On August 27, NANPA and ASMP submitted comments asking the Colorado Parks and Wildlife Commission to deny a citizen petition for an annual Wildlife Photographer/Artist Permit. It would apply before anyone sells, licenses, or commercially distributes a depiction of wildlife under the agency’s jurisdiction, anywhere in the state, including images made on private property. Civil and criminal penalties are proposed for violations.

What the Permit Would Cost Each Year

Colorado resident · Individual

$35

Nonresident · Individual

$100

Commercial entity · Including a photographer’s LLC

$250

There is no minimum revenue threshold. A single print sale, a greeting card, an old image later licensed to a magazine, or a wildlife-themed item sold by a small nonprofit could trigger the permit. (Comments, p. 4)

What NANPA and ASMP Asked the Commission

1. A Content-Based Burden on Protected Expression

   Requiring government permission to sell or license a photograph because of what it depicts raises serious First Amendment concerns. Selling an image does not strip it of protection.

   Comments, p. 2

2. Wildlife Authority Does Not Reach Art

   The agency manages wildlife. The petition would stretch that power into a licensing system for photographs and artwork.

   Comments, p. 2

3. Rules Should Follow Impact

   ASMP and NANPA support enforceable rules against disturbing wildlife or damaging habitat. The federal FILM Act already ties permits to a crew’s effect on the land, not to whether an image earns money.

   Comments, p. 3

4. Unworkable and Unsupported

   The petition sets no revenue threshold, leaves basic enforcement questions open, and offers no evidence that selling wildlife images harms wildlife.

   Comments, p. 4

Why It Matters to Nature Photographers

The permit would reach prints, stock licenses, and merchandise, and it would treat the sale of an image as the problem rather than any harm to animals or habitat. Photographs are how many people see wildlife and wild places they will never visit, and the petition would weaken that connection.

Photographers NANPA and ASMP Represent

7,500+

Nature and Wildlife Photographers Among Them

~1,800

Figures reported in the original September 2026 article.