concrete Jersey Barriers / K-Rail, located in Sparks, NV.

Through a phone quote, we were able to get a price of $662.00 for a single 10 foot long standard barrier. (This is actually a remarkably competitive price — we found others as high as $1200.00 each.)

As stated earlier, the perimeter fence around the BRC site is roughly nine miles long, or more specifically, 47,520 feet. The largest effective gap between two barriers that would prevent a car driving through would be four feet. This would still leave a gap that a participant could easily walk or ride a bike through. BLM did not state whether there would or could be gaps between the barriers, so we assume the worst case scenario of no gaps between the barriers.

In order to build a big, strong wall, it would require the purchase, transportation, placement, strike, return transportation and storage of 4,752 barrier lengths. A single, standard 10 foot Jersey barrier weighs 2 tons (4,000 lbs). As a top line cost, that amounts to approximately $3 million.

Before we even address the issues of moving them (all 19 MILLION POUNDS of them), it’s important to note that the vendor does not hold stock in these staggering numbers. When Burning Man Project inquired on how long the fabrication of our order would take, we were informed that the fabrication of our order would require 1,584 days, or four years and four months, assuming that the plant ran seven days a week.

Once completed, the barriers would now need to be transported. According to our transportation staff, a standard flatbed semi trailer can haul twelve barriers per trip. This would require 396 separate 115-mile one-way trips from Sparks to BRC at standard shipping rates of $3.30 per mile plus driver and gas costs. One-way shipping for the barriers would cost roughly $3150,282 which would need to then be duplicated at the end of the event, for a total of $300,564. No wonder BLM wants us to pay for future repairs to CR 34.

Once on site, the barriers would need to be offloaded and placed using variable reach forklifts. According to experts in our Heavy Equipment department, it would optimistically take an hour to offload and place a single truckload. This means we could offload and place 12 units per hour. This equates to a total of 396 man hours for offloading alone, roughly 49 days at eight hours a day, seven days a week or one month if we double the time or equipment and manpower. Of course, this entire process must then happen again in reverse at the conclusion of the event cycle.

[Editor’s Note: The preceding two paragraphs were updated on 4/16/19 to reflect new information about the size of the barriers, and the amount of equipment and time needed to transport, install and deinstall them, stemming from the fact that a flatbed can carry a dozen barriers at a time, rather than five, as originally stated.]

This single proposed idea presents millions of dollars in unnecessary costs and an impossible timeline. All of this in service of an imagined problem that is currently being more than effectively mitigated at an astronomical fraction of the time and cost. None of this even scratches the surface of other costs and concerns. Where do these barriers go after the event? How much does it cost to store them?

It does not appear that this mitigation was proposed in any interest of the Black Rock Desert environment or the sustainability of the event. Even if the unrealistic timeline could be overcome and environmental impacts resolved, the cost of this mitigation alone would represent an untenable increase in Burning Man Project’s operational costs.

Mitigation PHS-6

During pre- and post-Event time frames within the Closure Order, BRC will contract an ambulance service for emergency services.

BLM has not shown significant impact requiring mitigation. Each year during the approximately 65 days of pre and post-event, between zero and four people working within Black Rock City on the playa or in Gerlach request or require ground transportation to a local hospital. The agencies that undertake the transport are paid by insurance. There are fewer than 500 people on playa for all but 11 of the 65 days, and the peak population during those 11 days is around 3,000, at which time BRC has a sufficient number of ambulances in place on playa. This proposed requirement would cost BMP and ticket holders up to $600,000 in a typical year, or just over $150,000 per transport.

Burning Man is committed to public health and safety, as evidenced by our on-site hospital, six first aid stations, fixed-wing airplane for off-site transport, fire department, hazmatt response, crisis intervention experts, and year-round collaboration with multiple state and county agencies. BLM’s data simply does not support their recommendation. Furthermore this type of mitigation is beyond the scope of the National Environmental Policy Act.

Mitigation WHS-4

BRC will require all participants and staff on the playa to clean up and dispose of all fluids and materials by the appropriate means. The BLM will monitor disposals.

Background:

As written, this mitigation is nearly impossible to understand or comply with. Improper discharge or disposal of trash, grey and black water, human waste, fuel, and hazardous materials are already prohibited in the BLM’s Temporary Closure Order for the Burning Man event. Black Rock City already has three different teams working together on site to educate staff and participants and help ensure improper spills and disposal are minimized. Black Rock City can not create or enforce any requirement about “all fluids” or “all materials.” BLM has not defined “appropriate means” and has not shared their plan to “monitor disposals.”

Supporting the proper clean-up of all greywater, blackwater, and chemical (think paint or radiator fluid for example) spills has long been part of our year-round Leave No Trace guidelines and our on-site environmental education and compliance. Larger spills (which are rare) are remediated immediately, reported to BLM, and included in our Playa Restoration MOOP Map report, which identifies offending camps so that our Placement Team can address the issue directly with them. We clean up all remaining spills during Playa Restoration. As part of our Leave Nevada Beautiful campaign, we provide a hang-tag to every vehicle entering the event listing regional resources for proper and authorized waste disposal. Water is a fluid, and it is impossible to require all participants and staff on the playa to clean up water.

Mitigation WHS-6

The proponent will educate participants, vendors and contractors, and staff and volunteers on all wastewater (e.g., grey and black) management from motor homes, campers, and service trucks.

Background:

Black Rock City already provides information (here and here, for instance) in its primary communications channels about proper wastewater management, but can not possibly educate participants, vendors and contractors, and staff and volunteers on ALL aspects of wastewater management from motor homes, campers, and service trucks. This proposed mitigation, like so many others in the Draft EIS, exceeds the scope of NEPA by requiring a private operator to take responsibility for the actions of attendees while they are not on site. This type of requirement is excessive and doesn’t exist for other sensitive public lands, including National Parks.

Mitigation WHS-8

To prevent unnecessary and undue degradation, for BRC’s fuel storage facilities, BRC will create a spill prevention control and containment plan in accordance with 40 CFR 112, or if determined impracticable, a written plan in accordance with 40 CFR 109 that includes a written commitment of manpower, and equipment and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful or considered as a hazardous waste.

Background:

Again, we are looking into this but currently understand that neither 40 CFR 112 nor 40 CFR 109 apply to Black Rock City. Black Rock City does however have a spill prevention control and containment plan already in place as a measure of good practice.

 

Air Quality

Mitigation AQ-1

BRC must develop solutions to reduce dust events that are twice the NAAQS for PM2.5 and PM10.

Background:

The Black Rock Desert is made of compressed alkaline dust, which can be loosened by wind, people, and vehicles disturbing it year-round. Wind, a regularly-occurring weather phenomenon in Black Rock City and around the planet, will stir up dust into dust storms. The Department of Public Works already waters the streets and roads of Black Rock City, and we inform participants about the potential health effects of inhaling playa dust through our communications channels. Participants, armed with this information, are responsible for safeguarding their own personal health. Black Rock City can not mitigate the dust or the wind.

BLM Rangers and law enforcement, and the Pershing County Sheriff and Deputies routinely drive through non-designated areas repeatedly and at high speeds, causing significant, unnecessary whiteouts. The Draft EIS does not contemplate the impact of these agencies in this section or most sections of the Draft EIS.

Soils

Mitigation SOIL-2

BRC must require burn barrels for camp fires, which would be elevated at least 10 inches to prevent burn scarring.

Background:

The Draft EIS has failed to provide sufficient data to show that there are significant impacts that might need mitigations in the first place. Black Rock City has long required participants’ burn barrels to be operated and monitored safely, using physical protections that avoid heat damage to the playa surface (burn scars). For 29 years, our effective recommendation has been for fire barrels to be raised 6″ above the playa surface. We have found this to be more than sufficient to prevent burn scar damage. Raising barrels up to 10″ makes them less stable and more prone to being tipped over, while not providing any significant additional burn scar protection.

Mitigation SOIL-3

BRC will restore the playa contours by the end of the Closure Order.

Background:

BLM has not defined “playa contours” or “restore playa contours,” but as part of its regular annual Leaving No Trace efforts, Black Rock City’s Playa Restoration team runs a tactical dune-busting team that eliminates any large dunes on the event site. This is a very difficult, laborious, and time-consuming process, and one the Restoration team takes very seriously. Notably, the inclusion of a K-Rail terrorist perimeter around the event site, as required by BLM’s proposed mitigation measure PSH-3, would create a massive 10-mile-long dune (potentially two, on either side of the barriers) that would need to be eradicated, at great expense and with heavy machinery over a period of weeks or months.

 

Visual Resources

Mitigation VIS-3

BRC and the BLM must implement shielding intervention on mast-mounted work lights.

