Comments

Rosemarie Kanusky Thu, 09/21/17 - 16:33 In the case of genealogical research, generalizations about average life span may not be helpful. My mother was born to her parents late in life and consequently lost her parents at a young age. Yet under the new rules she and her descendants would lose the ability to learn vital information.

Tom Andriola Thu, 09/21/17 - 20:39 This is another step backward. It builds upon the regressive action that has taken away access to the birth indexes that were housed at the New York Public Library, which were available for adoptees to obtain their own PERSONAL records, protected by and necessarily accessible by them pursuant to HIPAA, yet denied. I would like my article on the subject to be available to those making decisions on this matter, which is equally regressive in nature. https://adoption.com/nyc-removes-birth-indes-books-from-the-public-library

Diana Frederick Sat, 09/23/17 - 17:26 I agree that the government has an obligation to protect all persons from fraud and identity theft. I also agree that people are living longer and their right to privacy and protection are of the upmost importance. However putting such an extreme limit on when a birth or death record becomes public is overkill. Restricted access to vital records is a huge roadblock for most genealogist and family historians, this rule would make the roadblock more like a mountain. Instead of a 125 year rule for birth certificates, try providing uncertified copies that cannot be used for identification purposes as a good alternative. Clearly marking the document as unofficial, not having the official state seal and maybe even a 20 year rule should be more than enough to protect the living and satisfy the desire of the genealogist who just wants the record for record, not for harm. With respect to protecting a deceased persons information, after a person dies the social security number is removed from active use and placed into the Social Security Administration's Death Master File database. Therefore that persons personal information cannot be used for legal reason. To my knowledge, a death certificate cannot be used to open an account, get a credit card, be used as identification or any other fraud or identity theft reasons. Again, instead of having a 75 year rule for death certificates, using the same uncertified copy suggestion above would be a great compromise. I realize that criminals have made this topic important but I hope that innocent people won't be punished by the solution. As I'm sure most of you on the board are aware, criminals don't care about the laws and will find other ways to commit identity theft and fraud. By only providing certified copies to those that can prove they are the person on the paperwork and uncertified unusable copies to everyone else, a fair and balanced compromise can be achieved. Thank you for your time.

Robert J. Friedman Sun, 09/24/17 - 18:27 This rule is for VITAL records, not VIRAL records as the title indicates.

Bruce Hamilton Mon, 09/25/17 - 10:23 Your proposed new rules are completely unreasonable, unnecessary, and will significantly impede genealogical research. New York State Department of Health rules are more reasonable. They provide uncertified copies of the following types of records for genealogy research purposes: Birth certificates – if on file for at least 75 years and the person whose name is on the birth certificate is known to be deceased. Death certificates – if on file for at least 50 years. Marriage certificates – if on file for at least 50 years and both spouses are known to be deceased.

Fern Gutman Mon, 09/25/17 - 11:11 The proposed new rules create a high barrier to finding family and historical information. There is no proof of widespread identity theft from these public records, the danger is in the large database thefts like Equifax. Genealogists foster family reunification. The proposed rules put records out of reach to the point they are beyond living memory.

Bobby Clark Mon, 09/25/17 - 12:05 This will be burdensome to people researching family history. I understand the need to protect privacy especially in the age of Identity Theft but this proposal goes way beyond what is required. A more reasonable approach would be to limit access to birth records for 100 years and death records for 30. Currently in the US only 0.0173% of the population ever lives to the age of 100. That makes is unnecessary to extend the restriction past that time. It also seems unnecessary to restrict access to death records beyond 30 years after all the person listed is deceased. I understand that maybe other family members might want privacy but still it seems like 30 years post death should be more than enough to be reasonable. Accessing these records is vital to people doing Genealogical and Family History research and Historians as well. We should be able strike a fair balance between the right of privacy to families and the need for researchers to access those records.

Linda Hauck Fri, 10/6/17 - 8:11 The impact this change will have on genealogists and especially family historians is unthinkable. Family history is so important! Often these documents are a starting point for someone who is just beginning their research or provide the only clue(s) that helps them break through that dreaded brick wall. We actively encourage family history research. We should be helping people find ways to learn more about their ancestors, not creating more obstacles. Linda Hauck, Director, Tottenville Historical Society

Gyda Sabaugh Fri, 10/6/17 - 13:11 Please do not implement this rule! This would be a nightmare for genealogists, adoptees, people trying to research family health conditions. There are plenty of ways to protect identities without restricting the records in this way, including: —offering "informational" or "genealogical" copies which can not be used for proof of identity —allowing direct descendants (children, grandchildren, great-grandchildren, great-great-grandchildren) access to their family members records —restricting the records for a shorter period of time (why so long for a death certificate? what identity theft will occur with a DC, especially after 20-25 years?) —allowing access to birth records with proof of death There has to be a way to balance the needs of those researching their history with identity protection. These proposed rules are incredibly burdensome and punish people who are just trying to figure out where they come from.

Kerry Neely Mon, 10/9/17 - 12:08 As a genealogist, timely access to these records are critical and essential for my research. The proposed restrictions on when birth and death records would become available for public access would create an unnecessary hindrance for myself and millions of others seeking to trace their families within New York City’s vital records.

Gary Zizka Mon, 10/9/17 - 13:20 RE: Proposed Guidelines for Access to Public Vital Records Dear Commission Members, I have researched several generations of my family who were citizens of New York City. As an aspiring professional genealogist, timely access to your municipal records are both critical and essential for my research. The restrictions on when birth and death records would become available for public access that you are now considering would create an unnecessary barrier for me and millions of other descendants of New Yorkers who are seeking to trace their families within New York City’s vital records. I recommend that you consider the following guidelines for access: • Access to birth records after 75 years (if the individual’s death can be verified) or 105 years if no death date is verified. • Access to death records after 50 years; or after 25 years to registered members of a New York genealogical society. • Access to the index to death records after 25 years (providing the name, date of death, place of death, date of birth, and burial/cremation information). In addition, I ask that you consider developing and implementing of an informational copy of birth and death records, which would provide important details for genealogical and historical research in a format not suitable for proving identity. Sincerely, Gary M. Zizka Washington, DC

Cecelia Baty Tue, 10/10/17 - 11:21 Please do not adopt this rule. The New You Genealogical and Biographical Society has a proposal for you that you should adopt instead. These records are vital for genealogists and there is no need to implement this draconian rule. Thank you.

James Henderson Wed, 10/11/17 - 16:07 As a NYC genealogist, timely and easy access to these records are critical and essential for my research. The proposed restrictions on when birth and death records would become available for public access would create an unnecessary hindrance for myself and millions of others seeking to trace their families within NYC’s vital records. The NYS Department of Health rules are more reasonable and provide for uncertified copies of the following types of records for genealogy research purposes: Birth certificates if on file for at least 75 years and the person whose name is on the birth certificate is known to be deceased; death certificates if on file for at least 50 years; and marriage certificates if on file for at least 50 years and both spouses are known to be deceased.   I recommend the following guidelines: - Access to birth records after 75 years (if the individual’s death can be verified) or 90 years if no death date is verified; - Access to death records after 25 years; or after 10 years to registered members of a genealogical society; - Access to the index to death records after five years; - Issuance of uncertified facsimile copies of original birth and death records, marked with a stamp indicating that the facsimile copy is not suitable for proving identity.

Alex Friedlander Wed, 10/11/17 - 21:05 While I can understand the privacy concerns involved in proposing this rule, such a change will create considerable difficulties for people doing genealogical research. In particular, the 75 year limit for death records is very problematic, and I do not understand how death records older than 50 years (a common standard in other localities) would compromise the privacy of such individuals or their families. I would urge you to consider two modifications: preferably, change the limits to 50 years for deaths and 110 years for births; or alternatively, create a process that would permit valid members of genealogical societies and/or professional genealogists to access death records older than 50 years and birth records older than 100 years.

Jane Wilcox Wed, 10/11/17 - 22:35 Access to vital records is vital to my livelihood. As a professional forensic genealogist, I need to quickly provide vital records to courts, attorneys, and others for probate and other cases. Birth and death records rightly need to have reasonable periods of access restrictions. Those periods that the NYC DOHMH proposes are unnecessary burdens to me as a professional as well as the general public. Birth records should not be closed after 100 years, and should be open within 100 years if the person is deceased and should be available to anyone in that instance. Death records should not be closed at all. The perceived threat of identity theft is just that -- perceived. Having open records allows open access to check for identity. Preventing access to records does nothing to thwart the problem.

jane werthmann Thu, 10/12/17 - 8:54 he impact this change will have on genealogists and especially family historians is unthinkable. Family history is so important! Often these documents are a starting point for someone who is just beginning their research or provide the only clue(s) that helps them break through that dreaded brick wall. We actively encourage family history research. Please dont do this- this was the only way I found out about my grandmother's death was due to breast cancer.

Louise Perrotta Thu, 10/12/17 - 9:48 I am NOT a professional genealogist but I DO need access to these records. I am researching MY extended family. Your proposed new rules are excessively restrictive. I understand that New York State Department of Health rules are more reasonable. They provide uncertified copies of the following types of records for genealogy research purposes: Birth certificates – if on file for at least 75 years and the person whose name is on the birth certificate is known to be deceased. Death certificates – if on file for at least 50 years. Marriage certificates – if on file for at least 50 years and both spouses are known to be deceased. If a person is DECEASED what is the problem? There is no need to restrict it for an arbitrary/excessive number of years.

jo solomito-haslam Thu, 10/12/17 - 10:27 Please do not adopt this rule. I have been able to use these records to find my grandfather who died in 1917 when my father was only 2yrs old. Dad was never told anything about his father and had no memory of him. Through the records on this site I was finally able to find Grandpa's death certificate and was able to give my dad a chance to visit Grandpa's grave before my dad died of Alzheimer's disease. Your records are vital to those of us trying to piece together our families, especially for those of us whose family members died so long ago. Now I am researching my father's uncle. Without your site I may never find him since I have no living relatives who can fill in some of the gaps. We are up against so many road blocks that prevent us from 'finding our roots'. Please do not add another.

Katherine Davis Thu, 10/12/17 - 11:29 Please do not adopt these harsh measures. It will hurt adoptees like me and genealogists who simply are looking for family information. There are other effective ways to safeguard these records. Please adopt the Genealogical and Biographical Society's proposal instead.

Anne Jeffery Thu, 10/12/17 - 12:21 I agree completely with an earlier comment made by Diana Frederick, who said: "With respect to protecting a deceased persons information, after a person dies the social security number is removed from active use and placed into the Social Security Administration's Death Master File database. Therefore that persons personal information cannot be used for legal reason. To my knowledge, a death certificate cannot be used to open an account, get a credit card, be used as identification or any other fraud or identity theft reasons." So far, my research has only been in the State of Delaware, where I was able to obtain death certificates of relatives. Some contained Social Security numbers, some did not but they all have the word "GENEALOGY" stamped on them in plain sight. I also had to provide proof of identification in order to obtain these documents. In summation, removing the social security numbers from both birth and death certificates for genealogical research would be a better solution than blocking research for 75 -100 years. Thank you for the opportunity to comment.

Dolores Royere Thu, 10/12/17 - 13:09 I feel it's not a sensible or acceptable change of rule for Genealogist. It is very important for us to find this information to continue with our work. The years you propose are too long of a period for us to wait out. Genealogy is not only for our own personal reasons it is also a job. This rule is stopping a professional Genealogist's work, which effects their livelihood. I believe lawyers also need this info for court cases as proof, etc..

Michele Carroll Thu, 10/12/17 - 13:39 Please reconsider this proposed rule. I am an avid genealogist whose Great Grandparents and Grandfather, entered, married, had children, and lived in New York. Access to these records are really important to me. I am even planning a trip to New York to research my relatives. This rule would put a stop to my research and my visit. There have to be alternatives to this rule. I know you will find a workable solution to this. Thank you, Michele Carroll

Sheila Perino Sapienza Thu, 10/12/17 - 14:42 Clearly the city does need to take measures against the theft of identity. However, as the proposal currently stands it becomes a road block to those who have a legitimate right to these records. The proof of death for a birth certificate would be impossible if the individual in question was long lived and his/her death was in itself not seventy five years old. In my own case my father and mother were born in 1915 and 1917 respectively. My father passed in 1995 and my mother in 2005. Even though I do have their death certificates it would still be impossible to get their birth certificates because they are 'recently' deceased. These documents should belong to their heirs. I think that the law should have allowances for those who can prove their relationship to the deceased. It also should also provide some other way for genealogical groups to have access to death indexes after 25 years.

Claire Kegerise Thu, 10/12/17 - 16:02 As a genealogist, timely access to these records are critical and essential for my research. The proposed restrictions on when birth and death records would become available for public access would create an unnecessary hindrance for myself and millions of others seeking to trace their families within New York City’s vital records.

Edward Patton Thu, 10/12/17 - 20:43 This proposed rule is very poorly crafted. In New York State it is very hard for family historians to discover their ancestor's information. Other states, such as Ohio, give a researcher access to their family history with much more liberal terms. People research their family for many reasons, including health issues, and to discover their ancestral roots, and as a pleasant pastime. Amazingly enough, the Federal government releases Social Security information very shortly after a person dies. At the very least any family member should be able to access their family information no matter how long their relations have been dead. Millions of people are pursuing this family research hobby. I believe that people have the right to the information that this rule would suppress even more than it currently allows. As president of a well respected genealogical organization I believe that this proposed ruling will only make our research efforts extremely harder. In my own case obtaining certificates on my grandparents would not be legal until 2016. Since I am now 76 years old it would be 9 more years before I would be able to get a copy of a record. I think this proposed rule is way to restrictive for those seeking more information on their families for health or other reasons including pursuit of a highly popular hobby.

Nancy Serra-Spencer Thu, 10/12/17 - 22:29 putting a 125 year and 75 year hold on vital records will severely restrict the ability of genealogists and the public to access the records of their deceased loved ones. I have encountered this in other states and it has served no one interests. My grandmother is dead since the 70's. With this law I could never find her birth record and the birth and death records of her 10 siblings, including 2 sets of twins who died before the age of 4 months and where they are buried. As a result of finding this information I was able to visit their graves and honor my grandmother. This is a bad Idea and will not save us from identity theft. This has been done in Colorado where I live with marriage records. It is devastating and I bed that you not do the same thing!

mark foster Fri, 10/13/17 - 10:13 As a member of the Italian Genealogy Group and the German Genealogy Group for many years, and having used the resources of the NYC Municipal Archives since 1993 for my genealogy work, I fully support the proposal made by the RPAC concerning the availability of NYC Vital Records. Thank you, Mark Foster

Robin Schectman Fri, 10/13/17 - 15:08 I agree with many of the comments already posted here. Under the proposed guidelines I would not have lived long enough to have been able to discover my great grandparents' names, which I was able to obtain from my grandparents' 1969 and 1973 NYC death certificates. The death certificate restriction already existing, that post-1948 you must be directly related to the deceased, and no further than a grandchild, is also too restrictive to be able to find and verify grand aunts' and uncles' relationships. Under the proposed guidelines I would not have been able, several years ago, to discover and contact over fifty second cousins, previously unknown to me. Public access to these important records should be made less restrictive, not more.

Christine Rose Fri, 10/13/17 - 16:16 I agree with the many posted comments as to the unduly harsh restrictions proposed. It would seem we should have access to the information we seek for genealogical purposes (or other family interests). It has not been proven that this would prevent identity theft or even great diminish it.

Sheryl Stern-Titone Fri, 10/13/17 - 20:39 Hello. I am a very proud 2nd generation American & native New Yorker. I am my family's historian & genealogist. I have been able to trace my family history back to Europe, Ukraine, Russia & Great Britain because I have been able to access my great grandparent's & other ancestor's vital records from the time they arrived in New York as far back as 1895. Because of the availability of these records to me, I have been able to construct a very decent sized family tree, re-connect with living relatives I had lost contact with, connect with cousins I knew of, but, didn't know personally & have even found cousins I had no idea existed & that I now, very happily, have relationships with. I BEG of you to NOT APPROVE 'Proposed resolution to amend Article 207. These records are of extreme importance to family historians/genealogists everywhere. In many cases, we find that our ancestors played a crucial part in American history on the whole, because, some family members know stories & historical facts about an ancestor that other family members do not know. Our ancestors are the foundation of ourselves, our children & all future generations. Being able to see certain information about our ancestors also answers personal questions & provides fun facts to us. For example, both my grandfathers were women's fashion designers on 7th Ave in women's fashion design houses. I have always known this & always knew that my children have artistic talents that were inherited from these 2 men, but, many people don't find out their grandparent's occupations until they see it on a census record, a military record, a naturalization declaration certificate, etc. They then have an 'ah ha moment' as to why they have a special talent or enjoy a certain activity. They realize they or their children have inherited a certain trait from an ancestor. Being able to access a birth and/or death record confirms a maiden name, a married name, a great grandparent's unknown name, which can lead to tracing the ancestor(s) back to their country of origin, the ancestor's history in their country of origin, how they lived there & frequently & sadly, the conditions in which they lived, survived or died. These are things that instill family pride in people, make people want to set life goals for themselves, honor the family members that didn't survive the atrocities of genocide & want to have their own effect on the present & future society. Knowing the vital information on birth/death records can even lead to the answers of why some family members have certain medical conditions & can tell a medical provider of the patient many important things about why the person is ill, how to treat the person so that there might be a cure, a remission or long term treatment so as to allow the person a better quality of life. Thank you for taking the time to read this & weighing my words when you are trying to decide to vote for or against the proposed rules. Thank you in advance for your NO vote.

Steven Rosenberg Sat, 10/14/17 - 5:38 California has a better solution for Genealogists. They provide certificates with a stamp that states that the document cannot be used for identification purposes so that only official documents with a raised seal.can be used for identification purposes. Issuing of death certificates and births where proof of death is provided are vital information for researchers. Your proposal will prevent those who can prove a relationship from continuing to obtain these documents which does violate the rights of relatives from tracing their family history. Modifications to documents are not a very good reason fro. Blocking a family researcher due to extreme time frames and unreasonable regulations for what should be information on deceased individuals.

Harriet Simons Sat, 10/14/17 - 10:31 Contrary to making it more difficult for legal, genealogical or medical research I believe that New York CIty should be making this kind of information more available. In fact I think all records should be available no later than three years after death. I certain instances records of living people should be available to authorized researchers.

Jim Spero Sat, 10/14/17 - 11:40 While I understand the need to protect against identity theft, the current proposal goes too far and tramples the legitimate needs of genealogists. The compromise plan put forward by the NYB&G sufficiently protects against identity theft while providing genealogists access the to vital records they need. The compromise proposal can be found at: https://www.newyorkfamilyhistory.org/nyc-vital-records-access#letter The site has other steps that can be taken to voice the concerns of genealogists regarding this proposal. Jim

Dara Markowitz Sat, 10/14/17 - 12:08 The stated rule change: “The Department believes that these proposed schedules balance the need to protect the personal information of people who may be alive, especially as it relates to the problem of identity theft as well as other privacy issues, with the public’s right to access historically important records, including the specific interests of families, genealogists and other researchers.” The rule change indicates that the proposers are “concerned” about identify theft. This idea of reducing identity theft by extending the closure of records seems unfounded and the use of this excuse could be considered in my mind as irresponsible fear mongering. The problem of “ghosting” has nothing to do with obtaining death certificates. Please reference an article by AARP on this topic http://www.aarp.org/money/scams-fraud/info-03-2013/protecting-the-dead-from-identity-theft.html. Other similar articles are available as well from consumer organizations. It is also important to point out that these historic records are not certified copies which are needed for legal transactions and which require additional documents (i.e. photo ID, letters from a gov. agency) in order to be released. The statement that there are privacy, “the state of being free from public attention”, issues at stake is a tricky one. In fact the Federal Privacy Act is clear that once dead, their information isn’t generally protected under the law. Furthermore, people searching for historic documents, often genealogists, are aware that surprises may occur and that those surprises could be unpleasant. Yet, as adults, they seek information willingly, and the government really has no place to deny them. So I ask myself, what could be a real reason for this suggested rule change? I considered if these government offices are deriving some stream of income that the release of these records could impact? Fiscal issues are often behind the scenes. Another issue that comes to mind is the work of a group called Reclaim the Records (I have no affliction with this group but have seen their work on genealogical forums). After consulting this group’s website, I noted that they have successfully required NY to release materials but that they were obstructed and needed attorneys to prove these cases. The have an upcoming Freedom of Information request that notes the the NY Dept Dept of Health has been out of compliance for 7 years with the current NY directives that release these birth record after 100 years. After looking though these materials, I believe that this rule change is an attempt to hide their non compliance, derail this and possible future Freedom of Information Act requests, and avoid potential costs of compliance and or possible litigation. It my hope that these public comments will be taken seriously. I see no reason to extend these closures and every reason to make them less restrictive.

Shelley Mitchell Sat, 10/14/17 - 12:10 Your proposal for a change to longer non-disclosure is preposterous. Not only will it make it impossible for genealogists to do research but the chance of misuse of the information is minimal compared to the chance of misuse by anyone using a computer. With all the record hacking going on, you should not jump to the extreme conclusion that we don't have a right to know our heritage while we are alive. When a mother gives up a child for adoption, the birth records are changed so as to remove the biological birth mother's name and replace it with the adoptive mother's name. And even the father named isn't always the real name of the father. Your caution, while being sincere, is unnecessary. I have not searched for my Roots for all these years to be blocked by my own government. It's bad enough that many records in Europe were destroyed and we can't get into most Russian records or Chinese records. The past is the past. It often helps to shape the future to know the events of the past. To not repeat the mistakes of the past, like having a child out of wedlock. Or to learn that someone died of cancer so you can screen more often. Please don't go backwards and limit access.

Robert Bongiovi Sat, 10/14/17 - 12:22 I believe that access to records for family historians should not be restricted due to the bad behavior of a few. Instead of restricting access for law abiding genealogists please increase the penalties against the criminals. Thank you.

Betty MATTIFORD Sat, 10/14/17 - 16:28 I am a genealogist who is researching Italian relatives who came into NYC in the late 1890's and early 1900's. My grandparents and their siblings lived into the 1970's and 1980's. It is ridiculous to forbid me to have access to their record for 125 years after their birth or 75 years after their death. 75 years from 1983 is 2057. I may not be alive then as I am already 72 years old. Most people don't get interested in their genealogy until they are retired; so they are already in their 60's trying to find out information of parents and grandparents who have probably died. I think the time period is entirely too long.

Chuck Weinstein Sun, 10/15/17 - 13:43 Identity theft is a huge problem in the US and around the world. However, today, there are much easier ways to steal or create an identity than to go through files looking for a birth or death certificate to appropriate. In recent years, data breaches from large corporations, including Anthem Health, Equifax, Target, Home Depot, and many others have put the personal information of most of the US population on line and easily accessible. The proposed solution to a non-existent problem is like taking a cannon to go after mosquitoes. It will harm the genealogy industry and provide little, if any protection, to individuals on record. This is a giant step backward in making public records available to the public. My suggested solution is to provide a genealogical certificate that is a matter of public record but redacts private information. These would be available 75 years after birth and 25 years after death. Remove home addresses from the birth certificate and addresses and social security numbers from death certificates. The cause of death may be extremely important in determining diseases that run in families. By law, including the HIPAA Act, the dead have no privacy rights. Birth records before 1942 and death records before 1992 should be made available for family historians and genealogists immediately. Full records should be available 100 years after birth and 50 years after death. A provision to allow families to opt out of the genealogical records program can be made available. This how many states have chosen to handle this issue. In order to obtain a genealogical certificate, one must either demonstrate an existing family relationship or sign a sworn statement that he/she is either related or has been engaged by a direct relative to obtain this information. One option may be to create a genealogy registry. Many other states have adopted this solution. Vital Records are called that because their existence is vital, both to the state and to the families of individuals. Please reconsider this poorly thought-out rule and make records easier to access for families rather than harder.

