National Park Service: Revenues Could Increase by Charging Allowed Fees for Some Special Uses Permits
Published: 2005-05-06T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The National Park Service routinely issues permits for special park uses, such as special events or commercial filming and still photography. However, the National Football League's use of the National Mall to launch its 2003 season raised questions about whether permitting such events was consistent with existing policies and law and whether all applicable fees for permitting special park uses were being collected. GAO (1) identified applicable policy guidance for issuing special uses permits for special events and for commercial filming and still photography, (2) assessed the extent to which this guidance was applied during fiscal year 2003, and (3) determined the extent to which the Park Service implemented the requirement to collect location fees for commercial filming and still photography.
section_title: What GAO Found
paragraphs: The Park Service has developed policy guidance for issuing permits for special events and for commercial filming and still photography activities. This policy guidance includes general criteria about the terms and conditions as to when and where specific types of activities can take place and requires park units to recover applicable costs associated with administering and monitoring special park uses. Recovery of costs associated with filming activities is required by law. Recoverable costs include, for example, the time charged by a park ranger to visit the site of the event, such as a festival held on park grounds, to monitor that the terms and conditions of the permit are met. During fiscal year 2003, park units did not consistently apply Park Service guidance for permitting special events and for commercial filming and still photography, and often did not identify and recover costs associated with permitting such activities, thereby decreasing financial resources available to the parks. Of the six park units we visited, one did not charge fees for processing applications; one only recovered monitoring costs associated with some of its permits; and three others had not updated, for several years, hourly charges to reflect current higher costs for personnel time for administering and monitoring permitted activities. For example, National Capital Parks-Central officials charged no administrative fees for the estimated 1,400-plus permits issued for special events and for filming and still photography in fiscal year 2003. Officials said that park units had not updated fees because of regional policy and a high workload or because updating the fees was given low priority. The Park Service has not implemented a law enacted almost 5 years ago to collect location fees for commercial filming and still photography, resulting in significant annual forgone revenues. The agency has not implemented the law because of delays in reviewing the proposed regulations at the Department of Justice and a lack of agreement among the Interior agencies about the fee schedule and how it is to be applied. We estimated the Park Service would have collected about $1.6 million in location fee revenues in fiscal year 2003, if the requirement to collect such fees had been implemented.

section_title: Letter
paragraphs: For over 50 years, the National Park Service has permitted special park  uses—such as special events or filming and still photography—that provide  benefits to an individual, group, or organization beyond those available to  the public at large. Annually, the Park Service issues thousands of permits  for special events, such as festivals, receptions, and fund-raisers. In the  past few years, questions have been raised by Members of Congress and  the public about taxpayer costs, commercialism, and Park Service policies  related to permitting these activities. One particular event—held in  September 2003, when the Park Service granted the National Football  League (NFL) use of the National Mall to kick off its season—caused  controversy. Because of some complaints that there was extensive  commercial advertising and some damage to the Mall grounds resulting  from this event, Members of Congress and the public questioned whether  permitting such an event was consistent with established policies, was an  appropriate use of the Mall, and whether taxpayer dollars were used to  support the event. The Park Service also issues hundreds of permits  annually for commercial filming and still photography on park land. The  Park Service is required by law to collect costs and location fees associated  with these permits, and is authorized to collect costs for other permit uses.
In this context, you asked us to (1) identify applicable Park Service policy  guidance for issuing special uses permits for special events and for  commercial filming and still photography, (2) assess the extent to which  this guidance was applied during fiscal year 2003 to ensure that all  applicable costs were identified and recovered, and (3) determine the  extent to which the Park Service has implemented the requirement to  collect location fees for commercial filming and still photography  activities.
We identified Park Service policy guidance for special uses permits and  obtained and analyzed applicable laws, regulations, policies, and  procedures. To evaluate the extent to which policy guidance was applied,  we analyzed permit records and other documentation of six selected park  units that we visited and interviewed Park Service headquarters, regional,  and park unit officials. We selected these park units because, during fiscal  year 2003, they had issued the greatest number of both special event and  filming and still photography permits in each of the six Park Service  regions within the continental U.S. To determine the extent to which the  Park Service implemented the requirement to collect location fees for  commercial filming and still photography activities, we interviewed Park  Service officials. We also collected and assessed the reliability of Park  Service data on filming and still photography permits from all park units for  fiscal year 2003 and estimated the forgone location fee revenues by  applying the established fee schedule of another federal land management  agency to the activities reported to GAO by the Park Service. The fee  schedule of the other federal agency is based on similar criteria included in  the legislation authorizing the Park Service to charge fees.
A more detailed description of our scope and methodology is presented in  appendix I, and a detailed description of our forgone revenue calculations  and results is presented in appendix II. We performed our work from May  2004 through May 2005 in accordance with generally accepted government  auditing standards.
subsections: section_title: Background
paragraphs: The National Park Service Organic Act of 1916 created the Park Service to  promote and regulate the use of national parks, monuments, and  reservations with the purpose of conserving the scenery, natural and  historic objects, and wildlife therein and to leave them “unimpaired” for the  enjoyment of future generations. The 1970 National Park System General  Authorities Act, as amended in 1978, prohibits the service from allowing  any activities that would cause derogation of the values and purposes for  which the parks have been established. The combination of these two laws  forms the basis of a mandate for Park Service managers to actively manage  all park uses in a manner that protects park resources and values.
Today, the Park Service comprises 388 units covering around 84 million  acres in 49 states, the District of Columbia, American Samoa, Guam, Puerto  Rico, Saipan, and the Virgin Islands. Figure 1 shows a map of the Park  Service regions.
National Parks are home to many unique and beautiful landscapes and  open spaces that are venues for a variety of special event activities such as  cultural programs, festivals, wedding ceremonies, and athletic events, as  well as commercial filming and still photography. These special uses  generally provide a benefit to an individual, group, or organization rather  than the public at large. In order to protect park resources and the public  interest, a special uses permit must be obtained from Park Service  superintendents for these activities. Special uses permits regulate the  amount, kind, time, and place of the proposed activity. The Park Service  issues special uses permits for several different types of activities,  including the two types we reviewed (1) special events, and (2) commercial  filming and still photography.