Background:

BLM has failed to demonstrate what significant impact would need to be mitigated.  Furthermore, BLM has not explained what is meant by “shielding intervention on mast-mounted work lights” and research reveals no matches for these words. If we assume this phrase refers to placing light shields above lights to limit upward light pollution, then this mitigation for Black Rock City is not supported by the analysis. Work lights, and the full light from them, are necessary  for safety during nighttime work shifts. Many artists and theme camps choose to work at night due to cooler temperatures and other factors, and BMP staff supports these efforts. “Dimming” lights potentially decreases work safety and has no demonstrable benefit to wildlife or cultural values. (Note: Tower lights used to illuminate work sites generally have lights heads that can be angled — and head units that only emit light on one side — like a flashlight. BRC is unsure what further shielding would achieve given the default construction of the industry standard equipment.) The whole of this mitigation is befuddling.

 

Economics

Mitigation ECON-1

BRC will negotiate with Washoe County to provide cost recovery for maintenance of CR 34 associated with Event traffic.

Background:

This proposed mitigation is beyond the scope of BLM’s authority. County Route 34 is a county-maintained road that was designed and built in the early 1970s to last 30-40 years, according to Washoe County records. It has surpassed its expected lifespan with year-round traffic from residents, land owners, businesses, law enforcement, tourists, tribes, ranchers, and nature lovers. Burning Man event traffic adds considerably to the use of CR 34 during summer months. State and county fuel taxes are imposed on drivers to pay for road maintenance. Burning Man staff and participants have paid millions of dollars into this fund over the years when they purchase fuel in Nevada on the way to and from the playa.  

Black Rock City has been working closely and successfully with Washoe County for several years behind the scenes to measure and study CR 34, and to understand options and costs for replacing sections of the road between Gerlach and 17 miles north where it turns to gravel at Jackson Lane. Because the road will need replacing, not just repairing, we have been working collaboratively to find a permanent solution instead of a temporary fix, and we believe we may have done just that. BLM’s Draft EIS ignores the work Washoe County and BRC have done together and instead imposes a command and control solution that Washoe County did not suggest and does not support.

Does the National Park Service make visitors pay local governments for road repair? No.

Through initiatives like the Burner Express Bus, incentivizing carpooling through our vehicle pass program, and expanding capacity of the BRC Airport, Black Rock City has worked diligently and successfully with the Nevada Department of Transportation, Nevada Highway Patrol, Washoe County, and Pyramid Lake Paiute Tribe to reduce traffic on the roads leading to Black Rock City. We believe that mandated cost recovery above and beyond those efforts is excessive and that this proposed requirement goes far beyond the scope and authority of NEPA.

 

National Conservation Areas

Mitigation NCA-1

BRC must post a reclamation bond sufficient to remove large art installations and theme camps left behind after Exodus. This bond is intended to remove the risk of unnecessary or undue degradation to the NCA and defray the costs to taxpayers.

Background:

Since 1998, only one project has had serious trouble leaving the playa at the end of the event. That project left the Burning Man event closure area just days after the event ended (while projects were still allowed to be on site dismantling), and left shallow, temporary tracks in the playa surface within the Burning Man closure area. BLM subsequently charged the producers of that project directly for the costs BLM incurred as a result of the Special Recreation Permit they were issued. No taxpayers were harmed.

BLM can not remove the risk of unnecessary or undue degradation to the NCA outside of the Burning Man event closure area by charging Black Rock City a bond, and they have conflated the actions of a separate party with BRC’s responsibilities under our permit. BLM has failed to provide data significant enough to justify this proposed mitigation. Black Rock City has passed every Site Inspection on time, well within our environmental stipulations, even under duress of severe weather, dust storms, and playa flooding. We believe this bond is unnecessary, unjustified, arbitrary, and capricious.

Mitigation NCA-2

The BLM will provide permittees with car passes for easy transit across the playa.

Background:

Burning Man Project already does this. We worked with BLM and other user groups to provide BLM permittees with car passes for easy transit across the playa through our closure order. We have gone above and beyond to accommodate rocketeer groups and ranchers, including erecting signs for them, to ensure their shared use of the area during our closure order.

Mitigation SPEC-3

BRC must educate and discourage participants from disturbing, harassing, feeding, or watering wildlife.

Mitigation SPEC-4

BRC must educate and encourage participants to report wildlife if found at the event.

Mitigation VEG-1

BRC will provide noxious weed and fire education safety information to participants.

Mitigation CULT-1

BRC must educate participants of the Nobles Trail through production and dissemination of pamphlets, showing trail maps on the front and trail facts on the reverse to be distributed at the Event.

Mitigation CULT-3

Through the website, social media, and other means approved by the BLM, BRC will inform staff volunteers, vendors and contractors and Event participants that collection, excavation, or vandalism of historical/archeological artifacts or sites is illegal.

Background:

While Black Rock City is happy to share information provided by BLM and advocate on behalf of the environment, BLM has failed to show direct significant impacts from the Burning Man event related to these five proposed mitigations and is abdicating its responsibility for public education about public lands to Black Rock City. This type of education is part of BLM’s federally-mandated mission. We pay 3% of our gross revenue to BLM — over $1 million per year on top of $3.5 million in permit fees and cost reimbursement — and they are required to use those funds in service of the National Conservation Area (NCA), including public education. BLM also have a large, fully staffed interpretive camp on the playa, centrally featured for these purposes. Burning Man should not be held responsible for doing BLM’s job. It’s considerably more than disconcerting that a government entity is seeking to regulate how and through which specific channels a private entity may communicate with the public.

 

Monitoring: Public Health & Safety

Monitoring Measure PHS-1

The BLM will monitor illegal substance activity for the full duration of the Closure Order using contracted resources if necessary. The costs of BLM employee and contracted labor will be recouped via cost recovery from the proponent.

Background:

BLM is trying to use the National Environmental Policy Act to place surveillance on Burning Man staff and participants while they are working and recreating on public lands. BLM personnel do not go on rafting trips to “monitor” the behavior of operators and clients on BLM managed lands. This mitigation is seriously overreaching.

Monitoring Measure PHS-2

The BLM will monitor the effectiveness of perimeter barriers (e.g., Jersey Barriers and K-rail fencing) from the time of installation until removed.

Background:

See above discussion outlining the preposterous foundation of this recommendation for barriers.

For the last two years, BLM has said that they are going to reduce their staffing and that BLM should not be involved in the running of a private event. Now BLM appears to be ignoring our capabilities and track record and instead assuming responsibility for watching the BRC operation 24 hours a day for the duration of closure order, an unprecedented requirement in Burning Man’s history or the history of BLM permitting operators on public lands. We have been assured time and again by the BLM Authorized Officer that BLM is not interested in escalating the agency’s operations on site and that their rightful role is top level assurance that the playa is returned after use according to our inspection guidelines. This recommendation from BLM is inconsistent with any actual data from history or analysis in the Draft EIS. Now they want to waste time and our money monitoring the installation of an absurd 9-mile Jersey barrier?

Monitoring Measure PHS-5

The BLM will monitor effectiveness of BRC’s and the BLM’s environmental and vending compliance programs.

Background:

We have worked for years internally and with BLM to ensure the effectiveness of our environmental and vending compliance programs. These programs are extremely successful and run by Black Rock City, as they should be. We have learned from the current BLM Authorized Officer that this language disguises BLM’s real intent, which is to catch people mid-act instead of assessing overall performance afterwards. This mitigation makes no sense and could lead to a situation where BLM would cite someone for failure to provide secondary fuel containment if they just arrived on playa and, in the act of unpacking, places their fuel can on the ground while they unload the secondary container.

Monitoring Measure WHS-1

The BLM will review the effectiveness of the required dumpsters in reducing litter in and around the Event site, including SR 447, during the Closure Order for 7 days after Labor Day.

Background:

See above discussion outlining the unsupported foundation of this recommendation for dumpsters.

Black Rock City already monitors litter in and around the event site, and on SR 447 for the entire duration of the closure order. In fact, we’re out there on foot and in vehicles picking up litter along the roads for two weeks after Labor Day, including picking up other people’s trash — year-round users including residents, land owners, truck drivers, businesses, law enforcement, tourists, tribes, ranchers, and nature lovers. This is our duty and our gift to nearby communities and the users of these public roads. We already have inspection standards for the event site and have passed them every year. Let our teams continue doing their excellent work. Dumpsters will not improve anything.

Monitoring Measure WHS-4

The BLM will audit the effectiveness of roadside cleanup by BRC along SRs 445, 446, and 447 and CR 34 post-Event.

Background:

See WHS-1 above.

Monitoring Measure AQ-2

The BLM or BLM-approved contractor will monitor dust aerosols during the Closure Order. The costs of BLM employee and contractor labor will be recouped via cost recovery from the proponent.

