Dear Ms. Cho (comments left at Eugene Hernandez's open letter to NYC re: proposed film permit rules)
Dear Ms. Cho,
It seems that the proper intent of the new MOFTB rules would be to regulate large budget commercial filmmaking activity. However, the proposed rules, as they stand now, severely restrict ordinary citizen's free speech conducted through the mediums of film, video & photography, & thus would invite legal challenges and lawsuits. If the MOFTB is interested in refining its policies towards big budget (a budget level could be identified in the rules to clarify what big budget is - over $250,000, over a million $s, etc.) filmmaking, the rules can specifically mention that and should specifically mention that amateur & low budget/"no-budget" filmmaking, video making & photography are excluded from the permit & insurance requirements of the rules. Otherwise the rules, as they stand now, invite harassment of millions of tourists, thousands of film students, also many amateur & low budget filmmakers from the police and other law enforcement agencies. The rules also invite, as I mentioned earlier, legal action against, and a ton of negative press for the office of the Mayor of New York. Beyond the legal and financial and publicity drawbacks to current proposed rules, the MOFTB will be putting the economic future of the New York based film industry at risk by making it difficult for new filmmakers to refine their skills through low budget filmmaking.
As a visitor to New York City and a fan of New York City filmmaking (an important section of the nation's film heritage has come from low budget filmmaking and careers started in New York; that of John Cassavetes, Andy Warhol, Spike Lee, Jim Jarmusch, to name just 4 world renowned filmmakers who got their start making low budget movies on the streets of New York) I sincerely hope that the permit rules as proposed do not become law but rather a more refined set of rules are adopted; a set of rules that protects the ability of the ordinary citizen to celebrate New York through film, video & photography and encourages aspiring filmmakers (future engines of positive publicity & wealth/economic activity for the city) to pursue low budget filmmaking without fear of police harassment.
Visitor to & big fan of New York City