Linda Hirsh Sun, 10/15/17 - 14:40 As a member of the Jewish Genealogical Society of New York, and the greater genealogical community, I suggest NYC follow the existing guidelines of the state of New York: • Access to birth records after 75 years (if the individual’s death can be verified) or 105 years if no death date is verified. • Access to death records after 50 years, or after 25 years, to registered members of a New York genealogical society. • Access to the index to death records after 25 years (providing the name, date of death, place of death, date of birth, and burial/cremation information)

Michael Whitton Sun, 10/15/17 - 15:35 There is virtually no evidence that suggests that vital records have contributed to the risk of identity theft. Residents of states with open access, such as Ohio, are no more vulnerable to identity theft than people living in more restrictive jurisdictions. Restricting access to PUBLIC records does not protect the public in any discernible way. The DOHMH should be focusing on making records MORE accessible, not less. Reasonable limits of 100 years for birth records and 25 years for death records is more than adequate.

Todd Leavitt Sun, 10/15/17 - 15:41 The Proposed Rule fails to recognize needs and standards of the genealogical community and will only make matters exceedingly MORE difficult for those most effected by the rule change. Kindly revert to the same rules as are presently practiced by the State of NY in its historical records access regulations.

Rich Venezia Sun, 10/15/17 - 19:55 As a genealogist, I find this proposed rule extremely restrictive and I hope that you don't encact it. The idea that restricting records like this will combat identity theft has been proven wrong in states that have open access to records, like Massachusetts and California. The proposed restrictions on when birth and death records would become available for public access would create an unnecessary hindrance for myself and millions of others seeking to trace their families within New York City’s vital records.

Robert Sweeney Mon, 10/16/17 - 12:55 As a professionally trained historian and active genealogist, I find your proposed rule change to be mystifying. Whose interest is being protected by extending the exclusion period for birth and death dates of no longer living persons? The only practical effect of such a rule change will be to make it much harder for historians, genealogists or just simply curious members of the public to find and examine information about our ancestors. Government agencies should be trying to further research into the past, not making it harder to carry out.

Elizabeth Rothman Mon, 10/16/17 - 17:44 I am an avid family historian and, although I live in Seattle, I have accessed records from the New York City Archive many times. I am concerned about the changes proposed concerning birth and death records. The increase in the time that the records are to be held will create a hardship on genealogists and historians, as well as for individuals with concerns that may involve health, identity, religious issues, and personal interest. I am particularly concerned about the restriction of individuals allowed to access records during the sequestered time. Although I could not easily confirm it by studying your website, I understand that only parent and child will be able to access a birth record. It is still rare that a parent or child will be alive in 100 years. By the new rules, a grandchild would need to wait an additional 25 years before accessing the birth record! I understand that the primary concern behind the rule changes is the risk of identity theft. Besides a few anecdotal cases, there is no evidence that identity theft due to records taken from an archive has been a problem. Meanwhile, computer hacking continues to jeopardize the personal information of millions. Please do not increase the length of time that these records are held. All living descendants should have a right to know, and to request to view these records.

Gina Carpentieri Mon, 10/16/17 - 19:15 I am totally opposed to this change in the law. It does nothing to protect people's privacy and only hinders what should be available to the populace. I cannot accept your reasoning for the change in this law. These are public records and should be available to people as they have been in the past.

Joyce Lambert Mon, 10/16/17 - 19:43 I believe your new proposed ruling on vital records is unfair to genealogists and denies us vital information that gives us the opportunity to learn about our ancestors. Birth records (to be discontinued) from the 1890’s to 1925 are vital to genealogical research. They give us the parents’ names, especially the mother’s maiden name which opens numerous additional avenues to research. Also, the birth record shows the child’s number in birth order. This tells us the family size and allows us to know how many more children to research. The 1900 census shows a women’s history of the number of children born and her children still alive. Without the opportunity of having access to birth records, from 1892 to 1900, our relatives born & died during those years will be lost to us. In addition, children born and survive from 1900 – 1925 will only be found on census records. These records are vague and many times do not use the child’s proper name. We will not be able to search for other records/information on these relatives. Again, a part of our family will be lost. Death records give us immense history of our ancestors and also let us know where our family members are buried. Visiting cemeteries & gravesites also gives us a wealth of information and further avenues to research. Death dates and social security numbers, as well as a person’s residence, are already available on line by the United States Federal government. THAT IS A PROBLEM with identity theft- NOT death records available at your facilities. Please reconsider your proposed ruling. I am 70 years old and researching my ancestors brings joy and gratification to me and my family. Since all my ancestors came from Europe and settled in NYC, your records are vital for my research. Through these different records, I have been able to locate and visit the gravesites of many of my great grandparents. I also have been able to discover where in Europe they originated. Please don’t take this opportunity away and consider the following: Birth records become a public record on January 31st of the year following 85 years after the date of birth, Death records become a public record on January 31st of the year following 50 years after the date of death.

Gary Parisi Mon, 10/16/17 - 21:27 I strong oppose the proposed amendment to the birth and death law. This proposed law would severely limit my ability to obtain records of my family history. NYC should keep the law as it currently is without any changes.

Adam Cherson Tue, 10/17/17 - 18:18 I don't find any evidence from what is stated in the proposal that the problems with the current regulations are significant enough to merit a change in the periods of privacy for birth or death records in the City of New York. You cite these statistics: "During the five-year period from 2012 to 2016, the Department processed 1,030 birth record corrections and amendments for individuals born in 1940 and earlier, including 24 delayed registrations of birth and amendments for individuals aged 90 and above. During the same five year period, the Department also processed 257 death record corrections and amendments for individuals who died in 1970 and earlier." For the birth record changes, you are not telling us how many people over 100 years had their birth records corrected or amended. It is only people born between 100 and 125 years prior to the study year that would be treated differently under the new regulation. So how many corrections and amendments of already public records would have been prevented if the 125 year regulation had been in place? WE DON'T KNOW. For the death record, you should be telling us how many people who died between the years 1895 and 1920 had their death records amended, because these are the only people who would have been treated differently under the 75 year versus the 50 year regulation. Again, WE DON'T KNOW. Only having these particular statistics would be able to evaluate whether the current regulations should be changed because they are causing too many administrative problems. Therefore I am not convinced that there is any need to make a change.

cara lowry Tue, 10/17/17 - 22:41 I strongly oppose changing the current access to these records. I believe that access to records should not be restricted due to the bad behavior of a few. Instead of restricting access for law abiding people please increase the penalties against the criminals. Thanks.

Julia Robbins Wed, 10/18/17 - 10:07 I strongly oppose this provision. I believe personal information is adequately protected by the current regulation. The only result from this provision, if passed, would be to keep historical information locked away from legitimate historians and researchers.

Cheyl Lieberman Fri, 10/20/17 - 16:52 I am a native New Yorker and have been very grateful to have access to birth and death records to assist in family research. While I understand the desire to protect the privacy of those whose records the city maintains, the proposed changes go too far. People may be living longer, but the requirement for birth certificates to be held confidential for 125 years makes no sense. Likewise, 75 years for all death records goes too far. Perhaps a compromise for these records would be where the age at death plus a given number of years add up to a certain age, maybe 100 and birth records for 100 years. Increasing longevity for some members of the population should not drive rules for everyone else, especially considering that the average ages are still not nearly as high as these rules seem to anticipate.

Erin Ceddia Fri, 10/20/17 - 18:39 Like many Americans, my ancestors first arrived in NYC, and began their lives there (meaning births, marriages, and deaths). Adding more stringent rules would negatively impact my ability to do genealogy research. I'm strongly opposed to this change.

Janet Blake Fri, 10/20/17 - 21:54 I strongly oppose this change. It sounds like a knee-jerk reaction to rumors. As adoptees' records are opening all over the nation, why would we be closing other records? The argument can no longer be "identity theft." Equifax (most recently) has taught us that the bigger threat is from within. NYC already has some of the most restrictive rules in the country. Do more open states have more identity theft? Of course not. Please consider coming up with a *quantified* and *justified* argument which proves the need for the change.

Jacqueline McGuire Sat, 10/21/17 - 9:35 I am opposed to the measure because it will hamper those who do family history research here in New York. Thank you.

Paul Rehac Sat, 10/21/17 - 11:43 I strongly oppose this provision. I believe personal information is adequately protected by the current regulation. The only result from this provision, if passed, would be to keep historical information locked away from legitimate historians and researchers.

Debbie Gurtler Sat, 10/21/17 - 12:30 I strongly oppose the changing of these regulations. It will greatly hamper the ability of those seeking information about their ancestors to obtain their records and continue building their family tree.

Laura DeGrazia Sun, 10/22/17 - 9:16 Genealogists do more than just create family trees. We study history as it pertained to families from all walks of life. We track families as they immigrate, and as they journey between states, counties, towns, and villages. We publish our documented findings in peer-reviewed journals. Our scholarly research benefits those who know that studying the past can help make sense of the present; history has always been an important subject for study. Some genealogists work with the court system to identify legal heirs. Others work with the federal government to identify family members of unaccounted-for soldiers who died in military service during the twentieth. We are more than curious hobbyists. New York City’s current proposal to increase the waiting time before a vital record is available to the public will impact the work of all researchers who are interested in people who lived and died in New York City—genealogical scholars, forensic genealogists, authors, historians, and private citizens who seek to know more about their own families. The city’s proposal is out of step with that of the state. Where New York City proposes to restrict access to birth records for 125 years, the state allows access after 75 years for the birth of a person who is shown to be deceased and 105 years if the death cannot be verified. And where New York City proposes to share death records only after 75 years have passed since the death, the state allows access to death records after 50 years. Privacy is an important issue, especially in today’s world. Government officials must find a reasonable balance that will both protect the rights of all citizens and allow genealogical scholars and researchers to conduct their important work. I sincerely hope that those in power will reconsider the current proposal and follow the state’s lead with respect to access.

Virginia Pratt Sun, 10/22/17 - 14:10 I am in agreement with the other posts against the proposed restrictions on vital records access. As a family historian who accesses vital records world wide, the current restrictions are well established and do not need amending. It is critical for genealogists and family historians to have access to these records; not only for the historical value but for the medical genealogy as well. Thank you for reading my email and listening to my opinion. Virginia Pratt

Meli Alexander Sun, 10/22/17 - 14:19 As someone who lived in The Bronx (and has deep NYC roots), this amendment would be absolutely devastating. So many people are becoming more interested in tracing their genealogies; having access to Vital Records is very essential. Certain populations (especially Ashkenazi Jews) need any type of verifiable record in order to help put the pieces of the puzzle together. Since I joined a certain DNA website, I continue to see cousins added on a regular basis who look for answers. In my case, I can only find one branch of my family tree that can be traced to the 1700s in Lithuania. But for a lot of people, having Vital Records inaccessible could be very frustrating & devastating.

Joel Novis Sun, 10/22/17 - 18:30 I am strongly opposed to the revised rules, as it unnecessarily hinders legitimate research. The current birth and death record confidentiality periods are adequate; increasing the confidentiality period for birth records to 125 years, for example, appears to be based on an arbitrary number, not justified by any type of fact-checking. At the most generous, it anticipates that longevity will continue to increase well beyond the limits that a tiny handful of individuals world-wide have achieved to date. There is no evidence presented that the community of living people in the age brackets that would be covered by this new confidentiality rule have been or would become targets of identity theft. Once again, the number of individuals in this community is small, and the underlying issue -- that of multiple versions of certificates available in the public domain -- is not changed by this update. Record-keeping entities need a full re-examination of how they maintain versions of vital records. The proposed change to the Code is, at best, a band-aid that does not address the root cause. Thank you.

Harriet Mayer Sun, 10/22/17 - 18:33 It has been shown that these records are not a factor in identity theft. There is no reason to keep death records secret for 75 years, nor to keep birth records unavailable for 125 years....The Bible notwithstanding, the large majority of people are not going to live anywhere close to that. Other places have much more lenient provisions and do not experience unwanted consequences.

Alexander Calzareth Sun, 10/22/17 - 19:43 I oppose the proposed Amendment of Provision of Article 207 of the New York City Health Code as currently written. I applaud the concept of a statute that permits for automatic transfers of birth and death records to the municipal archives, but I feel strongly that the proposed waiting period of 125 years for births and 75 years for deaths is too long. Although I support unrestricted access to the records for researchers, if there are going to be restrictions, a more appropriate period would be 100 years for births and 50 years for deaths. Please see the attached PDF for my full comments. Thank you.

Ronald Wencer Sun, 10/22/17 - 19:46 I enjoy family research as a hobby, but it is more than that. People have a right to know who their biological/legal ancestors were, to know about their ancestors' health and causes of death, to know if what they have been told is rumor or fact. Others’ privacy concerns do not override these rights. Accurate family research takes years. One starts with parents, works back to grandparents, and then to earlier generations. Authoritative copies of records (not necessarily official, certified copies) are a necessity. The proposed revisions to Health’s policies would have crippled my start in 1996 – I could not have begun in earnest until 2020, when I'll turn 74! An example: My grandmother's name is illegible on my late father's birth record. The best alternative source is a birth record for one of his siblings, born 1896-1912. Under the new policy, in 1996 I could not have seen such a birth record, or even my own grandparent's death record. Government birth/death records are absolutely necessary. In comparison… which of NYC’s churches am I to contact for a record of my grandparents’ marriage in the 1890s? In which church was my aunt baptized in 1912? To try to begin my research without City records would have been fruitless. Please note from the above that, in order to learn who my grandmother was, and who her parents were, I had to see records which pertain to other families (e.g., my cousins’). To learn about my great-grandparents, I needed information about yet more distant cousins. Aggressive privacy policies are likely to thwart spreading research such as this. To have approached Health in 1996 (i.e., for information still held as private) would have been a difficult, or even impossible. How could I have demonstrated a family connection to, say, my long-dead uncle who was born in 1910? He died unmarried and childless; there were no direct descendants to authorize anything. All his siblings were dead by 1996, except for one sister, who lived in a nursing home because she suffered from Alzheimer’s. On what meaningful basis could I have sought authorization from Health to see such a man’s birth certificate? In considering the proposed rules, NYC must look at the reality which it will face if they come to pass. Does it want to tell tens of millions of world-wide descendants of former residents that it refuses to provide records about dead people, people about whom so much is available online? Note that past U.S. Censuses are online, and report rent or home value, income, length of marriage, number of children born to a woman, periods of unemployment, incarceration in mental institutions and prisons, etc. What would be the point of not providing unofficial copies of documents, when so much other personal information is already widely available online without restriction? Please do not create a policy which impedes people from learning about their families’ pasts, and is likely to serve no good purpose.

Barry Spinner Sun, 10/22/17 - 21:07 I believe the time periods being proposed are far far too long durations. Particularly the period for death certificates. If this rule had been in place presently, my family would not have able to verify a death of a child - which death caused great psychological harm for generations within that Manhattan family.

Allan Bloomberg Sun, 10/22/17 - 22:29 The 125 year waiting period is very excessive and needs to be much shorter. I can see no damage that will be created by giving genealogists and people doing their own family research access to these documents.

Stew Cogan Sun, 10/22/17 - 23:40 To Whom It May Concern: I am adamantly opposed to the proposed rule. The effort to restrict access to these records is a solution in search of a problem. Of all the ways in which one might want to obtain personally identifiable information, given the state of current technology and the availability of all manner of information on the internet, it makes virtually no sense to impose the types of restrictions under consideration. My strong suspicion is that you will have fervent and widespread opposition to the proposed rule and few in favor of it. It is an unnecessary, ill-advised, and rather primitive attempt to protect privacy in a way that goes far beyond what is either appropriate or customary in Western societies. I urge you not to adopt the proposed rule. It is, at its root, a feel-good effort to solve a problem that is illusory. Thank you for considering my comments. Stew Cogan Seattle, Washington

Kevin Cassidy Sun, 10/22/17 - 23:56 I would like to encourage the Department of Health to reject the call to extend the restriction to public access to birth and death records to 125 and 75 years respectively. My paternal grandfather died in 1948 and that would restrict his record until 2024. I am glad I had access to it back in 1996. I did not commit any crimes with the information. That seems to be a very severe restriction. A better way to restrict fraud would be for every death certificate to be sent and notations made on the birth record when and where the person died. Both sets of my grandparents lost infant daughters in 1930 and 1932. These girls lived 20 and 9 days respectively. A note should have been added to their birth records to prevent scoundrels years later from trying to create fictitious identities. I think there are ways for individuals who may want to protect sensitive facts from public disclosure that do not require denying public access. Thank you.

Sheri Smith Mon, 10/23/17 - 0:55 As a family historian, genealogist I too strongly oppose restricting information for 125 years. Please consider the ramifications on how this will limit needed information doing family research. I am speaking with one voice here for many!

Bruce Reisch Mon, 10/23/17 - 9:11 No evidence is presented that necessitate the proposed changes, therefore I strongly oppose this proposal. There are no known instances open records access has led to more identity theft than where long embargo dates are used. Documents can be issued that are clearly marked "for information purposed only; not to be used for identification". This type of marking is used successfully elsewhere. Please reconsider the need for this rule change.

Susan Greenberg Mon, 10/23/17 - 10:55 This would make it impossible to conduct genealogical research on ones parents. You would have to be 75 years old prior to being able to access this information. This should not go forward into law! Please!!

JoAnne Thornton Mon, 10/23/17 - 11:16 As a genealogist vital records are an essential tool to finding out the key to our past, the legacy that our ancestors left behind. As a woman with many medical issues these records are the key to unlocking many doors to what nests inside me. I've been able to find, through these records, as far back as the early 1800's cases of hyperthyroidism, breast cancer, heart disease and more that my family were stricken with. All illnesses that were carried down through generations and have been extremely valuable tools for my physicians to know about . Without these records at hand we would have been at a loss. PLEASE DON'T TAKE THEM AWAY FROM US! We need them. The past is telling it's story. And that story NEEDS to be told.

Vince Patton Mon, 10/23/17 - 11:20 I am writing to you in strong opposition to your proposed restrictions on birth & death records. You are about to lock up my family history, and the history of millions of people, for nearly six generations. Locking up birth records for 125 years and death records for 75 years not reasonable. This is an overreaction with dire, unnecessary consequences. I am a genealogist with deep ties to the original American colonies, particularly New York. Your rule shuts off research into our ancestors for far longer than any state has ever imposed before. The single most important records in our research are proof of birth and proof of death. Without those confirmations, a family tree is not considered valid. Is it really reasonable to say no one is allowed to research their ancestors until they’ve been gone for 125 years? Impossible. This means we cannot do the research at all. We won’t live long enough. Even our children and even grandchildren would likely be locked out of their own family histories. This Proposed Resolution to amend Article 207 is a gross overreaction. I urge you to reject it. Vince Patton Oregon

Betsey Kirkemo Mon, 10/23/17 - 12:03 I reside in Colorado, and it's tough enough to research my family in New York over the miles. I plan on making a trip or two in the near future to break through some walls that I have for my NY family who migrated to Wisconsin. I have several big issues to resolve for my ancestors who fought in the revolutionary war. If you adopt these rules, you are going to make it beyond difficult for anyone to research genealogical statistics. It's super important to have the help of those who are still alive while we can. Please don't do this to us. It's bad enough that census information is limited to the 1940 census. I vote NO! Betsey Kirkemo

Anton W Bruchhauser Mon, 10/23/17 - 12:26 Hello, I started out in genealogy about five years ago after coming across an article about a relative who I had no idea existed until that day. I knew very little about my grandparents and nothing about anyone preceding them. I have since been able to trace many parts of my and my wife's families back to the 1800s and earlier. All of this became possible through the accessing of early records from the municipal archives as almost all of our ancestors lived in New York City at some point. We now have a much clearer picture of who these people were, how they lived, and just where we came from. Three years ago I was able to visit the town of my great-grandfather's birth for a hundredth anniversary celebration of he and his brother donating a large stained glass window to the church there. My wife has learned about an aunt that she never knew existed and about how her family came to live in the United States. These are a few of many discoveries that we have made. None of this would have been possible without those first documents obtained from the municipal archives and they would not have been available to us if the proposed rules had been in place. I completely understand the need to protect privacy as I have been affected by identity theft twice. I do know, however, that neither of these instances had anything to do with records from a municipality. One instance was from a card skimmer and the other from a website breach. I believe that the proposed rules, while well-intentioned are far too severe and do nothing to address the actual ways that our private information is exposed. I have also found that of all the places I have undertaken research, New York is already one of the most restrictive places for obtaining records. I appreciate the chance to voice my opinion and am truly hopeful that this rule change is rejected.

Shannon Green Mon, 10/23/17 - 13:02 As a genealogist, access to this type of information is critical for people trying to trace their family history. It would be such a shame to prevent this and future generations from learning about their roots.

Mary Fobian Mon, 10/23/17 - 13:06 I oppose the proposed Amendment of Provision of Article 207 of the New York City Health Code as currently written. I am in favor of a statute that permits automatic transfers of birth and death records to the municipal archives, but in my opinion the proposed waiting period of 125 years for births and 75 years for deaths is far too long.

Darrell McGraw Mon, 10/23/17 - 13:11 Hi: Please allow genealogists access to all vital records. I have been tracing my family tree for over 40 years and we need access to fairly-priced records to verify the lives of our ancestors; births, marriages, and deaths especially. Once an individual dies, there is no expectation of privacy for that person, in my opinion. The chance of an identity theft is very slight once a person dies. If the data is verified by the end-user, they will soon realize the person is using fraudulent information.

Charliece Hillery Mon, 10/23/17 - 13:34 Access to the vital records of the City of New York is essential to my efforts as a family history researcher. The current restrictions are already sufficient to make my work difficult. Locking up birth records for 125 years and death records for 75 years will make connecting people to their own past more burdensome than is necessary to protect the public. Please find a way, as other jurisdictions have done, to protect records from misuse while still making the information contained in them accessible.

Danelle Knapp Mon, 10/23/17 - 13:41 Please do not extend the restriction on accessing birth and death records. Genealogy is my hobby and a great number of my family lived, died or got married in NYC. It's difficult right now to find information and almost impossible to find records relating to Staten Island or Brooklyn or pre-1900. Further restrictions would have the same effect as destroying the records. Given the vast number of Americans who have been touched by New York, further restrictions would crater a lot of genealogy research. If your aim is fraud prevention, surely you can do this by making the records electronically available and only dispensing the actual certicicates to prople with proven legitimate reasons. Restriction by years seems the most clumsy and least effective way to prevent fraud.

Sarah Brown Mon, 10/23/17 - 13:43 As a amateur genealogist, researching my paternal ancestors in New York City and Orange County NY, it is challenging doing long distance research. The new rules would make that reach even more so. For example, my father's records, born in NYC in 1908 and gone now over 10 years, would still be closed. This seems excessive to me. As a victim of identity theft myself, if some of the reasoning behind the change is thought to address identity theft, this is a spurious deduction. My identity theft was a result of credit card scamming not as a result of hacking my ancestry.com account. I encourage you to not implement this additional time frame for accessing records.

Debby Holland Mon, 10/23/17 - 13:55 I am writing to urge rejection of the proposed rule by the New York City Department of Health and Mental Hygiene to extend the period in which birth and death records would be unavailable to the public. Acknowledging that average life spans have been increasing until recently, the new rule unnecessarily restricts public access beyond the reasonable privacy protections. The remedies proposed by the New York Genealogical and Biographical Society would sufficiently ensure the protection of individuals’ vital statistics while allowing interested parties, including genealogists, access to this treasure trove of data that would enable family researchers, genealogists and historians to create a more accurate and comprehensive account of the past. Thank you for your consideration of my remarks.

Jonathan Schwartz Mon, 10/23/17 - 14:09 I believe NYC vital records should not be restricted beyond what NY state allows. The public has legitimate reasons for accessing these records.

Barry B Miller Mon, 10/23/17 - 14:40 Dear Sir/Madam, I would like to comment to the NYC Department of Health and Mental Hygiene regarding the proposed rule changes which would further restrict access to New York City birth and death records. I am opposed to further restricting how long the public has to wait to access these public records. In fact, I would like to see the restricted period eliminated altogether. Instead, I encourage you to develop and implement means to allow for informational copies of birth and death records to be made publicly available in a way that would prevent their use for identification purposes, as other jurisdictions have done. But my primary comment at this time is express that I am NOT in favor of further restricting the New York City birth and death records. As a family history researcher, access to public records is critical. Thank you. Barry B. Miller

Aubrey Hemingway Mon, 10/23/17 - 14:53 Timely access to vital records is critical and essential to genealogical research. The proposed restrictions would be an unnecessary hindrance for myself and millions of others seeking to trace their family history in New York City's vital records. The proposed rule changes are too stringent. I ask that you develop and implement an informational copy of birth and death records, which would be available within weeks of the vital event (birth, marriage and death). The form should provide important details for genealogical and historical research in a format NOT suitable for proving identity.