Background:

We want to make one thing perfectly clear: the proponent (in this case the Burning Man organization) pays for EVERYTHING. Every penny BLM spends related to Burning Man comes from us and you. The cover page of this Draft EIS saying BLM paid $280,000? Wrong. We paid that. Last year we even reimbursed a BLM law enforcement officer for his Smart Cart at the airport. Plus 23% extra for administrative processing of his expense.

Having been on the playa for 30 years, we are confident that the dust in this ancient lakebed is not going away and that wind is not predictable. Why would BLM suddenly need BRC to pay for a vendor to say it is dusty? Good question.

Monitoring Measure VIS-1

The BLM will implement monitoring measure of the Burning Man Event Night Skies Study (Craine and Craine 2017). The costs of BLM employee and contractor labor will be recouped via cost recovery from the proponent.

Background:

This entire response is based on a single data point totalling less than 1 second in a five year period. BRC has already confirmed the inadequacy of this analysis with a third party subject matter expert. The lack of real, provable, sustained, repeated impact causes this BLM requirement to collapse. Here too is another example of BLM’s proposed massively increased presence and excessive operational oversight.

Monitoring Measure VIS-4

The BLM will monitor to ensure high-energy lasers and large lights (e.g., spotlights) are not used during the Event.

Background:

See VIS-1 above. This requirement is based on highly-questionable scientific analysis, and it leaves the BLM open to stop almost any light source they want. There is no definition in any of the specifications at all, and there is no statistically significant impact to warrant this new requirement.

Monitoring Measure TRAN-1

The BLM will install traffic counters at 12-Mile and Gate Road 14 days before Labor Day, and they will remain in operation until 7 days after Labor Day. The costs of the equipment and BLM employee labor will be recouped via cost recovery from the proponent.

Background:

NDOT already installed counters on SR447, and BMP scans all vehicles coming into Black Rock City. Why must BMP pay for an external vendor or additional agency to validate work already undertaken by the state of Nevada and BMP? The Draft EIS analysis does not provide evidence of impacts to warrant this unnecessary operation and expenses.

Monitoring Measure REC-3

The BLM will monitor and assess visitor use numbers, patterns, and activities, and determine if desired experiences are being achieved.

Background:

How will BLM conduct this monitoring and assessment? Does the Bureau of Land Management have the expertise or mandate from Congress to judge or establish what a desired experience is and whether or not it is achieved at a private event?


Top photo by Ron Worobec

About the author: Burning Man Project

Burning Man Project

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

146 Comments on “Fact-checking BLM: Draft Environmental Impact Statement Backgrounder

  • Davide says:

    One of the best art festivals and out of the ordinary. It is terrible that it is no longer done as usual. You have my support.

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  • Janet says:

    These pigs do nothing but lie about Burners. That’s there job. They dont like are kind out there having fun. They cant get laid so they come at us with all their mombo jumbo saying shit. We are the future. We are the singers of songs and shit. Aint noting they can do to us and they know it. Let the eat static!

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    • Stevie Hate says:

      A serious piece of analysis here. Thank you for your work. Sorry it’s coming down to this. I hope everybody will do all they can to stop this and keep the event going.

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      • Dan says:

        While maybe not the most eloquent way of putting it, at best. And a bit of burner snark(which I love). Or lame troll at worst…
        I typed it into Google translate to see what comes out…
        “Obviously a lot, and I mean a VERY LOT, of unnecessary, unfounded, wasteful, overreaching restrictions and mandatory(?) implimentations, despite no hint of burden of proof or value of said measures.
        This all despite an exceptional, *and absolutely unmatched by anyone/any event on the planet* track record. Which is impecably studied and documented by the Org and participants.
        It seems like either BLM or general non-involved governing bodies just -don’t like- Burning Man, and want it gone (taxed to extinction)
        I’d say fair sentiment.

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      • Larissa says:

        Under NEPA it is required that an environmental impact statement is conducted for this event because it is a major action on land managed by the federal government. The BLM isn’t out to get you. It’s required. The land you are using should be taken care of properly and unselfishly for human and other species sake. It’s about more than just picking up trash you left behind.

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      • LMAO says:

        You’re both right.

        The BLM is complying with NEPA, which the California druggies of Burning Man support for everyone but themselves, because they’re rich white techies who better than everyone else.

        And the BLM just doesn’t want Burning Man around anymore, because it has become too big, too messy, too arrogant, and too risky.

        Oh, and Nevada has had enough of you, thanks so much. Be gone, “burners!”

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    • George Hayduke says:

      Janet: please go back to school and learn how to spell correctly. Your grammar is horrible.

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  • ShowerMan says:

    Proudly burning since 2003.
    I’m aware of the complexity of the issues and I’ll keep it short.
    The BLM wants to milk us to death because we are a threat to their conservative way of life. If we give in, I can already see the next sign at the entrance: BLM proudly presents….
    These people are not our friends. Never been. And the acquisition of Fly Ranch may be turning into golden handcuffs. BMORG has conducted so many studies on so many issues. Why not start scouting for a friendlier destination and MOVE THE EVENT ! This BLM shit will not stop and because concessions done over the years, the event has become more hostile to it’s participants.
    IMHO

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    • Voo-Doo says:

      “This BLM shit will not stop and because concessions done over the years, the event has become more hostile to it’s participants.
      IMHO”
      And mine ShowerMan.
      Bend over and spread your cheeks FOR the MAN @ Burning Man

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    • LMAO says:

      Fly Ranch is not suitable for Burning Man. The land is very different, and cannot host the festival. If whoever runs the festival tries to hold there, they will learn a series of harsh lessons, including from the state and county authorities,

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  • FuckTheBLM says:

    #FuckTheBlm !!!

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  • Cap'n Jonny says:

    Just wondering how many people would run out of gas after waiting for a day or two in line to get into the event. How would that impact the event and the environment?

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  • Kevin says:

    If BRC is so concerned about carbon emissions, then perhaps it is time to design an implement a pulsing plan for gate entry.

    A well documented and published ingress puling plan similar to egress would do wonders to limit the amount of running engines. It need only be actually be applied during peak hours but would be very effective in reducing emissions.

    If you are in a four to six hour line only the front 1.5 hour of vehicles should actually be running to creep forward towards gate. the rest of the 2.5 to 4.5 hours of lines can easily move at the announced time at tops of the hour similar to how it is completed at exodus.

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  • Tyronus says:

    While i’m not an expert in any of these technical matters , i work with these types of reports in California. This draft report is a big f*cking deal. At the very least, the government is putting the event in a very difficult negotiating position with the drafting of this overblown report. It doesn’t help that it’s super verbose and wonky – not many burners have the time to read it, digest it, and respond effectively. But the community needs to realize how serious this is.

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    • LMAO says:

      Welcome to what ranchers put up with all the time. We might be the stupid rednecks who feed you, but we aren’t too drugged out to read the requirements like you are.

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      • LMAO_Troll says:

        LMAO:
        Go back under the rock you crawled from. You are a terrible person full of hate. Not one of your comments is even worth having posted, be part of the solution not the problem. Make some constructive suggestions on what could make this better for ‘your state’. Besides the 30-something % that goes to local workers, permits, equipment rental, contractors, and fees to the state.

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      • LMAO says:

        I’ll hide under my rock, but you and your drug festival will no longer be polluting Nevada. Tough shit, fake hippie. We don’t want you here. You have worn out your welcome. Hold it in Oakland, or is that too dark for your privileged white techno-assholes? Put that in your bong and smoke it, ha ha!

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  • Blue Coyote says:

    Absolutely Orwellian.
    Why even engage in attempting to apply reason or login here?
    You cannot fight insanity with intelligence, and you cannot litigate with a agency funded by federal government.
    Like it or not, they win.
    BMORG find a new home for our beloved event. It was a good run, but your time energy and effort would be better spent on finding is a place on private land where there would be less (not none) federal “intervention.”

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  • Jonny says:

    First year to attend for me, so apologies for my ignorance of the whole experience.
    Seeing this play out from the other side of the Atlantic, is little surprise to us.
    So what to do?
    Fight it? Really? Before you savage me, please think about this.
    We can all burn the man, wherever we are on our beautiful planet. Tech can help link us. Why not think about de-escalation and globalisation at one and same time?
    If we fight them, they get what they want.
    Outsmart them and get what we all want, 10,000 burning men simultaneously.
    But this would look like we gave in right ? And the MAN won. Correct. He won. But thru’ our munificence, we get to take this amazing event further and wider…
    If we fight, we lose; time, money, resource, love, compassion and most importantly the TRUTH.
    Change the game on the MAN. Let him build walls and watchtowers, destroy environments, harrass and detain people; for that’s his level of intellect. Do we really want to waste our lives trying to fight incompetence that is clear to a single celled amoeba?
    i don’t know how many people love and support this event, say a million?Globally. Is it not time for all that energy, intelligence, love, creativity, passion to be Harmonised??
    Make this years projects make a difference, in a new way.
    Yes we would be backing down in some eyes. But…..
    Fight them at your peril.
    Let’s find ways to turn their fear of us into understanding, and their actions against us, against themselves. Jiu-Jitsu.
    The MAN will burn himself without our help.
    Truth begets Love and Love is all.

