My Letter to the Nevada Bureau of Land Management

(concerning the Sonoma-Gerlach and Paradise-Denio Management Framework Plan Amendment and Draft Environmental Impact Statement)

November 24, 1998

From: Jeffrey Benner
18851 Kings Road
Homewood IL 60430-4111 U.S.A.

To: Gerald Mortiz
BLM Winnemucca Field Office
5100 Winnemucca Blvd
Winnemucca, NV 89445

Dear Mr. Mortiz:

I am writing to you about the Sonoma-Gerlach and Paradise-Denio Management Framework Plan Amendment and Draft Environmental Impact Statement. I have a number of suggestions about the document which I believe will work to the benefit of the Black Rock Desert, to the advantage of the State of Nevada, and allow the continued use of the Black Rock Desert by "large-scale" users.

First to introduce myself. I am a 36-year-old software developer and consultant who lives in the Chicago, Illinois area. I have a gross income of greater than $[censored] annually, and am the father of one child. I have a post-graduate degree from the University of Chicago. My girlfriend Debbie Schlesinger and I are active backpackers and campers, and generally plan several camping trips a year, generally in the Midwest near Chicago.

My first trip to Nevada, and my girlfriend's first trip to Nevada, was last year September 1998 to attend the Burning Man event. Because I wanted to see a little more of the state on my way to Burning Man, I flew into Nevada via Air Reno into Las Vegas. I rented a SUV from Alamo, and drove up to northern Nevada via the Grand Canyon (Arizona) and Utah. I drove to the Black Rock Desert via the "Loneliest Highway" and eventually flew back to Chicago on Air Reno, from Reno. My girlfriend and I were in Nevada for two weeks. We stayed in three hotels and ate out quite alot. Because of the SUV we bought plenty of gas in Nevada too.

It is important to note that if it had not been for Burning Man I would not have vacationed in Nevada this year, or possibly ever. This was my only long vacation, out-of-state, in two years. If it had not been for Burning Man, my only interest in Nevada would have been Las Vegas and the nearby Grand Canyon, the latter which is in Arizona and would have taken me out of Nevada. I most certainly would have thought of no reason to go to northern Nevada.

I understand the back-country use ethic. I had my own garbage bag with me, and carried out all trash when I left. I left no pits or holes at the site where I was camping. I stayed on the Burning Man site at all times during the event, and did not venture off the location. I did not build campfires on the ground. I did not let trash blow away in the wind. I brought plenty of water with me, and observed all safety and survival precautions. We used no offroad vehicles on the playa during our trip.


Burning Man was a very important event in my recent life. In 1998 I volunteered at the event for Black Rock Rangers, a volunteer safety force at the event. I was strongly impressed by the professionalism, esprit de corps, and sense of purpose of organizers at the event, and resolved to return to the event in 1999 and beyond. I will continue to put many hours of volunteer effort into the event. I was impressed by the enormous environmental awareness of organizers and attendees and the willingness to work closely with police and Nevada officials. I spent several hours my last day at the event helping with trash pickup, along with many other volunteers.

I have read much of the MFP Amendment and Draft EIS. I am concerned that many aspects of the document are very poorly researched, and that the Proposed Alternative poses potentially enormous long-term risks to the Black Rock Desert. On the first point, that of poor research and lack of factuality in the document, a number of unfounded assumptions are promulgated throughout the document. An example exists in the section "Special Recreation Permit Management". (page 2-19)

"Given increased applications for Special Recreation Permits (SRPs) and due to intensive and/or large-scale events, a concern exists that these [large-scale] activities may adversely impact sensitive resources to the point of non-recovery . . ."

This is a completely unfounded statement, a supposition or a fear without evidence, at least not with evidence obtained from the Burning Man event. The Burning Man event has never been shown to have any impact to cultural artifacts or the natural resources in the area, and has clearly been demonstrated to exercise a strong mission of environmental and cultural awareness in the area. In particular tight controls at the Burning Man event on entering and exiting the event during the event effectively precludes the possibility of the event participants endangering the nearby hot springs or segments of the Natural Historic Trail.

The Leave No Trace program of public education and direct cleanup projects following each event have prevented, year after year, trash and other types of pollution from becoming an issue. Each year the BLM has presented the Burning Man event a clean bill of health in this regard.

No evidence of impact on Indian cultural resources exists. No degradation of trails has occurred in association with Burning Man. There is no evidence that the event, at any size or time in its history, has threatened the local environment.