Special events permits are issued for a wide range of activities, including  sports, pageants, celebrations, historical re-enactments, exhibitions,  parades, fairs, and festivals. Commercial filming and still photography  permits are issued for such activities as major motion picture filming,  commercials, and magazine photo shoots. The Park Service has specific  statutory authority to recover costs associated with special uses permits  and to retain the funds recovered. The Park Service has guidance in place  to collect costs associated with special event permits, including costs for  commercial filming and still photography. In addition, it has been required  by law to collect costs and location fees associated with filming activities  for almost five years.
section_title: The Park Service Has Specific Policy Guidance for Issuing Permits and Recovering Costs for Special Park Uses
paragraphs: The Park Service developed specific policy guidance for issuing permits  and recovering costs for special park uses. This guidance includes detailed  permitting criteria for special events and for commercial filming and still  photography. Park Service superintendents are required to follow the  established policy guidance, including numerous cost recovery  requirements, when issuing permits. The cost recovery guidance generally  requires the park units to recover costs associated with the permitted  activity from the permittee.
subsections: section_title: Park Unit Superintendents Are Required to Follow Specific Guidance When Issuing Permits for Special Events and for Commercial Filming and Still Photography
paragraphs: The Park Service has developed extensive policy guidance that park unit  superintendents are to follow when issuing any Park Service special uses  permits. In this regard, the superintendent at each park unit is responsible  for reviewing, approving, and monitoring permitted activities and for  assuring that such activities are consistent with the Park Service’s purpose:  “to conserve scenery, natural and historic objects, and wildlife, and to  provide for the enjoyment of the public while maintaining the natural and  cultural resources and values of the national park system unimpaired for  future generations.” The policy guidance also gives the superintendent  discretion by directing that permits include “the terms and conditions that  the superintendent deems necessary to protect park resources or public  safety.” Permits establish conditions for the approved activity, such as  location, date, time, and estimated number of participants.
subsections: section_title: Guidance on Special Events
paragraphs: Special events within park units must meet basic criteria before a permit is  issued, and Park Service policy guidance gives superintendents discretion  when approving permits. The basic criteria for issuing a permit include that  (1) there is a meaningful association between the park area and the event  and (2) the event will contribute to visitor understanding of the significance  of the park area. However, the determination of what is a “meaningful  association” is generally left to the superintendent’s discretion. Some  special event activities may be appropriate within certain park unit settings  but not appropriate within others. For example, while the permitting of a  rock concert in an urban park setting may be appropriate, the permitting of  a rock concert at certain historical sites such as battlefields or cemeteries  may not be appropriate. Also, in order to protect the park resources and the  public’s health and safety, the policy guidance for special events provides strict limitations on certain uses, such  as fireworks displays and the sale of food in the parks.
Existing Park Service policies provide the superintendent with  considerable discretion to determine the appropriateness of proposed  advertisements. In 2003, the NFL kickoff event caused considerable  controversy about the size, scale, scope, and location of advertising  allowed during the event. In 2004, Congress passed legislation designed to  strengthen and clarify commercial signage restrictions for the National  Mall. This new legislation expressly prohibited the expenditure of funds in  fiscal year 2004 for special uses permits on the National Mall unless the  Park Service prohibited “the erection, placement, or use of structures and  signs bearing commercial advertising.” However, discrete recognition of  program sponsors was authorized. As a result, the Park Service has drafted  additional policy guidance, applicable to all park units, pertaining to the  use of signage recognizing program sponsors that will restrict the size,  scale, scope, and location of corporate logos and other lettering.
section_title: Guidance on Commercial Filming and Still Photography
paragraphs: In general, the Park Service encourages filming and photography “when it  will promote the protection and public enjoyment of park resources,”  provided that the activity meets basic criteria, such as the activity will not  cause unacceptable impacts to park resources. More specifically, the policy  guidance outlines when a permit is and is not required. For example, a  permit is required if the permitted activity involves the use of a model, set,  or prop—such as a model holding a product for an advertisement  photograph. However, no permit is required for visitors using a camera or  recording device for their own personal use within normal visitation areas  and hours. Some specific exceptions are included in the policy guidance— for example, a permit is never required for press coverage of breaking  news. Also, superintendents, at their discretion, may grant the permittee  access to a closed area of the park or permit the activity after normal  visiting hours. Regardless of the specific type of commercial filming or still  photography activity, the conditions specified in the permit must be  followed.
section_title: Park Service Guidance Includes Requirement to Recover Costs
paragraphs: Park Service policy guidance generally requires park units to recover costs  associated with managing special park uses, including special event and  commercial filming and still photography activities, unless cost recovery is  prohibited by law or otherwise exempted. This policy guidance is in line  with federal law requiring recovery of costs for filming activities and Office  of Management and Budget (OMB) Circular A-25, which established  guidelines for federal agencies to assess fees for government services and  for the sale or use of government property or resources. The OMB Circular  states, “When a service (or privilege) provides special benefits to an  identifiable recipient beyond those that accrue to the general public, a  charge will be imposed (to recover the full cost to the Federal Government  for providing the special benefit, or the market price).” The circular also  states that “user charges will be sufficient to recover the full cost to the  Federal Government,” and it defines full cost as all direct and indirect  costs—including personnel, physical overhead, and depreciation of  structures and equipment—associated with providing a good, resource, or  service. As authorized by law and under the policy guidance, these  recovered costs are retained at the units issuing the permits to defray the  costs of administering and monitoring the permits.
The Park Service’s 2001 Management Policies document, which provides  the service’s most current overall policies, states that “all costs incurred by  the Service in writing the permit, monitoring, providing protection services,  restoring park areas, or otherwise supporting a special park use will be  reimbursed by the permittee.” Park Service policy guidance further states  that “appropriate fees for cost recovery, as well as performance bond and  liability insurance requirements, will be imposed, consistent with  applicable statutory authorities and regulations,” and directs that “when  appropriate, the Service will also include a fair charge for the use of the  land or facility.” Consequently, each permit should stipulate that these  costs must be reimbursed by the permittee. Recoverable costs are those  costs directly attributable to the use or necessary for the safe completion of  the special park use. For example, the policy states that recoverable costs  include the time charged by a park ranger to visit the site of the event, such  as a festival held on park grounds, to monitor that the terms and conditions  of the permit are met. Additionally, the requirement includes recovering  costs for equipment and facility use as well as restoration of any damage to  park resources as a result of the event.
Park Service policy guidance also outlines the conditions under which  charges for special uses may be waived. According to the policy guidance,  exemptions from charges for special uses may be appropriate when  the incremental costs of collecting the charges would be an unduly large  part of the receipts from the activity;  the furnishing of the service without charge is an appropriate courtesy  to a foreign government or international organization, or comparable  fees are set on a reciprocal basis with a foreign country;  the permittee is a state, local, or federal government agency or a tribal   the superintendent determines that the use will promote the mission of  the Park Service or promote public safety, health, or welfare.