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  • Zippo says:

    Some of this stuff looks like it was written by people who’ve never even been to the Black Rock Desert, let alone to the event. ??Burning Man mitigate dust events?? You’re kidding, right??

    It probably emanates from Washington, maybe from the Trump administration. Let’s face it, in recent years the BLM’s relationship with Burning Man has become more and more tense. From what I read, the new E.I.R. won’t be finalized until fall, after the event.

    SO, let’s do it one more time for Larry, and then look for, and find, another place to have Burning Man, probably on private land. Even if Burning Man Project jumps through all these hoops, rest assured that next year there’ll be more, and on and on. The focus should be putting our positive, hopeful and creative energy into relocating the event and get out of this cycle of negativity with the BLM and their other assorted minions.
    The argument against moving the event has always been, “But we (The Org) have so much inVESTed in our relationship with the BLM. We’ll be able to work something out”. Now I think larger forces are at work than Burning Man Project can cope with and preserve the event in any form like it’s been.
    Oh, and BTW, sell Fly Ranch and take the 6 million the BMP paid for it and put the money into a down payment on some land we’ll own. It’s an asset that won’t be relevant any more.

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    • christopher quintana says:

      Good comment. Thumbs up

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    • LMAO says:

      You’re right to look to private land, but it will not spell freedom from regulation. It will spell freedom from federal regulation — probably — but just wait until the county and the state regulators get involved.

      Poor fake hippies. You think you know so much. Not a one of you ever thought about talking to the ranchers of the intermountain West about the BLM, and if you now go private, none of you will talk to anyone else.

      Why? Because you have more money than brains, yet you think you are better. Hmm.

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      • mathias says:

        Oh my god. Fuck off.

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      • LMAO says:

        “Fuck off,” it says. Well, back at ya. And now you’ll be gone, and not a minute too soon. Welcome to the world of the Bureau of Land Management. Your turn to get screwed, ha ha!

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      • Erik says:

        LMAO, what are you talking about? You didn’t offer a single solution; please explain what you’re saying because I don’t understand

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      • JustKim says:

        You are right about talking to ranchers. They can tell how their grazing rights and water rights are being taken away and forced off land they have been grazing for decades and longer. Look at what they are trying to do to the Hammonds after Trump pardoned them. The environmentalist are going nuts and it appears this event has become a target.

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  • Sherpa says:

    Outside the box idea on the Jersey Barriers. What if the BLM wants them not to keep people from getting in, but to contain where people drive to on playa outside the closure area. You know, like say, keeping a 747 from driving out into and across open playa.

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  • Little Mikey says:

    We have participated since 1997. The increase in size over the years completely altered our experience from wonderful to unpleasant. We finally stopped participating because it simply became too huge and made too many compromises with the founding principles of radical self-expression and self-reliance.
    When you have 50,000+ participants you must have a great many more rules than when you have 10,000 participants. Those added rules have killed the old Burning Man and made it into a pale simulacrum of its original self.
    The desire to increase the event size to 100,000 when it is already too big is both logical (from a monetary standpoint) and self-defeating (in terms of the original principles of the event).
    Everything must end.
    Why not choose now to radically re-imagine Burning Man?
    Let the current incarnation as an annual event die. Create a new festival on private land limited to no more than 15,000 participants at any one time. Hold the event as a series of week-long festivals linked together to accommodate demand.
    Burning Man as we knew it is already dead.
    Long Live Burning Man.

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    • akamai says:

      my vote is to protest blm’s new requirements by cancelling burning man for a year. blm likes the income burning man brings, and cancelling it for a year based on principle will speak louder than anything else. i don’t think writing letters of protest is going to be strong enough to cause blm change. strike millions of dollars from the blm budget by cancelling burning man… that speaks loudly. if that doesn’t make them reconsider nothing will. i would rather not go to burning man for a year and maintain the foundation of principles black rock city is based on than go to burning man and have the principles forever compromised.

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      • James says:

        Yes, it is time to protest. I will protest.

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      • LMAO says:

        It’s always fun to hear from a California city slicker who doesn’t have a single clue about what the BLM does, who they work for, or what they care about.

        Look, if you want to keep your party going, then find a private landowner who will tolerate you. Please do it in California.

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      • LMAO says:

        Always fun to see another California idiot who doesn’t know the basics about how the federal government works. Those checks from the Burning Man overlords are written to the U.S. Treasury, not to the BLM.

        The BLM never sees the money, and they couldn’t possibly care less. You know the old song, “Your cash ain’t nothin’ but trash?” Better dust off your turntable and find the record.

        You think you can buy everything. It’s what you and your kind do. Works in California, but not with the BLM. You and your drug fest are going to be evicted.

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    • Jumpseat says:

      VERY WELL SAID. I TOTALLY AGREE ….

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    • Fish Taco says:

      This already exists. You are describing a regional burn.

      https://regionals.burningman.org/events/category/regional-burn/list/

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  • Bob says:

    You dumb assholes. You have always left a trace. Fake fur, fake everything, Plastic everything, Waste of gas, waste of space. Shitty art. That gets promptly dumped in Reno. You have no core principles. I have been to BM parties and have watched how you “clean up” after, Nothing even gets recycled. You are built on the core principles of skeevy old guys who like to party with half naked dust bunnies. Nothing more. Give it up. You sucked before and you suck now.

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  • Xeno says:

    I’ve worked DPW since 2001 and have to echo the last few posts. The push toward growth has destroyed the core ideas that made the event interesting or relevant. Abusing idealistic workers while kow-towing to authorities while making sure the paychecks come through (living in SF year round isn’t cheap) has corrupted the vision of the BMorg. Time to let the thing die and see what else gets built in its place. There are a TON of awesome people contributing to this decrepit idea, turn all those people free to contribute to other things.

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  • Susan says:

    Orange man bad. #resist

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  • Cliff says:

    Welcome to the real world of government control. Do you really think that you were exempt?
    Why is it so hard to follow the rules that everyone else has to follow?
    The event is held on public lands, do you feel that you should be exempted from the rules we all follow for some reason?
    Find private land to hold your event on. Do not use public lands. Problem solved. (Except that private land has rules also…)

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    • mathias says:

      The reason it isnt held on private land is the RAVE act.

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    • HammeredOne says:

      Well Cliff. Thank you for your comments. Where to start?

      BM has been following the rules for years. This BLM assessment just keeps changing the rules. A couple of simple examples might help.

      1. Hire private security to search all attendees. Hmmm, do non burners who drive onto the playa during the rest of the year (to ‘target practice’) have to submit to searches?

      2. BM must compensate for the degradation of the access roads. Really? Isn’t that what fuel taxes are for? And see point 1.

      3. BLM will ‘monitor the event to evaluate participants experiences’. See point 1.

      There are rules, and then there are insanities.

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      • LMAO says:

        Look, child, the BLM is tired of you and wants you gone. If you weren’t stoned all the time, you’d look for private land and then do careful research into state and local regulations. But no, you won’t do that because you’ve done the impossible: You’ve become even lazier than the original hippies who you imitate.

        In any case, you’ll be gone. What the BLM wants, the BLM gets.

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  • Sage says:

    Would the BLM’s initiatives described here & their new requirements be instituted for the 2019 season or the 2020 season?

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    • Barney says:

      GREAT question. No one has managed to mention that or get an answer out of the org. I suspect that’s because the EIS could affect this year’s stipulations.

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    • Frost says:

      It says right on the first narrative page of the DEIS in the Executive Summary: “ES.2… The purpose of this environmental impact statement (EIS) is to analyze the potential impacts associated with a proposed multiyear SRP for BRC to conduct the Burning Man Event from 2019–2028. …”

      So yes, this year.

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  • Meesh says:

    What self-serving tripe. 5% of burners are ok people. The other 95% just want a drug fueled orgy with no rules and no responsibility. Stop ruining the desert and local ecology.

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  • Matt says:

    Where are the tech oligarchs to go to bat for the rest of us when you need them? C’mon guys, throw your weight around Washington a little, or you won’t have any more Burning Man either.

    The jersey barriers, gate security measures, personell tracking, etc, create an image less suited to protecting non-human wild-life, than one resembling the trappings of a concentration camp where there was once an arts festival.

    The introduction of private security will transform BRC – hypothetically & in structure – into a false flag mass casualty opportunity for the Globalists, due to the unaccountability that accompanies the corporate veil and the ‘national security’ privileges afforded to intelligence contractors.