Donna Brock Mon, 10/23/17 - 14:53 As the genealogist and historian for my family, with roots that are deep in both New York and New Jersey, I strongly oppose restricting information for 125 years. Information will be lost for generations if you continue down this path. Please consider the ramifications of your pending decision and it will severely curtail the ability to access critical information necessary for family research.

Elizabeth Bentley Mon, 10/23/17 - 15:35 Please don't restrict the records any further. Family historians need to access the information for perfectly legitimate purposes. The death records are particularly useful. In my opinion, privacy restrictions should be based on the date of birth, not death.

Christine Douglas Mon, 10/23/17 - 15:45 I believe the proposed rules governing birth and death records will adversely affect family historians and genealogists researching families having lived (born or died) in New York City. I know, for one, that it could affect my research. I believe the current safeguards are sufficient and should not be changed. 125 years is too restrictive and a harsh knee-jerk proposal for a perceived issue of access. I oppose the proposed Amendment of Provision of Article 207 of the New York City Health Code as currently written. I do support a statute that permits for automatic transfers of birth and death records to the municipal archives, but am opposed to a proposed waiting period of 125 years for births and 75 years for deaths as too long. Christine Douglas, Goodyear, AZ

Lee Martin Mon, 10/23/17 - 16:01 The new rule is way too restrictive, especially if some people do genealogy. Most people don't know where to start looking for information on their ancestors and the vital records department is the most visible government entity people think of to know where to start. If that is inaccessible, there's no way can get proof unless they think outside the box and look for substitute records that may help in the search.

Peggy Vander Yacht Mon, 10/23/17 - 16:10 As a family historian/genealogist, I am alarmed by this proposed change in birth and death records. It is absurd to have such a lengthy time when these historically valuable pieces of information would be unavailable to researchers. I could understand a shorter period to protect privacy, but 125 years for a birth certificate -- ridiculous!

Julie Stoddard Mon, 10/23/17 - 16:16 I strongly oppose this change. I agree with Diana Frederick’s comment that “putting such an extreme limit on when a birth or death record becomes public is overkill.” Her suggestions provide several solutions to better regulations. There are other great comments with reasonable suggestions to the problem.

Tristan Tolman Mon, 10/23/17 - 16:22 Please do not change the access to birth records to 125 years and death records to 75 years. As a genealogist, I use NYC vital records all the time and depend on them to help me identify and reconstruct families. So many people have family from NYC, and vital records are key to tracing our ancestors further. Allowing so many of us to connect with our ancestors and heritage is priceless - please do not take this away from us due to the poor choices of a few.

Tom Wilcox Mon, 10/23/17 - 16:30 My family history in New York City encompasses 3 family lines dating from 1872 to 1987. This new rule would be a tremendous hardship for family genealogists to learn their family history. I do hope that you will reconsider this drastic move which restricts information for too long a time.

Tommy Michaels Mon, 10/23/17 - 16:42 I recently discovered that my father's family lived in New York City and other areas of New York from 1880 to at least the 1970s. I am opposed to the proposed time limits that restrict access to birth and death records and am in support of the proposed time restrictions suggested by the New York Genealogical and Biographical Association. I am interested not only in my family history from a historical perspective but also from a medical perspective. Please do not implement the proposed rules that contain unreasonably long periods before release of birth and death information Tommy Michaels Williamsburg, Virginia

Robin Meltzer Mon, 10/23/17 - 16:42 The proposed rule change does not enhance protections again identity theft. It only hinders attorneys, or those trying to document a legal right or entitlement, from accessing vital information that is and has long been public record with no demonstrable harm. California has already conquered the identity theft issue by using a simple notation on copies of vital records issued for informational purposes: "INFORMATIONAL, NOT A VALID DOCUMENT TO ESTABLISH IDENTITY" is prominently imprinted across the face of the document. Please reconsider this unnecessarily restrictive rules change, and instead consider adopting California's quite sensible and effective method.

Rebecca Vaughn Mon, 10/23/17 - 16:54 As a professional archivist and genealogist, I completely oppose the proposed amendment to the general vital statistics. It has been shown that open record policies actually reduce the amount of fraudulent activity. Death dates, full names, and social security numbers are available online from the federal government. This has reduced identity theft as it has been made easier to prove that someone is deceased and that person's identity has been stolen. The 125 and 75 year restrictions are excessive, and hinder both genealogists researching their family histories as well as historians researching modern history topics. Not only does this amendment negatively affect the field of genealogy, one of the fastest growing professional fields, but it will negatively affect tourism. The number of genealogists who visit New York City, spending money in hotels, restaurants, and other attractions, will decline. Clients who might want to visit the places where their families lived or were buried will not be encouraged to travel to the city. Also, people alive today have the right to track diseases and health issues that they might be prone to suffer from due to their genetic history. Descendants have a right to these records and the medical history contained within. The year restrictions will only be to the detriment of the people of New York and others with family from New York. Your reasoning for these restrictions do not hold up in any way, so I strongly urge you to not pass this amendment.

Joan Sohn Mon, 10/23/17 - 17:33 My family came to the US and settled both in NYC and Philadelphia. The Pennsylvania birth and death records have been invaluable to my research into my family history. I would hate to lose access to the NYC records.

Frances Stein Mon, 10/23/17 - 17:50 I am opposed to the proposed resolution to Amend Article 207 as written. It is much too restrictive. As a family historian/amateur genealogist, further restrictions to our access to birth and death records seems unnecessary. I appreciate your concern for safeguarding privacy and identity; however, your proposal seems to overreach. Many states have birth and death record images online already that are much more recent - I have seen some from the 1990s! I am not suggesting that NY City do the same, just to be more reasonable. And, also, the Dept. of Health should transfer microfilm of birth records to the Municipal Archives after 1909-at least those through 1916. Also, by allowing access to the vital records will ensure a continued revenue stream for the city. I have spent several hundred dollars at the Municipal Archives in the past 2-3 years, having ordered documents by mail and in person. I support the guidelines proposed by the NY G&B Society and have already added my name to the "petition". Thank you.

Jerry Schneider Mon, 10/23/17 - 18:33 My name is Jerry Schneider. I am 73 years old tomorrow and I am disabled and housebound. About 20 years ago, my family visited Ellis Island and were introduced to the Ship Manifests for my father & paternal grandparents and those of my maternal grandparents. It was as though I was smitten by a bolt of lightning From that point forward, my life was dedicated to genealogy: first my own and then those of friends and relatives. I grew up being told that I did not have any family; in hushed tones, I was told that ALL OF THEM, except my grandparents; had been murdered in the Holocaust. As a Russian Jew, I was told that any vital records were destroyed in WWII. I then discovered JewishGen online and began to message with Russian genealogists. From their records, I quickly discovered that I was not Russian but Polish and that I may find some vital records in Jewish Records Indexing - POLAND. After much research, I was able to find my paternal family in records from Izbitsa and my maternal family in records from Zolkiewka. And, from the Ship Manifests found earlier, I learned that ALL of them had emigrated to New York, specifically the Bronx, and Brooklyn. At that point, I was introduced to the vital records of NYC. For a solid 2 years, I researched vital records of family members. These usually provided me with the name of parents and other info. The marriage records maintained by the city clerk offices provided even more pathways into the past and present. Quite frankly, without the present public access rule, I would have NEVER been able to identify other relatives who had survived the holocaust, or helped others find theirs. The new rules are like a second Holocaust, taking away the identity and history of several additional generations of ancestors and family. Please, I beg you, on behalf of the hundreds of family and relatives that were killed in the holocaust; and the thousands that live in the NYC vital records (those that will be subject to additional restrictions under the new policy), do not place additional restrictions or time constraints on the NYC Vital Records. Thank you for your consideration of my remarks. Jerry Schneider Burke, VA, USA 703-764-0272

Christopher C. Lee Mon, 10/23/17 - 19:03 I oppose the proposed rule restricting access to NYC birth and death records. Access to and research in these records serve a necessary function in New York Administration Law by contractors such as myself working to ensure the due diligence of attorneys. By severely restricting the records as proposed, the City stands to obstruct the administration and disbursement of estates to the proper beneficiaries, heirs, and other recipients. Beside this, contractors such as myself similarly access records that would be inaccessible under the proposed rule for New York residents and others seeking relatives and kin for their own planned gifts and disbursements of real estate and other property. If the proposed rule responds to a want to provide or increase privacy for individuals who were born or died in the coverage period, it is unnecessarily and unreasonably restrictive. Privately held personal records databases provide information enough to nullify entirely the effect of the proposed rule while limiting the ability of contractors and researchers to carry out the functions, including those with application in New York Administration Law outlined above.

Sharon Pike Mon, 10/23/17 - 19:34 I oppose the proposed Amendment of Provision of Article 207 of the New York City Health Code as currently written. I applaud the concept of a statute that permits for automatic transfers of birth and death records to the municipal archives, but I feel strongly that the proposed waiting period of 125 years for births and 75 years for deaths is too long. Although I support unrestricted access to the records for researchers, if there are going to be restrictions, a more appropriate period would be 100 years for births and 50 years for deaths.

paul guarino Mon, 10/23/17 - 20:34 Changing the time frame for birth and death records almost shields out the ability to do any genealogical research at all. My family was a big part of New York from 1890 -1940 and with the new changes, I would be blocked from finding out lots of impotant information.. The Department of Municipal Records does an outstnding job of processing requests. Please dont change it

Nicholas Rossi Mon, 10/23/17 - 20:37 In reference to the Proposed Amendment to General Vital Statistics Provisions (Article 207 of the NYC Health Code) regarding Birth and Death Records, I would like to offer a vote AGAINST the amendments as proposed, in that the lengths of time are excessive and unreasonable. 100-105 years for Birth Records and 50 years for Death Records are more than plenty to reasonably achieve the safeguarding of PII, and still allow for access to the many decent people who are searching for their ancestors, however close or far. These "old" records are not only most valuable for family historians and genealogists, but are necessary for piecing together histories of New York City and its people, as well as being tools for such situations as estate settlements whereby a common ancestor must be determined. It it my hope that the cooler and more rational minds will prevail. Thank you for your time and consideration. This means a lot to many people!

Steven Schwartz Mon, 10/23/17 - 20:38 Response to Introduction - NYC Health Code Section 3.25 states, “records ... shall be confidential and used only by authorized personnel of the Department or its authorized agents.” The Department and their staff should treat records with the “utmost confidentiality.” However, this does not imply unreasonable restrictions should be adopted to access the records. Response to Background and New Requirements Birth and death records - All agree birth and death records are important historical documents containing personal identifying information. The proposed rule change is overly restrictive and not based on sound reasoning. Fraudulent use - No evidence is given of even one case where the current rules governing vitals records from NYC has lead to identity theft or fraud. Rather, my experience is the lack of open records allows false claims and fraud to continue without being checked or corrected. Amendment and correction – Given the large number of records issued and the relatively few that were amended, it seems more “unlikely” that records will be amended after a reasonable period of time. Privacy concerns – we live in a free and open society. Federal census records are made public after 72 years. Other states are moving to make vital records public sooner rather than later. Model State Vital Statistics Act and Regulations (2011 Revision) - this is not approved by any official body of government. It is a recommendation by an advisory group (the the National Association for Public Health Statistics and Information Systems) and was adopted without public comment. Recommendation Do not accept this proposed Amendment. It recreates unreasonable restrictions. For example the New York State Department of Health (DOH) provides uncertified copies of 1) Birth certificates if on file for at least 75 years and the person is known to be deceased and 2) Death certificates if on file for at least 50 years. Thank you for the opportunity to comment.

Rhoda Miller Mon, 10/23/17 - 22:13 I strongly urge that you do not accept the proposed resolution! My doctoral dissertation study, The Association of Family History Knowledge and Cultural Change with Persistence Among Undergraduate Low-Income, First Generation College Students, demonstrated the outcome that family history knowledge is associated with resiliency. Restricting access to historical records that students need to research their family history is a destructive element in the educational process. Please do not cause destruction that is vital to a demographic of students who desperately need every strategy possible to develop the resiliency needed to succeed in life as well as to develop research skills involving primary source material. Thank you!

Debbie Hadley Mon, 10/23/17 - 22:22 This proposed rule change would be devastating to those of us researching our family history. Without access to vital records for our recent ancestors, we cannot make the connections that take us back generations. Please don't take our ancestors from us by imposing such an extraordinarily excessive rule.

Ruth Marin Mon, 10/23/17 - 23:17 Please do not take away my ability to get information about my family history.

Liana Mayer Mon, 10/23/17 - 23:19 It is already restrictive to get genealogically useful records from the NYC boroughs. The time limits do not need to become draconian when access to these records is not an identity-theft risk. Don't keep information on our families from us, the children, grandchildren, and great-grandchildren who would care,

Michael Miller Mon, 10/23/17 - 23:19 It is beyond comprehension why the NYC Birth Index should be shrouded in secrecy. It was because of that index that I, after many, many months of searching, was able to finally find out who my mother's birth parents were and what my mother's name was at birth. Why should anyone be denied knowing the identities of the people they come from? What gives the city of NY the right to block families from finding each other? Needless to say, I hope the NYC Birth records will be made public!

Carolyn Thompson Mon, 10/23/17 - 23:26 As a family historian, the proposed exclusion of access makes it impossible to search for ancestors. Many other states provide many more opportunities for success. Please reconsider. Myentire family began their lives or their road to citizenship in the 5 boroughs.

Seth Bookey Mon, 10/23/17 - 23:27 Everyone else has covered the general reasons why extending the period of time for this record is bad for research, but another thing you should consider: lost income for NYC! You guys make a LOT of money on the money you charge for these records. It's $11 at the Municipal Archives, and $15 or more for marriage and death records. It has been shown that access to these records does not really factor into ID theft and other problems. If the U.S. Census is good enough to have a 72-year waiting period, why must NYC have something in excess of that? It seems like overkill AND a great way to reduce income from the many people who need these records for legitimate genealogy research and health-related research. If someone is committing ID theft, there many easier ways to do that on the Internet. I mean, an ID thief it not going to go to 31 Chambers Street or the DOTHto spend money and TIME looking at microfilm to steal somone's identity. So many public records allow that online right now.

Vanessa Duncan Mon, 10/23/17 - 23:28 My great-aunt Agnes was born in 1912, and I would like to obtain her birth certificate for information about her parents, my great-grandparents. Agnes was never married and had no children, and presumably her parents are long dead. This amendment would make those records unobtainable by anyone for another 20 years from today. There is no other source of this information. Her brother, my grandfather, was much younger, and I suspect some historical details changed in the time between when they were born. Please do not extend the time period to 125 years after birth, information such as this will be lost forever in the additional generation gap. Thank you.

Lina Goldberg Mon, 10/23/17 - 23:29 I oppose the proposed Amendment of Provision of Article 207. Although I applaud your efforts to try and prevent identity theft, this is a hamfisted way to address the issue. No actual statistics are given in your proposal about birth and death records more than 50 years old being used for this purpose; do you have any reason to believe they have been? How often does it happen? If you're concerned about birth records being used to obtain other forms of identification, wouldn't a simple stamp on the birth certificate saying "deceased" serve the same purpose? Or releasing records stamped "for genealogical purposes only-cannot be used for ID"? It appears that NYC is using identity theft as an excuse to deprive citizens of the access to information that they are legally entitled to. My family lived in NYC a hundred years ago. Through genealogical research--which included many, many paid records requests--I have been able to get in touch with my New York roots. As part of that research I'm flying to New York this week to visit the places that my family lived, the cemeteries they are buried at, and generally to explore the city. In addition to the hundreds of dollars I have paid directly to the city for these records requests, I'm also contributing to the NYC economy while I continue my research--research that wouldn't have been possible without the birth and death records that you now seek to restrict.

Jennifer Silk Mon, 10/23/17 - 23:29 As a genealogist whose family resided in New York City for many years, I have experienced the many difficulties the city already introduces into the process of obtaining family records. Unlike other cities and states, these records have not been made readily available. The proposed rule introduces the potential to make such records less available than they already are, and actually prevent family historians from documenting their history. This is being done in the name of preventing identity theft, and yet such records have not been shown to be used for that purpose in any significant way. I strongly object to the proposal. The city should be looking for ways to facilitate record access, not constrict it.

Michael Morrissey Mon, 10/23/17 - 23:29 New York is a very difficult state to obtain family information. Your proposed rule change is excessive. 75 years after a death. Wow!

Kieran McKernan Mon, 10/23/17 - 23:31 As a user of the records they have help me trace my Irish ancestry to America. Up until now it has not been possible for me to trace my relatives records so no unsealing these records would stop me from moving any further with my research as I am based in Ireland. Lots of Irish relatives have found it very difficult to find their families as they left Ireland and never returned. I really hope the records are unlocked so I can go deeper with my research.

Shaun Harry Mon, 10/23/17 - 23:32 I have been collecting and researching my family's historical information for several years. I just recently found records of my Grandparents in the NY archives. With this information, I have been able to learn new things about my Grandmother that I otherwise would never have known and have been able to share this with her own children. If these records were locked for a longer period of time, her children may never have known this very valuable information about their own mother. Please reconsider extending the time period before these types of records are released.

pete franklin Mon, 10/23/17 - 23:32 As an adopted person who has been in contact with hundreds of adoptees in the military I can attest that access to vital records can save lives. Since NY still practices secret adoption when birth parents or adoptees develop inherited diseases it is nearly impossible to communicate this to biological family members. Allowing immediate access or transparency to these records will also deter human trafficking as predators are well aware that some states actual inadvertently aid misconduct by sealing records.

Cynthia Klein Mon, 10/23/17 - 23:35 I am against increasing the time limits before records can be publicly released. These strict new rules will severely limit the ability of anyone, even perfectly law-abiding genealogists, to gain access to old New York City vital records. A huge number of persons lived in New York City on the way to other places in America and are important proof of residency, relationships and more to genealogists and persons interested in their family's history. These proposed rules are stricter than almost anywhere else in America, and would be devastating to anyone researching New York City ancestors or collateral lines. I urge everyone involved to leave the laws as they are or create less restrictive, rather than more restrictive access to vital records. Cynthia Klein

Howard Weitzman Mon, 10/23/17 - 23:40 The good that is served by many of us trying to figure out our roots outweighs the potential harm of keeping the data free and public. Bad people will find a way to committ crimes with or without this days. Please do not throw the baby out with he bath water! Leave this data available for all good people to access, as it stands now!

Suzanne Malek Mon, 10/23/17 - 23:42 As a teacher and researcher, I am opposed to the New York City Department of Health's strict new rules that would severely limit the ability of anyone, even perfectly law-abiding genealogists, to gain access to old New York City vital records. These proposed rules are stricter than almost anywhere else in America, and would be devastating to anyone researching New York City ancestors or collateral lines. Families all over America depend upon honest use of vital records for genealogical research. Thank you.

Ellen Weiss Mon, 10/23/17 - 23:45 I vigorously oppose the rule change restricting access to birth records for 125 years and death records for 75 years. Being able to access New York death records for my maternal great-grandmother led to the discovery of family I did not know about, and who happen to be New York City residents. I am using New York City birth and death records to try to learn about my husband's grandfathers, and other missing family members. The details on these documents are the only clues to finding out about the people who made us who we are. Getting this information is effortful and costly, but if the rules change it will be impossible. A city rich with cultural diversity and history should be a leader in helping people discover their heritage. Please celebrate diversity by defending our freedom to explore it.

Gail Jorgensen Mon, 10/23/17 - 23:45 I oppose the proposed Amendment of Provision of Article 207 of the New York City Health Code as currently written. I applaud the concept of a statute that permits for automatic transfers of birth and death records to the municipal archives, but I feel strongly that the proposed waiting period of 125 years for births and 75 years for deaths is too long. Although I support unrestricted access to the records for researchers, if there are going to be restrictions, a more appropriate period would be 85 years for births and 50 years for deaths. Thank you.

Nancy Adelson Mon, 10/23/17 - 23:50 Please do NOT approve this new ruling! It would harm more then help families. For example, all of my dad's side of my family lived in New York City (5 Boroughs). I would not be able to prove my family relationships and cannot protect myself from identity theft.

Margaret Daly Mon, 10/23/17 - 23:51 I think the time provision is too long on the new proposals. This will be a handicap for geneoligists. We have all our personal information being sold now by companies collecting data. Holding onto a birth certificate for 125 years seems quite silly.

Jo Ann Fitzgerald Mon, 10/23/17 - 23:51 As a family historian and genealogist I strongly oppose restricting information for 125 years. Please consider the ramifications on how this will limit needed information doing family research. I would like to encourage the Department of Health to REJECT the call to extend the restriction to public access to birth and death records to 125 and 75 years respectively. I have many relatives which this would restrict access to. In fact, currently New York State is one of the hardest states to work with and get information from. There are better ways to ensure sensitive facts for individuals and to protect sensitive facts from public disclosure that do not require denying public access. Current technology and availability of all manner of information on the Internet, makes no sense to impose these types of restrictions under consideration like the census.

Cody M Mon, 10/23/17 - 23:54 Hello. I am strongly against the proposed rule. It is unreasonably restrictive. I am an amateur genealogist with a *lot* of family who lived in NYC. I see no reason for these rules to go into effect - is there any proof to identity theft as a result of this? If these rules were put into place - I would not be able to request my grandfathers birth certificate (Born 1907) until 2032 - and he has been dead since 1968. This makes no sense at all and just seems like a way for the city to LOSE money from genealogists and family historians! These records being available will do no harm - Censuses are available from 72 years ago, which the majority of these people over 75 would be listed in - and when you go earlier than that, you are probably going to find their mother's maiden name, which is the only real piece of personally identifiable information you can find on a birth certificate. In addition, virtually everything in today's world requires a social security number for verification. SSNs weren't required at birth until the late 1980s, so that is not a factor for decades. People have the right to know about their ancestors.

Margo Hebald Mon, 10/23/17 - 23:56 I was born in Manhattan, NYC, and my first ancestor came to to New York City in 1855. My parents and grandparents were born in NYC. I am the genealogist for my family and strongly object to any barriers to my family research. I oppose the proposed Amendment of Provision of Article 207 of the New York City Health Code as currently written. I applaud the concept of a statute that permits for automatic transfers of birth and death records to the municipal archives, but I feel strongly that the proposed waiting period of 125 years for births and 75 years for deaths is much too long. I understand the need for privacy and fraud prevention. The United States Census is released after 72 years of that Census, with far more information than a birth or death certificate. There really is no logical or legal reason for NYC to require a longer waiting time. Ancestry.com appears to provide all the information for a price. I support unrestricted access to the records for researchers. Surely with registration and other security measures, NYC can protect against fraud.

Marie Goewert Mon, 10/23/17 - 23:57 Please do not pass this very restrictive bill. I understand the growing problem of Identity theft. It's bad. But for the many many honest genealogist, this these vital records..are vital. Restricting the years to 125 after birth is going overboard and would be devastating to us genealogist looking for one of he key documents in genealogy. The 75 years after death is also too restrictive. Why not 25 or 50? I am a genealogist simply looking to Identity who my father was using DNA and other clues. He was born approximately in 1890. The best I'll ever know for him is a name...mom died in 1971. But.so far I can tell from DNA matches that my grandparents and possibly my father lived in New York City between 1850-1930. With your proposed date restrictions, I'll be dead before some of these records are publicly available.

NICHOLAS BOTTICELLI Mon, 10/23/17 - 23:57 To put such restrictions on Family Genealogy Research is completely beyond me. The purpose of these records is to build lost family connections. Generations of families are built and past on to future generations. I personally have connected my past NYC families back 5 generations, all of these records I can now leave for future family generations to embrace and continue research. Time for NYC to wake up and embrace Genealogy !!!!!!!!!!!!!!!!!!!!!