There seems within the document a sort of fetishism with numbers, as if the sheer size of the event, or its strangeness to certain officials within the BLM, presents a threat in and of itself. I believe before the BLM makes any conclusions and makes policies that threaten to alienate the Black Rock Desert's largest user group, that more evidence is needed. In fact the Draft EIS states, under Proposed Action Management Directive - Recreation:

"More time, however, is required to establish photo monitor and visitor use trends."

Other areas of the document state that the Limits of Acceptable Change study should take three to five years, and that certain types of data regarding the use of the playa only started to be gathered since Memorial Day 1997. It is clear from perusal of the document that you have not done enough research, and before you condemn the Burning Man event to death by adoption of the Common Pool alternative, you need to do more research.

Many, if not most, Burning Man participants are ecologically savvy and responsible people. If you, or we, in fact determine that certain types of environmental degradation are occurring, we will not fail to support or propose on our own policies which govern the size or behavior of the event to minimize these impacts. The event has a good history of policing itself.


The specific aspects of the Proposed Alternative that I found the most objectionable revolve around Common Pool and maximum event attendance size. You must realize that Burning Man needs the unique environment of the playa in order to continue. The playa is a natural tabula rasa, an environment on which a temporary community such as Burning Man can be constructed without effect on the environment. The action of water and rain on the playa, and the enormous depth of silt and clay in the basin, make the playa self-repairing after only a very short time. The lack of plants and animals removes them as a source of impact. Burning Man organizers and participants in turn have adopted the policy of not digging pits, or filling in holes dug, before we leave, so there is only the "road surface" which the natural playa process of erosion needs to reverse. It is an ideal and unique environment, and moving the event is not really an option, because anywhere else the impacts would be far greater. Only the playa is compatible with Burning Man event objectives.

It is important for you to realize that Burning Man is a temporary or transient community. We have no desire to limit the size of the event to some arbitrary number, because we want the community to grow. Whoever heard of limiting the growth of size of a city? I have never heard any state or federal body state that a city or village was too large, and that artificial means would be employed to prune the size of the city. Yet that is what you propose to do.

Burning Man wishes to grow because we are a community, not a rock concert, not a big party, not an "event". It is in the nature of a community to want to grow, to extend itself. Just because this particular community has a limited lifespan of only a few weeks does not mean that it needs to be limited in other ways.

Furthermore the use of Common Pool makes the proposal a zero-sum game, in which all users would be fighting for a limited number of "seats". Instead of forging cooperative links with the user community, you would be forcing us to fight one another for the limited Common Pool. And anyway, who was consulted or what database was used when you arrived at 50,000 user days as the Common Pool size? This seems a completely arbitrary number. No basis is given in the document for this number's value. The maximum attendance limit of 10,000 is also completely unsupported by evidence of damage to the Black Rock Desert. As I am sure many have reminded you, Burning Man in 1998 exceeded 15,000 participants, and we got a clean bill of health at the end of that event from the BLM itself. Even visits to the Hot Springs have been curtailed in 1998. Levels of trash that had to be picked up by volunteers afterwards were actually down from 1997 levels.

I agree with Burning Man project that the real culprit when targeting environmental degradation is the lone user or the unorganized desert user. As a backpacker I have noticed this phenomenon as well: serious outdoorsmen do not litter, do not commit acts of vandalism, do not venture off trails. Those who commit acts of irresponsibility are generally small groups with no proper outdoor training. Burning Man is extremely strong on education of its public and emphasizing that each participant is responsible for his or her own safety and well-being. We are a close-knit community, and it would be difficult for an individual to commit a serious act of cultural or environmental degradation without others noticing and correcting the situation. There is a huge volunteer force which prepares for the event for weeks prior, polices the event when it is underway, and cleans up afterwards. I was part of that force in 1998.


So, to summarize my position: I think that any change from current approvals of large-scale events is unwarranted at this time. The Common Pool approach is particularly damaging to development of an organized, custodial force of volunteers in the Black Rock Desert. I believe a strong, scientific and impartial study of the use of the Black Rock Desert needs to be undertaken. Any change in approvals of large-scale events should be contigent upon strong factual findings. In the meantime the BLM should approve large-scale events based upon the event's history and custodial volunteer role in the management of Black Rock Desert natural and cultural resources.

If you have any questions my work phone is 312-458-9623, home phone is 708-799-6474, pager is [censored]. Email If you want to talk directly on the phone paging me first is usually your best option.

Warmest wishes,



Jeffrey Benner

CC: Burning Man Project


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