Safe Amplification Site Society offers suggestions on regulatory review for live performance venues

The Safe Amplification Site Society has issued the following statement on the City of Vancouver's review of regulations for live performance venues:

In October 2009, the City of Vancouver’s Cultural Services launched a Regulatory Review for Live Performance Venues, a process that promised to “harmonize and modernize” the City’s regulatory systems surrounding live performance spaces. When the Regulatory Review was announced over a year ago, many of us in the cultural community were ecstatic to hear that finally, the City was going to legalize live performance and fix a messed-up system that has sealed the fate of countless local venues. We remain positive about the Regulatory Review and are cautiously optimistic that it will have a lasting positive impact.

As a non-profit organization that seeks to promote the legitimacy of music and arts communities within the city of Vancouver, the Safe Amplification Site Society is naturally interested in following the progress of the Regulatory Review. This Review is an exciting and historic opportunity, and as Cultural Services prepares to make their Administrative Report on Phase I of the Review this Thursday, February 3, 2011, we are issuing this statement. The Phase I Report makes many recommendations to Council, and in the spirit of trying to help make the Review as effective as possible, Safe Amp would like to add the following suggestions:

A- That Council direct Cultural Services to welcome input from Vancouver’s embattled music communities by giving them representation in the Cultural Facilities Implementation Team.

We believe that the Review should pay closest attention to the cultural communities most victimized by existing regulations, namely the small amateur organizations that usually host ”˜loud’ / ”˜edgy’ music and dance events. While these voices were included in the 2009 ”˜roundtables’ which led up to the Review, we are deeply disappointed that they have been excluded from the Cultural Facilities Implementation Team, the group mandated to provide Cultural Services with advice and community input. Of the eight non-City of Vancouver team-members listed in the Report, many represent large professional arts organizations. MusicFest Vancouver is the only music organization included on the team, and this group focuses on classical, jazz and world music only; the venues that host these genres are not the sorts of spaces that have historically been targeted by existing regulations. We are concerned that Cultural Services is getting their advice and community input from an imbalanced group of organizations, and that the advice and input this team provides will not help the cultural communities who need it most. We ask Cultural Services to expand their Cultural Facilities Implementation Team to include representatives of small and medium sized music organizations who are involved with loud and historically problematic live performance events.

B- That Council adopt the proposed Interim Program in a fair and attainable fashion.

If passed, the Interim Program proposed in this report will offer a probationary period to venues that fall victim to regulatory enforcement, allowing venue operators a grace period to bring their space within the City’s requirements before further enforcement action is taken. We support the Interim Program. In our opinion, this program will be a success if the terms of the probation are reasonable, affordable, and negotiated with adequate input from the venue operator. It must not be seen as an unattainable ultimatum forced upon venue operators by City inspectors.

C- That Council adopt the proposed ”˜all-in-one’ license for temporary indoor events with clear, affordable and attainable requirements.

Much of the Phase I Report deals with making it legal to hold occasional “temporary” live performance events in spaces that are not legally permitted to be permanent performance venues. This policy would enable the operator of a retail space, for example, to apply online for an ”˜all-in-one’ license which would allow one performance event. While we support this streamlined process for licensing live performance events, we are concerned that the term “temporary” is left ambiguous. How often will a facility be permitted to hold temporary events licensed with the ”˜all-in-one’ license? We ask Cultural Services to clearly define “temporary.” Furthermore, many of the criteria for obtaining an ”˜all-in-one’ license (such as emergency lighting, approved fire extinguishers, a fire alarm system or “designated trained personnel”) lack clear definitions and may be difficult to meet. Must emergency lighting be powered by an alternate power source? Who must the trained personnel be trained by? These questions must be clearly answered and all the requirements must be affordable and attainable by event organizers. If they are not, organizers will ignore the new license, continue holding illegal events, and the locations where these events are held will continue to be shut down.

D- That Council assist Cultural Services with putting their work online in a clear, specific and jargon-free manner.

The problems with lack of clarity on the ”˜all-in-one’ license criteria are symptomatic of a larger issue surrounding communication and the Review. The Review is now almost sixteen months old, and the amount of information that exists online is extremely lacking. We ask Council to give Cultural Services the resources necessary to put all of their work online as soon as possible, including the establishment of the new online centralized information system promised in the Report, clear explanations of all the different criteria for the new ”˜all-in-one’ license, and detailed information about joining the new Interim Program.

E- That Council do anything possible to speed up future phases of the Regulatory Review.

Since the Regulatory Review began sixteen months ago, at least four affordable live music spaces (Little Mountain Gallery, ROY G BIV, Red Gate, and Scratch on Richards) have either closed their doors permanently or have been forced to stop hosting live music events. While we are cautiously optimistic that the Interim Program and other future impacts of the Regulatory Review will keep venues like these open in the future, we worry that by the time these changes are implemented, there may not be any cultural spaces left to save. The focus of Phase I of the Review seems to be largely on damage control. If the Interim Program is implemented fairly, it should help decriminalize illegal venues and allow them to remain open. If the requirements for the ”˜all-in-one’ license for temporary indoor events are made clear and attainable, it will be possible to hold occasional legal events in spaces that are not recognized as permanent legal venues. The Phase I Report contains some important steps towards fixing the regulatory problems facing live performance venues in Vancouver, but unfortunately, these are just steps. The real long-term solution lies in making it uncomplicated and affordable to open legal venues on a permanent basis, and we are cautiously optimistic that if Cultural Services continues to improve their methods of communication and welcomes input from smaller louder music organizations, future phases of the Review will accomplish that goal. We recognize the commitment that Council has made to this Review by not cutting back Cultural Services’ staff in an economic environment where many other City services have been cut, but we also firmly believe that this Review is vital if we wish to elevate our city’s status as a cultural capital. If there is anything that Council can do to speed up the development and implementation of all phases of the Regulatory Review, we ask them to please do so immediately.

The text of the Regulatory Review Phase I Report can be found here: http://vancouver.ca/ctyclerk/cclerk/20110203/documents/csbu4CulturalServ...

Sincerely,

The Board of Directors,
Safe Amplification Site Society
www.safeamp.org