Susan Davis Mon, 10/23/17 - 23:59 New York City, the melting pot for those coming to America seeking new lives, should NOT alter or enact rules making it more difficult for descendants to find important genealogical information about their ancestors. Finding accurate information is difficult enough. What you are doing is denying multiple generations the ability to find out information about those who preceded them in making a new life in America. This has nothing to do with identify theft. It is a selfish move on your part to deny family members legitimate information about their relatives. Thank you. Susan Schapiro Davis

Kathleen Lee Mon, 10/23/17 - 23:59 I am adamantly opposed to the proposed extension of restrictions on public access to birth and death records. If passed, the restrictions would prevent legitimate historians and researchers from accessing historical information. Punishing those who follow the rules does not prevent those who break them from continuing to do so. If a change must be made, please look to pursuing the law breakers. As we have learned from data breaches, such as Equifax, computer hacking is a far larger risk to the personal information of millions of people than identity theft due to birth or death records from an archive.

Faith Skizewski Tue, 10/24/17 - 0:00 Please do not pass these proposed regulations, as a family historian I need this information and do not believe what is being proposed will be of benefit to fellow genealogists. Thank you for your time

MARC RODDIN Tue, 10/24/17 - 0:06 There is no reason to not allow death records to be viewed by the general public. Once somebody is dead, the word gets around and it would be impossible to impersonate that individual. Almost everyone has a social security number, and the social security death index records all dead numbers very quickly. After my parents died (earlier this year) within a week or two I got condolence letters from all of the people who paid them pensions, from their insurance companies, etc. Since death information is shared with those organizations, it should be freely available and shared with everybody. I've learned a lot from death records of my ancestors (all of whom are from New York) and it would be horrible if that information were no longer available to each person's descendants and other relatives.

Tina Wood Tue, 10/24/17 - 0:07 These proposed rules are excessively harsh to the point of being punitive. If someone wanted to steal someone else's identity, they would not go to the trouble of requesting genealogical records (where the request would leave an easy to follow paper trail.) The main people who would be adversely impacted by these rules are genealogy researchers and family members trying to find out what happened to their loved ones. As a volunteer "search angel," I helped a woman whose brother disappeared from his family and later died in New York City. These rules likely would have prevented his loved ones from finding out what happened to him. And there are millions of other stories of people whose answers and history can only be found in these records. Locking the records up punishes these innocent people while doing nothing to stop identity theft. Please do not adopt these rules.

anne leyden Tue, 10/24/17 - 0:08 Withholding public records for 125 years is unnecessary and excessive. The federal government releases census data after 72 years. Census records, too, have much personal information. There is no reason for NYC to exceed a 72-year time frame for the release the City's vital records data.

Laurie Savin Tue, 10/24/17 - 0:09 As a New Yorker with deep NY roots who has recently gotten very interested in my family’s history, I am bothered by this new proposal. The number of years you are proposing is and overreaction and too much. I do not appreciate this proposal for a litany of reasons. We are Americans living in a “free” society yet you would hold these vital records hostage so no family members can gain access without incredible hardship? This is NOT ok.

Donna Siegel Tue, 10/24/17 - 0:09 As a family genealogist for over 30 years I am opposed to the Proposed Amendment to General Vital Statistics Provisions regarding Birth and Death Records. 125 years for birth records, 75 years for death records to be released will severely hinder research of New York City records. These time frames are excessive and I believe would be one of the strictest rules in the nation. There are circumstances in which the extended time frames would benefit, but I feel there are far better ways to accommodate some of the scenarios sited in the proposal. Linking birth and death records of individuals, separating and classifying certificates that have had to be amended. And as for adoptions, those too could be sealed and classified with an appropriate time frame for those records to be released. Such drastic, across the board, limits would put New York City records out of reach for families and genealogists who are trying to piece together the puzzle of family history.

Donald Hoff Tue, 10/24/17 - 0:11 I am writung to you in opposition to the proposed changes which will limit my access to my immediate family, my ancestral family, unknown persons but related to me. My interest is in securing information which help me on health issues, and discovering issues important to my weldare, and background. It can be very difficult, labor intensive and expensuve I was born and raised in Brooklyn. My family has lived there since 1845. It is imporant to have very broad, and reasonable access to many kinds of records. This affects my family, my wive’s family. I believe the proposed restrictions. will prove to be harsh, very limiting, unfair and misguided. The intent of more stringent limits may appear to safeguard the Identity of many persons, but there many avenues where persins can carry out their illegal activities. I implore you to limit your proposed restrictionists

Laurie Savin Tue, 10/24/17 - 0:14 Who arbitrarily decided these number of years? I am very opposed. I would never have been able to piece together my family’s beautiful history with this kind of policy being enforced. Others should have the same benefits and rights. In this day and age there are no locks for thieves so why should the good guys always get crushed? 125 years is very unfair.

Mary Scafo Tue, 10/24/17 - 0:15 Dear Sirs; In regards to the Proposed Amendment to General Vital Statistics Provisions (Article 207 of the NYC Health Code) regarding Birth and Death Records, please do not pass this, it unfairly hinders legitimate researchers gaining access to their families histories. Many people have traced their families back generations with the aid of NYC vital records. People have regained family relationships that were lost within time, found new relationships with their ancestors they never could have if NYC had not made them available. I know what is being proposed in not the answer. This is not a viable option, you need to find another way with either a stricter vetting process or do not fix what is not broken. Can you assure us that your technology which houses our NYC vital records is impenetrable to hackers, system failure, etc., etc.? Also, regarding Identity Theft, for those of us born in NY, what recourse do we have regarding our own birth certificates, and other vital records if someone penetrates your system? Nothing is perfect, but what you have already works, just do what you need to do to make it safer and not impede us in our quest to connect with our past. Please do the right thing, thank you.

Madeleine Sann Tue, 10/24/17 - 0:15 I have been researching my and my husband's family for over 20 years. My grandparents and several of my great-grandparents emigrated to New York City and settled there. My extended family has lived in NYC for over 125 years; my husband's, for well over 150. The proposed rules are more restrictive than rules I've had to work around in eastern Europe in an attempt to reconstruct our family story. There are no US jurisdictions with such restrictive rules as proposed. NYC was the port of entry for millions of immigrants. Even if they moved elsewhere, many spent decades in the NY area. The proposed rules will make it impossible for even the grandchildren of immigrants to obtain crucial records. Families will not be able to pass on key information to their own descendants and that truly is a tragedy.

John Schroeter Tue, 10/24/17 - 0:16 I believe that Public Records should be truly public and accessible to all. There is no good reason to keep birth and death records locked up for 75 or 125 years. These records always were and should always be public. As a New York City native, 7th generation Brooklynite, a descendant of New Amsterdam, and a genealogist I strongly protest these prospective new rules.

Jeremiah Wilton Tue, 10/24/17 - 0:17 Millions of immigrants passed through New York City as our nation grew through the 20th century. Some stayed for a lifetime, others for a shorter time. Either way, our nation is composed of one time New Yorkers. For those trying to find their origins, slamming the door on vital records of long deceased people will create a barrier catastrophic to the effort. New York must remain the foundation of our country’s immigrant population by keeping access to records as open as possible. Be the guiding light not only for new immigrants but also for the millions who came before..

Aaron Goodwin Tue, 10/24/17 - 0:17 As a professional genealogist and resident of New York City resident, I oppose this proposal. I do however, recognize the importance of balancing access to public records with the protection of privacy. Accordingly, I recommend that the City adopt the legal restrictions established for the rest of the State of New York.

Joan Carol Lieberman Tue, 10/24/17 - 0:25 As genome medicine becomes increasingly important, it is critical that citizens from all states have access to vital records so they can effectively assemble a medical history chart of their ancestors. Causes of death and age of death can assist researchers and medical doctors in providing the best treatments for many patients. There is no reason to withhold such records.

Marcia Katzel-DeVries Tue, 10/24/17 - 0:26 I strongly oppose the proposed amendment to the birth and death law. This proposed law would severely limit my ability to obtain records of my and my clients' family histories. NYC should keep the law as it currently is without any changes.

Michael sirota Tue, 10/24/17 - 0:27 I was born in Brooklyn in 1949 and was raised in New York State. All of my ancestors lived in NYC after coming to the US. My job led me to the Chicago area. I am a serious amateur genealogist and have a tree of 4000 people, most of whom are from NYC. I have also helped many friends, acquaintances and family in researching their NYC roots. The proposed rules would make NYC the most anti-genealogy city in the US. Births and deaths are public events and the records have always been public. Privacy is a red herring. The most serious risk is electronic/internet-related privacy breaches, not killing the hobby of millions of people who lives began or ended in NYC. Your proposed rules are especially harmful to immigrants, whose descendants have tried to trace their roots to NYC, where most Jewish, Italian, Irish immigrants entered the US. If a person affirms that they need access to NYC birth or death records for genealogical purposes, that should be sufficient. Identity thieves have much more efficient means of stealing identities than looking at old birth and death records. I implore you to not implement these anti-genealogy, anti-immigrant rules, that will have not real world effect in protecting privacy. Best regards, Michael Sirota

Kathleen Naylor Tue, 10/24/17 - 0:31 I strongly oppose the proposed restriction on public access to public birth and death records for 125 and 75 years, respectively. These proposed limits are stricter than those in place in almost any other jurisdiction in America, and are based only on the "2011 Model State Vital Statistics Act," which has not been passed by any legislative body or subject to any public comment. While the genealogical community favors open records access, it is vital to note that these public records are not just important for hobbyists, but for crucial, real-world applications. Tracing family medical histories can't be accomplished without vital records, access to which can have life or death consequences for people trying to make medical decisions today. Needing to wait 75+ years to access their family's birth and death certificates leaves people trying to make decisions about when, whether, and how to undergo testing, initiate lifestyle changes, or expand their families to do so without the full picture of how inherited conditions or genetic propensities should influence their choices. Vital records access enables historical scholarship; in New York City, where huge numbers of immigrants first entered this country over the past several hundred years, restricting this access leaves an enormous black hole in our understanding of ourselves as a country and as a people. Vital records access is crucial to the legal and governmental applications of genealogical research techniques, which can be used to find heirs; discover who holds rights to land or other property; or even return the remains of missing members of the United States Armed Forces to their family members, often years after the family last heard from their loved one. There is no evidence that limiting access to vital records reduces identity theft or improves public safety and privacy (on the contrary, there is some evidence that open access to public records deters identity theft). Without an evidence-based rationale for imposing restrictions, arbitrarily limits these important activities. Enacting a 50-year embargo on death records and a 75-100 year embargo on birth records strikes a better balance between public privacy concerns and the need to access and use public records in a reasonable time frame.

Marilyn Robinson Tue, 10/24/17 - 0:33 I am a former New Yorker with ancestral roots deeply planted in NYC. I am against the proposed restrictions being implemented regarding access to Birth & Death Vital Records. Regards, Marilyn Robinso

Jeremiah Wilton Tue, 10/24/17 - 0:34 Millions of immigrants passed through New York City as our nation grew through the 20th century. Some stayed for a lifetime, others for a shorter time. Either way, our nation is composed of one time New Yorkers. For those trying to find their origins, slamming the door on vital records of long deceased people will create a barrier catastrophic to the effort. New York must remain the foundation of our country’s immigrant population by keeping access to records as open as possible. Be the guiding light not only for new immigrants but also for the millions who came before..

Randi Eckstein Tue, 10/24/17 - 0:49 I appreciate the attention on security. However, having timely access to one's ancestor's history is critical for tracking genetic medical problems. I know of at least one country that has allowed researchers to get vital record information otherwise held private, for that purpose. Additionally, this would seriously hamper anyone doing genealogy work (for fun or profit), given the number of people who have lived in the New York in the past (like virtually my whole family). Hence, I strongly urge that this proposed rule be rejected.

Neil Buchwalter Tue, 10/24/17 - 0:50 I am a family historian/amateur genealogist and I believe that the proposed waiting periods are ridiculously excessive. As a New Yorker by birth (Brooklyn Strong!), I rely on NYC records to help fill-in the gaps in my family history. I do not believe that any damage results by allowing genealogists and/or others doing family research to have access to these documents.

Janice Zoradi Tue, 10/24/17 - 0:58 I strongly oppose these restrictive new rules for vital records. They will be devastating for family history researchers, in addition to depriving taxpayers of their right to view and use records that are paid for out of public monies. In a paraphrase of the memorable Ronald Reagan moment from the 1980 Presidential debate, "We are paying for these records!" I support access to vital records...everywhere.

Andrew Sverdlove Tue, 10/24/17 - 1:02 FOI. When a government hides information it always harms the innocent. American values have mostly been to open and not close the doors of information. This is a terrible rule. As someone already said “I am adamantly opposed to the proposed rule. The effort to restrict access to these records is a solution in search of a problem. Of all the ways in which one might want to obtain personally identifiable information, given the state of current technology and the availability of all manner of information on the internet, it makes virtually no sense to impose the types of restrictions under consideration.” “It is an unnecessary, ill-advised, and rather primitive attempt to protect privacy in a way that goes far beyond what is either appropriate or customary in Western societies. I urge you not to adopt the proposed rule. It is, at its root, a feel-good effort to solve a problem that is illusory. Thank you for NOT IMPLEMENTING.

Michael Carlson Tue, 10/24/17 - 1:13 I am adamantly opposed to the proposed rule change. Extending the number of years before birth and death records are made public does not increase the security of personal privacy information. Rather, in the case of death records, the proposed rule would actually make the effort to prevent identity theft more difficult by keeping closed the very records that may prove an assumed identity is fraudulent. Criminals use bogus emails, hack websites and databases, and launch phishing attacks in order to acquire PII. They do not mine decades old birth and death records. Moreover, this rule does a great disservice to individuals seeking answers to questions of parentage, inherited medical conditions, or simply learning about their family heritage. Taxpayers funded the programs reflected in the records; they deserve reasonable access to them. Please reject the proposed rule.

Rebecca Krupp Tue, 10/24/17 - 1:15 The NYC Vital Records are an invaluable resource for thousands of researchers whose immigrant ancestors lived in New York. Death and marriage records can help us learn the names of the towns that these immigrants came from, and can tell us the names of their parents. In many cases this is information that cannot be found elsewhere. The ability to research one additional generation further back in a family tree may allow us to connect that information with records from other countries. I have personally worked very hard to uncover recorded details about my family's past, researching over the course of several years, relying in particular on the NYC Vital Records archives. We need to be able to access these records in order to uncover our histories.

Marge Vallazza Tue, 10/24/17 - 1:23 I am a genealogical researcher. It is vital that records and their genealogical data be available to researchers and family historians to continue the important task at hand. We do not use this information to create false identities and documents. We use them to find our families and flesh out the information we have on them, to discover them, to try to know them. Why not shorten the time to 50 years if you must cut access?

Judy Schuster Tue, 10/24/17 - 1:31 As a New York State person by birth, I am very frustrated by my inability to find death records for an ancestor, who died in 1890, or so...if you are concerned with privacy records for living people, then limit access to them (like limitations to US Federal Censuses), but allow access to records of people long-gone, where privacy is not an issue. thank you, Judy Gantert Schuster

Lynn Squire Tue, 10/24/17 - 1:47 These proposed rules are not the norm in most States. They are far more strict. The underlying rationale is unconvincing. As a serious family historian with family roots in New York, I urge the City not to adopt these proposed rules.

Eileen Keefe Tue, 10/24/17 - 1:49 As a long-time family historian with deep roots in New York City and as a native New Yorker I oppose extending the timelines for release of vital records. This will seriously affect my research and the research of thousands of other genealogists. Just affording copies is expensive for most of us without making us wait until we are 100 years old! I'm sure that many of the identity theft problems are not caused by anyone sending for one copy of a document that can take weeks to receive.

Elizabeth Warren Tue, 10/24/17 - 1:59 I urge the Department to reject the Proposed Amendment regarding birth and death records. Extending the wait time for public release of these vital records will not prevent fraud or identity theft. Identity theft is a sophisticated criminal activity and I believe that requires a sophisticated prevention method. New York City has the expertise to develop a more effective method to thwart the criminals. Thank you for allowing us to provide our comments for your consideration.

Kevin Fagan Tue, 10/24/17 - 2:15 Dear Commission Members, I am writing to register my strong disapproval of any attempt to further restrict access to birth and death records in the City of New York. I am a NYC taxpayer and also an amateur genealogist and I do not believe that further restrictions on these records would be in the public interest. The public records should be just that -- a public record. Further restrictions would greatly hinder the ability of myself and millions of other New Yorkers and people all over the world who have family history that can be traced back through the City to effectively trace our family origins. I ask that the commission consider the following common-sense restrictions which provide protection for the privacy of individuals while also allowing access to genealogically significant records in a timely manner: - Allow access to birth records after 75 years when the individual's death can be verified (and 105 years if no death is verified) - Allow access to death records 25 years after the individual's death As the connected world evolves, there is clearly a need for the protection of individual privacy. There is ALSO a need, however, to make available records which belong to the public as soon as they are no longer a privacy risk for the individual involved. Please consider my above comments carefully. We all deserve to know from where we've come and these further restrictions would hamper exploration of many peoples' family history without providing an actual increase in personal privacy. Many thanks, Kevin Fagan

Renee Steinig Tue, 10/24/17 - 2:23 I am dismayed at the proposed limiting access to New York City birth and death records. Such regulations would deliver a disastrous blow to family historians. I have been doing genealogical research for 40 years and have worked to discover, preserve, and share the stories of countless New York families -- my own and those of friends and clients. Our ancestors immigrated to the United States through Ellis Island and lived on the Lower East Side before moving to other neighborhoods in Manhattan, the Bronx, Brooklyn and Queens. The stories of their lives in America are contained in New York City vital records, and access to these materials is critical to my work. Like many of my colleagues, I have also used New York City vital records to help others -- adoptees, Holocaust survivors, and others searching for lost families or for the graves of loved ones. The proposed restrictions would drastically reduce my ability to do this pro bono work. The plan to lock up birth records for 125 years and death records for 75 years is extreme and based in part on faulty assumptions about the causes of identity theft. I understand that a number of organizations have suggested the following guidelines for access to public records. I support those recommendations, which are far more reasonable than those currently proposed: - Access to birth records after 75 years (if the individual’s death can be verified) or 105 years if no death date is verified. - Access to death records after 50 years, or after 25 years to registered members of a New York genealogical society. - Access to the index to death records after 25 years (providing the name, date of death, place of death, date of birth, and burial/cremation information). - Access to informational copies of birth and death records, which could not prove identity for financial and other transactions but would provide the information necessary for researchers. Thank you very much for your attention. Sincerely, Renee Steinig

Jeanne Gold Tue, 10/24/17 - 2:23 I agree, a balance is needed. However, the concept of erring on the side of caution can be taken too far -- as in the case of this proposal. Clearly, the framers of this bill/proposal have no real concept of how the electronic world works and the only people who will be held to toe the line are those who are honest in the utmost. To begin with, anyone wanting information about potentially living individuals need only subscribe to one of the many people finder services -- which will yield a wealth of information used to create false identities without all the work and cost. Because, frankly, it's far less expensive to pay for a one time search at about $10 on one of the aforementioned services than it is to pay for documents, one at a time, which can easily run $25 each and may require 4 or more documents to get the exact same information. The fact is the problem is easily solved by having two options in place. Documents which are for research purposes are altered to show that purpose and don't include any seals. Moreover, it will cost the agency less money to produce research only documents which savings can be passed on to the researchers. Those folks who want original legal documents are then required to prove their legal eligibility. Hence problem solved. The point that needs to be taken into account, which seems to have been neglected here, is that the real threat to protecting our identity aren't from the people purchasing the documents -- along with ID -- but the hackers. If you really want to protect identities, then invest time and money into better record keeping behind better security walls. Start with not allowing attachments not be sent in emails! Files can be shared by other means such as on secure servers which have no connection to the rest of the network. Get yourself some IT people who know what they are about and get rid of lazy solutions to problems not even addressed correctly, let alone understood in context of our current electronic world.

Barbara Hershey Tue, 10/24/17 - 2:34 As a genealogist, and someone born in NYC as were a couple of generations before me, I request that information that would help identify family members be retained within the current, not proposed, boundaries. It's been said that genealogists have not been the source of inappropriate action based on records like identity theft, etc. It is critical for historians to have access to information in order to develop our histories and the history of the city and state. This informs our future generations. Please do not pass the new public records privacy regulations.

Charles Steinman Tue, 10/24/17 - 2:45 I understand and appreciate the privacy concerns that may have motivated this effort. As a person who is concerned about the over-use of private information, I definitely sympathize. However, this rule goes way too far. It is a reach well beyond any reasonable requirement for privacy. If these records had no value outside of providing identification for the living citizens, this rule, or even a rule burning the documents would never matter. But that is not the case. Presently, Genealogy is the 2nd largest hobby in the United States. As a person with over 40 years experience doing genealogy, I can tell you that having recent records can make all the difference in the work. First of all, many people have utterly lost track of even close relatives. I have personally done research where people, quite a few people, did not know who their grandparents were! This is amazing but it is not as uncommon as one would hope or expect. Recent records can clear that up and help get genealogical research started as well as helping bring families together. In addition, babies who have died in childhood particularly get forgotten. It breaks my heart to find these children become lost and in the family histories that are written, they do not appear. But recent records helps with more than that. Getting the detailed information from my great grandfather's vital records helped my other living ancestors remember details of his life and stories about him. It was a jog of the memory and as a result, I was able to flesh out my family history and make the individual not just a name and numbers on paper but also a flesh and blood person with things he did and said. This was motivated by having recent records. Without those records, some of this would not have happened. And once those memories are gone with the ancestors, they can never come back. Please consider a different rule that would help maintain required privacy but also benefit family history research. 1) A birth record becomes public information on the 1st of January following 82 years after birth. (This would match the time frame when US Census records become public: 72 years after the census was taken. Children up to 10 years of age would appear in that census for the first time, so a similar period for birth records would be 82 years.) A death record becomes public information the first day of January in the year following the death of the individual EXCEPT upon notification by the living parent(s) of the deceased, the release may be delayed up to a maximum of 75 years. (A person who is dead has little or no special need for privacy but living parents might object to the birth record being released to protect their privacy) Thank you for protecting privacy, but please, also, try not to put a block in the way of people legitimately working to create vivid and accurate family histories and to find their roots. Thank you.

Terry Koch-Bostic Tue, 10/24/17 - 2:46 I oppose the DOH's proposed new rules for access to Birth and Death records for NYC. There are a number of issues that the DOH has not taken into account, maybe one of the most important is access to death records to build a family health history. In my own family, building a family tree revealed a virulent strain of cancer that took the lives of multiple women in three generations from 1929 through 2004. This important knowledge was used to guide testing and treatment for cancer occurances in my family in the past decade -- and this knowledge was gained from death records that spanned the 1930s, 40's and 50's. Under the proposed new death record rule, this information would be denied to my family. Genetic cancers tend to show up earlier in each successive generation, so it is important that death records not be given more limited access with a new rule, rather they should be given broader access as they actually also help to prevent theft of identity from the deceased.

Steven Smyrl Tue, 10/24/17 - 2:49 At the outset, a sweeping statement claims that the information in vital records is considered private! Every civil (vital) record in both the UK and Ireland is a Public Record that all citizens can access and yet the issues of fraud outlined by the NY authorities rarely arise. The existing regulations in NY are draconian enough without these additional burdens. And in fact access to vital records allows verification of the bona fides of others and thus actually reduces fraud. Instances of fraud occur much more easily where the perpretrator knows that the victim cannot access information that will expose their crime. These regulations should not be passed.

Elizabeth Cook Tue, 10/24/17 - 3:03 The proposed rule is inadvisable for several reasons. 1. Mis-use of birth and death records to establish false ID's is minor compared to the theft of personal information by other means; 2. the proposed rule will hinder legitimate research; 3. information critical to legitimate studies of causes of mortality will be delayed to the point of uselessness. I urge you not to adopt the proposed rule. It will not solve any problems. Thank you for the chance to comment. Elizabeth Cook, Genealogist and Historian

joe glass Tue, 10/24/17 - 3:13 I agree with all of those who are opposed to the proposed rule changes. These changes do not serve the best interests of today's public or the future public. There are better ways to protect against abuse of public records like these than by locking them up for so long that they can no longer serve any useful function at all, let alone historical research, family research or even probate research, among other rightful activity. I was born in New York and my family has deep roots in the City and the State of New York. This is a case actually, of identity theft, of a different kind, and one proposed by non elected public servants. Again, I am opposed to these changes.

