Burning Thoughts

2012

The challenge is not one of how to prevent any human-induced change,

but rather one of deciding how much change will be allowed to occur,
where, and the actions needed to control it.
Stankey, 1985 1
CONTENTS

I. Introduction……….………………………..…………..………..…….....3
A. Burning Man
B. Bureau of Land Management (BLM)
C. Moving Forward

II. Documented Impacts..……………………….….… ……..…………...4

A. Transient Dunes
B. BM 2007 Fence Dune
C. Desert Compaction
D. Decomposed Gravel

III. Limits of Acceptable Change………..…………………..…….…....22

A. The Human Presence
B. Measurable Impacts
C. Long-term Cumulative Effects

IV. The Largest User Group………..……………….………..…….…...25

A. Black Rock City Population
B. Year-Round Presence
C. Leave No Trace

V. Gradual Growth………..……………….…….……………..………...28
A. Ticket Sales
B. Clean-Up
C. Other Potential Issues

VI. BLM Management ………………….…………….………..………...29

A. Monitoring & Documentation
B. Enforcement
C. No Action Alternative – Not!
D. Outside Black Rock City

VII. Wait and See …..…………………..……………………..………...35

VIII. References………………………………..…………………….......36

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PART I – INTRODUCTION

This document aims to

 summarize documented long-term, cumulative impacts and
 relate concerns for next Burning Man Environmental Assessment (EA)

A. BURNING MAN

With over 50,000 participants, Burning Man is the largest permitted event on the public
lands for all the federal agencies. The combination art festival, social event, and
experiment in community living starts Monday before Labor Day and lasts 8 days.
Since the first ‘burn’ on the Black Rock Desert in 1990, it has continued there every year
since except in 1997 when it was on nearby private land. While all users impact the
desert, as the largest user group, Burning Man has the most significant presence.

B. BUREAU OF LAND MANAGEMENT (BLM)

Upon receipt of a permit application from Black Rock City LLC, the Winnemucca BLM
began the federally mandated analysis of potential impacts of the event. The results
were published in an Environmental Assessment (EA) 2. With the ‘Finding of No
3,4
Significant Impact’ (FONSI) , the BLM issued a 5-year Special Recreation Permit
(SRP) for Burning Man 2006-10 5. Upon review of the expired the EA and a public
comment period, the permit was extended for BM 2011 6,7.

C. MOVING FORWARD

A new EA is currently being contracted in BM 2012. The most significant issue to be

addressed in the next EA is a requested 55,000 population limit for 2012 with an annual
6% increase each year 8. This would allow for nearly 70,000 participants in 2016.

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PART II - DOCUMENTED IMPACTS

Observations summarized in this section are -

 Surface degradation indicated by the increased dune range and size
 Desert compaction as seen from the Black Rock City street imprinted on imagery
 Remaining non-native materials, spots and scars despite a Leave No Trace ethic
 Oct 2011 inspection at previous areas of concern

9-11
Refer to the 2006-08 Stipulation Monitoring Reports for detailed methods, results
and recommendations.

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A. TRANSIENT DUNES

SURFACE DEGRADATION

Dunes are not new to the Black Rock Desert but various users groups have noted an
increase in dunes size and coverage over the last dozen years.

Dune on in the Black Rock Desert in the late 1960’s.

photo credit : Neal et al 7

This prompted the BLM to issue a travel advisory in April 2000.

e-mail, Mike Bilbo, Outdoor Recreation Planner
New transient dunes have formed on the Black Rock Desert playa west of the Coyote Springs vicinity … and are a potential
safety hazard. We need to get the word out to respective publics through websites and other means. The central playa
trackways are partially covered by these dunes in certain areas and persons used to travelling at high speed, day or night,
might hit these due to low visibility (sun angle, darkness, color blending, travel direction, mirage, etc). … These dunes also
overlay parts of the land speed record trackway, especially the measured mile area.

EA & STIPULATIONS

1. The dunes and potential link to the event acknowledged in the Burning Man EA

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 Environmental Consequences 4.2.1.
Playa Sediments & Vegetation
During the past several years transient dunes have become common adjacent to the primary playa “roads” and also
downwind of Black Rock City. No complete inventory of transient dunes has occurred but the location of transient dunes
downwind of the Burning Man Event suggests that some of the transient dunes observed in the past several years are the result
of disturbances associated with the event. The actual formation of transient dunes following disturbance would depend upon
the number of strong wind events that occur following disturbances and prior to wetting rains.

