The Burning Man occasion is looking for a renewal of its 10-12 months permit to use the federally owned Black Rock Desert website managed by the Bureau of Land Management; the BLM has answered with a bizarre, overreaching Environmental Impact Statement that ignores the lavishly documented record of Burning Man’s top notch safety and stewardship file.
For example, the new Environmental Impact Statement requires Burning Man to rent an outside security pressure to replace its all-volunteer, community-based totally Black Rock Rangers, and to have those lease-a-cops search all property of all attendees: 80,000 humans in 30,000 cars, in a high-wind, low-visibility surroundings where, further to the risk to privacy there may be additionally a big chance of large amounts of private assets being whipped away with the aid of the wind and blown everywhere in the wilderness.
The EIS also ignores Burning Man’s popularity as the sector’s biggest, first-rate-controlled “leave no trace” occasion, where every piece of waste all the way down to individual sequins and metal shavings are picked up and packed out by means of attendees. Instead, the BLM wants Burning Man to put in numerous soccer-fields’ really worth of dumpsters on the occasion’s exit, with parking for 30,000 motors to drag up to them. In addition to eroding the norm of stewardship and waste-management this is intrinsic to the competition, this would also deprive the close by Pyramid Lake Paiute sell off sites of the millions they soak up from burners who pay to have their waste legally disposed of.
The EIS also requires the advent of a 19,000,000 lb concrete jersey barrier to encircle the web page, replacing the trash fence (a wildlife-pleasant fence that catches blown waste) and the perimeter patrols (which are highly effective at catching humans sneaking into the event). The concrete barrier would do untold habitat damage and reason scarring at the playa, as well as disrupting flora and fauna.
There’s lots extra — together with a mandate for the competition to behavior anti-drug surveillance of attendees, volunteers and workforce, that’s virtually out of scope of the National Environmental Policy Act.
Here’s my remark, submitted the day past:
To whom it is able to challenge:
I am a Burning Man attendee who has attended each 12 months for the reason that 2011, and I’m part of the Liminal Labs subject camp, which celebrated its twentieth consecutive year this year. I am a research fellow on the MIT Media Lab and a Visiting Professor of Practice of Library Science on the University of North Carolina, in addition to a Visiting Professor of Computer Science at the UK’s Open University. I am also a New York Times bestselling novelist whose 2013 ebook, “Homeland,” capabilities vast motion at the Burning Man festival.
I item to numerous of the recommendations inside the Draft EIS, for motives set out beneath:
* Mitigation NAT-2
Burning Man is the sector’s biggest and most a hit Leave No Trace occasion. Our camp — and every different attendee, almost without exception — packs out *all* its waste. Every yr finishes with a multi-hour scouring of our website online with rakes and rubbish selecting gear to ensure that no longer a lot as a unmarried steel shaving or zip-tie stays on website online. We take large measures — tasking a person to journey to a paid dumpsite in a designated condominium car, then taking that automobile to a automobile wash to make it presentable for return — to make certain that our waste is well disposed of.
For the few bad actors who exercise unlawful dumping after the occasion, Black Rock City’s Highway Cleanup Team conducts exhaustive trash sweeps of no longer only of Routes 447, 446 and 34 (as required with the aid of present lets in), and also RT 445 and Jungo Road (which are not required, but whose cleanup is undertaken in the spirit of accurate citizenship). Our camp makes use of paid dumpsites on Pyramid Lake Paiute Tribal lands, infusing an awful lot-wanted cash into certainly one of America’s poorest counties. Dumpsters would quit this exercise.
Moreover the BLM’s draft EIS does now not ponder the environmental effect of maintaining the dumpsters and imparting space to provider 30,000 automobiles to apply them.
The real file — that is publicly documented in a detailed annual file from the Burning Man Organization — does not support the want for this requirement. As an expert corporation, the BLM isn’t accepted by using regulation to make coverage without evidentiary guide.
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* Mitigation PHS-1
Every yr Black Rock City is one of the lowest-crime jurisdiction in all the country of Nevada. There isn’t any proof to aid the want for separate, personal protection forces onsite. Indeed, the Black Rock Rangers — a skilled, community-based, all-volunteer pressure — are most of the most commendable and exemplary factors of the metropolis’s management. Several of my campmates are volunteer Rangers, and I actually have seen firsthand how severely they take these obligations and how nicely they carry out them.
The environmental impact of gate-searches is full-size: unpacking and repacking complete motors in a excessive-wind, unsheltered, dirt-hurricane surroundings will produce an unquantifiable — but extensive — quantity of inadvertent clutter, and divulge humans no longer suspected of any crime to significant damage to their non-public assets, to mention not anything of the privateness dimensions of these searches, if you want to pressure attendees to reveal sensitive medical gadget, personal journals, literary and religious artifacts, and different non-public, touchy and constitutionally included substances to 1/3 parties.
Without evidence of crimes or risks that justify these excessive financial, privacy, personal, and environmental costs represented by means of this degree, this advice need to be useless on arrival.
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* Mitigation PHS-three
There isn’t any proof to support the need for jersey boundaries, with the intention to blight the land, impose a big carbon footprint at the event, pose unquantifiable environmental dangers, and burden the pageant with unjustifiable and big financial fees. The present trash fence, combined with Black Rock Ranger patrols and different longstanding measures have a completely lengthy track file of maintaining trash in and unpaid attendees out.
Without any evidence, the BLM have to not ask the festival to spend $3m to install 19,000,000 lbs of concrete limitations in a sensitive wilderness habitat.
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* Mitigation PHS-6
Again, there may be no proof that present ambulance and EMS services are inadequate to handle the prevailing price of harm on the festival — and adequate evidence that current measures are enough (according to capita mortality and morbidity from all reasons at Black Rock City are many of the lowest in all of Nevada). I am licensed in first useful resource and barren region first useful resource and on events I even have used my education to assist injured human beings at Burning Man, tending them even as looking forward to skilled EMTs to arrive; in both cases, EMTs arrived in beneath 15 mins.
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* Mitigation AQ-1
With the exception of wind-storms, the best dirt I have seen at the pageant that turned into gift at sufficient concentrations to pose a health and safety threat changed into kicked up by law enforcement vehicles operated by way of local LEOs and BLM officers, who mechanically flout BRC’s 5m/h speed restrict. If BLM is involved approximately Black Rock City’s air quality, they have to teach their officers to obey the law.
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* Monitoring Measure PHS-1
The National Environmental Policy Act can not be lawfully stretched to cover surveillance of this kind. It is grossly wrong for BLM to request it.
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Concluding feedback:
The BLM’s Draft EIS reads like a farcical want-listing concocted in an evidentiary vacuum. Burning Man is a great steward of public lands, a model for how different activities should behavior themselves. Administrative organizations are not approved to behave without evidence. The competition’s organizers and volunteers have painstakingly compiled and published exact, longitudinal research of the festival’s *real* environmental impact. This Draft EIS apparently considers none of that authentic record.