(via email to hon.steven.guilbeault@canada.ca) Dear Minister Guilbeault, On behalf of the Canadian Association of Research Libraries (CARL), we would like to once again voice deep concerns regarding the 2020 revisions to the Canadian Cultural Property Export Review Board’s (CCPERB) Guide to Monetary Appraisals. [...] Although CARL and other members of the archival community submitted feedback on the revised guidelines in the Fall of 2020, the Guide summarily ignores the concerns previously identified and summarized below: ● There is virtually no market in Canada for the sale of archival material. [...] The increased dependency on demonstrating comparable sales to determine fair market value and the rejection of other methods of reasoned justification, as well as the explicit exclusion of non-monetary values, greatly reduce Canadian research libraries’ ability to attract and retain significant and unique Canadiana. [...] This is particularly salient as the change is inconsistent with your government's vision of the Cultural Property Program, as cited in the 2019 Budget: “To encourage Canadians to donate cultural property of ‘outstanding significance’ [...] to certain designated institutions in Canada, such as museums and public art galleries, the Government provides special tax incentives. [...] We hope to have the opportunity to further discuss these concerns with you and to work together to develop reasonable alternatives in order to ensure that public collections of Canada’s documentary heritage continue to grow.
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