Special uses permits regulate the  amount, kind, time, and place of the proposed activity. In addition, it has been required  by law to collect costs and location fees associated with filming activities  for almost five years. The Park Service Has Specific Policy Guidance for Issuing Permits and Recovering Costs for Special Park Uses

The Park Service developed specific policy guidance for issuing permits  and recovering costs for special park uses. Park Service Guidance Includes Requirement to Recover Costs

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. 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. 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

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. 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. 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 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. Delays in Implementing the Law to Collect Location Fees for Commercial Filming and Still Photography Have Resulted in Forgone Revenues

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. 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). However, the law has not been  implemented. 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. 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. GAO Comments

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Why GAO Did This Study

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.

What GAO Found

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.