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2011 Comment Letter from Spatial-Ed PDF Print E-mail

To Whom It May Concern:

The degradation of the playa surface, evidenced by lost unique recreational opportunities, has been ignored.

I. Affected user groups and activities

It’s unusually flat surface and open space provides for activities that depend on the desert.  As the surface degenerates, unique opportunities are being lost by a wide range of users.  The ‘land of many uses’ is becoming less so.

A. Land Speed record attempts

The current land speed record was set on the Black Rock in 1997.  The surface is no longer sufficient for the needed miles of track.  Teams have looked elsewhere but choices are few.  The Bonneville salt flat cannot support the weight of such vehicles and other areas lack physical and/or bureaucratic access.

B. Rocketeers

Fugitive dust is worse every year, particularly at the September AeroPac and BALLS events which are downwind from the Burning Man clean-up.  There are limited locations in the US to obtain a 100,000-foot FAA flight waiver.

C. Landsailors

The surface is no longer smooth enough for dirt boats.  Many in the sport have been forced to move elsewhere.

D. Recreation at large

Transient dunes have increased in both size and coverage across the desert.  The hazard they present to those travelling across the desert has induced the BLM and the various user groups to include on their websites and other communications warnings against driving too fast on the deceptively flat open surface.

II. Documented desert impacts

A. Desert Research study

Their recently published study shows compression of the surface and its impacts on the invertebrates that reside on the playa.

B.  Burning Man Earth images

Burning Man Earth (BME) produces web apps to support the Burning Man organization, creates maps, and collects geospatial data during the event.  Unlike the millimeter-scale elevation change detected by DRI, the impacts they record are readily visible in their aerial images. The photo at clearly shows the BM07 perimeter fence dune crossing the open playa during BM08. The footprint of the BM08 city streets and perimeter fence is evident a year later in the northeast portion of the image taken during BM09 observations appear in their BM10 image

C.  Sand dunes on the Black Rock Desert

This website, complete with data and references, chronicles the history on the appearance of dunes on the desert.  Dunes were first observed by the site author in 1997.  In 2000, they were initially acknowledged in an e-mail by Winnemucca BLM recreation planner, Mike Bilbo.

III. Burning Man Stipulation Monitoring Reports

I have been at every Burning Man event from 1999-2008 – once each as a participant and local guest but most often associated with BLM as a volunteer (2 yrs),  employee (5 yrs),  and contractor (1 yr).   Despite a seemingly rigorous EA process, the ‘assumed permit compliance’ challenged me as a GIS Specialist to apply GIS/GPS tools to monitor and document compliance with permit stipulations.  Studies addressed census counts, trash transects, graywater, art projects and other issues. These reports are in the BLM files and can also be viewed at my web site

A. Desert surface

1. Large dune at BM07 perimeter fence

Transient dunes are indicative of the degradation of the playa surface.  Forces of nature such as seasonal variation in the rainfall and winds are critical but the human presence also plays a part.  Humans affect the playa surface by increasing amounts of fugitive dust by breaking the playa surface while traveling across the desert, and by providing structures and barriers against which the dust can accumulate and form dunes.  One documented example is the large dune formed by the BM07 perimeter fence which has persisted for years.  There are a number of opportunities for further studies.  Burning Man Earth could image the entire desert to inventory dunes.  DRI scientists could analyze these images to correlate dune development with wind and water patterns, soil types, visitor use and other relevant factors.

2.  Remaining decomposed gravel and surface discoloration

Decomposed gravel has replaced the ‘corrugated metal sheets or fire blankets overlain with sand’ as specified in the previous EA.  In 2007, a component in the decomposed gravel left orange spots on the playa that have persisted for years.   Although the previous EA specifies all non-native material (debris) be removed from the desert, gravel still remains at art burns and community burn barrel sites.   It is advised organizers return to proven burn pad materials that are more easily removed.

B. Black Rock City population limits

As determined by both the Burning Man and BLM, the previous EA identified 50,000 as the limit for effective site management.

1. The population approached the 50,000 limit in 2007 (47,366) and 2008 (49,599).  During all 5 years of the previous EA, BLM never developed a contingency plan should the population limit be exceeded.  In 2010, ticket sales exceeded limits set in the EA and the population was 51,515.  One questions the need for establishing policies if there is no intended enforcement or consequences for violations.

