Digital BW, The Print

-You may mail or hand deliver

comments to National Park Service,

Attn: Lee Dickinson, Special Park

Uses Program Manager, 1849 C Street,

NW., ORG CODE 2460, Washington,

DC 20240.

 

Within that link, this seems to be the appropriate contact person to voice
your concern. 

 

Eric

 

 

Eric Neilsen Photography

4101 Commerce Street

Suite 9

Dallas, TX 75226

http://e.neilsen.home.att.net

http://ericneilsenphotography.com

Skype ejprinter

  _____  

From: DigitalBlackandWhiteThePrint@yahoogroups.com
[mailto:DigitalBlackandWhiteThePrint@yahoogroups.com] On Behalf Of Gage Hal
Sent: Sunday, October 07, 2007 2:46 PM
To: DigitalBlackandWhiteThePrint@yahoogroups.com
Subject: [Digital BW] Re: Be Careful Who You Photograph in National Parks

 

Jeez, this is buried. Here is the link for searching for the 
document. plugin the document number DOI-2007-0035-0001. Then click 
on the comments link. http://www.regulati
<http://www.regulations.gov/fdmspublic/component/>
ons.gov/fdmspublic/component/ 
main

Here are my comments for what they're worth.

I am distress at the broad and vague language in the proposal to 
redefine the rules for photographing in National Parks. The use of 
the words model(s), sets(s), or prop(s) without defining any context 
puts all visitors to the National Park System at risk of violation. 
All your terms could be easily clarified by adding "for the purpose 
of promoting the sale or use of a product or service." Even this is 
too broad of a net. A commercial photography should be defined as any 
event of filming, photography, videotaping, or recording by other 
means that brings into a National Park equipment and/or persons that 
requires use of the resources of the national park beyond that of a 
casual visitor." This would include bringing in props that could 
restrict or impede the enjoyment of casual visitors. Setting aside 
for the moment the issue of use of resources (which a still or motion 
picture photographer does not consume simply by pointing a camera at 
a scene), having a friend or family member stop and stand to be 
included in a photograph causes no damage or use of national 
resources any more than any visitor to the park. The open ended 
language proposed puts all users of the national parks as suspect and 
thus at the mercy of a ranger's discretion for citation and the 
burden of proof on that user.

The ultimate purpose of the rules seems to me to insure that the 
natural beauty of the park is not compromised for commercial gain 
without compensation and regulation. This can only happen if support 
equipment beyond the usual (i.e. lights, stands, reflectors, but 
should not include tripods, backpacks and other personal equipment 
that many professional and amateurs alike use) and props beyond the 
usual (cars, boats, etc.) that that any other casual user might bring 
with them when enjoying the park (which could with certain types of 
parks include that the same). To put the emphasis on commercial gain 
is a slippery slope. There are photographers that are 
indistinguishable from casual park users who photograph like any 
other park user and whose photographs may at some possible point in 
the future be used commercially. Even a casual user's photographs may 
be use commercially someday. The point is that at best these 
photographs are made purely on speculation. To require a permit to 
photograph simply because there might be a possibility that someone 
some where might make a dollar on his or her photograph is absurd and 
onerous on the people simply enjoying and physically taking nothing 
away or consuming in the park. In light of these facts, "commercial" 
should be defined as assigned work that involves use of the park 
above and beyond that of the casual park visitor as outlined above.

In identifying commercial use of the parks by photographers you tread 
a fine line that could cause unwarranted restrictions on stock 
photographers, artists, and the casual visitor that wishes to enjoy 
the natural beauty of the parks in this nation when they cause not 
one iota of damage or use of our natural resources beyond the right 
to visit them.

Kindest regards,
Hal Gage

 



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