2. To facilitate cumulative impact studies, two alternating sites for Black Rock
City
DESCRIPTION of PROPOSED ACTION & ALTERNATIVES
Overview of Alternatives
Two sites—Rotating between two sites would potentially allow wind eroded areas additional time between uses for recovery
associated with transport of playa sediments by surface waters versus creation of a second site with elevated levels of residual
debris when compared to overall playa area. The use of two sites would also facilitate the joint BLM/Desert Research Institute
study to determine impacts to the playa surface from a single event. This study will begin in 2006.

3. Increased disturbance and potential dunes expected with more users

Cumulative Impacts
5.4.5. Playa Sediments and Vegetation
Continuing to permit the Burning Man event at two alternating locations would be expected to result in cumulative continuing
wind erosion of the surface of the playa at the location of Black Rock City (1600 plus acres).… The anticipated increase in
number of visitors to the playa, including participants at permitted events, would lead to increased surface disturbance. This
would lead to the potential for additional formation of transient dunes. The degree to which dune formation would actually
occur is unknown.

DATA & OBSERVATIONS

1. On the ground dune inventory

In 2000, BLM volunteers attempted to map each dune and qualify height, width and
depth but the number of dunes and enormity of the desert made this a challenge.

2. Historical documentation
The ‘Sand Dunes on the Black Rock Desert’ website is a comprehensive attempt to chronicle the history of dune appearance
14
http://sites.google.com/site/blackrockdunes/

3. Desert Research Institute study

In 2010, K. Adams and D. Sada15 published the results of a millimeter-level elevation study

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of the playa examined impacts to invertebrate spores. Relationships between dune
formation and impacts to and from vertebrates on the desert were not discussed. The paper
does not detail during which years and subsequently at which Burning Man sites data was
collected.

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2006 dune
Photo Credit:
Mike Bilbo, 2006

RECOMMENDATIONS - SURFACE DEGRADATION

See page 17.

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B. 2007 FENCE DUNE

SIZE AND PERSISTENCE

GPS confirmed that the large track visible from the left bottom corner of the photo
trending towards Trego Mountain is coincident with the BM 2007 perimeter fence.
Photo credit: Black Rock dunes site 14

A large and persistent dune formed from dust accumulated against the the BM 2007
perimeter fence. When BM 2008 moved back to Site B, the fence dune crossed Black
Rock City and snagged bikes, golf carts and pedestrians traveling between the
Esplanade and Open Playa.

BM 2007 saw the worst dust storms that can be recalled in a decade or more. Most likely
this - in combination with near drought conditions for several years, are the main contributing
factors to this particularly large dune. The dune remained prominent on aerial imagery for 4
years until it was bladed during BM 2011 clean-up efforts.

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EA & STIPULATIONS

The BM 2007 fence was dragged as required

DESCRIPTION of PROPOSED ACTION & ALTERNATIVES
2.2.10. Event Take Down and Clean Up: On-Site
….The perimeter fence would be the last structure to be removed. Dunes formed as a result of dust blowing into the perimeter
fence would dragged or graded.

Environmental Consequences
4.2.1. Playa Sediments & Vegetation
Dust storms during or immediately after the event would create sediment windrows along the perimeter fence. Dragging or
grading during the cleanup phase would eliminate these windrows. Event stipulations require watering of dust areas thus
reducing the amount of material potentially available for wind movement.

DATA & OBSERVATIONS

SEPTEMBER 2007
Like all dust that accumulates along structures, the BM 2007 perimeter fence was knocked
down after the event as shown below.

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JUNE 2008

During the Spring ‘08 inspection of the BM07 site, it was noted that the dunes not only
survived but seemed to have thrived. The perimeter fence location was defined by a
series of dunes on either side of the fence.

BM 2008

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Burning Man Earth (BME) produces web apps to support the Burning Man organization
by creating maps, and collecting geospatial data. This BM 2008 image shows the BM
2007 perimeter fence dune crossing the open playa.

Photo credit: Burning Man Earth 16

Red circle added for clarity.

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OCTOBER 2011

In June 2008, these unique dunes with a shape of these dunes resembling small
mountain ranges with peaks and valleys were noted along the section crossing the BM
2008 Open Playa.

The same location was re-inspected in October 2011 with similar observations.

MODIS imagery17 shows the Quinn River flow on the desert. Overlaying Black Rock
City on a 2011 MODIS image shows that the area of interest lies along the edge of the
Quinn River flow. This is not surprising as the flow is visible is other Black Rock City
images18.

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 This juxtaposition suggests that the BM 2007
dune is diverting the Quinn River flow. Rather
than flatter dunes with ripples caused by water
flowing over them, patterns in this area show
small eddies and streams as seen in 2008 and
2011 photos here.

