I invite indieWIRE members and readers of this blog to consider the following open letter to NYC’s Mayors Office of Film, Theater and Broadcasting (MOFTB), regarding the current open comment period for feedback to film permit rules proposed on May 25, 2007.
I will be emailing this letter to my contact at the MOFTB and encourage readers to post comments, feedback or suggested changes to the proposed rules. At the end of the week, when the comment period ends, I will also email these comments to organization for their consideration.
The full text of the letter follows.
Communications and Business Development
NYC Mayor’s Office of Film, Theatre & Broadcasting
1697 Broadway, 6th Floor
New York, NY 10019
Good Morning Julianne,
First, thank you for your responsiveness over the past few weeks regarding indieWIRE’s questions surrounding the MOFTB’s proposed Film Permit Rules. We appreciate your help with our coverage and as you know, indieWIRE’s article, written by Agnes Varnum, was published today.
As I mentioned to you on Monday, I have had numerous personal conversations with filmmakers and others active in New York’s independent film community over the past few days. As such, I would like to share a few thoughts before the public comment period concludes this Friday, August 3rd.
Putting aside any discussion about whether the MOFTB should be regulating such a wide array of filming and photography in the City of New York, in short, the proposed new rules seem overly restrictive. As you know, the wider availability of digital filmmaking and photography equipment coupled with the rapid growth of exhibition outlets at film festivals and through online sources over the past decade has led to ever-increasing numbers of established, emerging and amateur makers, many of whom adopt D.I.Y. (do it yourself) techniques and approaches. It is my view that these proposed film permit rules would stifle such activity.
A significant concern is the fact that New York’s independent filmmaking community was apparently not consulted when these proposed new rules were developed. Many people were unaware of the situation until emails and blog postings brought it to our attention and only now, days before the end of the public comment phase, are filmmakers here in the city coming to grips with the rammifications of these proposed permit rules.
In the indieWIRE article, you indicate that one of the options available to the MOFTB as it moves to the next step in the process is creating a new draft of rules and holding a new comment period and hearing. Based on my conversations with others in the community, I personally hope that the MOFTB will pursue this option so that concerned filmmakers and others have an adequate opportunity to be a productive part of the process. As I mentioned during our phone call on Monday night, your working with the IFP to gain further insight is a big step in the right direction and underscores your openness to working with New York’s filmmaking community.
I am also posting this email message on my personal blog in the hopes that it will lead to concrete suggestions, legitimate proposals or specific ideas that might be valuable to the MOFTB as it considers these proposed rules in view of any comments. I will send you another email at the end of the week with that feedback and we will, of course, continue to report on this issue in indieWIRE.
Editor-in-Chief & Co-Founder