Ironically the BLM has no 'standard' rules for commercial use, much less for photography.

I have gotten permits from various BLM offices for doing commercial activities all over S. Utah, and NONE of them run by the same rules. Some want to audit books, some want an 'honest' assesment from me to tell them how much I owe them. Most run on a standard %-age of the gross to determine how much to charge per user-day on their land. Gets really mushy and grey when I am going from National Forest to BLM to National Recreation Area land in one day.

Gets REALLY grey when I tell the people issuing permits that I have no idea how the images will be used. They 'could' potentially be used for all kinds of commercial activities, but for right now at the actual time of the picture taking they are usually on spec or for stock. I challenge any governmental entity to predict the future as to how one picture will sell in the future and one picture won't.

The fee system is a good idea, the park service is in dire need of funds, but IMO they could raise each entry permit a few more bucks and issue a few more tickets for parking where you're not supposed to and blocking traffic (in Yellowstone for example), and a few more tickets for idiots who are out petting buffalo than start splitting hairs and trying to figure out which activities are commercial and which aren't.

Granted, the line is very clear when you have lighting equipment, props, models, etc...then it's a no brainer. Charge them a ton and make them pass the cost through. I have no problem with that.

When I have to start paying fees to use my 'public' lands for non-commercial activitires, then they aren't so public anymore.