    There will be no recourse to Burners or BM.org once the image of severe violence reaches the world’s news feeds. Just think of the effects of one guy running into the man-burn. A single suicide & everyone freaked the F out! totally beyond reasonable proportion. In such a scenario visualization, BRC will go the way of country music festivals in the MGM Grand parking lot, the 4th Amemdment and the Dodo-bird.

    The Migratory Homo Sapien Sapien Endoplayatapus is the species most in danger of extinction here, and the Statists know it.

    A non-confrontational, face saving and utterly dismissive response is in order. However much I think a single year shut-down, ala Lavabit response, would send the right message, it would also sever the ritual habit, with unknowable consequences. An alternate venue must be found before we say no-thank-you to BLM and the Black Rock Dessert.

    The silver lining is that BRC can & must rebrand itself and take the opportunity to go 100% non-networked into the future. Playa surveillence must be structurally impossible so as to prevent the temptation to control it & impose a regimen of fear/violence/security responses, as is occurring in all other institutional domains.

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    • LMAO says:

      The “tech oligarchs” couldn’t give a shit about you. These are the same people selling spy equipment to both the Chinese and to the U.S. government.

      Your “free spirited” drug festival was useful to the “tech oligarchs” for a while. It made what they do look cool. Now that they’ve got their money and their power, they have already walked away from you.

      For some reason, you don’t know it. Maybe it’s that you’re afraid to know it.

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  • Voo-Doo says:

    The Dream Is Over.
    Metamorphos(e)s Indeed!
    ” You are not under arrest. I’m going to handcuff you for your own safety”…

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  • Peter says:

    Lmfao! Big government puts its big foot on the necks of the same people who tend to vote liberal…for expanding government and taxation. This is YOUR voted for government in action…the big bureaucracy. Enjoy it.

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  • Jannie says:

    I just want free stuff. I work at Starbucks. I hate all of my customers.

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  • Hey folks there’s no need to get your mental knickers tied in a knot. Chill. Think. Occam’s Razor: Simpler explanations are more likely to be true than complicated ones. Hanlan’s Razor: We should not attribute to malice that which is more easily explained by stupidity or some other more simple explanation.)

    “BLM” is not trying to kill BM. “BLM” does not want to implement (most of) the “Proposed Mitigations”. Try putting yourself in the shoes of someone in the BLM hierarchy IF there were a major terrorist event with much loss of life. The first or second thing you would see in the headlines would be something akin to, “Why Didn’t BLM Do Something To Prevent This”. And that would be parroted by blow-hard politicians in their stump speeches. And somebody in the BLM hierarchy would get tossed under the bus as the sacrificial goat.

    So, they are making some proposals which, if implemented, could be said to have prevented this calamity. “We proposed it and the public rejected it.” Really though, a legitimate argument could be made that they are doing what they are supposed to be doing. And yes, in common parlance it’s a simple CYA strategy.

    So, play your part in this scenario. Aspire to play it well. You’re the public. Provide those very good reasons not to implement these “mitigations”. Give them feedback so that they can legitimately say, “We proposed it but the public rejected it based upon xxx.” Notice that the most egregious proposals being made in the DEIS would be a major PITA for them. Notice that BLM would take a major financial hit if BM died (which it likely would if these “mitigations’ were implemented). Notice also that going through this charade is costing them a lot of social capital which, however much it may be obvious to you, it’s a damn sight more obvious to them. I don’t envy the position that those individuals are in.

    I have had conversations with many BLM employees, some relatively high in the hierarchy and some of them on the dirt level. Without exception (well, maybe one or two!), their expressed opinions were that, BM is cool, neat, and they compete against each other to determine who gets to “work” the event.

    Keep in mind that it’s not “The BLM”, it’s individual people faced with having to address some difficult situations. And they are our partners in making this thing work. And yes, sometimes it doesn’t seem like it but it’s true nonetheless.

    Cheers.

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    • LMAO says:

      BLM doesn’t care about the “major financial hit.” You are obviously a clueless California weenie who doesn’t have a clue about the BLM, what they do, who they work for, and what they care about.

      BLM is the federal government’s property manager. Burning Man means absolutely nothing to them. By the way, you people are “environmentalists” until regulations interference with your drug party.

      Too bad. Stay in California where you belong.

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      • LMAO says:

        Poor Ranger Fearless doesn’t seem to understand that the BLM is going to put Burning Man out of business, ha ha! Kid, if the BLM wants to put you out of business, they will do it, and you will do nothing about it.

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      • LMAO_Troll says:

        LMAO:
        Are you ok? You seemingly hate everyone. Your troll status is legendary. I’m sorry for your children and family, if you have any.
        So much hate towards an entire state (California) which helps out the state of Nevada quit a bit. Maybe you should google that instead of trolling for hours at a time. Clearly your ranching business isn’t doing that well if you have all this free time, or maybe that’s the source of your anger and its time for you to move on.

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      • LMAO says:

        California doesn’t do shit for Nevada. You are a cancer. We should build a double electric fence around you. Obviously that won’t happen, but it’s just as obvious that your drug and trash festival is over. Couldn’t have happened to more arrogant and deserving bunch of rich techies. Good riddance.

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    • Skip says:

      “Why Didn’t BLM Do Something To Prevent This”

      Oh, right, exactly like how NORAD was held to account in 2001?

      Yeah, that’s not how these things work.

      You don’t need a scapegoat when you have a patsy.

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    • Quickwit says:

      Thanks for pointing out that it’s not “the BLM” anymore than it’s “The Government,” but rather tons of… you guessed it, PEOPLE like you and me.

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    • The Hustler says:

      Overall the BLM does good work in maintaining public lands; if anything, I’d love it if they did more to keep people from driving through and shitting on sensitive areas. However, that’s another story.

      I met a few BLM rangers both in BRC and elsewhere, and while some were in the Fox News anti-reality bubble (like a few of the trolls in these comments), generally the BLM rangers seemed to be decent people solidly anchored in reality. If I had a choice between BLM rangers and Pershing/Wascoe County sheriffs, I’d lean toward the BLM.

      This proposal seems a lot like some sort of hastily-drafted paper that an upper manager pieced together based on sources like burners-dot-me or Info Wars or scrolling through the most influencery Instagram account to appease a cabinet member who is even less informed. Or, it looks like a shot across the bow, knowing the absurdity of the mitigations and the negative environmental and economic impact of them.

      Report comment

    • Kip says:

      Blame brad Thor’s idiot fantasy novel where terrorists hit burning man. He singly handedly caused this nightmare.

      Report comment

  • Mark McCormack says:

    Pay the BLM the curent lease rate for a 10 year lease running off of last years rules, with no additonal demands or needs dictated by BLM for the next 10 years. Pay half the 10 year lease now and the other half in year 5.

    BLM would know what their budget is for 10 years and would have to adjust accordingly. BMORG would be able to grow to 100,000 peeps during that time frame.

    Being a 10 time burner, attending roughly every other year, I dont see the need for the additional police force. IMHO, the police force could be reduced. Maybe I am missing something, but I just never see the police in action – except driving around. Maybe all the police needs happen after midnight and before 6am…. When I am asleep.

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  • LMAO says:

    Oh, the irony!

    Hey San Francisco techno weenies, here you thought that us ranchers who have to put up with the BLM’s routine stupidity and arrogance were a bunch of laughable rednecks. How does it feel now, kids? Still think we’re just a bunch of militia cranks?

    BLM will win. See, you don’t own the land. The federal government does. BLM is the property manager, and they can change the terms any ol’ time they want. I guess you’ll have to do it the old-fashioned way: Find a private landowner who will tolerate you, much like the original Woodstock.

    Oh, and please do that in California. You’ve ruined your own state, so stay there. Nevada doesn’t want you. We’re no friend of the BLM, but this is one time, and maybe the only time, that I will ever be on their side. Stay home.

    Report comment

    • Elizabeth Lie says:

      We pay our land usage fees. We don’t refuse to pay and then arm ourselves and take over national lands while desecrating indigenous artifacts.

      Report comment

    • HammeredOne says:

      LM – I understand that you have an axe to grind with BLM, based on your repeating ‘I’m a rancher’ claim. I also understand that you appear to be angry and dismissive of Burners in general, and Californians specifically. I am sorry that you’re having a rough time of it, but am genuinely confused about why you are trolling this BM site. Aren’t there bovine-related websites or ‘generally pissed off about the people who invented pretty much every single piece of technology that you use’ chat rooms that you might enjoy more?

      Report comment

      • LMAO says:

        I’m laughing at you, because “Burning Man” will be shut down. You have just found out what the BLM can do, and now you’re mad at me for telling you? By the way, I’m doing just fine. You, on the other hand, will soon be doing your drugs somewhere else.

