February 23, 2021

Dear Minister François-Philippe Champagne, Minister Steven Guilbeault :

I write to you on behalf of the Association des archivistes du Québec, the Association of Canadian Archivists, and the Canadian Council of Archives, to protest the extremely short deadline for stakeholders to present comments to the “Consultation on how to implement an extended general term of copyright protection in Canada”. These three organizations represent the Canadian archival community through its institutions and the members of its English and French-language professional associations.

The issues involved in this consultation are complex and are of extremely high importance to the entire Canadian archival community. A deadline of less than four weeks for submission of comments is completely inadequate, given the complexity of the issues involved – including the implementation of term of protection extension, Orphan Works, and Crown Copyright. We must have enough time to seriously consider the options presented in the consultation document, to consider other possibilities, and to consult appropriately with our community.  There is also the added complication that we are presently in the midst of global pandemic when communication is more difficult. We question the urgency, given that final decisions are not required until 2022.

We urge you to immediately extend the deadline to something more realistic, that will also allow all stakeholders to proceed in a reasonable and transparent way towards the deadline for implementation of the CUSMA term extension.

Nancy Marrelli

Special Advisor-Copyright/Conseillère spéciale, Droit d’auteur Board of Directors/Comité de direction Canadian Council of Archives/Conseil canadien des archives

130 Albert Street, Suite 1912 Ottawa  ON  K1P 5G4

Tel: (613) 565-5445  Fax: (613) 565-5445  Cell: (514) 804-8118 http://www.archivescanada.ca/

Cc Erica Hernández-Read, President, Association of Canadian Archivists

Frédéric Giuliano, Président, Association des archivistes du Québec

Joanna Aiton-Kerr, Chairperson/Présidente, Canadian Council of Archives/Conseil canadien.des archives

copyright-consultation-droitdauteur@canada.ca