Exemptions from charges are appropriate when  a charge is prohibited by legislation or executive order; or  the requested use involves exercise of a right pertaining to water,  property, minerals, access, Native American religious practices, or the  rights guaranteed by the First Amendment to the Constitution, including  freedom of assembly, speech, religion, and the press.
Through their special uses permit system, Park Service superintendents  also manage requests for public assembly for the exercise of First  Amendment rights, including freedom of assembly, speech, religion, and  the press. Consistent with the First Amendment, it is the Park Service’s  policy to permit groups to assemble peaceably and exercise freedom of  speech on park lands. The number of First Amendment permit requests  varies greatly by park unit. For example, each year hundreds of permit  requests are submitted for First Amendment activity in Washington, D.C.,  area park units, but there are few requests for this type of permit at remote  units such as Yellowstone National Park. For First Amendment permits, as  with other special uses permits, the superintendents establish conditions  for the assembly, such as site location, date, time, and number of  participants. However, unlike other special events permits,  superintendents are required by Park Service policies to issue these  permits without requiring fees, cost recovery, bonding, or insurance.
section_title: Inconsistent Application of Special Park Uses Guidance Has Resulted in Some Park Units Not Fully Identifying and Recovering Costs, Thereby Decreasing Resources Available to the Parks
paragraphs: At five of the six parks we visited, we found failure to adhere to the Park  Service’s policy to recover from permittees the cost to either administer or  monitor permits for special events and for commercial filming and still  photography activities. This inconsistent application of agency policy  included not assessing or underassessing fees for reviewing and issuing  permit applications, and not charging or undercharging for the cost of  monitoring permits. As a result, parks did not fully identify and recover  costs for permitting special events and for commercial filming and still  photography. Consequently, in some parks, a portion of the financial  resources spent on reviewing, issuing, and monitoring permits was not  recovered from permittees, and therefore was not available to manage the  park permits programs.
subsections: section_title: Failure to Consistently Apply Guidance Means That Some Costs Are Not Identified and Recovered
paragraphs: Of the six park units we visited, we found that one park unit did not charge  fees for reviewing and approving permit applications. Although five of the  six park units charged administrative fees, three of these units did not  recover the full costs associated with reviewing and approving permit  applications. All six park units had established fees for monitoring the  implementation of the permit. However, four of these units did not recover  the full costs associated with their monitoring activities.  Table 1 shows the  park units we visited and whether they charged administrative or  monitoring fees and recovered the associated costs.
The Park Service does not maintain centralized data on the number of  special event and commercial filming and still photography permits issued  each year. However, an agency official informed us that for fiscal year 2003,  National Capital Parks-Central issued the largest number of these  permits—estimated in excess of 1,400—of all park units. National Capital  Parks-Central charged no administration fees for permitting special uses.  For example, during fiscal year 2003, this park management unit did not  assess any administrative fee for permits issued for special events, filming,  and still photography, as required by Park Service policy unless prohibited  by law or otherwise exempted. National Capital Parks-Central officials told  us that since the mid-1990s, it has been regional policy that park units  within the National Capital Region would not charge any administrative  costs associated with processing permits. For example, National Capital  Parks-Central issued permits for both the NFL kickoff event and the  filming of the major motion picture National Treasure, both of which  engaged Park Service personnel in numerous planning meetings, but for  which no administrative costs were recovered. As a result of GAO bringing  this issue to the attention of the Solicitor’s Office at Interior, the Solicitor’s  Office modified its guidance and directed the National Capital Region to re-examine its administrative cost recovery practices. As of February 2005,  according to Interior’s Solicitor’s Office, steps were being taken to require  all park units in the National Capital Region to assess processing or  application fees for all permit applications.
Administrative fees are based on the actual costs incurred by the park unit  involved in overseeing the permit activity and should include all costs to  the Park Service associated with processing a permit application from the  time the first inquiry is received until the permit is signed and issued. For  example, officials at Independence National Historical Park charge a $50  nonrefundable fee for each permit application. In fiscal year 2003, this park  unit issued a total of over 300 permits for special events and for  commercial filming and still photography. According to these park officials,  this fee has not been updated for at least 8 years and will be increased to  $100 in late 2005 to reflect increased administrative costs.  Blue Ridge  Parkway charged a $25 nonrefundable fee to cover the costs of initially  considering permit applications and an additional $75 to cover additional  processing costs for each approved permit. According to a park official,  these fees had not been updated in 8 years, but the fees have now been  increased as of January 2005 to $50 and $125, respectively, to reflect  increased administrative costs. In fiscal year 2003, this park unit issued a  total of about 40 permits for special events and for commercial filming and  still photography. Officials at these park units agreed that their 2003  charges did not reflect increases in costs, such as for personnel, that had  occurred during the past several years.
In contrast, according to park officials, Golden Gate National Recreational  Area, Jefferson National Expansion Memorial, and Yellowstone National  Park charge administrative fees based on current costs. These park units  periodically assess and adjust their fees to reflect increasing costs, such as  for salary and associated benefits.
subsections: section_title: Monitoring Fees Not Fully Recovered
paragraphs: Delicate natural resources in park units (see fig. 1) require monitoring to  ensure resources are protected for the enjoyment of future generations.  For example, at Yellowstone National Park, if a film crew consists of five or  more persons, a park official assigns staff to monitor the crew’s activities at  all times to ensure compliance with permit conditions, safety, and that the  activity does not interfere with the visitor experience. If the filming activity  is at or near one of the park’s thermal pools, a Park Service staff monitor is  required as part of the permit conditions to ensure that the film crew does  not damage this natural resource or its surroundings by entering a  restricted area to obtain a particular photo or angle of view.
According to Yellowstone’s film permit coordinator, permittees sometimes  try to push the boundaries of the permit conditions, without understanding  the potential damage or injury that could result. The Yellowstone  coordinator stated, however, that because of their close monitoring  actions, there has not been any resource damage from permittee actions.
At three of the six parks we visited—Blue Ridge Parkway, Yellowstone  National Park, and Golden Gate National Recreation Area—hourly  monitoring fees had not been updated to reflect current higher costs,  according to park officials. As a result, staffs at these units are not  collecting fees sufficient to cover their monitoring costs. According to the  Blue Ridge Parkway permit coordinator, actual hourly monitoring costs are  about $50 per hour; however, the park has charged only $30 per hour since  1997. At Blue Ridge Parkway, not only were the monitoring fees below  actual costs, but staff who monitored permitted activities did not submit  documentation that would allow the park unit to bill and collect monitoring  fees from the permittee for 20 of 28 permitted special events. Blue Ridge  Parkway officials plan to increase the monitoring fee to $50 per hour in  2005.