Kenneth Kennedy Tue, 10/24/17 - 4:06 As a lifelong New Yorker, and someone whose family has been living in, and a part of New York City history, for several hundred years, I find this proposal to be ridiculous and not supported by the data that has been offered as the rationale for this proposed change. My family values its historical ties to NYC--in part because of its history of inclusion and openness, which has always been reinforced by a civil bureaucracy that reflects those same values. This proposal ignores that centuries-old symbiotic relationship for reasons that they can't even explain in logical terms in this proposal. In addition, as someone who has been a genealogist for more than 40 years, I find this proposed change to be appalling and one that would have no measurable effect on the protection of the privacy of individuals, as the proposal claims it will. I see no indication nor proof that adding 25 years on to the availability period would stop identity theft (for instance)--this is simply a decision made using anecdotal "evidence" that a longer waiting period "must" lead to lower levels of identity theft. All around the world, other jurisdictions are opening their archives and posting full records (not just indexes) online--for example in Sweden and Missouri--and in New York City, a place that prides itself on freedom and openness, we are heading in the opposite direction, due to the misguided and unsupportable proposal of several bureaucrats? What a sad state of affairs and commentary on where we are. Please stop this proposal!

remo pe Tue, 10/24/17 - 4:25 The 125 year waiting period is very excessive and needs to be a lot shorter. I can see no damage that will be created by giving genealogists and people doing their own family research access to these documents.In Italy is 70 years

remo pe Tue, 10/24/17 - 4:26 The 125 year waiting period is very excessive and needs to be much shorter. I can see no damage that will be created by giving genealogists and people doing their own family research access to these documents.In italy it is 70 years long

Anita Grossman Tue, 10/24/17 - 5:14 As someone who is currently doing genealogical research on my family, I strongly oppose any further restriction on access to NYC vital records. The regulations are too restrictive as it is.

Mimosa Mack Tue, 10/24/17 - 5:26 Please do not change the rules to make birth records unavailable for 125 years. Our family has been in NYC since before the revolution. Vital records are vital to my research! Thank you, Mimosa

Ken Hughes Tue, 10/24/17 - 5:49 These proposed rules are stricter than almost anywhere else in AMERICA, and would be devastating to anyone researching New York City ancestors or collateral lines. As the largest city, everyone has an ancestor who lived, died or got married in New York City, so I ask why would you make it so difficult to learn of your past.

Denise Ramo Tue, 10/24/17 - 5:59 The proposed changes are ridiculous. As it stands, the rules are efficient - though quite excessive - for the protection of the person named on a document. Identity theft should be of no concern as anyone with a credit card in today's times is almost guaranteed, thanks to Target, Equifax, & others. No one oaying & waiting for these records is putting in that time & expense for fraudulent means. We are simply trying to find our families.

suzy mccormick Tue, 10/24/17 - 6:04 I was never told how my Grandparents passed. When I was diagnosed with Transverse Myeolitis in my brain cord, I was continously asked about my family history. I was able to obtain death certificates for many relatives, looking for clues. I also started to become extremely interested in my N.Y.C. Family History, where I, and all great grandparents, was born and raised. To be able to find my families birth, death, and most importantly medical history, has helped myself and my family tremendously. I strongly oppose the new proposed rules, as everyone is entitled to know their origins. Why cant there be" informational " copies available as California provides? IAs a true New Yorker who loves their city, and never left, and where my family was born and died, I am hoping The DOH will realize these records hold much more than times and places, they hold the truth.

Adam Stein Tue, 10/24/17 - 6:32 I am strongly opposed to the proposed rules. There is no reason to increase the length of time these documents are available. If anything, it hurts those looking for information about their family (historians, genealogists) rather than helping reduce fraud.

lisa doscher Tue, 10/24/17 - 6:35 I understand with these new rules you are trying to protect privacy. Please consider less strict guidelines, such as reducing the amount of time before records can be obtained. The vast majority of us are only trying to research our family history, and I am concerned the time frame proposed would hinder that greatly Thank you

Christine Clark Tue, 10/24/17 - 6:42 I am writing to express my opposition of Proposed Amendment to General Vital Statistics Provisions (Article 207 of the NYC Health Code) regarding Birth and Death Records. I'd like to start out by pointing out that I am a CURRENT, Brooklyn born resident of the City of New York and am employee of this great city. This record set includes my family including the birth, marriages and deaths of my children, my parents, my grandparents and many more direct ancestors who were born in the 19th century. However, I am also a genealogist and extending the time would be detrimental to much of the research on which many of us rely - particularly for those like me who are tracing common surnames such as Clark and Johnson. I fully understand the need to protect privacy but this is taking it to the extreme. I feel that waiting 50 years after a death and 100 years after a birth is sufficient. I belong to many genealogical organizations and I repeatedly help to direct other like minded individuals who no longer live here plan their trip to NYC to trace their ancestors steps. They visit the graves in our cemeteries, they go to the houses or tenements where their ancestors lived, they visit the Statue of Liberty and Ellis Island, visit our museums such as the Tenement Museum and the Museum of the History of New York. They spend money on visiting our ethnic restaurants such as Katz Deli or dining in Little Italy or pull a pint in McSorley's Ale House. They come to our great city and spend time and money - without some of these records, they might not be able to further their research or figure out where the address in which grandma was born. Thank you for taking the time to read my comments. Christine Clark Brooklyn, Kings County, New York City, New York

Judith Lipmanson Tue, 10/24/17 - 6:42 These proposed restrictions are similar to swatting a fly with a sledgehammer: well-intended but damaging. There are more valid methods of protecting data against illegal use than withdrawing them from serious historical and genealogy researchers. You already have the start of a database to enroll interested parties into a program for those with a genuine and/or legal basis for examining these records. To this you could also put some restrictions on how the information can be used and published without safeguards. Your proposed approach should be reconsidered and amended. Yours truly, J. Lipmanson, Ph.D.

Chiara Osborne Tue, 10/24/17 - 6:45 As a family historian and aspiring professional genealogist, I find these rules to be extreme and needless.I find the thought process as to curb identity theft to be far-fetched as these records are not being used for this purpose. I find the city to be putting needless restrictions on the birth and death records. New York City is already one of the hardest places to find your roots and research in. I strongly urge the City of New York not to follow through with this proposed rule change. The current standards are rigorous enough.

Elizabeth Snead Tue, 10/24/17 - 6:49 Is a family genealogist I oppose Proposed Amendment to General Vital Statistics Provisions (Article 207 of the NYC Health Code) regarding Birth and Death Records. I feel that I have a right to learn about my ancestors and that you would be impeding my ability to do so.

Pamela Morrison Tue, 10/24/17 - 6:50 Please help us Genealogist have access to birth and death records for our ancestors

Eileen Naglieri Tue, 10/24/17 - 6:52 Balancing privacy and security with access to records is a delicate balance. I encourage NYC to consider the detrimental ramifications of this proposed rule to those families engaged in Family history research. I was born and raised in NYC as were several generations before me. NYC records have been invaluable to me to learn how my ancestors lived and died. In some cases I have learned who these people are. I have learned not just names and dates. The research starts with vital records. I have also learned health history from cause of death. This is not just valuable as history but helps the family to take proactive steps in today’s world. If the proposed rule was in effect when I gathered my current research , so much information would have remained unknown. History would have been lost. Valuable, useful information would have been lost. Access to records is vital!

Anne Evola Tue, 10/24/17 - 6:58 I ask that the new rules proposed for the viewing of birth and death records not pass. Please the the current policy in effect to enable those who wish to trace family lines. The Irish diaspora of the nineteenth and twentieth centuries was devastating to family ties. Because I was able to view NYC records I would no longer be able to view under the new rules, I have reestablished ties with family here in America as well as in Ireland on both sides of my family. Visiting the site of my third great-grandparents in Kilkenny, Ireland on land still held by my cousins has been the highlight of my genealogical research. I still have many sites to visit and am fortunate to have the info to do so. Please allow those descendants of nineteenth and twentieth centuries to have as much of a chance as I have had to trace their lines. Surely there must be other ways to head off problems while leaving the records open to the public.

Michael Savoca Tue, 10/24/17 - 6:58 While I can understand seeking to protect the privacy of New Yorkers, this proposal to amend the release schedule of vital records is simply a knee jerk reaction to a problem which can be fixed in a multitude of ways. NYC already has some of the most strict laws regrding vital records, often to the detriment of the public. As of now, we can not access a death certificate for an uncle, he died unmarried, without children, and has no living siblings or parents. Issues like this are the result of reactionary legislation, and it is a shame. If you want to protect identities but provide reasonable record access, perhaps the dept of health needs to offer non-certified copies. In this way we can have access to vital records, provide the city with a solid revenue stream, and the certificate will be null for anything but informational purposes. I'm the fourth generation of my family born in NYC and this unnecessary action by the health department serves no purpose but to restrict access without any consideration for other options and other sides. I urge the board to consider informational copies, and admonish them for not overseeing proper record transfer to the municipal archive of records for years now. Reconsider this proposal, we can be protected while maintaining our access to these records. Thank you for considering my opinion, and hoping for a positive outcome.

Gail Schulte Tue, 10/24/17 - 7:06 I very strongly oppose this change, especially the change in death record availability. Please reconsider and come up with a well thought out, quantified, and justified argument which proves this extremely restrictive change is necessary. Such restrictions should be similar to those imposed by other cities and states.

Lauren Apicella Tue, 10/24/17 - 7:17 I strongly oppose this amendment. Both sides of my family came through and lived in New York for generations. Restricting access to these records would very much impede my work as a family historian as well as many others work and research into their own families. These limits are too long and would not prevent fraud.

Amos ZEZMER Tue, 10/24/17 - 7:28 I am appalled by these proposed new rules. They are simply meant to make vital records inaccessible to the general public, genealogists and family historians like me. Why not crank up the time limits to 250 years for births and 150 years for deaths? This will certainly bring all our genealogical and research projects to a screeching halt and appreciably reduce the work load of civil servants who fulfill requests for copies of vital records. The proposed new rules simply deny access to information on our ancestors, for we will also have passed away or perhaps become senile by the time these finally-accessible records have any meaning for us. The public has the right to know. The living public has the right to know. The proposed rules disrespect the Freedom of Information Act. Shame on you!

Tammy Poole Tue, 10/24/17 - 7:30 I will keep this short. I strongly oppose restricting these vital records for 125 years. Although I currently reside in Texas, and you may not care about my opinion since I am not a constituent, but my ancestors and their records reside on your soil. Please reconsider. Thank you.

Shirley Fields Tue, 10/24/17 - 7:34 Birth and death records are PUBLIC records and should not be withheld from their owners -- THE PUBLIC -- in any way for any length of time! New York should set the standard and allow such records to be available to the public. Open access to such records would facilitate determining the true identity a person is claiming and could help stop identity theft! The rules being considered to hide such records will allow identity theft to flourish! Shame on you if you aid such illegal acts to continue.

Sarina Amiel-Gross Tue, 10/24/17 - 7:34 In today's day and age of computers that have the ability to cross check, using a dead person's information already carries with it a felony punishment. To withhold this information, which for the most part is exclusively used by genealogists and /or family historians is simply unwarranted. Laws already exist to protect the use of this information, why does the City feel the need to create another barrier that will serve no purpose. Kindly re-think this proposed rule. It will makes little sense and it will cost the City more when those same genealogists and/or family historians sue the City under the FOIA, and win to have the information released anyway.

Susan Johnston Tue, 10/24/17 - 7:35 These rules are unnecessarily broad and would severely hinder the ability of genealogists and those wishing to join lineage societies access to records they require. While some may assume that lineage societies are comprised of teetering old folks, in fact, these societies are in large part service organizations. For example, the National Society Daughters of the American Revolution is the largest women's service organization in the world and members donate millions of hours of their time to community service each year. To join, however, one must prove lineage to a person who assisted in the cause of freedom during the American Revolution. They must provide birth and/or death certificates for themselves, their parents and grandparents. Your proposed rule would prevent anyone whose ancestors happened to reside in New York City from being able to join DAR or other lineage/service societies as as most of the rules for admission have similar requirements. By the time your 75 or 125-year rule was complete, most of the people who wished to join these organizations in service to our nation, would be dead themselves.

Linda Mallalieu Tue, 10/24/17 - 7:36 As a family historian and amateur genealogist, I strongly oppose changing the accessibility rules for our family information. The NYC Municipal Archives holds a treasure trove of valuable information that belongs to us as itizens, part of our cultural heritage that we have a right to view. I fail to see any sound reasoning behind making our family information less, rather than more, accessible. The current rules provide ample protection of privacy, and the proposed extended periods are excessive. I am a resident of Long Island and frequently come to the city to do research at the archives. This is our history, and we have a right to learn about our ancestors and our stories. More bureaucracy and restrictions are an overreach and unnecessary.

Holly Kilpatrick Tue, 10/24/17 - 7:38 I strongly oppose this unreasonable and ineffective restriction on citizens' records. This is so typical of one of the most regulatory states in the United States. Not government for the people, but government against the people. Americans all over the country have ancestors who lived in New York, and these restrictions create further obstacles to their finding out about their roots. The Department should review the policies of other states, and model New York after the states who support freedom and transparency, not authoritarianism and backwardness.

Patricia Farrell Tue, 10/24/17 - 7:52 It is vital that I have access to this material in order to continue researching my family's history back to the 1890s.

Dan Hoffman Tue, 10/24/17 - 7:54 While it is true that birth and death records contain vital information that should be protected from possible misuse for a reasonable period of time, the proposed rules exaggerate this period unduly. Other major states such as Texas and Pennsylvania have chosen to post their death certificates going back to the 1960s. As a family historian, I depend heavily on the information in these documents and hope that this proposed rule will be defeated and will be replaced by a less draconian option. My question is if there are any stats that indicate the extent of fraudulent use of these records? And, even if there is fraudulent use, for the most part wouldn't the same information be available from some other sources, though in fragmented pieces, in any case? Thank you for reading and considering this comment.

Kirsten Manton Tue, 10/24/17 - 7:58 This is response to the proposed resolution to amend Article 207 of the NYC Health Code. Thank you for allowing me to express my concerns. I understand your need to control the transfer and availability of vital records documents. The time limits you propose, though, are some of the most restrictive that I have ever seen and I would urge you to set the limits for birth records to match the federal government in terms of privacy – 72 years. As a professional genealogist, I utilize vital records documents from all over the world. As NYC was an important gateway to many seeking refuge, vital records from NYC are often the only link I have between an immigrant and his new life in America. I also have a personal interest in NYC records as many members of my family have lived there.

Edward Cain Tue, 10/24/17 - 8:02 As a Family historian these changes would severely hamper my ability to research family members born in the early years of the 1900's and who have died before 1980 I would suggest changing the birth amendment to 100 years and the death amendment to 35 years

Amy Feldman Tue, 10/24/17 - 8:03 This proposed change would be detrimental to my genealogical search since most of my ancestors lived in new York City when they first arrived in this country. Please do not make this change!

Walter Bartus Tue, 10/24/17 - 8:11 This is an unfortunate over reach in response to hacking incidents. I concur with Reclaim the Records that the proposed rule as currently written is too broad. Further, I feel that the proposal below adequately safeguards records, yet allows for research: 1. Access to birth records after 75 years (if the individual’s death can be verified) or 105 years if no death date is verified. 2. Access to death records after 50 years; or after 25 years to registered members of a New York genealogical society. 3. Access to the index to death records after 25 years (providing the name, date of death, place of death, date of birth, and burial/cremation information) This will more than adequately protect privacy and place New York city in congruence with other jurisdictions. Thank you for considering my request.

Thomas Byrnes Tue, 10/24/17 - 8:13 I am a native New Yorker and have been researching my family history for several years. The value of the availability of vital records is critical to that research. I think that 125 years for birth is too long, we would be better served by a shorter period of time, say 105. Death records at 50 years is much more appropriate for researchers that 75. Thanks for the opportunity to voice my opinion.

Frank Strovel Tue, 10/24/17 - 8:13 To Whom It May Concern The 125 waiting period for the Birth Records and 75 years for Death Records from New York City needs to be much shorter. I am a genealogist along with many more of my fellow genealogist all over the world. I have many relatives from NYC and need to have access to the records. Not only for correcting information of my ancestors, but for the many people who are not doing genealogy minded. This information is needed for many reasons as other have mentioned in their posts. Let this get done quickly as many of us are older and the need for this information is crucial! Agency: DOHMH

Ann Irving Tue, 10/24/17 - 8:16 I oppose this very severe restriction of access to NYC birth and death records. There is no research to show that these records need to be restricted for such long periods of time in order to prevent identity theft. In doing so, genealogists and family researchers would be seriously hindered in their work. New York City is in a unique position among cities in the U.S. because of the millions of immigrants who arrived there and began their lives and the lives of their children in NYC. My family has deep roots in NYC, and much of the information I have found about them would be inaccessible if this law is passed. I ask you to please consider the negative consequences to passing this unnecessarily restrictive law. Thank you.

Jon Levine Tue, 10/24/17 - 8:19 As a resident of NYC and genealogical enthusiast, I strongly oppose this amendment. The current privacy laws have served the city well for many years and nothing is to be gained by making these changes. Thank you.

Helen Moore Tue, 10/24/17 - 8:20 I have been doing family history research for my family and friends for about 10 years. Unless you've experienced it, it is difficult to describe the absolute joy of discovering details about an someone through a public record, and the frustration of failing to have access to other information for what strike me as artificial barriers to additional information. The proposed changes seem focused on preventing those who are legitimately seek to learn about their history because some tiny number of people may seek to misuse this information. Please don't do this. Thank you.

Christopher Padgett Tue, 10/24/17 - 8:21 What is most egregious about this rule proposed is the city of New York has been profiting handsomely off the sale of this data to commercial businesses for quite some time. The rule is only being proposed to prevent family historians from freely obtaining records on their ancestors. Many people do not have the money to travel to New York to obtain these records. If this rule is implemented, the real motivation behind it will be revealed during the discovery phase of future litigation. I can only imagine the contents of the emails of those who schemed and plotted to create this rule. Shame on the bureacrats who proposed this awful rule.

Kris Gilbert Tue, 10/24/17 - 8:25 I enjoy doing genealogical research for myself and others and live in New York State. I strongly oppose the move to restrict records access for such unreasonably long time periods. This information is important for people doing genealogical research, including for religious and health purposes, those seeking documentation for dual citizenship and lineage society applications, those who want to pass knowledge of heritage along to descendants, and who do research for personal interest and fulfillment. Knowledge of cause of death of indirect ancestral relatives such as great uncles and cousins can provide very important health information to those living, and their descendants. Death records especially should be made available far earlier, and equally to all researchers, not just members of a particular group. States which have open records do not have more problems with identity theft than states that are more restrictive; identity theft threat comes primarily from the hacking of company databases stored online, not vital records. Sincerely, Kris Gilbert

Lori Wall Tue, 10/24/17 - 8:26 I would like to encourage the Department of Health to reject the call to extend the restriction to public access to birth and death records to 125 and 75 years respectively. A better way to restrict fraud would be for every death certificate to be sent and notations made on the birth record when and where the person died. When children die at a young age, for example a few days, a note should be added to their birth records to prevent scoundrels years later from trying to create fictitious identities. I think there are ways for individuals who may want to protect sensitive facts from public disclosure that do not require denying public access. Thank you.

Lynn Blumenau Tue, 10/24/17 - 8:28 I strongly urge that the stringent restrictions currently proposed be abandoned. I live in New York State but do not have easy access to NYC. I rely on my current ability to access family material to further my genealogical research. Thank you for your consideration of the needs of NYC genealogical researchers worldwide.

david moore Tue, 10/24/17 - 8:34 As my family historian I find the 125 year waiting period is very excessive and needs to be much shorter. Being able to research my family has already enabled me to find relatives I never knew existed. Such a wonderful opportunity.....don't limit that experience for me and many many others looking for extended family.

Kenneth Dreitlein Tue, 10/24/17 - 8:38 Limiting access to public records is not acceptable and will severely limit research for those of us whose roots are in New York. Please do not incorporate this limitation of access.

Bonnie Mucia Tue, 10/24/17 - 8:42 I am strongly opposed to this proposed rule. As a genealogist, I have used the records to help many families find their family roots. So many people have immigrated through NYC and lived in the area before moving other places. This is a non-issue in other places that records are freely accessible. There are other avenues that identity theft is much more a worry than records of long dead people. Please do not limit access to these vital public records. There are a lot of people that trace their family trees for other reason like health history and this would be devastating to these people. Also, think about the history that would be lost of stories of ones grandparents and great-grandparents that one can pass down to the next generation. Our history is not only important but vital and knowing your own personal family tree and history is such a gift to many. Please do not pass this ruling. Do not let history get lost.

maureen hunt Tue, 10/24/17 - 8:42 It has been shown that these records are not a factor in identity theft. There is no reason to keep death records secret for 75 years, nor to keep birth records unavailable for 125 years....The Bible notwithstanding, the large majority of people are not going to live anywhere close to that. Other places have much more lenient provisions and do not experience unwanted consequences.

Angela Fitzpatrick Tue, 10/24/17 - 8:47 People have a right to know who their ancestors were, to know about their causes of death, where they are buried to know if what they have been told is true. Copies of New York City birth/death and marriage records are crucial to a genealogist’s research. Without the information in those records, I would not be able to ascertain if "John Smith" is my "John Smith" or another family's John Smith. There would be no other way to verify my information. Trying to begin genealogical research without City records would be a waste of time. Do not create a policy which stops people from learning about their families.

judi wagner Tue, 10/24/17 - 8:51 I was born in NYC, and am in favor of NO restrictions on birth and death records. These should all be public and available to researchers. I have been able to use these records to further my genealogy studies, and believe the records should be available to all. I am still a part time NYC resident, and want access for myself and others to continue their research. Many other cities and countries permit less restrictive usage and NYC should comply.

Veronica Knapp Tue, 10/24/17 - 8:53 Your proposed new rules are completely unreasonable, unnecessary, and will significantly impede genealogical research. New York State Department of Health rules are more reasonable. They provide uncertified copies of the following types of records for genealogy research purposes: Birth certificates – if on file for at least 75 years and the person whose name is on the birth certificate is known to be deceased. Death certificates – if on file for at least 50 years. Marriage certificates – if on file for at least 50 years and both spouses are known to be deceased

Tony LaLuzerne Tue, 10/24/17 - 8:54 As a genealogist, I am against this proposed amendment. Genealogists support NYC businesses and tourism through research trips, and the Municipal Archives and NYC Dept. of Health through record fees. Restricting NYC DOH records will have a severe impact on those researching their family's health history, possible predispositions to cancers and inherited illnesses, and for those looking for patterns of illnesses in their families. Genealogical research is one of the fastest growing professions and restricting records would impose huge barriers to business growth - for those researchers in-state as well as those out of state and around the world. Access to vital records imposes no risks to personal security - in fact, having open records is proven to make personal identity more secure as it can be more easily checked.

Susan Bowen Tue, 10/24/17 - 8:54 I live in Manhattan, and I oppose these changes. Vital statistic records should be available for descendants and geneological research on a timely basis. 125 years to release a birth certificate, and 75 years for a death certificate is too long! I understand the need to protect privacy, but there is no need for such long waiting periods - indeed, the strictest in the country. Genealogical research is very important to families and historians who need timely access to birth and death records. And while we're at it, amending birth certificates in cases of adoption is wrong. It is falsifying a legal document! Original birth certificates should remain as they are, and Certificates of Adoption should be issued when applicable.

Freddy Villano Tue, 10/24/17 - 8:54 The 125 year waiting period is very excessive and needs to be much shorter. I can see no damage that will be created by giving genealogists and people doing their own family research access to these documents.

Mary Kozak Tue, 10/24/17 - 8:56 As a family historian with deep roots in New York, I would like to encourage the Department of Health to reject the call to extend the restriction to public access to birth and death records to 125 and 75 years respectively. It is commendable to try and limit identity theft wherever possible, but extending the years of availability of birth and death records will not accomplish that goal. The proposal will have unintended consequences, like preventing families from knowing health history which could improve or change health outcomes. Additionally, birth records are an important tool in piecing together family history and 125 years is clearly excessive. Given the size and scope of NY vast mealting pot, this act would have dire consequences on family history throughout the country. Please consider carefully your decision on this matter.

Carl Johengen Tue, 10/24/17 - 9:00 As an adult adoptee in New York State, I am against any change to rules regarding birth records which would limit access. New York State's records access is already the strictest in the country. If anything we should be making access easier, so that family members have an easier, not a harder time locating each other. I strongly oppose these changes to the rules.

