NANPA Submits Comments to NPS re: Commercial Use Authorization (CUA) System

As part of its ongoing commitment to ensuring that your voice is heard at the highest levels of government, yesterday NANPA and ASMP submitted comments to the National Parks Service regarding changes to the Commercial Use Authorization (CUA) system which is the basis for workshops and permitting in the Parks system. Read on to see the submitted comment, and special thanks to NANPA Past President Sean Fitzgerald for his work in this effort. Thanks also to those members who took time to let us know their opinions on this matter and who submitted comments directly. NANPA will continue to work diligently on your behalf to ensure that nature photography is accessible and respected by the NPS.

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Online Commercial Use Authorization Application and Reporting System 

(ASMP/NANPA) submits these Comments to the National Park Service (NPS) in response to its proposed Online Commercial Use Authorization Application and Reporting System (Online System). ASMP/NANPA represents over 6500 members, including many photographers who organize and lead photography-focused commercial services on NPS lands, such as photo workshop/tour leaders and photo guide services. 

We generally applaud the Online System for its thoughtful focus on streamlining the application and reporting process. We offer our comments and suggestions for improving the Online System based on the unique character and needs of photographers who provide those services. 

Photo Workshop/Tour Leaders and Guides are Unique 

Photographers who lead photo workshops and tours or provide photo guide services differ from many other commercial service providers in several unique ways. For example: 

• Small Businesses with Relatively Modest Incomes. Many photographers who run photo workshops or tours are solo operators or run a very small business. For them, income from workshops and tours is relatively small and administrative overhead can quickly become burdensome.
• Photo Workshops and Tours are Infrequent. Many photographers lead photo workshops across the United States and internationally and may only do single workshops in a particular park with relatively small attendance (usually less than 10 people).  Many of those workshops are scheduled months and years in advance and may only take place once, or only a few times in any one calendar year.
• Photo Guide Services are Continual. Some photographers live near a particular park and provide a daily guide service to individuals or small groups during a park season or calendar year. Many are booked at the last minute.
• Personal Transportation within Park. Although some photo workshops are large enough to justify chartering buses or the like, most workshops mandate that participants provide their own transportation to set meeting locations within a park. We believe such services would be included within this Online System and not under the future online system for road-based commercial tour operators. Our comments are provided under that assumption.

Recommendations 

Given the unique characteristics and needs of those who lead photo workshops/tours or provide photo guide services, we suggest the following improvements to the Online System: 

• Maintain Local Contacts and Requirements.  Photo workshop leaders and guides often work closely with local park contacts for application purposes and to coordinate how the workshop is conducted. This generally works quite well. We encourage workshop leaders to conduct workshops responsibly without stressing the land or its wildlife and having a local contact is essential. The CUA application and reporting service should make it easy to establish contact and coordinate with the appropriate person at a particular NPS unit where the permit is sought.
• More Flexible Application Fees for Small Service Providers. While we understand the intent to standardize application fees from an administration standpoint, there is a disparate economic impact on small commercial providers such as those who lead small-scale photo workshops once or twice in any year. They are less able to afford those fees than large operators carrying large groups by bus. We suggest allowing for a lower fee for such small photo workshops (e.g. less than 12 participants and no group transportation) or allowing for a single application within a year to cover multiple photo workshops.
• Flexible Application Fee for Different Parks. We also believe the system should have some flexibility to allow for lower application fees for less visited and less stressed parks. It would help shift some workshops away from overly crowded parks and to parks that can more easily accommodate the activity.

• Reasonable Reporting Requirements. While the Online System greatly streamlines the reporting process, we hope it will not result in a universal requirement to provide monthly reports for all commercial service providers. As noted above, many photo workshops only take place once or a couple of times in any particular year. While it is reasonable to require a monthly report immediately after the workshop is conducted, there is no reason to continue to require reports thereafter and requiring so would be burdensome.
• Online Help. Although the Online System seems very user friendly, there are still issues which could prove confusing. An online help button pertinent to each stage of the application and report process would help guide service providers through the process more efficiently.  If the online system could be responsive to the particular type of service provider (such as photo workshops), that would make the process even more intuitive. Having someone online during business hours available through a chat box would also make for a more user-friendly experience.
• Beta Testers. We would be thrilled to help further build and test the system as our members include many of those who lead photo workshops and tours or provide photo guide services on NPS lands.

Thank you for your attention and continuing work on the Online System. Your efforts are greatly appreciated.