        Report comment

      • Tripod says:

        LMAO: So you think the BLM and Nevada are tired of all of the revenue they derive from this little event in the desert?

        If the BLM wanted to shut down Burning Man they would simply refuse to grant a permit.

        They don’t want that. What they want is to try to control everything about the event while profiting even more from the event.

        But you know all of that. You are only here to troll, but you aren’t particularly good at trolling…

        Report comment

    • The Hustler says:

      You don’t have to pay your ridiculously-low land usage fees. You get to demolish public land and drain aquifers for nothing while making enormous profits in your raches.

      In the rare occasion when one of you people face some necessary consequence for the destruction of public property and terrorist activities, you have giant crying temper tantrums.

      You’re not going to convince anyone, snowflake, that you people do any sort of good. Trolling the Burning Man website probably isn’t the best use of your abundant free time.

      Report comment

      • Chad says:

        >Trolling the Burning Man website probably isn’t the best use of your abundant free time.

        I’d rather fuck you wife if you weren’t a 50 year old virgin.

        Report comment

      • LMAO says:

        I’ll decide what the best use of my time is. But guess what? You will soon be getting stoned somewhere else. The BLM doesn’t want you there, and you will be gone.

        Report comment

    • SF Techno Weenie says:

      LMAO:
      Clearly you have anger issues. Sorry this has triggered you. Come to California and we can get you the help you need. We might also be able to educate you about cyber bullying and other mental issues you clearly have. You have spent hours of your day trolling this site, have you nothing better to do? Is Ranching giving you this much free time to be angry. I’m worried about your health, so much stress isn’t good for you.
      Further more, assuming everyone is too drugged out to read lets us know how narrow minded you really are. I hold 3 degrees, 2 in engineering and 1 in math. I don’t even drink, let alone do drugs. Clearly you have it all figured out.
      I honestly hope you find help for your anger, best of luck to you and your family.

      Report comment

    • nvpat says:

      It is important to remember that the Federal Government does not own this land…..THIS IS PUBLIC LAND MANAGED IN TRUST BY THE BLM FOR THE AMERICAN PEOPLE….That is why ranchers pay their grazing fees…You need to pay the American Public back for your welfare supported ranching…if you had to pay state grazing fees it would be a whole different game for you (approx. 10 times the federal fee per AUM) That said I support the alternative in the DEIS that reduces the number at the event to 50,000…keep it at that manageable level, and solve most of the problems.

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    • Kip says:

      Rancher Bundy ignored blm for decades and got away with it. Nevada’s economy and lack of income tax depends on tourists mostly form Cali spending one billion per year there. Without us you have no INCOME OR JOBS. you’re welcome.

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  • Burner Bee says:

    Some of these requirements are not practical and could not be implemented; others require more thought and could be considered in an improved form.

    The thrash disposal always has been a problem. Once outside the event, people overload the dumpsters in the surrounding communities or just toss or lose their disposables.

    Instead of setting up too many dumpsters, BRC should more aggressively show an example, insist and motivate people on HOW TO BRING IN AND CREATE LESS THRASH. While this is obviously happening to some degree already, it may not be enough as it is.

    The free and progressive spirit of the participants is obviously irking dystopian Globalist fantasies. Embedding 3rd party private security would not only be costly and offend the spirit, but indeed raise the possibility of a false flag event that is meant to extinct the flame all together.

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  • Quickwit says:

    Is it 3% of gross revenue or 3% of ADJUSTED gross revenue, meaning revenue less expenses? Form 990s don’t list “adjusted gross income,” like a 1040 or Schedule C would, but they do list revenue minus expenses. The permit says 3% of adjusted gross income plus cost recovery. Also, how is it that BLM lists Plug and Play camps as a source of revenue? Is it because equipment rentals – RVs etc are contracted so that when a plug and play camp rents services, BMP brings in revenue? 2018 permit lists the following revenue sources:
    – ticket sales
    – coffee and ice sales
    – revenue from contracts [some of which are given to BRC LLC by BLM]
    – revenue from film and photography
    – revenue from outside services and donations for management of the event on public lands
    – REVENUE FROM PLUG AND PLAY CAMPS

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    • LMAO says:

      You don’t get it. BLM wants you out of there. You got too big and too messy, and wore out your welcome. Sayonara, Burning Man. I won’t miss you, anyway. You were always a pretentious pain in the ass, not to mention the litter.

      Report comment

      • LMAO_Troll says:

        LMAO: Maybe its time for you to move since you hate it so much. You clearly have no idea what this money have done for ‘your state’, but continue to troll, all you are doing is fueling hate.

        Report comment

      • Yolanda says:

        Stop hating on the Indians. They make tacos and pick up the trash on the side of the road when they’re not too drunk to walk. BM keeps them all alive until next year. We are the dreamers of dreams. Maybe if we had more Mexicans out there, the Indians could take a break. But who cares anyway? Cinco demiyo!

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  • Clean it up says:

    Leave no trace, HA. Burners leave a trail of trash from the Black Rock all the way up 80 and back to CA. Its disgusting and you all should be ashamed.

    Report comment

    • Reniol says:

      Stop being racist. There’s 3 foot tall fence around the playa that catches all of the trash. It’s magic.

      Report comment

    • HammeredOne says:

      Based on my limited observations of roughly 1,000,000 miles of highway, I would conclude that Americans in general are not a particularly tidy people. Comes as no surprise that some Burners are like other Americans. Pretty confidant that the people who visit the playa during the rest of the year (to shoot guns, leak oil, erode the soil) leave some beer cans and cigarette butts too.

      Report comment

      • Yolanda says:

        But not as much.

        Report comment

      • LMAO says:

        Stay in California. Ruin your own state. This might be the only time I’ve ever agreed with the BLM. They have just told you to leave, and by God you WILL leave.

        Report comment

      • Yolanda says:

        Our movement has grown beyond California. We’re taking Nevada and Arizona, and probably Texas. There’s nothing you can do about it. We need to party and we need to fight for the right!

        It’s just the Indians who are a pain in the ass. But we’ve defeated them before.

        Report comment

      • LMAO says:

        Yolanda, you and your drug festival is going to be driven back to California where you belong. Why not hold it in Oakland? Too dark for you over there?

        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.
    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

  • Gringo Starr says:

    Special interests and self interest always cloak themselves in the similar robes of victimhood, martyrdom, Us vs. Them, and endless justifications. As a 4-time Burner I am of course in love with the event, the people, and the magic. But one could easily remove BM platform, and insert Oil co., Dairy industry, land developer, etc. and hear the same arguments “these bureaucrats and environmentalists cramping our style”, aka, we want what we want no matter what. Very simply, BM isn’t perfect but in fact a very messy luxury– non-sustainable, gorgeous, polluting, exhilarating, magical, unreasonable fairyland. It needs to evolve. The lack of recycling alone is absurd, as are all of the exhibitionists, sexual harassers, and party-at-any cost a-holes mixed in with truly beautiful and joyous humanity. Adapt or die.

    Report comment

    • Carla says:

      Metamorphoses: Not for the faint of heart! :) There is recycling though; recycle camp is awesome… or should I say recycle camp was awesome? Ah, adaptation…

      Report comment

    • it's a sad day says:

      I second that!

      There are indeed a lot of issues that need to be addressed without delay, some of which you mentioned above. I for my part met my husband and made a new family at BM and will be forever grateful for that and for the people making the effort every year to go out there and make it the beautiful experience it can be when done right. I personally volunteered from my first year on as well as at regionals. This way I was lucky to meet the right people (in a way).
      I for my part don’t need the wild parties, harsh drugs, inconsiderate sparkle ponies, Selfie-crazy tweens etc. there. But I go for the people, the true burners who make the event beautiful and have made my life complete. In my opinion it wouldn’t be completely wrong to cut short the “radical inclusion” principle a little bit in some departments in order to bring back some of the old spirit and focus more on the other principles which some of these categories of people seem to completely ignore (e.g. leave no trace, decommodification, radical self-reliance, communal effort, etc.)

      I would hate for BM to go, but I understand that things need to change. I do not think that most of the proposed regulations will do any good on that part though.
      As a part of the public I’m open to any realistic, ecologically and environmentally supportive regulations that will make everyone involved better-off to a degree without constricting participants freedoms. Lets try to find compromises by making regulations to improve the conditions of BLM and all 3rd parties involved so that they can in all conscience feel they did their jobs or aren’t at a disadvantage without needing to infringe on our freedoms.

      Just saying: If going to BM wasn’t what “the public” wanted to do, then “the public” wouldn’t go, now, would they?

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  • Cherub says:

    SPEC-2 Requires BRC to reduce the amount of light pollution by banning the use of high-energy lasers and search lights being pointed straight up, and requiring shields on sources of light at night where feasible to protect Migratory Birds.