2. The need for accurate census data diminished when permit fees to the BLM changed from a per person/day method to a cost-recovery basis not tied to the city population.  Is the primary concern event management or calculating permit fees?

3. It is proposed that this limit be increased to 60,000 total for the next EA.  What changes will be made to ensure the event is still manageable and impacts are minimized with a 20% increase in population of 10,000 more people?

C. Playa access by the public during the event

1. The Black Rock City runway is adjacent and parallel to a major playa road originating from the 3-Mile playa access.  This road is open to the general public and could be easily confused with the runway itself.  Closer coordination between Burning Man and BLM is needed to ensure the runway location is included in the public closure areas, which it did not in 2007.  The presence of air traffic and the runway location should also be clearly noted on the maps posted at all playa access points.

2. While the event covers a small percentage of the playa, it impacts all major roads (NV447 and 34) and the 3- and 12-mile playa access points.  While there is an obvious need for the Black Rock Rangers to stop gate crashers, many have been unduly harassed while legally entering the desert with a heading that clearly does not intersect the event.  This can be corrected by properly training the event perimeter patrols and reminding them of others’ equal right to access the public land.

IV. Responsibility for desert impacts from the event and for increased year-round use

Burning Man organizers promote Leave No Trace.  This ethic was introduced by Mike Bilbo, former BLM Recreation Planner, when the event was significantly smaller.   50,000 people traveling to a one-road in/one-road out event cannot possibly ‘Leave No Trace.’  Can the predicted 60,000 future attendees even Tread Lightly?

A. The largest user group on the desert

By permit, the second largest group on the desert is the rocketeers.  They attract about 500 total to their 3 or 4 launches each year.  The combined total for every rocket event totals less than 1% of Burning Man’s peak population.

B. Month-long clean-up

Burning Man teams remain a full month after the week-long event to clean-up.  If it were truly ‘leave no trace’, why are so many people needed for a full month to clean up?

C. Allowable debris

In the spring, the BLM conducts trash transects at both randomly sampled and heavily visited sites. Most years, Burning Man has been well below the allowable 1 square foot per acre of remaining debris.  How is it that any debris that remains 6-months later is still considered ‘leave no trace?’

D. Increased desert use year-round

At a few thousand people, the second largest gathering on the desert is the now annual the Fourth of J’playa campout.  This event continues to elude the special recreation permit (SRP) process. While this not officially organized or sanction by Burning Man, many are Burners.  World- and nation-wide publicity the event has brought to the Black Rock has attracted many to the area.

Burning Man has evolved on the Black Rock.  Even with the $1,000,000+ permit fees paid to BLM and the various local economies it boosts, it probably could not find a home elsewhere.   As the largest permitted event on the public lands and the high public visibility it attracts, it is critical that BLM closely monitor and document compliance with all permit stipulations.  Some data was collected in 2009 or 2010 but never as defined studies, nor was it analyzed or published in a final report as in 2006-8.   The BLM did not contract monitoring despite turnover of most of the NCA staff and need to re-issue a new EA.  While trash transects provide some assessment of desert impacts they do not consider cumulative, long-term effects or the numerous recreation opportunities that have already been lost.

BLM is mandated to manage the public land for all users groups.   In drafting the next Burning Man EA, it is my hope that BLM not merely change the permit dates on the previous EA but that

a.  The fore mentioned issues be taken into account

b. These perspective be incorporated into new or amended permit stipulations

c. Courses of action for the monitoring and enforcement of these stipulations be prescribed

d. As the largest user group on the desert, the some responsibility for desert impacts from the event and for increased year-round use be attributed to Burning Man

Previous monitoring reports have been received favorably by the Burning Man organization with constructive comments and offers of supporting data.  Through my communications with all groups mentioned here, I see a mutual interest in further exploring the dynamics of the Black Rock Desert.  The resulting knowledge could aid the BLM in adopting policies that would restore and preserve desert activities for all user groups while minimizing impacts to the public land. This would benefit all special recreation permitees, all uses by the general public - and the desert itself.

Respectfully Yours,

Laura M. Levy

December 3, 2010