Introduction 

I am writing about the Environmental Impact Statement and the BLM efforts to draft a land use plan for the Black Rock Desert in Nevada. There are specific provisions that are being proposed in order to manage the increased use of this environmentally sensitive land. However, I will not attempt to address any of these specifically, but make my argument that permitting groups on the desert should be significantly based on their ability to minimize their impact. Specifically, I argue that Burning Man is a model user of the desert and should be permitted annually or even permanently, without limitation on the number of participants.

I agree that the Black Rock Desert is a very valuable and fairly pristine area that is experiencing increased usage in recent years. It is high time to develop a management plan and implement some forms of control in order to monitor, and perhaps influence, its usage. Having for years hiked in backcountry of nationally managed areas such as the Grand Canyon, I have great appreciation for the implementation of such plans which have a huge impact on preserving these areas even under significant human usage.

Precedence in Land Management 

In most nationally managed areas such as national parks and forests, and even many BLM lands, the strategy for usage involves "developing" a high-usage zone, where over 80-90% of the human impact takes place. In a way, such very small zones are a compromise between those who would have no restriction on usage of the areas, and those who would banish people from these areas altogether. National parks and forests have some staffing, rangers and other personnel, who serve to maintain these high-usage zones, and educate visitors. This personnel also monitors the ecological health of the whole area, and provides support for the few users who venture into the backcountry. These visitors are treated very differently, and much higher expectations are set for them to cooperate in preserving the uniqueness and pristine state of the areas.

I provide this background in order to draw some parallels between the sucessful management of these more established areas, and the Black Rock Desert, whose management is now under discussion. The most important tools that emerge from the profile above are the following:

- high usage zones which concentrate the majority of the usage in a managable scope,

- staffing which serves to maintain the area and educate visitors,

- entrusting purposeful and educated backcountry users to be self-policing and to minimize impact.

Desirable Management Practices 

I believe that the usage of the Black Rock Desert by various individuals and groups should be evaluated along these lines. Instead of implementing head-count caps or simple individual permits, a management system should be implemented that brings the tools listed above to bear. The next three paragraphs develops each of these, and applies them to the Black Rock Desert.

- Concentrating high usage to limited zones is often implemented through markings, explicit development of physical facilities, and some degree of policing. None of these approaches are desirable for the Black Rock Desert, by any measure. Instead, it should be encouraged by empowering groups of people who gather in explicit events and in concentrated locations. This ensures that most usage is limited to a tiny fraction of the area as a whole.

- Staffing the Black Rock Desert with rangers is obviously not a feasable solution. Instead, the functions of such staff need to be filled by the users themselves. Groups who explicitly pride themselves on sucessful cleanup, containment and education, and foster a culture of minimal impact fill this role. Groups who extend this culture and participate in active management of the area frequently balance the impact of their use, and often provide real benefits to preservation in the face of increased use by the public as a whole.

- Differentiating between various users and entrusting them according to purpose, education, and ability to manage themselves and their conduct in the area is a vital component of most recreational land management plans. Individuals and groups demonstrate their behavior profile through past usage patterns, and by making implicit and explicit commitments to the area's preservation. The permitting of various types of user groups needs to reflect this profile, and should encourage trends of self-policing and sustainable land use.

Management By Groups 

In this light, a management plan should assess the user groups by impact and permit the impact, rather than the individuals by number. Groups which embody the three aspects above should be treated as a single entity with desirable behavior, and be permitted liberally. Groups which lack any of them should be permitted more restrictively. Land use should not be managed by total or even group-specific head-count caps, since these are truly meaningless in assessing impact.

Long Range Goals 

The overall impact on the Black Rock Desert should be managed in such a way as to foster a culture of sustainable use and long-term preservation. With the exploding population in the Great Basin as a whole, the public lands of the area are experiencing increased use that, while not nearly as destructive as much of the mining and development, is still destroying the fragile ecosystems of the desert at a rapid pace. While it is impossible to roll back the clock to a better time, it IS possible to develop and foster a culture of respect and sustainability for these lands. Like any other culture, this is best done by example, and by encouragement of behavior that embodies the desirable principles.

Burning Man & Black Rock Desert 

The Burning Man community is a stellar example of how extended use of the desert that is significant to the human experience can be conducted with minimal impact. For one week each year, Burning Man embodies a culture that is utopic to most human communities: an economy based entirely on gift-giving, a society based solely on shared creative expression, and a relationship to the land that exemplifies sustainability and minimal impact (No Trace!). Burning Man is proud to call the Black Rock Desert its home, and is desperately seeking a relationship with its wardens that will permit the community to continue this experiment for the long term. It would be a credit to the BLM of Nevada to create a land use plan which reflects the principles it purports, by making a group's impact, not its headcount, as a major permitting factor. Burning Man plays a significant role in the Black Rock Desert not nearly as much through its actual environmental impact, which is minimal, but through its huge cultural impact as a model for how to manage one's impact in pristine lands. I hope that the BLM reconizes that Burning Man is actually an enormous asset to its long-range goals, and permanently integrates this community into its land use plan.

Thank you for your consideration.