    According to data reviewed on Cornell Lab of Ornithology’s Birdcast (http://birdcast.info/live-migration-maps/), there is no bird migration in this area of Nevada during the event. BLM should specify and give evidence of which birds migrate in the area at the time of the event or withdraw the Mitigation Measure.

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    • LMAO says:

      You love the environment except when you want to spoil it. Typical Californians. In any case, it doesn’t matter now. The BLM has just served an eviction notice. They’re not calling it that, but it’s what it is.

      They are going to strangle you with regulations. If you’re stupid enough to think you’ll save yourselves by complying, just wait until next year.

      Report comment

      • Kip says:

        90% of Californians weren’t born there and are from somewhere else. Nevadans out of Cali!

        Report comment

      • Jaded.Burner says:

        Eviction? What eviction? We still own the land, BLM is just going to cut out the parasites in the bay area. It’s going to make BM great again. We can pay $5 instead of $600+, and there will be no cleanup. We can use the police and medical services for free (hope none of the locals has a heart attack while we’re using their ambulance, I guess they should’ve raised taxes or moved). We’ll no longer have a ticket lottery, nor any traffic restrictions on public roads. All 250,000 burners can come! We can bring food trucks, since it will be a traffic jam. Also guns and fireworks. If that puts a few rangelands up in flames, I’m sure they’ll catch the one responsible. It’ll be nice to camp off the playa, just cut some of that rusty barbedwire out of the way. It’s only a $500 fine if they catch you. We can even start burning earlier – my German friends get 4 months off, and college kids can skip expensive CA rent all summer. Can’t wait for the man to stick it to the Man. Then these rednecks will get to really taste some Freedom and we can ditch this anti-capitalism and show them some real economics, Rainbow Festival style.

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  • Tibby Elgato says:

    I have done a considerable amount of work analyzing and commenting on Logging Plans in the state of California. Some attempts to log have been blocked for almost 10 years. This is very similar and there are a few things to keep in mind.
    1/ What is the goal of the BM organization in submitting comments to the DEIR? To create a public record on which to base a lawsuit? To show overwhelming public support?
    2/ Some of the comments from the Burning Man organization are of the battling experts category. In court, these are usually a losing proposition, the courts will generally side with the agency and the agency will always side with itself. Where the BLM is vulnerable is where they do not have any data, science or logic to back up their mitigation plans.
    3/ Many of the BLM mitigations are based on hypothetical situations that have not happened in 30 years of the event taking place.
    4/ Responses from the public or the BMORG that attack the BLM no matter how justified are a very bad idea in this situation.

    Report comment

    • LMAO says:

      It doesn’t matter what your comments say. The BLM has decided it doesn’t want you there, and this means that you will have to get stoned somewhere else. You can yammer as much as you want, but that’s how it will be.

      Report comment

      • please, repeat says:

        Dear LMAO,
        I didn’t know they started stoning people in the US. Medieval ages are back…
        Obviously you are throwing that first stone.

        btw LMAO not all of us are Californians or druggies ;)
        and I think we understand by now what YOUR view of the matter is. But please, tell us again!!

        Report comment

      • LMAO says:

        You might as well be California druggies. Be gone!

        Report comment

  • Peace says:

    Again, these answers make sense when you are considering the history of Burning Man. But Burning Man has never gone over 70,000 participants. You can’t rely on what has happened before when you are proposing a huge change in population. Drop the request to increase population and these answers make sense. If you continue to ask for 100,000 participants you put the event at risk.

    Report comment

    • LMAO says:

      It doesn’t matter now. Burning Man is on the BLM’s hit list, and the BLM always wins. Back to California, druggies, and you will not be missed.

      Report comment

      • Clank says:

        LMAO,
        Are you attempting to sabotage the constructive conversation?
        Similar to what happened in social media during the 2016 election?
        Please return to your cubical and attempt to effect the mindless masses with your rhetoric.
        I can use smaller words if you would like

        Report comment

    • Carla says:

      That’s inaccurate, Peace, on the population numbers. Still, I agree with the core of what you are saying.

      Oh, and LMAO? Fuck yer bern, you knitwit.

      Report comment

  • Scott says:

    Take a closer look at
    Phs-4
    BRC will facilitate all structures over 10 feet to be inspected by qualified and Nevada-certified building inspectors prior to occupancy.
    Depending on how they interpret PHS-4 it could be ever shade structure on playa. Anything 10′ tall that is a habitable “living” space. Temporary shade structure would be exempt if you don’t out lights on them.
    Music stages would be fine, everything else might need permitting and inspection.

    3.5.1 Public Health and Safety (Including Law Enforcement)

    Proposed Mitigations for All Event Alternatives

    Inspection by Nevada-licensed building inspectors of habitable structures over 10 feet tall provides additional protection in preventing structure collapses during the Event (Mitigation Measure PHS-4; Appendix E). Implementation of licensed inspections reduces the threats of structure collapse to the
    health and safety of participants and first responders (BLM 2018b).

    2018b. Public Health and Safety at the Burning Man Event. September 2018. Internet website:
    https://go.usa.gov/xnBTu.

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  • Ranger Magnum says:

    LMAO…

    You are right. The BLM doesn’t want us, Washoe and Pershing don’t want us, and most of Nevada doesn’t too. Hell, I wouldn’t either. I think the event has become too large and burdensome.

    But I think you may be wrong about the BLM not re-issuing a permit. I’ve read almost the entire draft EIS, and in it the BLM recognizes that if they choose to not issue a permit, people are going to come anyway. And possibly by the thousands.

    Then what? It will be like the wild fucking west. Fireworks, guns, and rampant stupidity. Other than closing the Playa for months, the BLM would be powerless to stop the hordes of people that will inevitably show up to party.

    You can’t put the genie back in the bottle. But you can limit what she does when she is out. Reduce the population back to 50k, and maybe hold the event every other year.

    And I agree 100% that the org should have bought private land. But instead, they were like a sailor on shore leave; buying up everything in sight in and around the area, without securing the events permanence. It’s kind of like buying a bunch of performance parts for a car you are only renting.

    And not all of us Califonia people are pot smoking hippies. I fucking hate weed, and listen to Metallica when off road racing.

    Anyway, gonna see how this all plays out. If the event doesn’t happen, I’ll still come out, but only to see how fast I can make it from Empire to Winnemucca on Jungo Rd. in my race car.

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    • Zimbo says:

      Every community is sick of Burners. They’re not even ‘Burners’ anymore. That endearing term ended in about 2005. Since then, it’s been a shitfest of ravers and litter’ers; people who don’t give a shit about anything other than the party. They dump their trash along the roads and anywhere in Reno they can find a bin. They trash hotel rooms in Reno and beyond and expect everyone along the way to treat them like enlightened monks.

      Even San Francisco is sick of Burners. The Mission is a delight during the months that DPW ilk are gone… And still this notion exists – that the world would be better if the Burner ethos propagated throughout the world. What the hell? This notion can only come from ignorance of who the event has devolved. Or it comes from people who took MDMA for the first time on the playa and think the high they got was from the god, Dr Zuss and struck them with a bolt of lightening, gifting them with pure enlightenment on their way back from the porta-potties.

      It’s all bullshit. Your participation is bullshit. Stop doing it. Do something else with your friends. It’s cheaper and more fun.

      Report comment

    • LMAO says:

      If they don’t get the permit and they come anyway, they will learn a very, very harsh lesson.

      Report comment

      • Ranger Magnum says:

        How harsh could it really be? It’s public land. Camping without a permit? Un-lawful gathering? I suppose trespassing if BLM closes the Playa.

        Those are pretty mild charges.

        Likely would only be a cite and release. It’s highly doubtful anyone will get hauled off to jail.

        The BLM knows people are going to show up regardless. It’s not like armed militia on the whitehouse lawn. Hippies on piece of shit land.
        Ruby Ridge this isn’t.

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      • LMAO says:

        Go, and you will find out.

        Report comment

      • Ayatollah Jones says:

        People will come anyway. People still show-up at the 1969 Woodstock festival site in Bethel NY every year. Same thing would happen here.

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  • Cindy says:

    I think the wall is actually a good idea. It will keep the head hunters out, and protect the white man. What man can’t trust the red man. We are mortal enemies. And their tacos aren’t very good.

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  • This year will be my first burn. I’m not a rich guy, not a drug user, not a partier, and not a Bay Area resident. Just an artist, nature lover, people lover, and fairly experienced camper. I really hope this year isn’t my last opportunity due to government overreach.

    I’ve submitted my comment already, focused mostly on the silly dumpster idea. BM providing dumpsters would simply be an unmitigated disaster (bad pun intended) for any number of reasons (including being a clear example of a “tragedy of the commons”).