2011 MODIS IMAGE

Photo credits: Spatial-Ed.com 19

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This suggests the human presence is influencing natural forces. Water that would be
expected to run impeded and smooth out the desert surface could be being disrupted by
the increases surface disturbance and dunes.

This image showing Quinn River flow is featured on the covers of the Burning Man
Operating plan 20,21 and BLM Special Stipulations documents 22-26
Photo Credit: Will Rogers

RECOMMENDATIONS - SURFACE DEGRADATION

See page 17.

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C. DESERT COMPACTION

IMPRINT OF BLACK ROCK CITY STREET

Visible in this BM 2009 image is the BM 2007 fence dune and an imprint of the BM 2008
city streets.

Photo credit: Burning Man Earth 27, http://gigapan.org/gigapans/fullscreen/3431.

EA & STIPULATIONS

There is not a stipulation per se against dunes and footprints but both are indicative of
surface degradation and compaction. As discussed later, the effects many on the
desert have experienced suggest these impacts have exceeded the limits of acceptable
change.

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RECOMMENDATIONS - SURFACE DEGRADATION

The observed surface degradation evidenced by transient dunes, the BM 2007 fence
dune and imprinted city streets merit further exploration. Playa dynamics studies
could aid the BLM in adopting policies that would minimize further impacts, and
restore and preserve desert activities for all user groups.

1. Remote imagery
Imagery - rather than on the ground efforts, is necessary to inventory dune and dune
fields. Imagery could be obtained from private (Burning Man Earth, Google Earth
and/or GeoEye) or government sources (Navy, USGS).

2. GIS Modeling
Through image analysis and GIS modeling, a correlation between dune development
wind and water patterns, soil types, visitor use and other factors might be made.

3. Re-examine watering of roads

Stipulations require roads to be watered to minimize fugitive dust. Trucks can only
deliver so much water. Even significant amounts of rain, quickly dry on the large desert
surface area. Daily dust storms within the confines of the event also seem to watering
the roads does reduce fugitive dust. During Black Rock city whiteouts, areas outside of
the wind pattern of the event remain clear. This also suggests more fugitive dust is
being generated by the event than can be controlled.

4. Watering aids surface compaction

The EA suggests that compaction does not occur during the event because the desert
is dry. By adding water, the watering trucks may be contributing to the compaction of
the desert. This issue should be re-visited in the new EA.
4.2.1. Playa Sediments & Vegetation
Compaction on the playa occurs primarily on the 115 miles of playa “road” which are used almost yearlong by vehicles.
During the spring, when the moisture is at or near the surface, repeated passage of vehicles causes compaction of these areas.
The Burning Man Event would occur during the driest part of the year and on a part of the playa that dries early in the year.
Event traffic would slightly increase the potential for compaction on the playa surface for both Sites A and B in areas of high
traffic volume especially the entrance road.

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5. Propose an alternate Black Rock City
Based on observed MODIS imagery, place an alternate BRC site further from the Quinn
River flow.

6. Compare the Black Rock Desert with other deserts

There are several dry lake beds in North Nevada and beyond. It would be of interest to
determine if other playas have similar dunes and correlate dune formation (or the lack
thereof) with differences in size, environmental factors (climate, topology etc) and levels
of recreational use. First recommended for comparison would be the adjacent ‘high
28
dries’ and Buena Vista playa .

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D. DECOMPOSED GRAVEL

GRAVEL AND DISCOLORATION AT EVERY BURN PAD

In 2007, decomposed gravel (DG) was introduced as a burn pad material. Despite
efforts to pick up the gravel with backhoe much remains after the event. An unknown
element in the gravel also stained the desert orange. Upon re-inspection in October
2011, both DG and the orange stains remain at monitored art burn sites.

BM 2007

Note the orange discoloration from the decomposed gravel burn pad

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EA & STIPULATIONS

1. Decomposed gravel directly on the playa; fire not elevated above surface

2.2.6 Fire Management

Open fires would only be permitted by BRC in burn platforms or barrels raised above the playa surface. Campfires directly on
the playa surface would not be permitted.

2. Larger art burns require corrugated metal or fire blankets

2.2.6 Fire Management

Art Burns, the burning of larger art structures including “The Man”, would be permitted by BRC. Permitted burns would use
corrugated metal sheets or fire blankets overlain with sand under the burning objects to eliminate surface scarring.

Art Burns, the burning of larger art structures including “The Man”, would be permitted by BRC. Permitted burns would use
corrugated metal sheets or fire blankets overlain with sand under the burning objects to eliminate surface scarring.

3. Decomposed gravel and discolorations remain

BM 2008 Stipulation #19 Authorized Fires
19. Organizers of each “Art Burn” and BRC are responsible for implementing procedures for the complete cleanup of each
burn site consistent with stipulation #79, including, but not limited to:
a. Removal of ash.
b. Removal of unburned material such as nails, screws, and glass.
c. Grading and raking to eliminate burn scars.

