NANPA Opposes a Colorado Permit for Selling Wildlife Photographs

[Blog Poster]

Advocacy/Public Lands and Access

Public Lands and Access

NANPA Opposes a Colorado Permit for Selling Wildlife Photographs​

With ASMP, NANPA asked the Colorado Parks and Wildlife Commission to deny a petition that would require an annual state permit before anyone sells or licenses an image of wildlife.

September 12, 2026


On the Record

Comments Submitted​

Submitted
August 27, 2026
Agency
Colorado Parks and Wildlife Commission
Filed By
ASMP and NANPA

Last reported development: September 7, 2026. Howard Paul reported that the petition had entered internal review.

Open the Comments PDF

Follow the Shared Matter at ASMP

On This Page
The Proposed PermitWhat We AskedWhy It MattersThe Comments

“Orfeo Vs Kanthaka” · Sand Wash Basin, Maybell, Colorado
© Donna Fullerton · Mammals, Top 100 · NANPA Showcase 2025

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)


The Question Before the Commission

Should Colorado require photographers and artists to buy a state permit before they sell or license an image of wildlife?

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

“You do not conserve wildlife by charging people for pictures of wildlife.”

Thomas Maddrey, ASMP CEO, in the comments submitted for ASMP and NANPA (p. 5)

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.

Credits​

Howard Paul, president of ASMP Colorado, first brought the petition to ASMP National’s attention. The ASMP Colorado chapter also filed its own comments and helped bring photographers’ concerns to the Commission.


The Submitted Document

Comments of ASMP and NANPA​

Submitted August 27, 2026 to the Colorado Parks and Wildlife Commission.

PDF · 5 pages · Original submitted comments

Read the comments PDF

Read the citizen petition

Share This Matter​

The existing NANPA share kit includes graphics and suggested post text.

Download the existing share kit


Individual graphics: Feed Graphic (PNG, 1080 × 1350) · Story Graphic (PNG, 1080 × 1920) · Link Card (PNG, 1200 × 627)


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The Original Documents​

Browse comments, briefs, letters, and statements with their source records.

Document Collection