At Yellowstone National Park, the $50 hourly monitoring fee has not been  updated in about 10 years. The hourly monitoring fee at Golden Gate  National Recreation Area ($65 per hour) has not been updated for 4 years.  Officials at Blue Ridge, Golden Gate, and Yellowstone explained they had  not updated their hourly monitoring fees either because of a high workload  at some park units or because updating fees was given a low priority at  other park units. However, they said they plan to revise the fee to more  accurately reflect actual costs in fiscal year 2005.
Officials at National Capital Parks-Central are not collecting fees sufficient  to cover their monitoring costs. These officials require permittees to bear  the cost of Park Service overtime to monitor permitted activity for those  permits where a bond is required. However, National Capital Parks- Central officials do not recover their costs for any permit monitoring that  occurs during normal business hours and where no bond is required.
In contrast, two park units, Independence National Historical Park and  Jefferson National Expansion Memorial, charged monitoring fees based on  current cost rates.
section_title: Additional Park Revenues Are Available to Parks If Costs Are Collected from Permittees
paragraphs: As mentioned earlier, five of the six parks we visited—Blue Ridge Parkway,  Golden Gate National Recreation Area, Yellowstone National Park,  Independence National Historical Park, and National Capital Parks- Central—did not fully recover applicable administrative or monitoring  costs. Some of these parks failed to collect several thousand dollars or  more in fiscal year 2003. For example, had National Capital Parks-Central  charged a $50 administrative fee like Independence National Historical  Park, it would have collected at least $70,000 for the estimated 1,400-plus  permits the park issued in fiscal year 2003 for special events and filming  and photography. As a result, if these park units had implemented agency  policy and the OMB directives to fully recover all costs, additional—and in  one case, significant—revenues, such as those at National Capital Parks- Central, could have been available for managing permits programs.
section_title: Delays in Implementing the Law to Collect Location Fees for Commercial Filming and Still Photography Have Resulted in Forgone Revenues
paragraphs: Delays in implementing the May 2000 legislation requiring the Secretary of  the Interior to establish a fee schedule for commercial filming and still  photography have resulted in significant annual forgone revenues for the  Park Service. This law requires the agencies to establish a fee for the use of  the land—referred to by the Park Service as a location fee—in addition to  recovering agency costs. If the law requiring the Park Service’s officials to  collect location fees for commercial filming and still photography had been  implemented, GAO estimates that, for the reported permitted activity in  fiscal year 2003, the agency would have collected revenues of about $1.6  million (unadjusted for inflation). According to the Park Service’s Special  Uses Program Manager, the commercial filming and still photography  permitted activities used by GAO to estimate forgone revenues of about  $1.6 million are representative of a typical year’s worth of activities. The  Park Service, along with three other federal land management agencies, is  currently participating in a working group to develop regulations to  implement the legislation and the associated location fee schedule.
subsections: section_title: Law Requiring the Collection of Location Fees Has Not Been Implemented
paragraphs: The Commercial Filming Law, enacted in May 2000, requires the Secretary  of the Interior and the Secretary of the Department of Agriculture to issue  permits and establish reasonable fees for commercial filming and still  photography activities. The law affects Interior’s Bureau of Land  Management (BLM), Fish and Wildlife Service (FWS), and Park Service,  and Agriculture’s Forest Service (FS). However, the law has not been  implemented. Although BLM and FS already had established filming and  still photography fee schedules in place prior to this law, the Park Service  and FWS are collaborating with FS and BLM to develop a single fee  schedule for all four agencies.
Subsequent to the law’s enactment, the Department of the Interior’s Office  of the Solicitor created a working group, in June 2000, with representatives  from each of the four affected agencies to develop implementing  regulations and a fee schedule. To ensure that First Amendment issues  were adequately addressed, attorneys from the Solicitor’s Office agreed to  seek concurrence from the Department of Justice prior to finalizing the  regulations. In October 2000, the Solicitor’s Office submitted the proposed  regulations drafted by the working group to Justice’s Office of Legal  Counsel. However, Justice’s suggested revisions were not provided to  Interior officials until October 2003. Since that time, representatives from  each of the four land management agencies have worked together to  finalize the regulations and the associated fee schedule. According to  officials at Interior and the Park Service, the draft regulations are currently  being circulated among the appropriate reviewing officials in each agency,  and the agencies plan to have them published in the Federal Register later  this year.
In addition to drafting regulations to implement the Commercial Filming  Law, the working group considered two different approaches when  developing a uniform fee schedule: One approach specifies a uniform  minimum fee schedule allowing the land management agencies to assess  additional fees based on comparable markets, while the other approach  does not allow for fee adjustments based on comparable markets. For  example, the Forest Service currently uses the same fee schedule in five of  its nine regions. In contrast, BLM’s existing fee schedule for filming and still  photography, while similar, varies by state and is set by BLM state offices.  Although the working group has developed a standardized fee schedule,  one of the group’s challenges has been to reach consensus among the  affected agencies on whether the use of a standardized fee schedule would  allow individual locations to assess an additional fee for use of its sites.
section_title: Proposed Location Fee Schedule Includes Charges Based on the Number of People and Duration of Filming
paragraphs: The Commercial Filming Law requires the Park Service to establish a  location fee for commercial filming and still photography that provides a  fair return for the use of the land to the United States. The law specifies  that this fee must be based upon the following criteria: (1) the number of  days the filming activity or similar project takes place on federal land under  the Secretary’s jurisdiction, (2) the size of the film crew present on federal  land under the Secretary’s jurisdiction, and (3) the amount and type of  equipment present. Furthermore, the law allows that “other factors” may  be included in determining an appropriate fee. The Forest Service has a fee  schedule, developed prior to this law and implemented under other  legislative authority, that uses similar criteria. For example, the Forest  Service’s commercial filming fee schedule ranges from a minimum of $150  per day for crews of 1 to 10 people to $600 per day for crews of over 60  people. These fees are then multiplied by the number of days the crews  are on the site during all phases of filming. For example, applying this  schedule to just one of the 320-plus filming permits issued by National  Capital Parks-Central in fiscal year 2003 (65 people for 2 days) would have  resulted in a $1,200 return to the park. Once these fees are collected, they  remain with the Park Service units and are available until expended.
section_title: GAO Estimated Forgone Revenues of about $1.6 Million for Fiscal Year 2003
paragraphs: Using the fee schedule that the Forest Service has in effect, we estimate  that the Park Service would have collected location fee revenues of about  $1.6 million in fiscal year 2003. The Park Service has drafted a proposed  standardized location fee schedule that would charge higher fees than the  Forest Service for larger parties, but it has not yet been finalized. Using the  Park Service’s draft fee schedule, we estimate forgone revenues of about $2  million in 2003 (see app. II).