Erin Sawaya Tue, 10/24/17 - 9:05 I would like to post this comment against extending the time period restricting access to vital records. I was born and raised in Brooklyn, and most of my extended family is also from NYC. I have recently started researching my family and have already been able to learn information that has been very enlightening to all of us and which would have been completely impossible if records were restricted this long. I cannot see the value in preventing family members from accessing information about their long-dead relatives, and by extension about themselves. In fact, I am currently unable to view the birth certificate of my great-great aunt, born in 1910, because the archives are not available from that year. After a lot of research, her birth certificate is probably the only place I can get accurate information about her parents, since the country they were from is currently at war. This extension would mean nearly another twenty years of waiting, for basic information about my relative that dates from the Taft administration. Please do not allow the time period of restriction on access to be extended.

Carole Wiseman Tue, 10/24/17 - 9:09 I am adamantly opposed to the new rules proposed by the City of New York. I would like to know what is to be gained by delaying a birth record to 125 years after date of birth and 75 years after date of death. Family researchers are using this information for personal use only. I, personally, have been tracing family history and am very interested in obtaining those records for my family who were born in the 1920's. These records would not be available until 2048 or later and many of us will be long gone.

SUSAN SPEERS Tue, 10/24/17 - 9:12 Please do not adopt this proposed rule. I have used the NYC Vital Stats office in person to locate marriage records, births, and deaths to confirm my father's family history and intend to return to do further research in the future. I believe that there is an important public purpose to birth and death records and the current delay in release is adequate to protect privacy. Thank you for allowing public comments via your website. Sincerely, Susan Speers Descendant of German immigrants arriving in 1884; NY-born African American farm workers; and freed slaves from Virginia and South Carolina who came to New York City in the 1870s.

Michael Pisapia Tue, 10/24/17 - 9:13 I oppose -in the strongest possible terms- the proposed Amendment of Provision of Article 207 of the New York City Health Code as currently written. The proposed waiting period of 125 years for births and 75 years for deaths is excessive. This onerous waiting period will be crippling to family researchers and devastating to professional genealogists who provide a vital service to families and to attorneys and the Courts in kinship hearings and heirship proceedings. There is no damage created by giving genealogists and people doing family research access to these documents. Bear in mind -this information is the property of the public- and the government agencies are custodians -with a fiduciary duty to maintain and provide this information accurately. The effort to restrict access to these records is a blunt instrument and does devastating harm and no discernible good. If the rationale is protection against identity theft -please consider the current state of technology and the availability of all manner of information on the internet- not authoritative information of use to genealogists and family researchers, but detailed information regarding living individuals used by malfeasors for nefarious purposes. Amorphous and vague ‘privacy concerns’ are not addressed by the lengthening of the waiting periods and do not out-weigh the right to obtain public records, which are held for the benefit of the public. There is no rational basis to impose the types of restrictions under consideration- it only harms the genuine researcher and will not hinder the hacker. People have a right to know the identities of their biological and ancestors of record, to know their ancestors' life-circumstances and causes of death, to be able to discern if family lore is fact or fiction and to back up their research with authoritative records- of which the government is the custodian- for the benefit of the public. Authoritative copies of these records (not necessarily certified copies) are a necessity and a right! The 125 year waiting period is excessive and must be considerably shorter. The proposed amendment is unnecessary and over-reaching. I urge you not to adopt the proposed policy and rule changes.

MaryBeth Johnson Tue, 10/24/17 - 9:20 I oppose the proposed regulations. As someone with famiiy who emigrated to NYC, obtaining important family information is already more challenging than it should be. Please keep the records available!

Patricia Foos Tue, 10/24/17 - 9:22 I vehemently object to the proposed rule change regarding the length of years before records are open to the public. As a family historian and amateur genealogist, this would have a devastating effect on my ability to research. I am a retired teacher who pursues this hobby but I had to wait for retirement to devote my time. Now that I have the time, I do not want to see the records closed to me. Most of my relatives are native New Yorkers and I would have no other recourse. If fraudulent activity is feared, perhaps the records could be altered in some way to prevent that. Please reconsider your proposed rules change. The Majority of people using these records are law abiding folks looking to learn about the present by visiting the past.

John Albertini Tue, 10/24/17 - 9:22 These are PUBLIC records and having them publicly available enhances personal security, does not weaken it. Make these records available to ALL.

Mary Beth Kooper Tue, 10/24/17 - 9:29 Although people are living longer there is so much information about individuals available online that this added restriction does not make sense to me. It will hinder thoughtful people in getting the information they need for research purposes, while those seeking similar information about people will be able to do so by doing an easy search of the internet. Please also work towards digitizing all of your records.

Michael Carragher Tue, 10/24/17 - 9:40 Please do not consider making changes that are more restrictive. There would be no gain in fraud prevention and only make Family History research more difficult. Personal privacy would not have substantial benefit from these changes. Sincerely, Michael Carragher

Jane Hatch Tue, 10/24/17 - 9:40 Please do not change the rule to make it more difficult to obtain family records. I am a cancer patient and would not have been able to find my grandmother’s cause of death had the changes been in place. I implore you to not to make the proposed rule change. Thank you.

Robert Lazell Tue, 10/24/17 - 9:41 As a resident of NY I would like to encourage the Department of Health to reject the call to extend the restriction to public access to birth and death records to 125 and 75 years respectively. This is a completely inappropriate reaction to the cited issue of "identity theft" and would do little to combat it as identity theft is based largely on theft of social security numbers, bank information and a myriad of secure records NOT birth and death records. As a genealogist and historian this would greatly hamper my work as well as many others. Given the increasing interest in ancestry and family history over the past decade or so (I cite as evidence popular TV programs such as PBS's Finding Your Roots) I believe this would negativity impact the public you serve and provide little of no added protection against identity theft.

Chris Klemmer Tue, 10/24/17 - 9:46 I oppose the proposed restrictions. Being Brooklyn born as my parents and grandparents before me, New York City has a special place in my heart, something I would like to pass on to my children and future generations. Researching my family history is an integral part of sharing my heritage and family lore. It disturbs me greatly that The City would propose breaking that chain of continuity by restricting access to vital records. Isolating me and my descendants from our heritage in the name of "privacy" is, in my opinion immoral and just plain wrong.

Laurie Downs Tue, 10/24/17 - 9:46 I'm against changing to 125 years.I do family history and these records help in proving who what where and when.

lauren manera Tue, 10/24/17 - 9:47 As a private genealogist with deep New England and New York roots, I strenuously object to these vital statistic records being out of reach of researchers. I believe it is in everyone's best interest to allow these records to remain accessible to researchers, professional or amateur. They are important documents, historical and legal, and must remain open to the public.

Nan Starjak Tue, 10/24/17 - 9:50 As a long-time family historian with many ancestors from New York -- including NYC -- I strongly oppose this measure. New York is already a difficult state in which to research. This rule presents no solid facts to justify withholding family records even longer than they curretnly are.

Tamar Weinberg Tue, 10/24/17 - 9:56 I have been trying for hours, weeks, days, YEARS to learn of my family's history. My family made it to Ellis Island after rough times being persecuted in their home countries. Records there are sparse. Getting NYC records is the only way I can learn of my history, and there is still so much to learn. Relinquishing our access to our great-great grandparents' records would be beyond devastating.

Cindy Burtt Tue, 10/24/17 - 10:00 I think this is a terrible idea and detriment to those who need this information for their family history research. Please Please reconsider these very long time spans and how many of us who will be negatively affected. My whole family immigrated to New York in the early 1900s and without these records my link to my family history will be gone. It's so unfair.

Patrick Deady Tue, 10/24/17 - 10:13 I use the birth and death records of NYC in the preparation of family trees for my clients and myself. I believe that the proposed rule is not necessary as it is an unnecessarily restrictive rule and will do nothing substantive to protect privacy. None of the birth certificates that appear on the index or are available publicly have social security numbers on them. This is the primary method of identifying people in our society today! Therefore, this proposed rule will not really do what you say it will as far as privacy is concerned! As far as death certificates go, these also could easily be redacted to remove the SSN when they are posted. This is just an incredibly restrictive rule that has not been well thought out and should not be implemented!!

Pat Grabowski Tue, 10/24/17 - 10:14 As a lifelong New Yorker and family researcher, I strongly oppose the proposed rules regarding New York City vital records. Restricting access to these records would cause much difficulty for those researching their family history. As it is, there are many people who are not listed in census or other records. The only trace of them may be their birth and death records. Having to wait 125 years to get their information means that they may never be found. Most people looking for this information are family members of the deceased. Their motives are honest, not criminal. Our rights to our own family records should be honored, not restricted.

Mary Lish Tue, 10/24/17 - 10:16 As a researcher, I completely oppose these new rule changes. Other states have posted their vital statistics on-line almost immediately and have not had "catastrophic" results from people learning their grandparents maiden names. These records are owned by the people, not by City workers. Sunshine produces better results. I would suggest opening the records earlier rather than hiding them away past anyone's lifetime. Stop this ridiculous change. If anything, change it to be open earlier.

Edward Creem Tue, 10/24/17 - 10:17 There must be a reason other than those contained in the proposed rules to extend the time periods for release of birth and death records. Every bit of personal information, the proposed rules claim to be trying to protect, is readily available for most people through a simple google search. As a serious genealogy researcher for more than 20 years, these rules seem draconian compared to other governmental entities. I am of Irish descent and many of my ancestors lived and died in New York City or were born in New York City. These proposed rules would have seriously hampered my past research and if implemented will be a serious detriment to future research. Let me put it this way with regard to death records. If someone dies today in New York City, I can often find virtually all of the information that would be contained in their death record, in a Newspaper Obituary tomorrow. Same for someone who died 10, 20, 30 or more years ago. So why are you proposing to release "official" information on a person's death until 75 years after they are gone when "Unofficial" information of the same nature is readily available in the public domain? And there has to be a better way of protecting the birth records for the handful of City residents who live beyond 100 years, than a 125 year waiting period from the date of birth. For researchers, it often times is the birth records for relatives who died in childhood or early adulthood that are being sought. I could be dead myself before records I need would become available. Sounds like using an atomic bomb to kill an ant, if you ask me. Therefore, I urge you in the strongest terms to scrap this proposed rule which appears to me to be a solution to a problem that does not exist. Thank You.

KATHERINE MARIE FISH KIERSZTYN Tue, 10/24/17 - 10:18 Katherine Marie Kiersztyn born August 4, 1965, St Joseph's Hospital, Syracuse New York. Born to Helen Kiersztyn, Biological Father's first Name "David." Adopted by Elmer Moses Fish, May 1970, (Deceased January 1971). Brother Simon Thomas Kiersztyn born June 29, 1966, (adopted name "Fish"). Who is "David?" and What is his Last Name?

Lindsey Ottman Tue, 10/24/17 - 10:19 As a Native New Yorker and professional genealogist based in New York City, I strongly oppose the proposed restrictions and would like to respectfully suggest that New York City follow the same guidelines established by New York State. Lindsey M. Ottman, Ottman Research Services, LLC

Barbara Mathews Tue, 10/24/17 - 10:20 The proposed rule states, in the section on Model State Vital Statistics Act and Regulations (2011 Revision), that, "Now in its sixth revision, the Model Law is a cooperative effort among state governments and the federal National Center for Health Statistics of the Centers for Disease Control and Prevention." This is untrue. This is a misrepresentation. This is a statement that the Department must know to be untrue. The last Model Act that went through a review by all of its stakeholders -- the last Model Act that was approved by the Centers for Disease Control -- was the 1992 Model Act. That model act received review by stakeholders, including not just vital statistics registrars but also personnel from the CDC and genealogists. The 2011 Model Act was never reviewed by the CDC. It was promulgated by the National Association for Public Health Statistics and Information Systems (NAPHSIS) but never reviewed by the CDC. Only NAPHSIS has approved it. To state that it was a cooperative effort that included the CDC is to be disingenuous. In fact, after the CDC refused to consider the 2011 version of the model act, NAPHSIS took time to discuss this prior to making the decision to release the text on its own. Steven Schwartz again, the New York City Registrar, is a member of NAPHSIS and knows that the statement that the 2011 Model Act was accepted by the CDC is untrue. What is missing from the 2011 Model Act is review and input from stakeholders. The value of the records is determined by the stakeholders. The keepers of the records are there to implement the wishes of the taxpayers and stakeholders. This seems to be an idea that so far is foreign to the department. Do not continue this errant policy. The rest of the argument on behalf of longer closure periods for records skates as far from the facts as this item does. Yours, Barbara Mathews

Joe Carpenter Tue, 10/24/17 - 10:22 I oppose the proposed rules. While attempting to thwart crime is seemingly at the root of this rule change, the proposed changes impact law abiding citizens to a far greater degree than potential criminals. There are other ways to prevent criminals from misusing these critical databases. Please do not institute these proposed rules. I would much rather see an analysis of the average wait time for across all municipalities in the US and see NYC consider coming into line with the average / median of that data set, and not just look at the average age of NYC citizens.

K. Desmond Tue, 10/24/17 - 10:23 Genealogy is an enormously popular pastime. Millions of Americans are very interested in discovering their New York City roots. The Proposed Rules would impact genealogy researchers very adversely. It is already somewhat burdensome to research and request birth, marriage, and death records from Municipal Archives. Please do not make the process more difficult.

Catherine Dente Tue, 10/24/17 - 10:24 As a citizen, I recognize that criminals are trying everything possible to steal personal information. Though the intent of the 125 year rule being proposed shows your heart is in the right place, the info you are proposing to protect is easily available in all sorts of other ways to criminals. Meantime, you would be overly restricting the right of law-abiding citizens to access public records. Please do NOT approve the amendment to article 207. I am a genealogist, born in NYC, and am really upset by your proposal.

Carla Garner Tue, 10/24/17 - 10:28 Hello, I am opposed to the unnecessarily extended length of time for New York birth and death records to be transferred. As others have commented here, "What would be the point of not providing unofficial copies of documents, when so much other personal information is already widely available online without restriction?" There are other more pro-active ways to provide records security besides limiting access. Thank you Carla Garner

Nathan Schachtman Tue, 10/24/17 - 10:29 The Department claims that its proposed schedules balance the needs of living people with the public’s rights of access to information, but the Department provides no support for its hypothetical concerns about identity theft. In particular, the Department has advanced no empirical evidence about identity theft rates in jurisdictions with open as opposed to jurisdictions with closed records. Without actual data, the Department’s claimed concerns are actually worse than hypothetical; they are conjecture conjured to defeat legitimate rights of families to their own identity and historical information. The absence of foundational facts and rigorous analysis renders this proposed rule irrational and a violation of the state and federal constitution. In addition to the reasons urged by others in opposition to this regressive proposed rule, I urge the City to reject it.

Anne Gallagher Tue, 10/24/17 - 10:31 I feel the 125/75 year restriction is onerous. In Pennsylvania, we use 105/50, which has proven to be hugely beneficial to genealogists, while still protecting privacy. My ancestors came to NYC from Ireland, and it would be so awesome to find some (any!) records for them! Thanks for your consideration.

Gary Jones Tue, 10/24/17 - 10:31 Please do not impose the strict new rules that you are considering. I live in New York and have taught genealogy for years and find that NYS is one of the most restrictive states when it comes to vital statistics. Please don’t make these records even more so.

Jennifer Mendelsohn Tue, 10/24/17 - 10:37 Dear Commission Members, As a genealogist with deep New York City roots, I strongly object to the proposed rules regarding access to public birth and death records of New York City. Access to these original materials are critical and essential for our work. The proposed restrictions would create an excessive interference for myself and my fellow members seeking to trace their families within New York City’s vital records. We ask that the commission consider the following guidelines for access to public records, namely:  Access to birth records after 75 years (if the individual’s death can be verified) or 105 years if no death date is verified.  Access to death records after 50 years; or after 25 years to registered members of a New York genealogical society.  Access to the index to death records after 25 years (providing the name, date of death, place of death, date of birth, and burial/cremation information). Beyond genealogical research, many of our peers and colleagues require access to these records when tracing medical histories within their family—specifically those related to genetically inherited diseases. Access to these records is essential for those seeking to understand and treat medical conditions. Therefore, we ask that you consider creating an informational copy of birth and death records, which could not prove identity for financial and other transactions, but would instead provide the information necessary for researchers. Thank you for your attention to this important matter. Sincere regards, Jennifer Mendelsohn

Ron Schnell Tue, 10/24/17 - 10:41 We New Yorkers deserve rights to access our records. These changes must not be adopted, as they infringe on our Rights. As someone who is researching my family, I need access to these records.

James Tanner Tue, 10/24/17 - 10:44 As a practicing trial attorney for 39 years and a genealogist for more than 35 years, I am deeply concerned about the changes in the General Vital Statistics Provisions (Article 207 of the NYC Health Code) regarding Birth and Death Records. Both the proposed time periods for death and birth records are unnecessarily excessive. The general references in the supporting information to "privacy" concerns and possible instances of identity theft are totally unsupported by either facts or reality. All of the information contained in both birth and death records is easily obtainable from presently available public records online. As an attorney, for a very small fee, I could obtain the information available in both birth and death records from multiple online companies who specialize in supplying such information. For example, most doctor's offices require much more information than is supplied by either certificate to obtain the services of a doctor. Targeting these two records serves no purposes. Restricting the availability of death records such as the recent restrictions on the availability of the Social Security Death Index, in fact, opens more opportunities for fraud rather than restricting such actions. Extending the time periods and adding restrictions to these particular records is motivated by the desire of the government agencies to enhance a revenue stream obtained from selling copies of these records to family members who are required to provide these documents for a variety of purposes. I see no reasons for extending the time periods for either of the two types of records.

Harriet Simons Tue, 10/24/17 - 10:49 I am the senior member of a family with branches that lived in New York for up to 5 generations. I am also the person who does the genealogy research for all branches of the family. The proposed changes to the rules are absolutely unnecessary and obstructive. In fact I believe even the current rules impose a barrier to legitimate and important research. I understand the necessity to protect living persons but I believe that there should be access to records no later than 10 years after death. I would agree that a 10 year rule might be modified to access to only those showing a legitimate reason by way of registration for each person/family to be researched.

Karen Hergenrider Tue, 10/24/17 - 10:54 This proposal seems to be fear mongering with the addition of the "feel good" because we NYers (even expats, like me) are living longer. My own relatives in NYC never had obituaries, funeral home notices were considered suspect. Someone will know that the house is empty! Just this week, thousands posted a meme on FaceBook that contained their ancestors' surnames and maiden names for most of the FB world to see. What is the first security question the bank usually asks? Fearless! The federal government (SSDI) and many states (TX, CA, NV, IN, WA, OH, etc. . .) have had current/recent vital records available on-line for years. Both indexes and scanned documents are freely and readily accessible. Has this caused an uptick in identity theft? Probably not. Anyone with internet access, anywhere in the world can search any name. Dozens of databases exist with information on those who do not fly completely under the radar. As someone who has researched local history and genealogy for 20+ years, I beg you to take a look at what a step backward this really is. Thank you.

Antonia Annecchiarico Tue, 10/24/17 - 10:59 I strongly oppose “Proposed Amendment to General Vital Statistics Provisions (Article 207 of the NYC Health Code) regarding Birth and Death Records”. This proposed amendment unnecessarily impedes legitimate research without substantiating the underlying premise. The offered evidence for proposing these restrictions on NYC birth and death records is confusing. The offered evidence refers to “New Yorkers” vs. NYC residents. So, which is it? Will this proposed amendment apply to the entire state or only to NYC? Other than the 2010 census, I would be interested in the statistical proof that prompted the “Proposed Amendment to General Vital Statistics Provisions (Article 207 of the NYC Health Code) regarding Birth and Death Records”. This proposed amendment suggests the authors believe the general population will regularly live up to and perhaps beyond 125 years. Where is the actuarial evidence to sufficiently establish this theory? According to the 2010 census, centenarians made up less than one half percent (0.45%) of the NY(C) population. In 2015 the American Community Survey stated that 901 New Yorkers (presumably NYC) died at age 100 or higher. What percentage of total population in 2015 does that number represent? Where is the evidence that supports the premise that persons “protected” by this amendment are or will be targets of identity theft? How did the authors arrive at the 75-year moratorium on death certificates? Again, where is the available information validating the belief that identity theft is the underlying reason for imposing a 75-year waiting period? How many people in the “protected” age brackets were actually victims of identity theft? Given today’s technological advances and data available in the public domain, the proposed amendment does virtually nothing to protect individual confidentiality/privacy concerns. An overhaul of record-keeping protocols might better serve the public and allow legitimate researchers access to important research data. Let me reiterate, I strongly oppose “Proposed Amendment to General Vital Statistics Provisions (Article 207 of the NYC Health Code) regarding Birth and Death Records”.

Michoel Ronn Tue, 10/24/17 - 11:01 I am a New York State resident and I strongly oppose the proposed restriction on public access to public birth and death records for 125 and 75 years, respectively. These proposed limits are stricter than those in place in almost any other jurisdiction in America.

Stephanie Murray Tue, 10/24/17 - 11:03 I am also a family historian/amateur genealogist and I believe that the proposed waiting periods are ridiculously excessive. I do not believe that any damage results by allowing genealogists and/or others doing family research to have access to these documents. Please do not adopt these proposed rules.

Bob Bashford Tue, 10/24/17 - 11:04 This proposal is much too restrictive. Approving it would be a TRAGEDY for family historians..

Pat Finnegan Tue, 10/24/17 - 11:06 I am adamantly opposed to the proposed changes regarding the birth and death records. The extension of the years needed to view these records is totally unnecessary, does nothing to extend privacy to those whose records are being sought and seeks to create a greater barrier to those wishing to learn about their own family history - a right to which they should be entitled.

Sean DALY Tue, 10/24/17 - 11:12 I am a native New Yorker who returned to NYC this year after many years abroad. I began researching my father's family six months ago, about which I had little information: he passed away with Alzheimer's years ago and himself knew little about his grandparents, as his parents were deaf-mutes. He had passed two handwritten documents to me, from his mother and an aunt, which had inconsistencies (and errors and omissions, as I have discovered). With the assistance of the NYC Municipal Archives and the National Archives office at Bowling Green, as well as the staffs of Holy Cross and Calvary cemeteries, and of course genealogy services (FamilySearch, Ancestry, & FindMyPast), I have succeeded in identifying nearly all of my family members who emigrated from Ireland to New York in the mid to late 19th century. My research has also located two previously unknown cousins my age, both of whom possess photographs I had never seen of my great-grandfather, grandparents, and my father, aunts and uncles in their youths. One of these cousins had not even known who these relatives in the photo were, and was thrilled to learn their stories. Under the proposed rule, this research (which is of great interest to over two dozen of my cousins throughout the USA as well as my mother and siblings) would be far more difficult if not impossible. The birth records of my grandparents and great aunts and uncles born in NYC would be sealed. So would the birth records of cousins of my grandparents, for example a WWII Airborne veteran buried in Arlington who died during the Korean War. I realize the rule would not apply to previously released records, however even recent records have been very useful for me. For example, my grandmother and her sister had a great feud in the 1930s which greatly affected my father's family (they were evicted from their home). My research turned up a distant cousin from Ireland who emigrated in 1925, staying at first with my great aunt; she married in NYC in 1927 and from there, I found her daughter's marriage in NYC in 1955, and I am close to finding her son my age somewhere in the West - a person who called my first cousin ten years ago trying to learn about the family. This cousin could help me understand what happened all those years ago. Records of the Catholic churches in NYC are precise and informative, but quite difficult to find, as there is no central index. The federal and state censuses, cross-checked with the NYC municipal vital records, have allowed me to identify the relevant parishes, where I have research requests underway. I fear that the proposed rule will make this already difficult process extremely difficult, and with only marginal benefit. Identity theft is a real problem, but can be better fought with modern data processing. For example, efforts could be made to reconcile death records to birth records, allowing alerts to be raised if the foundational birth record of a dead person is used to obtain other ID.

Sheila Benedict Tue, 10/24/17 - 11:15 New York City already has some of the most restrictive privacy rules of any other part of the USA. For me, as a professional genealogist, it is difficult to retrieve important documents my clients need and want. I respect the argument for privacy but the proposed rule changes are far and away the most damaging to our profession as well as to people legitimately needing vital records from New York City. Please do not adopt these proposed changes.