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OBSERVATIONS & DATA

While the following photos document one particular site, gravel and orange discoloration
remained at many site.

JUNE AND OCTOBER 2008

These discolorations negate the need for accurate GPS navigation as the orange spots
could be detected from hundreds of feet away. Close view of this area shows the
pattern of discoloration matches that of the previous inspection photos recording the
same observation. GPS also confirmed this to be the site of the large art burn.

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OCTOBER 2011

Upon re-inspection in October 2011, these spots and others that have been carefully
monitored with gps-photos have persisted 4 years and counting.

Many more areas were found with the same type telling signs of decomposed gravel.
Although no monitoring was done in BM 2009 and BM 2010, presumably these
correspond to art and community burn barrel sites. The desert is being littered with
and stained by the same decomposed gravel intended to protect it.

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RECOMMENDATIONS

1. Return to proven burn pad materials

Encourage the use of materials for burn pads that are more easily removed. In the
past, numerous types of materials including wallboard, corrugated metal and Kevlar
have been effective.

2006 Temple
Corrugated metal and concrete blocks
burn pad

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 In 2008, all but
one burn pad
documented
by the
Monitoring
Team was of
decomposed
gravel.

2. Determine if decomposed gravel use should continue

DG does not appear to be a reliable material. It is hard to contain and an unknown element
has created lasting stains. Its components may vary from year to year and continue to
cause unpredictable impacts.

3. Improve gravel containment and recovery

If decomposed gravel will be continued to be used, explore methods of containment

(mesh netting, blankets etc) to aid in more efficient removal.

4. Examine previous BM sites

Burn platforms were not required until 2000. Some past monitoring has been done for
art burn sites and fire pits in 1994-5. These could be re-visited to follow up on
experimental methods used to recover baked and scarred sites.

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PART III – LIMITS OF ACCEPTABLE CHANGE

‘It is the mission of the Bureau of Land Management to sustain the health, diversity, and productivity of the public lands for
the use and enjoyment of present and future generations.’
BLM 29

The BLM mission and various federal policies acknowledge recreation as a legitimate
use of the public lands and make it clear it is never an option to close the public lands
to recreational users. Limits of Acceptable Change (LAC) 1 is a management approach
which also recognizes both natural processes and humans inevitably have impacts. It
aims to inventory existing conditions using quantitative measures, set standards for
desired amounts of change and create management policies to preserve conditions
within those limits. While short-term, measurable impacts have been addressed by
Burning Man and BLM, the larger, cumulative impacts evident by the loss of
opportunities unique to the desert exceeds the limits of acceptable change.

A. THE HUMAN PRESENCE

Dunes are caused by the interaction of wind, soil, weather and obstructions; however, it
is clear that the human presence also plays a significant part. As we travel across
the desert, we contribute to their formation by breaking the desert surface and
increasing fugitive dust. We also provide structures and barriers against which the dust
accumulates and forms dunes.

1. Desert users acknowledge the consequences of their affection

Burning Man, and all of us who love and foster the event, have a huge problem: We are destroying the desert
The problem is that 49,599 attendees stir up a lot of dust, which gets blown around the desert and is changing the Black Rock
Desert from one of the World's flattest places—suitable for the 1997 ThrustSSC land speed record—to a dune field.
- http://sites.google.com/site/blackrockdunes/ 14

2. Dune increase attributed to vehicle traffic

It is likely that the socio-cultural record of the Black Rock playa is most significant in explaining the presence of the playa
“dunes”. The increased use of the playa resulted in a concurrent increase in sediment budget due primarily to vehicle traffic
associated with large-scale events. The previous playa equilibrium was affected as the sediment budget crossed a threshold
where seasonal reworking could not reestablish open playa conditions. A recent increase in sediment load in the seasonal
playa lake resulted in bedform formation. The playa system is moving toward a new equilibrium associated with the new

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 sediment budget by establishing “dunes” on the open playa.
- Preliminary Analysis of Playa Bedforms of the Black Rock Desert, Washoe County, Nevada, 2000 30

3. Increased surface disturbance contributes to dunes

from Burning Man EA
3.3.1. Playa sediments and vegetation
The sediments of the playa are subject to displacement by winds when dry and disturbed. Winds that most commonly move the
surface materials are associated with frontal passage or thunderstorms. Wind movement of sediment particles can cause the
periodic formation of low, transient dunes. Wind erosion is a function of particle erodibility, surface roughness and weather
conditions. Vehicle use and other disturbances on the playa alter the surface roughness. Increased roughness slows sediment
particle movement across the surface, causing particles to accumulate on the leeward side of low features forming transient
dunes.