section_title: Conclusions
paragraphs: The Park Service is required by law to collect costs and location fees  associated with permits for commercial filming and still photography and  authorized to collect costs for other permitted activities. Because costs  recovered from permitting activities are used by park units for managing  their permit program and other park programs, failing to recover such  costs decreases the financial resources park units have for processing  permits and monitoring permitted activities. Unless steps are taken to  ensure that units fully identify and collect administrative and management  (including monitoring) costs associated with special event permits and  with commercial filming and still photography permits, the Park Service  will continue to deprive itself of funds important for managing and carrying  out agency policy and delivering agency services. This is particularly  evident in the National Capital Region, where only recently has  consideration been given to charging administrative fees to recover costs.  Because our review was limited to six park units, the extent to which other  park units are not consistently applying existing cost recovery guidance is  unclear. Conducting a systemwide review would help identify park units  that are not fully recovering costs for special events and filming and still  photography, and the measures necessary to ensure that all park units  identify and collect all appropriate permitting fees.
Significant revenues that would be available to the Park Service to help  defray the costs of administering its commercial filming and still  photography permit program are forgone because of delays in  implementing regulations consistent with the Commercial Filming Law. By  law, the Park Service is now required to collect location fees for  commercial filming and still photography activities. Expediting  implementation of the law will help ensure that the Park Service does not  experience more forgone revenues.
section_title: Recommendations for Executive Action
paragraphs: To ensure that the Park Service fully identifies and collects administrative  and monitoring costs associated with special event and with commercial  filming and still photography permits, as well as location fees for filming  activities, we recommend that the Secretary of the Interior direct the Park  Service Director to take the following four actions:  Ensure that the park units we visited consistently apply existing cost  recovery guidance and maintain updated cost recovery fee schedules.
Ascertain the extent to which other park units are not consistently  applying existing cost recovery guidance, and take appropriate actions  to ensure they are consistently applied and costs are identified and  recovered.
Expedite the implementation of the law that requires the Park Service to  collect location fees and costs for commercial filming and still  photography, when appropriate.
Follow through to ensure that the National Capital Region assesses  administrative fees to recover the costs of processing permits for  special events and for commercial filming and still photography.
section_title: Agency Comments and Our Response
paragraphs: We provided the Department of the Interior with a draft of this report for  review and comment. The department provided written comments that are  included in appendix IV. The department did not comment on our  recommendations; however it suggested language to clarify the application  of Park Service general policy guidance to the National Capital Region.  Specifically, it suggested that we include language to clarify that the  regulations governing special events within the National Capital Region are  different from those contained in the Park Service’s general regulations,  particularly as it applied to the NFL kickoff event. We agree that the  regulations governing such special events in the National Capital Region  are different from the general regulations and have included clarifying  language in the report. The department provided other technical  clarifications that we have incorporated, as appropriate.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to the Secretary  of the Interior and other interested parties. We will also make copies  available to others upon request. In addition, the report will be available at  no charge on the GAO Web site at http://www.gao.gov.
If you or your staff have questions about this report, please contact me at  (202) 512-3841 or nazzaror@gao.gov. Key contributors to this report are  listed in appendix V.
section_title: Scope and Methodology
paragraphs: We identified and analyzed applicable laws, regulations, policies, and  procedures to determine Park Service policy and requirements applicable  to the review and approval of special uses permits, including those for  special events and commercial filming and still photography. This included  an analysis of servicewide guidance as well as guidance applicable to the  specific units we visited, such as units in the National Capital Region. We  discussed the policy guidance with the Office of the Solicitor, Department  of the Interior, and with officials from Park Service headquarters and each  of the six park units visited to gain an understanding of how the guidance  should be interpreted and applied.
To evaluate whether policy guidance was consistently applied, we reviewed  files and examined permitting practices at the nonprobability sample of six  park units visited and interviewed park unit officials about their  procedures in reviewing, approving, and monitoring permitted activities.  We also reviewed these units’ procedures to identify and recover costs  associated with permit activities.
We first searched for existing data sources describing the number of  special event and commercial filming and still photography activities on  park land. However, the Park Service does not maintain national or  regional data about these activities. We also contacted sources outside of  the Park Service—including the Sierra Club and The Motion Picture  Association of America—to ascertain whether these sources had  information on the number of special event and commercial filming and  still photography permits issued by each of the park units, but these groups  did not have such data, either. In the absence of this data, we used an  expert referral technique to identify park units to visit. We asked officials  from each of the Park Service’s seven regional offices to identify, using  their knowledge of regional operations, the three park units within their  respective regions with the greatest number of (1) special event and (2)  commercial filming and still photography permits. In each case, the  officials produced a list in which the same unit had both the most special  events and the most commercial filming and still photography permits for  fiscal year 2003. We selected the top park unit from each of the regional  offices. Park Service regional officials identified the following seven park  units issuing the greatest number of permits for both special events and for  commercial filming and still photography in fiscal year 2003:  Alaska Region—Denali National Park,  Midwest Region—Jefferson National Expansion Memorial,  Intermountain Region—Yellowstone National Park,  Pacific West Region—Golden Gate National Recreation Area,  Northeast Region—Independence National Historical Park,  National Capital Region—National Capital Parks-Central, and  Southeast Region—Blue Ridge Parkway.
Because of the relatively low number of reported permits issued in the Park  Service’s Alaska Region, we limited our site visits to parks in the six Park  Service regions within the continental United States.
To determine the extent to which the Park Service implemented the  Commercial Filming Law, requiring it to collect location fees for  commercial filming and still photography activities, we analyzed the  legislation and interviewed Park Service and Department of the Interior  headquarters officials. We also contacted officials at the Department of  Justice and obtained their concurrence regarding the delays and changes  made to the draft regulations. In addition, we analyzed documents  pertinent to Justice’s review of Interior’s proposed regulations for  collecting location fees to verify reported delays in Justice’s review of the  regulations. We asked the Special Uses Program Manager at Park Service  headquarters to assist GAO in administering a data collection instrument  (DCI) sent to each of the Park Service’s 388 park units to obtain  information on the amount of commercial filming and still photography  activity that would have been subject to location fees in fiscal year 2003, if  the legislation had been implemented.
