Clarification on Issuing Special Recreation Permits for Commercial Filming and Still Photography

IM 2013-126
Instruction Memorandum



May 23, 2013

In Reply Refer To:

8370, 2920 (WO-250, WO-350) P



Instruction Memorandum No. 2013-126

Expires: 09/30/2014


To:                   All Washington Office and Field Office Officials

            Attn:  State Recreation Leads

From:               Assistant Director, Renewable Resources and Planning

Subject:           Clarification on Issuing Special Recreation Permits for Commercial Filming and Still Photography

Program Area:  Recreation, Lands and Realty

Purpose:  This Instruction Memorandum (IM) provides further clarification and narrowing of criteria to be used when deciding whether to issue a special recreation permit (SRP) for  still photography activities under 43 CFR 2930 Subpart 2932.

Policy/Action:  The following text replaces paragraph 2 of BLM Handbook H-2930-1 (2006), Recreation Permit Administration Handbook, Chapter 1. Special Recreation Permits, I. Types of Permits, F. Relationship with Other Permits, 1. Commercial Filming Permits Issued in Conjunction with an SRP, page 13.

An SRP is not required for still photography on public lands, if it takes place where members of the public are generally allowed, except when one or more of the following situations apply:

  1. It uses a model, set, or prop which is not a part of a site’s natural or cultural resources, or administrative facilities, as defined in the attachment.
  2. The photography takes place at a location where or when members of the public are generally not allowed.
  3. The agency would incur costs for providing on-site management or oversight to protect agency resources or minimize visitor use conflicts.

Timeframe:  Effective immediately.

Budget Impact:  Minimal.

Background:  Public Law 106-206 creates an exemption from requiring a permit for some still photography activities which would otherwise be permitted under 43 CFR 2930 regulations.

Manual/Handbook Sections Affected:  Bureau of Land Management Handbook H-2930-1, Recreation Permit Administration (Public) 2006. Chapter 1, I, F, 1, paragraph 2.

Coordination:  Development of this IM was coordinated between the Division of Recreation and Visitor Services (WO-250), and the Division of Lands, Realty and Cadastral Survey (WO-350).

Contact:  If you have questions regarding this policy, please contact David Ballenger, Division of Recreation and Visitor Services (WO-250) at, or 202-912-7642, or contact Vanessa Engle, Division of Lands, Realty, and Cadastral Survey (WO-350) at, or 202-912-7339.



Signed by:                                                       Authenticated by:

Edwin L. Roberson                                         Robert M. Williams

Assistant Director                                           Division of IRM Governance,WO-560

Renewable Resources and Planning



3 Attachments

      1 – Public Law 106-206 (2 pp)

      2 – Definitions Related to Commercial Filming and Still Photography (1 p)

      3 – Questions and Answers for Still Photography (2 pp)


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