B. MEASURABLE IMPACTS

Six months after the event BLM and BM staff and volunteers traverse 65 plots through
the randomly chosen in Black Rock City. Non-native materials are collected and
catalogued. Debris levels have always been below allowed 1 square foot per acre.
These ‘acceptable’ amounts of debris have become the celebrated mark of success by
Burning Man, the media and BLM alike. However, they were never intended to
become the SOLE criteria for permit compliance.

C. LONG-TERM CUMULATIVE IMPACTS

Potential oil drips from vehicles31 and debris via the annual BLM inspections32-35 are
fairly easy to establish a baseline and monitor for change over time. Larger changes
such as surface degradation and compaction offer a much larger challenge to measure.
Evident, however, are the effects of these impacts. Dunes and dune fields have
increased enough to warrant safety warnings, to appear on aerial imagery, and to
inconvenience vehicles and pedestrians during the event.

The unusually flat surface and open space provides for activities that depend on the
desert. The EA addresses this issue –
4.2.3. Recreation
Physical disturbances, such as pitting or rutting of the area surface, or debris left from the event could leave the playa in a
less than ideal condition for other uses. Having a flat playa surface is critical to land sailors and land speed record attempts.

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 Even with cleanup after the event, small portions of the playa could be less usable for these activities until wetting rains
provide moisture to stabilize and redistribute playa sediments.

Unique opportunities are being lost by a wide range of users.

1. 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 few36.

2. Landsailing
The surface is no longer smooth enough for dirt boats. Many have been forced to move
elsewhere.

3. Rocketry
Fugitive dust is worse every year, particularly at the September AeroPac37 and BALLS38
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.

4. Recreational users at large

Transient dunes present a safety hazard to those travelling across the desert. BLM and
various user groups have warned against driving too fast on the deceptively flat open
surface via the Web and other communications.

Surface degradation contributed by the users of the desert themselves is making

the ‘land of many uses’ less so. This exceeds the limits of acceptable change.

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PART IV – THE LARGEST USER GROUP

Burning Man attendance has increased nearly every year since arriving on the Black
Rock in 1990. Based on past numbers and recent ticket sales, this trend is expected to
continue. This presents the largest challenge for Burning Man organizers to date. To
keep the event manageable, a sensible approach to control growth gradually has been
adopted.

A. BLACK ROCK CITY POPULATION

Burning Man is the largest user group on the desert. The second largest group on
the desert with a special recreation permit is the rocketeers whose 3-4 launches per
year attract about 500 people total. This is less than 1% of Burning Man’s peak
population during the week and does not consider increased visitation the event has
brought year-round.

* Burning Man did not take place on the public lands of the Black Rock Desert in 1997, but on adjacent private land.

Data Sources: http://en.wikipedia.org/wiki/Burning_Man 39 and growth projections 44

Please see Page 40 for more details about the proposed figures

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B. YEAR-ROUND PRESENCE

Although the previous chart shows Black Rock city population for the week, the event
has a presence on the desert much longer than 8 days.

1. Preparation and Clean-up

Burning Man is present on the desert from mid-Aug through Oct each year. Organizers
are on the desert preparing the site weeks in advance. Post-event clean-up require an
additional month.

2. Visibility
World- and nation-wide publicity the event has brought to the Black Rock has attracted
many to the area year-round.

4.2.3. Recreation
The event has introduced thousands of people from throughout the world to the Black Rock area either through participation
in the event and/or increased media coverage associated with the event, which may have long-term impacts to the recreational
environment in the area.

A proposed visitation study to measure increased year-round visitation was

recommendation in a communication accompanying the 2008 stipulation monitoring
report 40.

C. LEAVE NO TRACE

Burning Man organizers promote Leave No Trace, an ethic introduced to Burning Man
by Mike Bilbo, BLM Outdoor Recreation Planner. When the event was significantly
smaller this made sense. Although a majority of the participants are conscientious and
teams do remain a full month to clean-up, can 50,000+ people traveling to a one-road
in/one-road out event really Leave No Trace41? Is a ‘Tread Lightly’42 ethic even
appropriate?

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PART V: GRADUAL GROWTH

In preparing the BM 2006-10 EA, both Burning Man and BLM mutually determined
50,000 the maximum limit for event and site management. This limit was reached or
exceeded every year of the EA. Unlike the previous 5-year EA which set a limit of
50,000 for the entire permit period, the exact limit each year will be determined by the
authoring officer of the permit.

from Draft EA43

Under the 58,000 to 70,000-Person Maximum Alternative (Proposed Action), the Bureau of Land Management (BLM) would
issue a five-year Special Recreation Permit (2012-2016) for the Burning Man event in Pershing County, Nevada, with a
maximum population from 58,000 to 70,000 people. The authorized officer would determine the maximum population within
this range for each year of the five-year permit.