The DCI was sent to all park units to obtain information on permits issued  for filming and still photography activities occurring in fiscal year 2003. We  asked the park units to provide (1) a permit number for each permit issued,  (2) the date the permit activity started, (3) the number of days for which  the permit was authorized, (4) the number of people using the permit, and  (5) if the park unit would have charged a location fee based on current  Park Service policy guidance. We requested that the information provided  by the park units in the DCI be sent to GAO with a copy to the Special Uses  Program Manager.
We coordinated with the Special Uses Program Manager to ensure we  received all of the responses and printed out hard copies of the filming and  still photography activities provided by the park units. Because some of the  smaller parks have a management office that issues permits for multiple  park units, some of the respondents provided information containing the  aggregated responses. These DCI responses were grouped into 27  combined park unit responses representing 95 individual park units.
Of the 388 park units operating in 2003, we removed 17 because they either  (1) did not own or manage property in their designation or (2) were not  located in the United States or the District of Columbia, leaving us with 371  park units. Of the 371, we received responses from 355, giving us a  response rate of 96 percent. Of these 355 park units, 95 were provided in  grouped responses and the remaining 260 responses were from individual  park units.
We reviewed all of the filming and photography permits at four of the six  sites visited. We reviewed these permit files to determine whether they  contained specific required administrative information, such as evidence of  the recovery of incurred costs. However, we did not review the permit files  for evidence of all administrative requirements outlined in policy guidance  because it was outside of the scope of this assignment. We reviewed  7 permit files at Jefferson National Expansion Memorial,  77 permit files at Yellowstone National Park,  76 permit files at Independence National Historical Park, and  15 permit files at Blue Ridge Parkway.
The key administrative information regarding cost recovery was present in  all of the 175 files we reviewed.
Our file review at both of the remaining sites included an additional level of  review. For these two sites, we reviewed the files for key administrative  information as we did for the other four sites previously described. In  addition, we also compared the information provided by the park unit on  the DCI with the information contained in the permit file.
Of 152 total permits at Golden Gate National Recreation Area, we  reviewed 10 filming and photography permits with the highest costs  recovered. These permits were selected using the park’s 318 account  summary, which lists all fees charged and collected for filming and  photography permits for fiscal year 2003.  All key administrative cost  recovery information was present, and all DCI information matched in  these 10 permit files.
We could not identify the top 10 highest-cost filming and photography  permits for National Capital Parks-Central based on the park’s 318  account summary for fiscal year 2003, because the account combines  costs recovered for filming and photography permits with other special  uses permit costs. As a result, we requested files for filming permits that  included 25 or more people, as indicated on the returned DCI from  National Capital Parks-Central. This resulted in a review of 29 of 678  permit files (4 percent), which, according to National Capital Parks- Central staff, would generally be comparable with the permits with the  highest costs recovered in fiscal year 2003. All key administrative cost  recovery information was present, and all DCI information matched in  these 29 permit files.
The information we gathered was provided by staff at National Park  Service units. The Park Service staff located the data by pulling paper files  and transferring the information into the DCI. This information is not  centralized, and it had never been gathered on a national level prior to our  data collection for fiscal year 2003. The Special Uses Program Manager is  responsible for ensuring that all Park Service staff adhere to the policy and  guidance regarding issues associated with permit procedures, drafting  policy and guidance associated with permitting procedures, and the  coordination of the training and curriculum for Park Service staff on  permitting policies and procedures. In her opinion, the information  provided by the park units was accurate, complete, and reflective of the  amount of permitted activity in a typical year.  Based on our comparison of  DCI data with hard copy files and our discussion with Park Service officials  regarding the data, we determined that the data were reliable enough for  the purposes of this report.
Using the data we obtained from these park units, we estimated the  forgone location fee revenues for fiscal year 2003 by applying the  established fee schedule of the Forest Service. Both the Bureau of Land  Management (BLM) and the Forest Service have established location fee  schedules in place; however, the BLM fee schedule varies by state.  Therefore, we used the Forest Service’s established fee schedule for our  calculations because it is standardized within five of its nine regions and  based on similar criteria included in legislation authorizing the Park  Service to charge fees. We used these data to estimate forgone revenue.  Details of these calculations are provided in appendix II.
We conducted our work from May 2004 through May 2005 in accordance  with generally accepted government auditing standards.
section_title: Details of the Forgone Revenue Calculations
paragraphs: To estimate the revenues the Park Service could have collected in location  fees in fiscal year 2003, if the requirement to collect such fees had been  implemented, we asked the Park Services’ Special Uses Program Manager  to assist GAO in administering a data collection instrument (DCI). The Park  Services’ Special Uses Program Manager sent the DCI to each of the Park  Service’s 388 park units to obtain information on the amount of filming and  still photography activity that would have been subject to location fees in  fiscal year 2003. In the DCI, we asked for information on activities  specifically related to the number of filming and still photography permits  issued, the number of days each permit was in effect, the number of people  using the permit, and whether the unit would have charged a location fee  based on current Park Service policy guidance. Park Service policy allows  the superintendents to waive fees under certain conditions, such as if the  permittee is a state, local, or federal government agency or a tribal  government, or if the superintendent determines that the use will promote  the mission of the Park Service or promote public safety, health, or welfare.  In our calculations to estimate forgone revenues, we only used the permit  activity reported by the park units where a location fee would not have  been waived. We received responses from 355 of 371 park units in our  sample, giving a 96 percent response rate. (Seventeen units were removed  from the universe. See app. I for details of our methodology.)
To estimate forgone revenues, we used the information collected from  respondents, along with the Forest Service’s existing fee schedule used in  five of its nine regions for commercial filming and still photography  activities (see tables 2 and 3). We also used the Park Service’s draft fee  schedule to provide an alternative estimate of forgone revenues even  though its fee schedule is not yet final (see tables 4 and 5). Both schedules  charge daily fees based on the number of people participating in the  activity; the Forest Service’s fees are lower for larger parties.
To develop the forgone revenue estimates for activities in fiscal year 2003,  we multiplied the number of people using permits each day by the  corresponding Forest Service and Park Service fees when the park unit  would have charged fees for the permitted activities. For example, as  shown in table 6, we estimated forgone revenues for fiscal year 2003 of  $1,135,250 and $464,450 for commercial filming and still photography  activity, respectively, using the Forest Service fee schedule, for a total of  $1,599,700. By comparison, we estimated forgone revenues of $1,292,850  and $750,950 for commercial filming and still photography activity,  respectively, using the Park Service proposed fee schedule, for a total of  $2,043,800. However, this schedule has not been approved for use, and it is  uncertain whether the amounts in the schedule would have been applicable  in fiscal year 2003.
section_title: Information on the 2003 National Football League Kickoff Event
paragraphs: In September 2003, the Park Service’s National Capital Parks-Central staff  approved a permit for the National Football League (NFL) to hold its  annual kickoff event on the National Mall (Mall) in Washington, D.C. The 4- day event was promoted as a welcome home for American military troops.  The Department of the Interior’s Take Pride in America initiative was listed  as a partner in the event. The event was attended by thousands of people— estimates ranged from 100,000 to 500,000—who participated in football- related activities and attended performances from a variety of entertainers.  Public reaction to the event ranged from “joy to anger,” and many questions  were raised about the event and the Park Service’s permitting process.  Specifically, concerns were raised about the appropriateness of permitting  this event on the Mall, the extent of commercial signage, limitations on  public access, and whether costs to repair damages to Mall resources and  property were recovered from the NFL.
