On December 20, 2019, a group of music librarians, archivists, and library copyright specialists submitted comments to the Copyright Office in response to its Notice of Inquiry regarding Music Modernization License Implementation Regulations.
We write to encourage the Office to include options in the new blanket licensing structure appropriate for libraries, archives, museums, and other educational and cultural institutions. We are music librarians, library copyright experts, and library associations who work with educational, research, and nonprofit institutions holding collections of sound recordings that could benefit from the MMA blanket section 115 “mechanical” licenses. However, for our institutions to benefit from the MMA’s blanket license provisions, the Office must include licensing options appropriate for our nonprofit, educational institutions.
Read our comment here: MMA-20191220-reply-comment-LibrariansArchivistsALA .
The comments were solicited by the US Copyright Office as it writes rules to establish blanket licensing for downloads and interactive streams of musical works. The rules being considered are unfortunately tailored for large commercial providers, such as Pandora and Spotify. Music and copyright librarians, along with the American Library Association, argued that libraries, museums, and educational institutions would benefit from licenses that were tailored for educational and nonprofit uses. College radio stations, for example, currently rely on educational rates. The MMA comment points out that an educational / nonprofit rate could allow institutions to share locally produced works and unique collections, generating royalties and exposure for artists, and use of libraries’ unique collections.
More reading:
- Music Librarians, Archivists, and Library Copyright Specialists NOI Reply Comments, available at:
- Others’ comments and reply comments at Regulations.gov
- Copyright Office “Notice of Inquiry” (NOI)
- Basic info about the “Music Licensing Modernization Act”, Title I of the “Music Modernization Act” (MMA), and more info about the MMA