Original press releases reported Burning Man LLC had proposed for 2012 is a
population of limit of 55,000 with an annual 6% increase each year 8. The Preliminary
EA references only numbers of 58,000 and 70,000 with set limits ‘to be determined.’
therefore, number throughout this report vary as do the sources from the which the
information is quoted. While the figures for population limits have not been determined,
what is clear is that the event will grow gradually from more than the previous 50,000 to
nearly 70,000. The key is gradual growth which is intended to ease the
implementations of any necessary changes.

Will Roger is one of the board of directors that helps run the event. He spoke about wanting to grow the event recently, but
doing so at a slow pace. “For everyone concerned, slow growth is better than big growth“ 44

A. TICKET SALES

Ticket sales is the first opportunity to control the city population and currently the largest
issue Burning Man LLC has dealt with to date. 2011 was the first year tickets sold out.
A supply-and-demand market made the previously assumed 5% no-show/donation rate
invalid. The peak population in 2011 was 51,515. In 2012, in an attempt to control
demand and scalping, a lottery system was employed. Despite the best intentions, it
backfired when many who actively participate to build the city infrastructure and theme
45, 46
camps were left without tickets . The last 10,000 tickets are to be distributed by a

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STEP program designed to put tickets in the hands of those who are key to the Black
Rock City’s very existence 47.

B. CLEAN-UP
from 2008 Inspection Memo 32
…There were some aspects of the 2008 cleanup effort that raise concerns about the 2009 event and future events. Specifically:
• The level of residual debris within the City has risen 100% since 2006 and was at 60% of the standard this year.
• The number of plots that exceed the standard doubled since 2007 and two plots were more than twice the standard.
• The number of items for the most used portions of the event area (the City and the Playa) has substantially increased during
the past two years.
The area occupied by the City has grown by almost 32% in the past two years.
The increased population and increased City and Event area continues to lead to substantial increases in the area the cleanup
crew is required to cover. While outreach efforts to the population of the Event by Black Rock City, LLC (BRC) have resulted
in increased appreciation and effort by individual participants during the event, the data collected over the past several years
suggests that future efforts by the “Playa Restoration” crew will need to be increased to keep up with the changes in the event.

from 2009 Inspection Memo 33

As the city grows, it is a ‘risk that the cleanup effort becomes too large and the standard would be exceeded.

C. OTHER POTENTIAL ISSUES

Past increases were accommodated by expanded streets, more porta-potties and an

improved Exodus plan. It remains to be seen what changes will be incorporated into the
Burning Man Operating Plan to adapt to a 40% increase over the next 5 years.

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PART VI – BLM MANAGEMENT

Given the size and nature of event activities, and BLM permit fees exceeding $1.4
million, the event commands much public visibility. Past efforts have focused on law
enforcement rather the special recreation permit stipulations that ensure both visitor
safety and resource protection. To meet challenges presented by the proposed
population increase, it is critical BLM to closely monitor, document and enforce the
permit they issue.

A. MONITORING & DOCUMENTATION

The use of geospatial tools was explored for real-time monitoring during BM 2006 and
2007. GPS-cameras greatly improved the efficiency of the staff allowing organized
studies to address concerns. In 2008, monitoring was contracted to the former BLM
employee who developed and led monitoring efforts the previous 2 years. Reports
published for these 3 years concluded that short-term impacts were minimal, but
9-11
cumulative, long-term impacts addressed by the EA were ignored . Monitoring data
for BM 2009-11 was collected by internal BLM staff and volunteers but results were
never compiled or published.

B. ENFORCEMENT

2010 Metropolis theme

from Stipulations
GENERAL
1. Black Rock City LLC (BRC) is required to manage its advance ticket sales in a manner to keep the maximum population of
the event from exceeding 50,000 participants.

The population limit of 50,000 participants was closely approached or exceeded every
year of the permit. Most years lacked an action plan and reporting procedures should
Burning Man tickets exceed 50,000 people during the event. After the event, the
consequences for failing to stay below the limit were none.

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C. NO ACTION ALTERNATIVE’ – NOT!

It is generally assured a permit will be issued. While part of EA process is to consider a

‘No Action Alternative’ (i.e. no permit, no event), this is not an option for many reasons.

