chris_carvalho

<p>I submitted this comment today. Feel free to add your own thoughts and share with anyone willing to help our government understand the importance of unfettered access to wilderness for photographers, as long as they leave no trace:<br> <br /> I am a photographer who takes pictures for personal and professional purposes. I sell my work as fine art, and also for publication. Some of it is newsworthy and has appeared in documentaries, books, and in the press. Most of my subject matter is nature, and often taken in wilderness areas. I am highly concerned about the proposed regulation for the following reasons:<br> <br /> 1. The eventual use of an image (whether still or video) is often understood only after it has been taken and published. The proposed regulation assumes the image usage is known before it is taken, and even before the photographer travels to the site (any permit must be submitted well in advance of the visit.) Nearly every photographer has a story where an image taken for personal use became one that had commercial value, often unexpectedly.<br> <br /> 2. Photography is very dependent upon weather, site conditions, vegetation growth, bloom time, and bloom quality. These conditions cannot be predicted in advance where a permit entails lengthy delays.<br> <br /> 3. Permit fees and applications present an unnecessary barrier to free expression and the photographer's right to record nature. This is a form of speech and must not be hindered by governmental intrusion.<br> <br /> 4. The permit process creates a bureaucracy that imposes additional expense and burden on taxpayers, as well as additional costs for anyone in business who photographs for art, journalism, or publication. Digital technology has reduced compensation to paper-thin margins. Permit expenses will effectively prevent photographers from taking wilderness images and being fairly compensated for them.<br> <br /> 5. Video and still photography have essentially merged with new technology. Nearly all new cameras and cell phones can take either form of imaging. Regulations must not limit the ability to record video or stills, causing a person to be in violation of the law by the simple decision of taking a video during a still photo session.<br> <br /> 6. While the proposed regulation applies to commercial filming, it creates a slippery slope toward placing the same restrictions on still photography. Many still photographers now shoot video as a means of promoting their work and supplementing their often meager income. Video is often done in conjunction with still photography. If enacted, video producers will seek to have the same restrictions applied to still photos out of fairness concerns.<br> <br /> 7. The regulation is already inaccurate in its use of terminology. I'm not being flippant to note that "filming" isn't a valid description of today's motion-picture equipment. Film is seldom used, what happens today is almost always digital capture, either still or video. The technology is changing so fast that any attempt to regulate it will likely be obsolete as soon as it's written.<br> <br /> 8. Photographers and journalists play an important role in watchdogging the government. The proposed regulation has the potential to limit that ability, depriving the public of important knowledge about wilderness management, impacts, and exploitation, whether by the government itself or by other parties seeking to benefit unfairly from a resource that belongs to the entire public. Documentation is a valuable purpose for citizens to record history and debate controversial topics. Documentation should not be restricted in any way as long as it is not impacting the wilderness resource.<br /> For these reasons, I recommend that the proposed directive be shelved permanently. Any directive to regulate photography and video in wilderness areas must not restrict the taking of images as long as the process is done in accordance with the existing guidelines of no-trace usage, non-motorized access, and keeping the party size below twelve people. The sole limitation requiring a permit should be impact to the wilderness resource. Existing restrictions not allowing models, props, or sets are enough and need not be changed as those items are external to the wilderness and make a clear separation between a for-profit commercial use that is planned in advance, versus spontaneous, creative use for journalism, artistic expression, publication, or documentation.<br /> Thank you for the opportunity to comment.<br> <br /> Sincerely,<br /> Chris Carvalho</p>