Park Service guidance states that special events should “contribute to  visitor understanding of the significance of the park area.” Consequently,  critics questioned whether the Mall was an appropriate venue for an NFL  kickoff event. The Mall is a two-mile greenway that stretches from the U.S.  Capitol on the east side to the Lincoln Memorial on the west. The Mall is  the setting for world-renowned national museums, memorials, and  significant federal buildings. However, for many years the Mall has also  been host to diverse events, including fund-raisers, sports tournaments,  and festivals as well as hundreds of First Amendment activities. Park  Service policy for special events states that it “will not permit the public  staging of special events that are conducted primarily for the material or  financial benefit of organizers or participants; or are commercial in nature;  or that demand in-park advertising or publicity; or for which a separate  public admission fee is to be charged.”  Critics of the NFL kickoff event  asserted this was a commercial event that was conducted primarily for the  financial benefit of the NFL and the event’s commercial sponsors.
As discussed in this report, Park Service superintendents have a great deal  of discretion in applying the agency guidance for approving permits.  According to Park Service officials, the NFL kickoff event was intended to  honor members of America’s armed forces and to promote volunteerism on  public lands. According to a September 3, 2003, statement by the Secretary  of the Interior, the NFL kickoff event was “a wonderful opportunity to  showcase public service by volunteers” who put “their love of country to  work to improve our national parks, wildlife refuges, public lands, cultural  and historic sites, playgrounds and other recreation areas.” In addition to  setting up a Take Pride in America booth at the event to recruit volunteers  for this program, public service announcements about Take Pride in  America, narrated by Washington Redskins players, were broadcast during  the NFL team’s season opener. Finally, Park Service officials stated the  product-related signs were allowed as a form of sponsor recognition for  those companies underwriting the cost of the concert and other activities  that were all free to the public.
subsections: section_title: The 2003 NFL Kickoff Permit
paragraphs: On May 7, 2003, a permit application for a season-opening event on the Mall  was submitted to the Park Service’s National Capital Parks-Central office  by an NFL representative. In the application, the event was described as a  celebration of American treasures, heroes, places, and pastimes. Following  receipt of the application, numerous discussions and planning meetings  took place between Park Service and NFL representatives. According to  Park Service officials involved in these meetings, the key issues addressed  involved public safety and protection of park resources.
Park Service permits for these types of events contain general conditions  such as the requirement to procure liability insurance that lists the agency  granting the permit as an insured party. In addition to meeting the general  conditions, the NFL was also required to acquire certain permits from the  District of Columbia through the city’s Emergency Management Agency,  which coordinates with the Metropolitan Police, the Fire Department, and  other District agencies to assure the NFL provided adequate emergency  medical services such as first aid stations and ambulances during the event.  In late August 2003, National Capital Parks-Central formally approved the  agreed-upon terms and conditions for the event by issuing the event permit.  National Capital Parks-Central officials continued to meet with NFL event  planners to reach agreement on last minute details of the event and a  revised permit was issued on September 3, 2003.
Due to the location of the event—the Mall—the NFL was required to  closely coordinate all security plans through the United States Park Police  (Park Police), which provided public safety and security for the event and  related activities. A condition of the permit stated that the NFL was  responsible for obtaining the necessary permissions and permits from the  Metropolitan Police Department and from other agencies and departments  with jurisdiction over the public lands not under the jurisdiction of the Park  Service. In addition, the Park Police used the assistance of other law  enforcement officers from federal, state, and local agencies to provide  sufficient staff and personnel to handle the event. As required by the  permit, the costs for providing law enforcement officers, including Park  Police, were reimbursed by the NFL.
During and following the event, criticism was directed at the Park Service  over the lineup of entertainers, which included Aerosmith, Britney Spears,  and Aretha Franklin, as well as the content of some of the performances.  For example, some people did not consider specific aspects of Britney  Spears’ show to be appropriate family entertainment for an 8:00 p.m.  broadcast. While Park Service policies state “the theme of the special event  must be consistent with the mission of the park and appropriate to the park  in which it is to be held,” National Capital Parks-Central officials stated  they do not make “content-based decisions on whether to permit”  requested events.
section_title: Signage
paragraphs: The NFL kickoff event was advertised as a welcome home celebration for  American soldiers—a tribute to the military personnel serving in Iraq and  Afghanistan—and an opportunity for people to gather and watch popular  entertainers for no charge. But to some observers, such as the President of  the National Coalition to Save Our Mall, it was a “tasteless extravaganza of  electronic advertising.” Following the event, criticisms directed at the Park  Service for allowing commercial signage on the Mall grew. Critics claimed  there were contradictions between the Park Service’s policies and the  activities that occurred during the event. Some critics of the event claimed  that most, if not all, of the commercial signs should not have been  displayed on the Mall. One author, a former national park ranger who is the  director of a Washington, D.C.-based advocacy organization and former  president of the Conservation and Preservation Charities of America,  concurred with outraged critics over “the dimensions of the commercial  displays that had no legitimate place on the National Mall in the first  place”—his description of the giant product banners on the grounds  between the U.S. Capitol and the Lincoln Memorial.
According to the National Capital Parks-Central Superintendent, the  nationally televised event was a new experience for park staff and resulted  in many “lessons learned.” Concerning the “excessive commercial signage”  described by some critics, the current Superintendent, who was the Acting  Superintendent at the Park in September 2003, took responsibility for these  issues and said she had misunderstood the amount, type, and size of  signage the NFL planned to use. In the event permit, she noted, Park  Service had not quantified the number of sponsor recognition signs allowed  because they had not foreseen the need to do so. Consequently, there were  also far more banners and signs posted than the Park Service had  anticipated.
