Public Comment

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Re: Proposed Amendments to chapter 2 of Title 49 of the Rules of the City of New York

As those researching the lives and stories of New Yorkers past and present, we strongly object to the proposed amendments to chapter 2 of Title 49 of the Rules of the City of New York. 

The New York City Department of Records and Information Services (DORIS) is a public archive funded by the taxpayers. These rules (and proposed amendments) enable DORIS to charge individuals for personal use of their materials—far beyond the cost of making a copy. The changes allow DORIS to charge twice for access to a public record: once for the copy (which seems reasonable), and once to actually “use” it in any other form (which is a step too far). 

Restrictions placed upon the use of these public records are not acceptable.

We are genealogists, educators, scholars, and researchers who desire to use public records (i.e. materials created with taxpayer funds) without fees beyond the cost of replicating them. We strongly oppose any proposed language requiring a contract for “Permission to Publish/Use,” for educational, scholarly, non-profit, or media use. This language indicates the very use of these public records requires a license. 

We ask that DORIS eliminate the concept of a license to use public records for personal, educational, scholarly, non-profit, or media purposes existing in the current rules and within the proposed amendments to sections 2-06 and 3-01.

In summary, licenses (paid or free) to use public records for personal, educational, scholarly, non-profit, or media purposes are illogical, especially when materials were created and maintained by taxpayer funds.

 

Sincerely,