With regard to specific legislation, ANA opposes S. 1614, a bill that we believe would largely be unworkable and impractical. ANA believes it would be extremely difficult to make these types of determinations in a timely manner. Commercial producers cannot do their work if the approval process encourages delay, arbitrary decision making, or excessive fees and we believe that these provisions could lead to just this kind of unintended result. In addition, we oppose a fee structure that attempts to set fees according to the production costs of a commercial, such as the proposal contained in S. 1693. Filming at a national park often is a relatively small proportion of production costs.
Additional costs incurred by an advertiser routinely run much higher than filming costs.
These all are among the features of a commercial that could cost far more than the filming actually executed on public lands. ANA knows of no similar licensing arrangement in the commercial production industry. In addition, it is important to note that advertising budgets are proprietary business information that would be extremely valuable to an advertiser's competitors if placed on the public record, creating a major business impediment to the success of this approach. This fee schedule is based on the number of personnel and the number of days they are on the land. ANA hopes and believes that a reasonable, predictable permitting system and fee system can be worked out.