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(dd) On State land, no person shall sponsor, conduct or participate in any organized event of twenty or more people, except under permit from the department. Examples of organized events include, but are not limited to: sponsored hikes; archery and fishing tournaments; snowmobile; bicycle, horse and orienteering races, runs, rides or competitions (including biathlons and triathlons); encampments; and re-enactments.(ff) On State land, no person shall sponsor, conduct or participate in advertising, weddings or film making and other such events, except under permit from the department.
(ee) On State land, no person shall sponsor, conduct or participate in any research project except under permit from the department. Examples of research include, but are not limited to, population studies, collection of scientific samples, placement of scientific instruments, seismic exploration and archeological studies.
To whom it may concern:My primary concerns with the proposed amendments to Part 190 are subdivisions 190.8 (dd) (ee) and (ff).Requiring permits for gatherings on public land is unreasonable, and it violates our constitutionally guaranteed freedom to assemble in public places.Requirement of permits for noninvasive scientific study or research smacks of restricting access for studies that the Commissioner may not want to have done. Things that would affect the greater usership of the parks are already covered by other provisions governing the placement of structures and so forth. There is no need to force permits for observation or measurement in parks.Finally, the unlawfulness of filming on public lands without permit is equally disdainful. It is limiting perfectly reasonable access to our public access to lands that we pay to maintain. Remember in this digital age nearly any camera can take videos, and zealous enforcement of this law could result in nearly anyone visiting our parks being in potential violation. There is no definition of film making - anyone taking video for any reason, whether a family holiday or nature scenes for a personal or school project would need to be issued a permit. For what benefit? How does this needless red tape benefit those who enjoy, appreciate, and want to share the great outdoors?Thank you for your attention to these matters.[signed, address]
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