1. It is assumed a permit will be issued

Every year, a majority of the non-refundable tickets are sold before the annual trash
transect is even scheduled. BLM lacked time to author a new EA for BM 2011, that
event was permitted under an extension of the 2006-10 EA. However, before this
decision announced, the initial round of tickets had already been sold. 40,000 tickets
were sold for BM 2012 well before the preliminary draft EA was completed and posted
online at the contractor’s Colorado office.

2. BLM must issue a permit

Burning Man has evolved on the Black Rock. Even with the $1,400,000+ permit fees
paid to BLM and the various local economies it boosts, it probably could not find a home
elsewhere at its present size. Lacking a permit, many would still come to the desert.
Neglecting to issue a permit to Burning Man would leave BLM liable for the resulting
resource damage and compromised visitor safety. There is no choice but to issue a
permit to Burning Man. The alternative to no permit would be unthinkable…..or
perhaps something similar has arrived as discussed in the next section.

D. OUTSIDE OF BLACK ROCK CITY

With the recent ticket fiasco, many have inquired about the required distance for
camping on the desert but outside Black Rock City. With a potentially large numbers of
campers on the desert outside the provisions provided by the Burning Man
infrastructure, operating plan and permit the potential for resource damage and concern
for visitor safety is high. It is NOT an option to close desert to non-ticket holders Labor
Day weekend. BLM has faced similar issues in the past, but this issue has now been
brought to forth even more so.

These ‘organized groups’ could and (maybe) should apply for a SRP but the reality is

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that BLM permit requirements (organized/advertised group, commercial, competitive
and vending) are too vaguely defined are unclear, and the process requires more lead
time afforded between now and Labor Day 2012. Previous similar past experiences
have proven to be quite a management challenge -

1. Burning Bush
In 2004, artists gathered on the Blue Wing playa for weekend. The organizers were
encouraged to work with BLM to obtain a permit but eventually, the event disappeared.

2. 4th of J’Playa
For many years, BLM has yet to be able to locate ‘organizers’ of the now annual 4th of
J’Playa event that attracts thousands to the Black Rock.

3. Smoke Creek alternative event

Online postings appeared for an alleged rogue event on the nearby Smoke Creek
desert for those who did not receive or pursue BM 2011 tickets. No attendees were
found but the possibility prompted BLM to post a federal closure on the nearby Smoke
Creek Desert 48 and patrol the area.

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PART VII – WAIT AND SEE

 Completion of contracted EA,

 Burning Man Operating Plan
 Issued Special Recreation Permit (SRP) and Stipulations
 Monitoring, documentation and enforcement by BLM
 Cumulative, long-term impacts and effects

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PART VIII – REFERENCES

1. The Limits of Acceptable Change (LAC) System for Wilderness Planning, George H. Stankey et al, USFS, 1985.
2. Environmental Assessment: Burning Man 2006 – 2010, Special Recreation Permit , NV-020-06-EA-11, Black Rock
Desert–High Rock Canyon Emigrant Trails National Conservation Area, BLM Winnemucca Field Office, June 2006.
3. Finding of No Significant Impact: Burning Man 2006 – 2010, BLM Winnemucca Field Office, June 2006.
4. Decision Record: Burning Man 2006 – 2010, BLM Winnemucca Field Office, June 2006.
5. Special Recreation Permit: Burning Man 2006 – 2010, BLM Winnemucca Field Office, June 2006.
6. Decision Record: Burning Man 2011, BLM Winnemucca Field Office, March 2011.
7. Special Stipulations: Burning Man Event 2011, BLM Winnemucca Field Office, March 2011.
8. Burning Man Organizers Ask For 20k More Burners, Reno Gazette Journal, 2011
9. 2008 Stipulation Monitoring Report, LM Levy, Spatial-Ed.com
10. 2007 Stipulation Monitoring Report, LM Levy, Spatial-Ed.com
11. 2006 Stipulation Monitoring Report, LM Levy, Spatial-Ed.com
12. Playa Surface Features as Indicators of Environment, Proceedings 1970 Playa Lake Symposium. Texas Tech University,
Neal, James T., 1970, posted at "http://www.lib.ttu.edu/playa/ text/playa9.htm
13. Black Rock Travel Advisory, M. Bilbo, April 2000.
14. Black Rock Dunes site, C Brooks, http://sites.google.com/site/blackrockdunes/
15. Northwestern Nevada: Physical Processes and Aquatic Life, Adams, Kenneth D. and Donald W. Sada, Black Rock Playa,
Desert Research Institute, May 2010.
16. Burning Man 2008 image, Burning Man Earth, posted at http://www.gigapan.org/gigapans/15019
17. MODIS imagery FAQ, from http://lance.nasa.gov/imagery/rapid-response/frequently-asked-questions/
18. Burning Man Organizers Ask For 20k More Burners, http://unofficialnetworks.com/burning-man-organizers-20k-burners-
38595/, August 29, 2011.
19. How Wet was the Black Rock this year, Spatial-Ed.com, July 2011.
20. 2006 Burning Man Operating Plan, Burning Man LLC, 2006.
21. 2011 Burning Man Operating Plan, Burning Man LLC, 2011.
22. Special Stipulations: Burning Man Event 2010, BLM Winnemucca Field Office, 2010.
23. Special Stipulations: Burning Man Event 2009, BLM Winnemucca Field Office, 2009.
24. Special Stipulations: Burning Man Event 2008, BLM Winnemucca Field Office, 2008.
25. Special Stipulations: Burning Man Event 2007, BLM Winnemucca Field Office, 2007.
26. Special Stipulations: Burning Man Event 2006, BLM Winnemucca Field Office, June 2006.
27. Burning Man 2009 image, Burning Man Earth, posted at http://gigapan.org/gigapans/fullscreen/3431
28. Personal Communication with Mike Bilbo, Nov 2011
29. BLM Mission Statement, http://www.blm.gov/natacq/BLMMissHistExc.pdf
30. Preliminary Analysis of Playa Bedforms of the Black Rock Desert, Washoe County, Nevada, D. Craig Young, Jr.,
GeoOpt Research, Inc., July 2000.
31. Oil drip Study, http://www.burningman.com/preparation/event_survival/oildrips.html, 2003.
32. Inspection memo: Burning Man 2009, BLM Winnemucca Field Office, 2010.
33. Inspection memo: Burning Man 2008, BLM Winnemucca Field Office, 2009.
34. Inspection memo: Burning Man 2007, BLM Winnemucca Field Office, 2008.