Congress passed legislation putting new restrictions on permits issued for  the Mall. Public Law No. 108-108 prohibited the use of appropriated funds  in fiscal year 2004 for special event permits on the Mall, unless the permit  “expressly prohibits the erection, placement, or use of structures and signs  bearing commercial advertising.” The law still allowed for recognizing the  sponsors of special events, providing “the size and form of the recognition  shall be consistent with the special nature and sanctity of the Mall and any  lettering or design identifying the sponsor shall be no larger than one-third  the size of the lettering or design identifying the special event.” As a result  of this legislation, the Park Service has drafted policy guidance to restrict  “the size, scale, scope and location of corporate logos and script.” In  addition, National Capital Parks-Central officials now require permit  applicants to provide detailed lists of planned signage along with a scaled  replica of each sign to the Park Service for approval at least 30 days in  advance of an event.
section_title: Public Access Restrictions
paragraphs: Park Service regulations for the National Capital Region state that the  decision to issue a special event permit must be based on a consideration  of a number of factors, including whether the park area requested is  reasonably suited in terms of size, accessibility, and nature of the event.  The NFL kickoff event, although permitted, raised a number of access  issues. For example, while the permit for the event stipulated that “all  sidewalks, walkways, and roadways must remain unobstructed to allow for  the reasonable use of these areas by pedestrians, vehicles, and other park  visitors,” some groups complained that large portions of the Mall were  inaccessible for days leading up to the NFL event. Another condition of the  permit stated “no vehicle shall obstruct or interfere with the Tourmobile  service that utilizes Jefferson and Madison Drives, from 3rd to 14th Streets.  However, the National Tour Association Web page advised tour operators  and motorcoach drivers bound for Washington, D.C., to be aware of several  street closures and the closure of access to the Mall at noon on September  4 in association with the NFL kickoff event. The Smithsonian Institution  museums remained open during the festival, but access was not available  from the regular Mall-side doors on the afternoon of the NFL kickoff event.  According to Park Service officials, these streets were closed during the  event for security reasons consistent with security plans for other large- scale public gatherings on the Mall. The Mall entrance to the Smithsonian  Metro stop was also closed at noon on the day of the NFL event by the  Washington Metropolitan Area Transit Authority for security reasons. In  addition to addressing signage limitations, Public Law 108-108 also stated  that “the Secretary shall ensure, to the maximum extent practicable, that  public use of, and access to the Mall is not restricted.”
section_title: Resource Damage Cost Recovery
paragraphs: There was significant turf and walkway damage to the Mall as a result of  the NFL kickoff event. Prior to the event, National Capital Parks–Central  officials required the permittee to provide irrevocable letters of credit  totaling $250,000 to cover event-related liabilities, such as monitoring costs  and potential resource damages as a result of the event. The actual cost of  the event far exceeded the Park Service’s estimated costs. According to a  November 3, 2003, letter to the permittee, the increase in damage recovery  costs occurred in part due to “the increase in the number and types of  heavy equipment that were utilized during the setup and break down of the  event staging and other facilities.” The Superintendent noted that several  days of heavy rain also contributed to the higher-than-expected amount of  damage to the turf and walkways. However, a condition in the NFL kickoff  event permit—which is a standard condition in special event permits— specifies that the permittee is liable for damage to the resource as a result  of the permitted activity. Consequently, after the NFL kickoff event, the turf  and walkway damage was assessed and the permittee was notified of the  damage along with the Park Service’s estimate of repair costs. The NFL  ultimately reimbursed the Park Service over $430,000 to cover both event  monitoring costs and to repair resource damages (primarily to turf and  sod).
The NFL reimbursed the Park Police almost $700,000 to cover the cost for  security personnel for the NFL event. Prior to the event, the NFL posted a  letter of credit for the Park Police in the amount of $1,150,000. The actual  expenses charged for Park Police support of operations relating to the NFL  kickoff permit totaled $698,625. The inclement weather was cited by Park  Police officials as a factor in their reduced costs, because fewer  participants showed up at the event and fewer people stayed late. This  resulted in fewer required security personnel than originally anticipated  and with fewer actual hours of monitoring.
Reimbursement was not sought from the NFL for the time both Park  Service and Park Police officials spent in planning meetings for the 2003  NFL kickoff event. The practice of the National Capital Region—to limit  charges for administration of permits to cost recovery for overtime  expenses—was based on a mid-1990s unwritten legal opinion from the  Solicitor’s Office at the Department of the Interior. National Capital Parks- Central officials told us they viewed time spent in event-planning meetings  and in processing the permit paperwork as a “budgeted” or sunk cost. In  February 2005, Interior’s Office of Solicitor revised its legal conclusion and  recommendation on this matter and advised both Park Service and Park  Police officials in the National Capital Region to re-examine this practice in  order to come into better compliance with cost recovery policy guidance.
section_title: Comments from the Department of the Interior
paragraphs: The following are GAO’s comments on the Department of the Interior’s  letter dated April 25, 2005.
subsections: section_title: GAO Comments
paragraphs: 1. We added the Special Park Uses Manager’s comment about the  appropriateness of charging cost recovery when the monitoring was  conducted as part of routine operations, in footnote 8 on page 10.  However, based on our review of permit documentation and  discussions with officials at Blue Ridge Parkway, this circumstance did  not exist at Blue Ridge Parkway. Thus, no change to the example on  page 3 is needed. 2. We have included the Reference Manual 53 Web site address in footnote  10 on page 13, so that readers can more easily seek out Park Service  policy guidance. 3. We agree that further definition of the term “administrative fee” is  warranted. As a result, we added clarifying text and a footnote to page  13 to more explicitly describe permit processing costs included in  administrative fees. (See footnote 10.) 4. While it is true that FWS and Park Service were barred from collecting  a location fee for filming and photography prior to the passage of the  Commercial Filming Law, this was a regulatory prohibition instituted  by the agency itself. The Commercial Filming Law effectively repealed  that prohibition. 5. Park Service regulations are cited in footnote 4 on page 8;  consequently, including a lengthy excerpt from the regulations in the  text is unnecessary.  6. See GAO comment 5. 7. We have removed the reference to the general Park Service regulations  and modified the text on page 34 to describe the specific regulations  associated with the National Capital Region’s permitting of the NFL  event and public access restrictions.  8. See GAO comment 1.
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to those named above, John Delicath, Doreen Feldman,  Timothy Guinane, Julian Klazkin, Roy Judy, Diane Lund, Judy Pagano, Paul  Staley, and Mary Welch made key contributions to this report. Darren  Goode, Robert Martin, Miguel Lujan, Glenn Slocum, and John Warner made  significant contributions related to cost accounting issues during this  review. Kevin Bailey, Denton Herring, and Matthew Reinhart made  important graphic or data input contributions to the report.