500 participants in an approximately 25,000 square foot area is 1 person per 50 square feet, or one fifth of what is normally considered a "loose" crowd.  This seems to be an unreasable restriction on the maximum number of participants.

Having the partiipant threshold for requiring a permit at 10 persons seems to be so low as to prohibit bona fide activities which are not making a social statement or creating a risk to the public, and so low as to lead to ambiguity regarding what constitutes an individual event/gathering. This low number might also create ambiguity in how citizens not participating in a gathering / event might be allowed to enjoy the area while an event, consisting of a small number of people (say 12, for example), is taking place.

I think it is unreasonable to prohibit individuals from enjoying the monument area at night.  It is an aesthetically pleasing place at night for walking and contemplation.

I think that the public should be allowed access to the stairs for their peaceful, legal, enjoyment (e.g., sitting, picnicing, using as a pedestal to view the srrounding area, etc.).