Sean DALY Tue, 10/24/17 - 11:20 I am a native New Yorker who returned to NYC this year after many years abroad. I began researching my father's family, about which I had little information: he passed away with Alzheimer's years ago and himself knew little about his grandparents, as his parents were deaf-mutes. He had passed two handwritten documents to me, from his mother and an aunt, which had inconsistencies (and errors and omissions, as I have discovered). With the assistance of the NYC Municipal Archives and the National Archives office at Bowling Green, as well as the staffs of Holy Cross and Calvary cemeteries, and of course genealogy services (FamilySearch, Ancestry, & FindMyPast), I have succeeded in identifying nearly all of my family members who emigrated from Ireland to New York in the mid to late 19th century. My research has also located two previously unknown cousins my age, both of whom possess photographs I had never seen of my great-grandfather, grandparents, and my father, aunts and uncles in their youths. One of these cousins had not even known who these relatives in the photo were, and was thrilled to learn their stories. Under the proposed rule, this research (which is of great interest to over two dozen cousins throughout the USA as well as my mother and siblings) would be far more difficult if not impossible. The birth records of my grandparents and great aunts and uncles born in NYC would be sealed. So would the birth records of cousins of my grandparents, for example a WWII Airborne veteran buried in Arlington who died during the Korean War. I realize the rule would not apply to previously released records, however even recent records have been very useful for me. For example, my grandmother and her sister had a great feud in the 1930s which greatly affected my father's family (they were evicted from their home). My research turned up a distant cousin from Ireland who emigrated in 1925, staying at first with my great aunt; she married in NYC in 1927 and from there, I found her daughter's marriage in NYC in 1955, and I am close to finding her son my age somewhere in the West - a person who called my first cousin ten years ago trying to learn about the family. This cousin could help me understand what happened all those years ago. Records of the Catholic churches in NYC are precise and informative, but quite difficult to find, as there is no central index. The federal and state censuses, cross-checked with the NYC municipal vital records, have allowed me to identify the relevant parishes, where I have research requests underway. I fear that the proposed rule will make this already difficult process extremely difficult, and with only marginal benefit. Identity theft is a real problem, but can be better fought with modern data processing. For example, efforts could be made to reconcile death records to birth records, allowing alerts to be raised if the foundational birth record of a dead person is used to obtain other ID.

Adam Gelman Tue, 10/24/17 - 11:27 I am wholeheartedly opposed to the Proposed Amendment to General Vital Statistics Provisions (Article 207). As a historian and genealogist, I find myself searching and utilizing the NYC birth and death record collections almost on a weekly basis. The information found in these records is critical for historical scholarship and genealogical research and can often be found nowhere else. These record collections are already severely restricted in NYC (much more than most U.S. jurisdictions), so any further restrictions sound ludicrous. I understand the fear of identity theft and the transfer of “personal” information to the public, but the claim that these records in some way pose a threat to the identify of living persons is baseless and unfounded. The 50-year confidentiality period for deaths and a 75- or 100-year confidentiality period for births seems more than adequate to me. Again, I vehemently oppose this proposed amendment and sincerely urge the NYC Department of Health and Mental Hygiene to reject it.

Steven Wiezbicki Tue, 10/24/17 - 11:32 Please don't restrict access to these records. Genealogy is the biggest hobby in America. Most immigrants entered the U.S. via New York. A lot of them lived there. How can we find out our ancestry without this resource?

Alicia Weiss Tue, 10/24/17 - 11:33 These rules would have a devastating impact upon genealogists and others who wish to gain reliable information about their families. As someone who lost most of their family in the Holocaust, the ability to trace my existing family through the records of those who came to America and survived is extremely important. Knowledge of one's family is a birthright; please do not restrict those of us with legitimate reasons for accessing these records from doing so within out lifetimes. This is especially important to those of us who are no longer young and cannot wait another 50 years. Thank you

Elisabeth Wellington Tue, 10/24/17 - 11:42 I live in Iowa but my entire family history traces back to NYC. These are people I have never known. I am a law-abiding citizen of this country and these rules are limiting me to be able to trace "my roots". Family history is important and everyone should know where they come from. The significant rule changes will limit that ability. Don't stop people from being able to learn who they are and where they come from.

Mary Ann Mooney Tue, 10/24/17 - 11:45 I would not have bee able to find my family female deaths from breast cancer if your proposed rules were currently being enforced. I have told my physician about this history and she treats me as being in a high risk category. The persons whose lives are shamefully affected are adoptees searching for their family members. Not only are you denying them the information you have on your family, you are denying them their basic medical history and negatively impacting their basic rights to proper medical treatment. This tightening up of year restrictions is not considered legally required in the rest of New York State. You should strongly consider adopting the New York State restrictions which are working well for millions of out-of-City New York Staters. You may want to add a small stamp on the non-certified certificates, stating "not certified." Please do not use a stamp that obliterates most of the data on the form.

Helen Keating Tue, 10/24/17 - 11:49 Please keep all historical vital records available to the public...they are valuable resources for those seeking historical records for genealogy purposes.

Karla Huebner Tue, 10/24/17 - 11:54 I request that the proposed time periods limiting access to New York birth and death records be reconsidered. While I appreciate the desire to protect privacy of living persons, this proposal goes much too far. The general public benefits from reasonable access to family history and health data, while identity thieves have shown that they (unlike the general public) are quite capable of hacking into insurance and financial databases to steal massive amounts of personal data. Thank you in advance for your attention to our comments. Karla Huebner

Carol Fisher Tue, 10/24/17 - 11:55 NewYork vital records are essential to those tracing their lineage. Please, Please do not close these records to us. My family lineage is all from New York state, and dates to 1630. My family members will be at a loss to research without the records you retain. We just experienced the addition to our family a cousin and brother (current age 70) who had been adopted at birth in New York, and was registered as adopted in New Jersey. thanks to his efforts, the law regarding adoption records opening in Jan 2018. We never would have known of this wonderful man and family member without this release of records. Please Please do not close us off our family history.

Catherine Negrycz Tue, 10/24/17 - 12:03 I think the proposed new rules increasing the time periods are excessive and far exceed other state and cities time frames. The living have a right to know about their ancestors, and not only direct ancestors, but those that are related like aunts, uncles, cousins, etc. It is part of a person's own history, something that is important to people today. Even young school children ask questions now. My own generation, I'm 74, did not ask questions, which was considered impolite, but we lost so much knowledge of our backgrounds because of this. We can build our story, our history with access to records such as birth, marriage and death. In the cases of fraud, why punish the many because of the few.

J Adams Tue, 10/24/17 - 12:14 I oppose your making access to birth and death records more restrictive. The timeframes are way too restrictive. Access to vital records rarely cause identity theft. Look at how other states handle their records. Perhaps you need to do some research in the matter before making unnecessary rules. People need to access their family records for family history research and family medical research. Do not fix what is not broken.

Ed Howard Tue, 10/24/17 - 12:15 Even the Federal Census bureau has a less restrictive view of our family records than the proposed changes. As most people in my family have arrived in NY and chose to live there or across the river in NJ I find that not being able to see their records which will lead to their lineage is excessively restrictive and basically unnecessary. Most identity theft will not occur by searching these records. If i were to search the web I know I will find people who have my SS number and other personal data. As a matter of fact while trying to find a friend of mine I found more personal history than you are trying to "protect". Please leave the rules the same or if anything make them less restrictive. Thank you for having this forum available.

Caroline Shultz Tue, 10/24/17 - 12:17 I strongly oppose this provision. I believe personal information is adequately protected by the current regulation. The only result from this provision, if passed, would be to keep historical and medical information locked away from legitimate historians and researchers. The amount of time in the proposal does not make sense, as most of the information can be found publicly already... Dates of birth are listed in other public records. Dates of death and location are released by Social Security after 3 years. DO NOT PASS this proposal to amend Article 207.

Ya'akovah (Jamie) Weber Tue, 10/24/17 - 12:31 PLEASE do not change the rules concerning availability of old birth and death (etc.) records! Genealogy research is challenging enough, without the government making it even worse! If this proposal is carried out, G-d forbid, it would limit the ability of anyone, even perfectly law-abiding genealogists, to gain access to old New York City vital records. These proposed rules are stricter than almost anywhere else in America, and would be devastating to anyone researching New York City ancestors or collateral lines. Imposing these restrictions is like locking up my relatives in a dungeon, only to be seen by far, far removed generations who may not have enough information to know to look for them in the first place! This info. should not only be available, but it should be available ONLINE, like many other cities' records of this sort! I have made the trip by subway from my home in Brooklyn, to look at the microfilms. Please don't take this away from those generations whose families have only lived in America for 100 years or less! I am a resident of Brooklyn for almost 20 years now, AND I VOTE! Thank you.

Bobbie Sue Daitch Tue, 10/24/17 - 12:39 Regarding: Proposed Amendment to General Vital Statistics Provisions (Article 207 of the NYC Health Code) regarding Birth and Death Records, there is NO reason to make this change. Use your employees to make records available to those of us who are looking for our family history. Stop wasting taxpayer money to write more restrictive rules. WE WANT ACCESS! Thank you!

Tony Mc Carthy Tue, 10/24/17 - 12:41 I am a genealogist based in Ireland and I believe that the proposed restrictions on the availability of Birth and death certificates is excessive and unecessary. The proposeals are not in keeping with those existings in most western societies.

Jane Barber Tue, 10/24/17 - 12:48 I strongly oppose the proposed changes to Vital record availability These proposed changes would impose a real hardship on those of us who are researching our families' histories.

Richard Getz Tue, 10/24/17 - 12:51 Please do not pass the unnecessarily strict proposed guidelines. I am an amateur genealogist and agree with other comments that there is value in accessing records for historical reasons and they are becoming increasingly valuable for medical reasons. I believe a better balance between security and historical value would be to match New York State's existing guidelines of - Birth certificates - if on file for at least 75 years and the person whose name is on the birth certificate is known to be deceased - Death certificates - if on file for at least 50 years - Marriage certificates - if on file for at least 50 years and both spouses are known to be deceased

Margaret McMahon Tue, 10/24/17 - 12:52 I strongly oppose these new rules. These proposed rules are unrealistically strong and stricter than almost anywhere else in America. They would be devastating for legitimate researchers.

Nicole DeRise Tue, 10/24/17 - 12:52 I strongly oppose the proposed amendment to limit access to birth and death records. As a historian, this proposal will severely limit my ability to conduct research and add to the historical canon. History and the associated primary sources are essential in helping NYC'ers and Americans identify who they are. These records help us think critically by making us assess and contextualize, and, ultimately, make us more engaged citizens, citizens who know where we come from and how. Additionally, we cannot ignore that vital records have applications and implications across legal and medical landscapes. Limiting access to vital records is not going to solve the problem of identity theft, and it is naive to think so.

Bruce Schoenberg Tue, 10/24/17 - 13:05 As a lawyer and amateur genealogist, I rely on access to birth and death certificates to do research. These records are also necessary for legal purposes, including proving heir-ship for inheritance purposes. There is a great deal of personal information regarding individuals already available on line, including dates of birth and social security numbers, and keeping vital records secret will not appreciably reduce the risk of identity theft. These records have been open for years, and I have not heard of an epidemic of identity theft using vital records -- you are much more likely to have your identity stolen due to a credit card data breach. This seems like a solution to a nonexistent problem. If any type of rule is adopted, there is certainly no reason to protect death records, as there is no privacy interest after death. I urge you not to adopt the proposed rule. If any new restrictions on access to public records are imposed, I urge you to include exceptions for the purpose of legal and genealogical research. Respectfully submitted, Bruce Schoenberg

Stephanie Ray Tue, 10/24/17 - 13:06 New York is not just another municipality... it is the prime port of emigration for millions upon millions of future U.S. citizens. While the urge to prevent "ghosting" is certainly admirable, the use of the stamp "For Informational Purposes Only" is sufficient for that purpose, and there are very effective tools available to monitor one's credit. New York is too important to too many people to allow further restrictions of information. What is the point of collecting the information if it is not available to use?

Jean Moore Tue, 10/24/17 - 13:10 I, too, am strongly against changing the rules for vital records access. Please check with other states that are more genealogically friendly -- like Ohio and California and Nevada. There is no good reason to keep the vital records of NYC private for so long. Family history research is important to so many people and needs to be as accessible as possible. Thank you for your consideration.

John de Jong Tue, 10/24/17 - 13:17 RE: Amendment to Provisions of Article 207 of New York City Health Code Regarding Proposed Transfer Schedule of Birth and Death Records to DORIS I am writing this letter in consultation with our Chief Genealogical Officer, David Rencher, to inform you that FamilySearch International is very concerned about the proposed changes for access to birth and death records as proposed by the New York City Department of Health and Mental Hygiene. Please review the attached for our recommendation. thank you, John de Jong, AG®* North America Field Relations Manager FamilySearch International Email: jdejong@familysearch.org

Karen Horn-Jansen Tue, 10/24/17 - 13:23 I am a family historian/genealogist and I am utterly disappointed and concerned that the proposed waiting periods are inappropriately and unnecessarily overly cautious. I am a native New Yorker and so is my husband. His family has roots in the NYC area for the past few generations and so I rely on NYC records to research his family history which is also the family history of our children. I do not believe that any damage results by allowing genealogists and/or others doing family research to have access to these documents.

Kim Cotton Tue, 10/24/17 - 13:34 I strongly oppose the proposed rule restricting vital records. Restricting these records not only makes it difficult for people to trace their family medical history, but also keeps them from appreciating their own connection to New York. As a professional genealogist, access to original records are necessary and critical to my work, which includes helping to connect people to their roots — roots which often pass through New York for days or decades. Please reconsider reducing access to these important records. I stand with the New York Genealogical and Biographical Society in their call to consider a shorter restriction period for the public and to allow access sooner to members of NY genealogical societies, if some additional restriction is truly warranted. Thank you for your consideration in this matter.

Cara Berkowitz Tue, 10/24/17 - 13:36 I am an New York City resident and my family has lived across NYC for decades. Having access to vital records has been instrumental in my family research and are a great resource for the public. I am grateful to have the ability to obtain these records and making them more difficult to access will impede New Yorkers like me that one to learn more about their own family history and track down loved ones. Protecting citizens from fraud is important but given so much personal data exists online, locking up older records seems like an unhelpful and impractical solution that will do more harm than good.

Meredith Sellers Tue, 10/24/17 - 13:36 I oppose the proposed amendment to the general vital statistics provisions. As a genealogist, I believe the proposed schedules for making these records public and transferring them to DORIS are excessively long.

JAMES BOOTH Tue, 10/24/17 - 13:42 I am writing to state my opposition to the proposed rules to restrict access to Birth Certificates until they reach 125 years and Death Certificates until they reach 75 years. While I am supportive of plans to begin turning over older records to the NYC Municipal Archives, I find these age limits to be highly restrictive and a hindrance to those of us who research their family history. We all share the need to ensure that the identity of individuals is secure, I believe there are ways in which we can keep records open and also protect the identity of those who were born and died in the City of New York. I have therefore put together some ideas about how we may be able to do both. My proposal would be as follows: Birth Certificates: Birth Certificates would be kept by NYCDOH for 100 years. Up until 100 years, birth records can only be accessed by the individual on the record, parent of the individual, and the spouse of the individual, if the person on the record is still alive. If the person is deceased, and the death can be proven, the record would be available to anyone with a blood relation to the person on the record. After 100 years, the records are then turned over to the NYC Municipal Archives. To protect the identities of any individuals who may still be alive, the NYC Municipal Archives would not certify any record less than 125 years old and the record would be stamped conspicuously with a stamp stating "For Genealogical Use Only." This would prevent the record from being used in any official capacity that would result in identity theft. A certified copy could be made available to anyone eligible as if the record were less than 100 years old. (Using same standards as above). At 125 years, all records could be certified by the NYC Municipal Archives. Death Certificates: Death Certificates would be kept by the NYCDOH for 60 years. A certified copy would be available to the child of the deceased, parents of the deceased, siblings of the deceased, grandchild of the deceased, or anyone with a legitimate right to the record for estate purposes. After 60 years, the records would be turned over to the NYC Municipal Archives. I do not see a reason beyond 60 years for any additional restrictions. Therefore, NYC Municipal Archives would certify any death record it issues. I would ask that the City of New York consider these proposals as a compromise to allow researchers to continue to have access to most of the records they have access to now, while also counterbalancing the need for greater identity security. Thank you for your time and attention to this matter. James Booth Westtown, Orange County, New York jbooth75@optonline.net 845.492.6255

Donald G Wilson Tue, 10/24/17 - 13:48 This records access is more restrictive than the restrictions required by the State. Although I now reside in the State of Washington, my ancestry is extensively in New York City. My research depends on access to NYC vital records information. Should these more restrictive dates be enacted, please at least consider providing index access to these events after the present access dates. For death, the index information would include decedent's name, date of death, place of death, parents names, and disposition (cemetery name), and perhaps certificate number. For birth, name of individual, place of birth, date of birth, and mother's name, and perhaps a certificate number. Access to this information would at least mitigate for genealogists and researchers the overly restrictive time periods proposed.

Nancy Bateman Tue, 10/24/17 - 13:50 Most of my family started out in this country in New York City. I am a amateur genealogist, and I am in agreement with the 125 year schedule for making a birth record public, but I would favor a 50 instead of a 75 year schedule for making a death record public.

Steven Lally Tue, 10/24/17 - 13:56 Making access to birth and death records more restrictive is unnecessary. I concur with the many points already mentioned in this comment section. I am a researcher who has worked on my own genealogy and that of others, in addition to using the currently available records for historic research. My family has lived in all five boroughs at one time or another over the past 184 years. I have been a resident of Brooklyn for the past 20 years, and I lived in Manhattan before that.

Matthew Ladd Tue, 10/24/17 - 14:17 I urge you to reconsider the proposed rule. I travel to New York once or twice a year and always make a point to visit the Municipal Archives to research my family's history with the vital records. The current New York State Department of Health rules for making vital records public are a good balance between privacy concerns and providing access for legitimate purposes. I suggest that the New York City DOHMH adopt a similar protocol for its records. Thank you for your consideration.

Virginia Roarabaugh Tue, 10/24/17 - 14:22 As a family historian, and generally a believer in freedom of information, I strongly object to limiting the birth and death records. The restrictions are stringent enough as they exist, and this only puts a hardship on those of us trying to do legitimate research. I am sure there are ways to counter any illegal use of birth and death records other than making a limitation that impedes genealogical research.

Christine Angel-Wich Tue, 10/24/17 - 14:25 I am a former New Yorker who is totally opposed at this piece of legislation that NYC is attempting to put to a vote. I have to agree with the other comments that we are a country of immigrants and we should be allowed to have access to records of our ancestors/people to have gone before us for our personal interest as well as for the interest of others. It is a joke already that as an adoptee from NYS, that I have to wait 99 years in order to officially find out who my real parents were. I am 66 years old and it is about time that NYC and NYS move into the 21st century and allow this information to be public. And now you are trying to say that someone like me who would live in NYC would have to be 125 years old to find out info about their birth parents?? What planet are all you people living on?? Get your heads out of the sand and get rid of this ridiculous proposal. I am a novice on looking up ancestrial information and by you blocking all this stuff prohibits me from having access to information that could be vital for me. Look around you-- even NJ has gotten their heads out of the sand and have lifted these ancient laws.. And now you want to en-act new ones??? Get real !!!!!!! I sure hope that this proposal never becomes law...

Lisa McCole Tue, 10/24/17 - 14:34 Please DO NOT implement this proposed change. It will does not make sense to put in such restrictions to the access to birth and death records. I do not agree with this proposed change.

Judith Forbes Tue, 10/24/17 - 14:40 My husband's mother was born in 1916 and was adopted in NYC. We have the adoption papers but not the original birth certificate. She died, her biological parents are dead, her adoptive parents are dead. According to ur current and proposed rules we will be dead b4 her information is available. The current and proposed rules are way too restrictive to access information for genealogical purposes.

Mary Collins Tue, 10/24/17 - 15:01 I strongly oppose these Proposed Rules. I believe that the time period is excessive and not needed for security. It will be almost impossible to trace families in New York.

Irene Monley Tue, 10/24/17 - 15:06 As a genealogist whose family lived in New York City from the 1800's to the 21st century, the birth and death records that have been available on microfilm and online have been invaluable. For the insight to my family's history that those records have made possible, many thanks. I think that the proposed 125-year limit on birth records is too onerous. A 100-year rule would be adequate. Maintaining privacy is obviously of utmost importance. However, although you cite continuing improvements in longevity, in fact, those improvements are slipping. Just yesterday, Bloomberg reported that the Society of Actuaries found an increase in U.S. mortality from 2014 to 2015. This is likely not an anomaly, given the rollbacks in access to healthcare coverage and EPA regulations. The proposed 75-year rule for death records is appropriate. Thank you for the opportunity to comment.

Benjamin Milder Tue, 10/24/17 - 15:09 I am a New York City resident and I oppose this amendment. The proposed waiting periods are far too long and would keep public records from law-abiding New Yorkers for no good reason. It is not plausible that providing access to death certificates from the 1950s would create any meaningful risk of identity theft. In fact, access to such records could help the public combat identity theft.

Michael Carlson Tue, 10/24/17 - 15:18 I understand and sympathize with the argument made in the Statement of Basis and Purpose that because a handful of birth and death certificates may be modified, this may cause authenticity “confusion” and therefore require whole series of records to be withheld for a certain length of time. I think this is a minor concern. Probably most of the “pre-modified” certificates in the public space are those received by the individuals who subsequently proposed changes made to the certificates and perhaps close family relatives. Confusion can be mitigated through clear descriptions in catalogs and other finding aids. But I believe that the argument does not justify closing whole series of records for the length of time in the proposed rule.

Veronica Malmberg Tue, 10/24/17 - 15:21 Please reject this new model rule affecting the release of birth and death records. I am a native of NYC as were my parents and grandparents. I have spent many years tracing my family history but still have many gaps in my research. As other commenters have said there are many many examples of stolen identity data. Criminals do not need to go to the trouble of trying to obtain a birth or death certificate from the City of New York to get this data. Does NYC need to put up this roadblock to family history researchers? You mention amended birth and death certificates as an issue but the numbers appear to be very small compared to the total number of births and deaths. Perhaps more rigorous justification for amendment would work for you. Thank you for listening.

Rachel Silverman Tue, 10/24/17 - 15:31 As a professional genealogist based in NYC who specializes in immigrant populations, and as a tax-paying New Yorker, I strongly oppose the proposed restriction on public access to public birth and death records for 125 and 75 years, respectively. These proposed limits are stricter than those in place in almost any other jurisdiction in America, and are based only on the "2011 Model State Vital Statistics Act," which has not been passed by any legislative body or subject to any public comment. The proposed time restrictions are entirely arbitrary, based on exactly zero evidence. These rules will not only have a detrimental effect on my own livelihood, but on the family history/genealogy communities as a whole. It should go without saying that the City's income will also suffer as a result of the thousands fewer record copies that will be allowed if these rules are enacted. There is no evidence that limiting access to vital records reduces identity theft or improves public safety and privacy (on the contrary, there is some evidence that open access to public records deters identity theft). Enacting a 50-year embargo on death records and a 100 year embargo on birth records strikes a much better balance between privacy concerns and the need to access and use public records in a reasonable time frame. If changes must be made, I strongly encourage the City to adopt these more reasonable limits. But in truth, there has never before been a need to enact such restrictive policies, and there isn't a need now.