    But at the same time, clearly more needs to be done about illegal dumping. The 2017 survey showed that ~10% of participants dumped their trash in “unpaid” dumpsters on the way back home. That’s 10% too high. (I hope I’m interpreting that slide incorrectly and that the number is much lower. But even if it’s 1%, that’s 800 people burdening someone else with their garbage.)

    There are *probably* some creative things the Org could do to improve education and to avoid selling tickets to attendees who won’t be the littering type. (I have some half-baked ideas on that, but I won’t mention them here or they might end up being taken seriously by some bureaucrat and included in the next EIS! lol)

    But there’s probably also more that can be done by the 90% who grok that LNT doesn’t stop when playa turns to pavement. One small example: maybe we need to promote “adopting” trash we see on the way back, *especially* if it looks like it might have been dumped improperly by another BRC resident. Because even though it’s not our trash, it’s “our” trash.

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  • Rebecca Willowood says:

    It is clear to me that the sum total of the absurd, conflicting, unrealistic, unconstitutional, and logistically impossible requirements being made of Black Rock City amount to a thinly-veiled attempt to simply end the festival.

    If banning Burning Man is the natural result of all of these requirements, then it is logical to interpret that as the actual intention of those imposing these “requirements”. And that itself would be a further constitutional violation of civil rights of the most egregious sort.

    I know we have lawyers in our ranks, burner family. Let’s see this ridiculous attempt to ban our freedom of expression through to its natural end: another failed attempt by “the man” to kill Burning Man.

    We will keep burning “the man” as many times as it takes!

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  • Doug Casler says:

    I just wanted to make a suggestion that I think might be a viable alternative to the 1500 trash dumpsters. I believe that if the Gerlach General Improvement District can be persuaded to open the Gerlach Transfer Station on Sun/Mon of Exodus, it could have several positive impacts.
    1st, it could almost eliminate loose trash falling off of vehicles on Hwy 445 and 447.
    2nd it could reduce the trash being disposed of in Reno and surounding area dumpsters, resulting in businesses complaining.
    3rd, It could produce substantial revenue for the Transfer Station and the GGID. If they were to receive the standard $5 per every bag of trash they take in, Perhaps the experts can estimate the total amount of vehicles exiting each day, and an average number of trash bags per vehicle multiplied by $5 to come up with an amount to show the GGID that it may be in their best interest.
    I’m sure the Transfer Station would need our volunteer help with such an influx to help manage traffic and help support their operation. Since traffic is usually moving so slowly in that area approaching down town Gerlach, impact on traffic delay could be minimal. Traffic control volunteers could help keep the flow just like they do at Gate Rd @ SR34. I envision traffic on SR34 splitting into two lanes (with signs for each option) for a few hundred feet. One going strait ahead and the other turning right onto Transfer Road. Traffic from Transfer Road would re enter the 2nd lane on SR 34, merge with the other lane and continue to Gerlach. Volunteers could also suggest or encourage vehicles with unsafe cargo (ie: loose trash) to use the right lane or to exit here.
    I’m sure that there are both obvious and unforeseen problems with this plan but like the lady (Siren) said at the BLM Hearing, “There is no problem we can’t solve!” Additional transfer trucks/trailers can be contracted out of Reno and staged there to handle the overload. Compactor trucks can be contracted to assist with collections. I have other suggestions and I would volunteer to help lead this project.
    I believe it could be a good compromise with BLM’s DEIS to satisfy the need for dumpsters on the Playa, to lessen the work load on the Hwy clean up crews, and still allow us to maintain our “Pack it in, Pack it out” LNT principle. Perhaps the idea should be considered if it hasn’t already.

    Report comment

    • LMAO says:

      Give me a break. You have been trashing the place for many years. Stay in California, and trash your own state for a change. You are not wanted here.

      Report comment

      • Doug Casler says:

        LMAO, Thank you for your comment on my post. It’s good to know that at least one person is reading it. I’m from Reno and a native to this area, and I don’t use drugs. Isn’t this my land as much as it is yours? Wouldn’t you think if the event could be held in Oakland, that it probably would be?
        BTW, Why don’t you put your name in your posts? Why hide your identity when you voice you opinion.

        Report comment

    • Clank says:

      Excellent idea Doug!

      Report comment

  • Edward Miller - Flyer says:

    Would executive order 13771 be applicable here where two regulations need to be removed for one to be added? Isn’t the BLM controlled under the Federal executive branch?

    Report comment

  • Makkusu says:

    LMAO, we are the ones we hate so… are you high? I think you need better drugs. Did California hurt you? Do you even have any black friends in Oakland?

    All that being said. I’ve burned for 12 years and have witnessed BRC change dramatically from what it used to be. This event has already completely lost its identity and it’s magic. It needs to die. It’s time. Call it. Kill Burning Man

    Report comment

    • LMAO says:

      Doesn’t sound like you have any black friends in Oakland, or you wouldn’t want to run hundreds of miles away from your “friends.” Face it, you’re nothing but a pack of rich, white, racist techno overlords. You are not wanted.

      Report comment

      • Ranger Magnum says:

        Lmao

        I’ll be there, Burningman or not. Gonna blast across the Playa in the race car. Probably won’t camp out there; I probably will stay in Reno and trailer it out there for the day.

        Anyway, I don’t see how the BLM can stop me, unless they close the Playa, which would take a whole lot of manpower. And I just don’t see that happening. But fuck, maybe you are right and they hate Burningman that much.

        But if they don’t issue a permit, and leave the Playa open, come join me for a ride. I have an extra seat in the racecar. I even have an extra fire suit and helmet. You ever been in a Baja 1000 prepped off road car? In less than a minute, I’ll have you laughing your ass off, or shitting your pants, depending on how big your balls are.

        So, you up for it? Leave in the AM, then dinner and beers at Bruno’s before sundown.

        Let’s do this, Hombré!

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  • Stop Burningman what 15 years ago mentioned most of these items. Its finally coming to light. BLM has been kinda slow.

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  • Ginny Foos says:

    While I understand the frustration. This problem is of BM’s own making. Even if you set aside that this event has become almost entirely commercialized, with literally hundreds of companies making profits from it (whether those are RV rentals, private air craft operators, “modeling” agencies, and corporate entities buying in bulk), even the non-corporate folks are leaving trash not just at the site, but all around Reno and Tahoe. Leaving no trace on the Playa while trashing the surrounding cities is spiritually and intellectually corrupt….Leave the Playa clean, but you can dump trash everywhere else. That is on top of the ongoing sexual assaults, which is the reason I stopped going at the end of the 1990s. It’s time for the organizers to grow up and take responsibility for the actions of the participants and put in REAL safeguards for both the participants and lands around Black Rock and some rules to prevent the monopolizing of the community by those with means. What the BLM is asking is actually no different than any other large festival, so be adults and figure it out just like every other festival organizers have to.

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  • Jane Doe says:

    Just copy our answers and turn them in… just like you did in school.

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  • modapkx says:

    Would executive order 13771 be applicable here where two regulations need to be removed for one to be added? Isn’t the BLM controlled under the Federal executive branch?

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  • Clank says:

    Thank you for allowing me to comment.
    First of all I attend the 2016 and 2018 Burns. I saw a dramatic increase in law enforcement form 2016 to 2018. In 2018, I felt I was under constant surveillance. In 2018, we saw multiple flybys of Blackhawk helicopters and F-16 and it seemed the majority of cars trucks and vehicles in the Playa were law enforcement vehicles. Maybe I’m being paranoid? However, Burning Man website posted concerns about the increase in search along the entry highway and within Playa. The BLM now wanting to do additional searches while entering and leaving Burning Man cause me serious concerns about my freedom and rights.

    I would like to point out that if Burning Man was a mining or oil drilling operation there would be little oversight by the BLM and none of the EIS requirements that are being attempted to be imposed. The BLM / government recently reduced the size of the Escalante Nation Park; if you do an overlay of the uranium mines and oil drill rigs you will understand why it was reduced. My point being, there are much greater polluters with massive footprints doing serious environmental damage that have far less regulation but have more lobbyist.

    If the event was a cattle ranch with 80,000 head of cattle, the BLM wouldn’t care about the dust created, the manure, damage to the hot springs, vegetation or wildlife. The beef industry has lobbyist.

    Anytime, you get 80,000 people together that have the ability to be highly organized , capable of being self-sustained in the harshest environment, have the technology to create massive fireballs, explosions, huge lasers and sound systems that can melt your ears, you are going to call attention to yourself and cause concern to those in power. The only organizations I can think of capable of pulling this kind of event off in such a short period of time is the military. I’m sure this worries some that are in power on both sides of the isle. Hence the increased surveillance.

    I think they are trying to undermine Burning Man by burdening it with undue regulation, law-enforcement and excessive costs. It’s time for Burners to unite and buy a very large tract of land that Burners control.

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