BURNING THOUGHTS 2012 PAGE 36 OF 38 WWW.SPATIAL-ED.COM

35. Inspection memo: Burning Man 2006, BLM Winnemucca Field Office, 2007.
36. Personal Communication, Jon Higley, North American Eagle Team, Dec 2010.
37. Playa Serpents, http://www.aeropac.org/serpents.html, 2000.
38. Notes on driving at Black Rock, Experimental Rocketry Association of Arizona, http://www.ahpra.org/drive.htm.
39. Burning Man entry, Wikipedia, http://en.wikipedia.org/wiki/Burning_Man
40. Communication to BLM accompanying 2008 Stipulation Monitoring Report, LM Levy, Spatial-Ed.com, Dec 2008.
41. Leave No Trace, http://www.burningman.com/environment/resources/lnt.html
42. Leave No Trace and Tread Lightly, http://www.burningman.com/environment/resources/tread_lightly.html
43. Preliminary Environmental Assessment, DOI-BLM-NV-W030-2012-0007-EA, Burning Man 2012-2016, Special
Recreation Permit NVW03500-12-01, BLM Winnemucca Field Office, March 2012.
44. Burning Man Organizers Ask For 20k More Burners, http://unofficialnetworks.com/burning-man-organizers-20k-burners-
38595/, August 29, 2011.
45. Burning Man ticket fiasco creates an uncertain future, http://www.sfbg.com/pixel_vision/2012/02/02/burning-man-ticket-
fiasco-creates-uncertain-future
46. What was the impact of the new Burning Man lottery ticketing system in 2012?, http://www.quora.com/What-was-the-
impact-of-the-new-Burning-Man-lottery-ticketing-system-in-2012
47. Burning Man 2012 Tickets: After the Main Sale, http://blog.burningman.com/2012/01/news/burning-man-2012-tickets-
after-the-main-sale/, Jan 2012
48. BLM Issues Temporary Closures for Smoke Creek Desert,
http://www.blm.gov/nv/st/en/fo/wfo/blm_information/newsroom/2011/august/blm_issues_temporary.html, August 2011.

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SEE YOU ON THE DESERT ?!?……..

electronic version of this report is available at

www.Spatial-Ed.com

ABOUT THE AUTHOR

Laura M. Levy
Laura is the founder of Integrated Mapping Strategies, a GPS/GIS consulting business
emphasizing geographic fundamentals, hands-on training, and ongoing support. The
company empowers clients by integrating strategic thinking and geospatial tools to provide
documented, defensible data as the basis for informed decisions. As a former GIS
Specialist for BLM Winnemucca, she led efforts to monitor stipulations and daily population
figures at the Burning Man event, and continued those efforts in 2008.

This report is a volunteer effort to summarize conversations with many involved (event
attendees, managers and philosophers), and to extend previous monitoring efforts for an
event and area that continue to intrigue. As always, responsibility for all content lies solely
with the author.

Your comments or questions are warmly invited via [email protected]

v. 04.16

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