Linda Zolinsky Tue, 10/24/17 - 15:32 Please do not make any changes that would further restrict access to vital statistic records. As a genealogist and family researcher these records are imperative to read and study. As genealogist we know that these records will provide information that we cannot obtain elsewhere. Please understand that anyone wanting basic information to do harm can obtain that information in other places and sometimes online. Those of us that lives outside the state of New York but can trace our family to New York rely on these records. Thank you

Alec Ferretti Tue, 10/24/17 - 15:32 I recently applied for Dual Italian Citizenship. Descendants of Italian immigrants can be legally recognized as citizens if they fit certain criteria. I had to supply the birth, marriage, and death certificates of five generations of my ancestors, many of whom lived in New York City. Under the current law, I am not legally entitled to my grandfather John’s birth certificate. He was born 89 years ago, and has been deceased for 20. If my dad hadn’t been able to sign the form, I would have had to go to court. I could easily prove my relationship to him, we even have the same last name! Yet this didn’t matter. To get a simple birth certificate, I would have had to hire an attorney and go before a judge! It would have been so cost-prohibitive, I couldn’t have become an Italian citizen. But what about the oft-cited fact that the document itself can increase identity theft? Even if the information can be found from other means, doesn’t having the original certificate make it easier to steal someone’s identity? The answer as it turns out is a resounding NO! I went state by state and tabulated the policies for each and every department of health. There is almost no continuity. Some states, like Massachusetts, Connecticut, and California have almost no restrictions on their records. A relative can get any birth or death record they want, be it from the 19th century or last week. Others like Mississippi or West Virginia have some of the strictest restrictions in the country. Incidentally, not one state is as strict as that which New York City proposes. I then analyzed state by state the rates of identity theft published by the FTC and cross referenced the two data points. Theoretically, if access to vital records increased the likelihood of fraud, states with lax laws would have higher rates. As it turns out, they don’t. At all. I’ve plotted all the data out on this scatter plot: states with open records are on the left, stricter states are on the right. The Y axis represents the level of fraud. This line of best fit represents the level of correlation between the two, or in this case, the lack thereof. The slope of the line is nearly 0, meaning there is virtually no correlation. In fact, it slopes slightly upward, meaning stricter states have a slightly higher level of fraud. This entire proposal is based on an assumption, that in no way shape or form is factual.

John Dorman Tue, 10/24/17 - 15:33 While I am very sensitive to privacy concerns, I believe that the proposed restrictions are excessive and will unnecessarily handicap genealogists and others with legitimate need of the records. I believe that the current timelines and controls should be maintained.

Nancy Mumford Tue, 10/24/17 - 15:42 I strongly oppose the proposed Amendment. Genealogists MUST be allowed to access vital records, often the only source to trace family history, find family members or trace medical issues. Many other states offer options to genealogists such as issuing an "informational" copy of a record which is a perfectly reasonable alternative. We are far more at risk from hackers than from genealogists.

Victoria Boutilier Tue, 10/24/17 - 15:44 I am a lifelong resident, a taxpayer, a voter, and (soon) a parent of the City of New York. The proposed rules concerning access to New York City birth and death records are unreasonably extreme. More reasonable rules do not create a risk of "identity theft" because nobody is requesting for the right to obtain certified copies of the records of unrelated *living persons,* who have an identity to be stolen in the first place. And there are ways to release death records that omit, say, Social Security numbers, something that is common practice in other US States. The proposed rules, which are already being practiced, have hindered and will continue to hinder legitimate research. The rules will reduce tax revenue from professionals who rely on research for their income and reduce satisfaction in government by New York voters who have ancestry in New York. I would like to see the laws of the City of New York similar to that of the rest of New York State, for example, 75 years after the birth *if DEATH CAN BE PROVED* and 50 years for deaths. These regulations have hardly proved a disaster for the rest of the state. --Victoria Boutilier, Brooklyn, NY

FREDERICK KOLBRENER Tue, 10/24/17 - 15:56 I am opposed to the proposed rules change. I am currently 72 and have been working on my family's genealogy since 1982. If these rules are implemented, it will have a detrimental effect on members of my family to piece together family members and write family histories. I have depended on birth records to establish correct dates of birth, prove that unknown (= died early) children were born in the family; establish when and where members were married and to whom (wife's maiden name is key to building a genealogy) and establishing the dates of death and in sole case the cemetery where family members were buried. My family came to this country in 1886 and 1890 and although some children were born overseas, many were born in the NY area. If you implement these rules, it would have been impossible for me to locate the actual marriage dates and maiden names (often in question or lost) for the majority of my family members. Implementation of the proposed rules would mean that I would be able to START on my family's genealogy in about another 2 years and I would not have accomplished what I've been able to assemble so far..

Anna Stern Tue, 10/24/17 - 15:58 I oppose the proposed rules for several reasons 1) The argument that this will prevent identity theft is specious. The data on identity theft do NOT show that access to vital records is a contributing factor. http://www.identitytheftjournal.com/common-causes-identity-theft/ https://www.libertypowercorp.com/leading-cause-id-theft/ 2) I was an Associate Commissioner of Information Texhnology at HRA until 2016. Trying to get records from NYCDHMH was problematic even when it related to the official business of the City. This is an agency that does not want to make important data available, period, and keeps finding exercises for refusing to do so. 3) I am an amateur genealogist. Like millions of other Americans, my family settled in New York. To prevent us from getting access to birth and death records would prevent us from learning a great deal about our ancestors, all for no reason. 4) I have family members who are adoptees. This will prevent them from learning about, and locating, members of their birth family, which will be very painful to them. In summary, do not allow this regulation to be implemented. NYC has perfectly valid rules covering records, pane DORIS is an able custodian with viable protocols. Please don't let a meaningless bureaucratic response from NYC HDMH overrule that. Thank you,

B Robertson Tue, 10/24/17 - 16:03 Please do not pull up more barriers than what's already in place. Manners of Vital Statistics are public record and also data to make sure that the medical profession and research and other items should be considered. Also having the ability to verify affiliations of the past based on connections should be honored. It is not necessary to put up more barriers. There are laws in place currently that protect confidentiality. We don't need more please shoot down this additional Amendment

Rona Pertz Tue, 10/24/17 - 16:06 I have been researching family my genealogy and wish to continue to accords birth and death records. The proposed changes would preclude access to records for ancestors who have been in this country for less than 125 years. This would preclude continuing to research family line. I oppose this change.

Ira Leviton Tue, 10/24/17 - 16:07 The statement of basis and purpose to the amendment for article 207 published by the Department of Health states that the proposal balances the need to protect the personal information, especially as it relates to identity theft as well as other privacy issues, with the public’s right to access historically important records, including the specific interests of families, genealogists and other researchers. This is utter nonsense. There is no balance in this proposal - it shuts out the public's right to obtain *public* information in any meaningful way. I hereby remind the Department of Health that birth and death certificates are public documents that happen to contain some private information - and the time limits being proposed are absurd. Identity thieves and other people with bad intentions seek to obtain records that are useful to them in electronic format so they can obtain millions of bits of data in seconds, not old birth and death records one at at time. Furthermore, birth certificates of people who are no longer alive should be available to any other person - the right to 100% privacy and confidentiality of the information on them does not apply beyond the grave. Death certificates are public documents, with the arguable exception of medical information, which can be redacted. This proposal is tremendously unfair to genealogists (whether professional or hobbyists), people interested in the history of New York City, the vast majority of family members, and others who have a right to this information without waiting 125 or 75 years after the fact. The Department of Health is moving in the wrong direction on this - other jurisdictions (entire states, such as Pennsylvania and others) are making it easier to obtain this information by methods such as putting images of death certificates on the Internet for direct viewing, and in the case of death certificates, some states such as Florida allow anybody to obtain a death certificate (except for the cause of death information) with no time delay except for the several weeks it takes for it to arrive in the mail. The 21st century is the information age, not the information suppression age.

Suzette Stringer Tue, 10/24/17 - 16:10 I am trying to follow the trail for my family in NYC since their arrival in NYC in 1919 and 1911. Some of the street directories are not available (destroyed in a fire). Making birth and death records inaccessible just puts more frustration in my path!

Deborah Dworski Tue, 10/24/17 - 16:11 It is absurd that I can view online, free of charge, all of my relatives' Austrian & Polish birth records from the early to mid-1900s, yet I cannot access, under any circumstances, my own grandmother's 1910 Manhattan birth certificate. This is beyond privacy-overkill; it's totally irrational. Is there really a problem with identity theft in the 100+ age group? I think not. And as for not wanting to divulge one's real age, I've yet to meet anyone over the age of 90 who isn't thrilled to shout from rooftops that he or she has survived on this planet for nine decades. The proposed change for viewing death certificates is even more surreal. Our societal standard has long been to lift the veil of privacy upon death, and on several occasions, having access to relatives' death certificates has helped save lives of my other family members. When it comes to familial disease patterns, knowledge is power, so I hope you think carefully before withholding potentially life-saving information from public view.

Jay Paul Tue, 10/24/17 - 16:11 I am very concerned about this proposed new rule. While it purports to safeguard against identity theft, there have been no cases that I am aware of where identity theft has occurred based upon access to paper copies of vital records. Instead, those focused on identity theft are carrying out (apparently quite successfully) hacking of major businesses to access personal data (most recently the extraordinary hacking of Equifax). In addition, some people succumb to various email "phishing" efforts, where they may be lured to fake websites and asked for personal information. The very limited potential for identity theft in the case of vital records is based upon the limited return for the effort of requesting a particular birth or death record -- which only gives the potential of the theft of a particular individual. The older a person gets, with limited income, the poorer a choice they would be for identity thieves. In contrast, the loss to those of us conducting genealogical research is tremendous. I was born in Brooklyn, and many of my relatives were born, married or died in New York City. In addition, I have been working hard to link up the specific relationships of persons whom I only know to be distant cousins. My genealogical efforts began when I was in my late teen -- I am now in my early sixties. The potential loss to me of clarifying family linkages and family information by this change in rules is enormous, especially as I learn about further lateral branches of my family tree. Others working in the area of genealogical research would be similarly hampered. The costs to many contrasted with the hypothetical benefits to a few by changing these regulations is simply way out of balance. I beg the governmental authorities reviewing this proposed rule change to veto any such alteration to the current time frames in place, which are stringent enough.

Denise Duffy Tue, 10/24/17 - 16:14 I have been very grateful in my genealogy search to have access to birth and death information from my ancestors. I am concerned that this would severaly impact my ability to conduct future research. Is there some other way to protect the privacy of these records instead of restriction. Thank you.

Bill Gladstone Tue, 10/24/17 - 16:14 As a genealogist I often use the NY birth, marriage and death records. I oppose any extension of the privacy time restrictions before these records become available. Much better to shorten the period until the records become available so as to enhance the public's ability to research our family heritage. If you can't shorten the period, at least don't make it longer!

Bonnie Belza Tue, 10/24/17 - 16:14 I adamantly oppose the proposed restriction on public access to public birth and death records for unnecessarily long periods of time, 125 and 75 years, respectively. These proposed limits are stricter than those in place in almost any other jurisdiction in America, and are based only on the "2011 Model State Vital Statistics Act," which has not been passed by any legislative body or subject to any public comment. As a former New York resident with many present and past family and friends living in New York, I am dismayed at this proposal. Restricing access to information which is vital for health, genealogical and historical research is a disservice to the tax payers who provide for the preservation of these records. The argument for security is spurious as restricting this access will do little to deter the determined criminal and punish the millions of honest users. DO NOT IMPLEMENT THIS PROPOSAL>

Stephanie Locke Tue, 10/24/17 - 16:14 You have no right to keep the public from accessing their records. You do NOT own our records or the records of our ancestors....I can think of NO GOOD reason for you doing this, except that you are LAZY and have decided it is not VITAL to YOU! I would hate to think that this is for any other reason, because that would be diabolical. Those of us who are working as Genealogist or tracing the roots of their family will be severely hurt by what you are doing. Who gave you the right to destroy the records you have already destroyed? I have just found out about this and intend to obtain legal advice. I see a class action suit against the State of New York in your future, when the public is made aware of what you have done. I am NOW on record as opposing this proposed RULE.

Anne Merrell Tue, 10/24/17 - 16:17 I strongly oppose the proposed restriction on public access to public birth and death records for 125 and 75 years, respectively. These proposed limits are unnecessarily strict and eliminate important transparency. These records are vital for the genealogical community and for tracing family medical histories, which can often only be done through vital records. Having to wait 75+ years to access family birth and death certificates, hinders an individual's ability to make important medical decisions. Vital records have great significance in historical research. New York City is of great significance to our country's history as it was the arrival port of millions of immigrants. Some of whom stayed for a few days and others for generations. There is no evidence that limiting access to vital records reduces identity theft or improves public safety and privacy (on the contrary, there is some evidence that open access to public records deters identity theft). Without an evidence-based rationale for imposing restrictions, arbitrarily limits these important activities.

Maureen Murphy-Hathaway Tue, 10/24/17 - 16:19 I am in total agreement with "Reclaim The Records" on this issue you are proposing and intend to fight with them by financially supporting them to stop this proposal, Your department is the most rude and condescending employees I have ever had the displeasure of dealing with and I still have no call backs or answers to my inquiries. You have no right to impose this proposal on the public. We who cherish our family histories and past family members and have worked for years on our genealogies will not accept this proposal without a fight. I am also going public on Facebook to make as many others aware of these shenanigans as possible. They may not be in time to meet the dead line today....but you can bet there will be a backlash when we join up with "Reclaim The Records..... and legally fight this.

Patricia Ann Kellner Tue, 10/24/17 - 16:20 Vital Records brought my extended family back together for the last 3 years at Family Reunions... Because I found vital records for my great grandparents, I became interested in our family history. Those interactions led to me bringing family back together at our Family Reunions. Cousins have come from all over the country back to NYC for thsoe reunions. And the best part of all... our children now feel more grounded as they've connected with their extended family. Please continue to give families access to vital certificates, they are essential in helping all of us, and our children, to know our family history and connect with one another. Any proposed changes should make the job of finding family easier. Solid families and good society depend on it!

Eliana White Tue, 10/24/17 - 16:23 Please do not further restrict access to NY records. It is so challenging already to follow my family in Brooklyn dating back to the 1800's through the mid 1900's. I need marriage, birth, death records at the minimum Further limitations will make it much more difficult.

Mary Colbert Tue, 10/24/17 - 16:24 I strongly object to the extreme restrictions on the birth and death records. My immigrant ancestors lived in NYC for several generations. They had no land, no will and, the birth and death records are often among the few documents available for them. There is no reason to restrict birth records for 125 years, most places restrict for 75 - 100 years. The Irish records are available at 100 years and if someone older is alive and wants to restrict them they can do so (If you are over 100 years old and you do not wish the image and details of your birth record to be made available on-line, please make a request in writing for the Department to redact the records from www.irishgenealogy.ie.) Death records should be available after 50 years - this is common in many places and has not caused any problems. My father came from a very poor family which kept no records. I was able, using NYC records, to put together a family tree for him. I can see no reason to change the law, if it ain't broke, don't fix it. Thank you.

Diane Ungar Tue, 10/24/17 - 16:27 I am also a semi-professional geneologist and family historian and archivist. I would have to be DEAD before I could investigate my family's (or others') lineage to locate missing family members, to find out what relatives died from in order to establish what diseases might run in families, and to pull together for the still-living, often already old, a composite of the family background they seek to know before they themselves pass. But making it 125 years after birth is ludicrous. And 75 years after death - well, why not just upon death. They are gone. Identity theft may still be something of an issue but clearly not a robust issue and one that bumps up against other equally compelling needs and concerns for family history and historians and archivists. To seek out these records? Well the thieves have far more easy ways of getting maiden names, parental names and so forth. That said, it is not at all fair to penalize families doing family research to prevent us from researching them until WE OURSELVES are ostensibly also DEAD. Unfair, patently unfair, esp in light of other ways that thieves have already long had to get similar information. Keep info confidential till death? Maybe, but it still might get in the way of archivists. No one who submits to the govt expects their records to be confidential, and I would bet that more people WANT information than WANT TO HIDE information. Your new proposed rule is utterly on the wrong track, I cannot urge you enough DO NOT PASS THE NEW PROPOSED RULE(s) - keep our research and access alive. Let us know who we are and where we came from, from whom we came and to whom we are related. Do not relegate this to when people are too old to know and share and gain traction and meaning from the discoveries. PLEASE, I am beseeching you. Thank you very much, Diane E. Ungar, Esq. Attorney at Law Family Historian & Archivist

Steven Wohlstetter Tue, 10/24/17 - 16:29 I strongly object to the proposed changes to Article 207 of the NYC Health Code for Birth and Death records. Though privacy and protection of individuals are paramount, the current law still seems to sufficient.

Pearl Lipner Tue, 10/24/17 - 16:30 Besides the obvious health and medical benefits of having the information from family member death certificates, please remember the millions of Jews who are trying to make family connections after the Holocaust. These records can be vital to making families whole. Thank you

Barbara Krawiec Tue, 10/24/17 - 16:33 Thank you for permitting us to share our thoughts and concerns. While, on the surface, the stricter rules seem prudent and respectful in light of identity theft issues, the fact that there are continuing security breaches of government servers and other public and private entity servers makes these proposed rulings NOT foolproof. On the other hand, balancing the right to know with privacy issues, I am living proof that having learned at age 69 that I had a half-brother that I am stymied from finding thanks to NYC’s already too-stringent policies, policies that are NOT (thankfully!) in place in most other states in this union, is frustrating and heartbreaking. Born in NYC, as were the relatives I am agonizingly trying to locate--to no avail/with zero possibility under the revised proposed rules of ever finding--makes me sad/regretful, rather than glad/grateful to have NYC roots. Please reconsider keeping the current timeline in place—or reducing it, not increasing it—so that those of us searching for relatives have a fighting chance before we die of learning the truth about who we are and whose we are. Please do not close the door on us by making available genealogical records at the current (already sufficiently time-delayed) access rates virtually impossible to obtain. Realistically, given the proposed timeline changes, in effect, at least one immediate genealogical generation (and more likely two) will be not outlive the requisite wait time…thus never gaining access to records that make us more fully human—more fully New Yorkers with a rich family and community history. (Watch the tv series “Long Lost Relatives” if you want to see the heartbreak of searching for familial relationship answers. I find it hard to believe you would penalize NYC members once you see how gut-wrenching is the quest for answers. Please don’t close the door to those answers. Thank you!)

sandra fowler Tue, 10/24/17 - 16:34 As a part-time genealogist and NYC history researcher, I would like to go on record as saying that I am absolutely opposed to the new restrictions that the NYC Department of Health is proposing on vital records access. There are means by which the city can insure the records are not used for nefarious purposes, without impacting the access that historians, librarians, museum archivists, and researchers from around the world currently have.

Pat Iurilli Tue, 10/24/17 - 16:35 I would like to express my opposition to the proposed changes to the NY laws which will limit access to NY vital records. I am very much against any such changes to the laws. I was born in NY, was married in NY, and so were my parents and siblings, as were my extended family, and although I now live in NJ, I am against any tightening of any laws to restrict access to any vital records. I do not feel that by giving access as currently mandated, that constitutes a privacy risk or any other type of risk. I think that the old adage applies here to not try and fix something that is not broken.

Russ Wilding Tue, 10/24/17 - 16:35 I respect the concern that Birth and death records contain individually identifiable information, which may be considered private and therefore should be treated with appropriate regard. However I disagree with the time periods being proposed for making these NY records publicly available. US census records are made publicly available 72 years after the census is taken. I realize census records are not birth and death records, but they do provide a benchmark for releasing information about individuals. I do not support changing the time period of when the NY birth and death records should be released to the public as proposed in this Amendment. I suggest both types of records should be made publicly available, digitally, within 30 days of either the birth or the death.

Janet Mulshine Tue, 10/24/17 - 16:39 I am a non-professional genealogist who has extensively used the New York City vital statistics and archives for both my own family and my husband's family research. I urge you to consider the NYG&B proposals for a more reasonable time frame for releasing document information. I have also known other family members and friends who have used these records to fill in any blank spaces in their own pasts. The need for accessibility must be weighed very thoughtfully against privacy. Thank you for seriously considering these needs.

Maria Sabatino Tue, 10/24/17 - 16:51 Please add my name to the many others who oppose the proposed amendment to the General Vital Statistics Provisions (Article 207 of the NYC Health Code) regarding Birth and Death Records. I applaud the government's desire to prevent identity fraud. However, given the state of current technology and availability of all manner of information on the internet, there are better ways to prevent identity theft. As others have suggested, perhaps issuing "genealogical" or "unofficial" copies of NYC birth and death records would not impede the research so many genealogists and amateur family historians so vitally pursue, and yet still preserve the value of an "official" document for legal purposes. These NYC birth and death records were compiled by PUBLIC agencies using PUBLIC taxes and therefore should remain available to the PUBLIC within reasonable time periods. Why should the regulations in NYC differ from those in other municipalities within NYS? Restricting access has not proven to diminish identity theft. Please do not punish the majority of law-abiding people by the proposed changes to the law. The good that is served by many researchers outweighs the potential harm by a few "bad apples".

Michael Cassara Tue, 10/24/17 - 16:53 I am a professional genealogist and a small business owner. I have lived in Queens for 15 years, and have owned and operated a Manhattan-based business for the last 12. My ancestors and relatives have lived in all 5 boroughs and surrounding areas for the better part of the last 150 years. At a time when other cities are liberating data and finding ways to celebrate their unique heritage, these proposed rules seem to be poorly thought out - and, in many ways, crippling. 125 years is excessive - it will do far more harm than good. It has been clearly proven that vital records (such as the ones in question) are NOT a factor in identity theft and, if anything, help to combat it. With a city so rich in history, why prevent access to it? As demonstrated by the extremely vocal response to this proposal - please do NOT pass these excessive new rules. Please allow our city's incredible heritage to be discovered by generations to come.

Linda Sanders Tue, 10/24/17 - 16:53 I strongly disagree with the proposed restrictions on access to NYC birth and death records. Birth and death events are a matter of public record and the associated records should not be severely restricted. The argument that the delayed release of personally identifiable information is necessary to prevent identity theft is not valid. Personally identifiable information is widely available on the Internet. Also, many states openly publish birth and death index info with no proven increase in identity theft occurrences. I respectfully request that NYC make information-only copies of birth and death records readily available to the public.

Sharon Miller Tue, 10/24/17 - 16:56 Please do not do this. For many of us who lost family in WWII, in the Holocaust, having access to records has been a way to reunite families that were torn apart 70+ years ago.

K. Manning Tue, 10/24/17 - 16:57 I am a born New Yorker (Brooklyn) and my family’s genealogist. Over the last 10 to 15 years I’ve been fortunate in obtaining many NYC vital records from the NYC Municipal Records Department, for many of my ancestors, all of whom were born, lived and died in New York City. I urge the Board to not adopt this amendment. The proposed new schedules are prohibitively limiting for genealogists, or those wishing to track family health history. Many reasons against instituting the proposed changes have been given by the other commenters, so I will not repeat them here. I simply urge the Board NOT to adopt this amendment. If anything, the current limits should be changed to make the records more accessible.

Leslie Corn Tue, 10/24/17 - 16:58 I am a forensic certified genealogist. I strongly object to the limitation on public access to birth and death records and to the NYC Department of Health’s reasoning for that limitation. The proposed amendment is based on arguments of identity theft and violation of privacy through record access. Yet open record access has not proved this correct. Florida’s Department of Health, for instance, offers unrestricted access to birth and death records. Has their open access led to increased violation of personal identity in their state? No. The Office of the City Clerk of the City of New York only restricts access to marriage records for 50 years. If both parties to the marriage are deceased, a more recent record can be accessed. NYS DOH restricts access to birth records for 75 years and death records for 50 years—a shorter limit than NYC DOH’s proposed 125 years for births and 75 years for deaths. As additional proof of the error of identity theft based on record access, other countries with open access to vital records, such as England and Ireland, have not reported a rise in identity theft. A professional genealogist and associate in Germany wrote the following about open access to vital records there: “In Germany you have access to all civil vital records regardless of date if the person in question is your ancestor (parents, grandparents, great-grandparents)… I have no information about identity theft, never heard about it over here and I do not think that there is any in connection with vital records.” Access to vital records is essential to my work in assisting attorneys, executors, administrators, and distributees in testate and intestate matters. NYC DOH’s proposed restrictions will hamstring distribution of estates and resolution of other legal matters, such as entitlement to real property and dual citizenship.. When Jane Smith and John Doe announce their engagement in their local paper, does Jane Smith redact her maiden name for fear of identity theft? No matter what extreme limits the NYC DOH seeks to place on its holdings, the magnificent genealogical horse is out of the barn and running faster every day. Thanks to the work of individuals, genealogical societies, libraries, archives, and corporate and governmental entities, we have more and more vital records and indexes online, via mail-order, and onsite. I recommend that the NYC DOH reconsider their retrogressive proposition and adopt the following in transferring records to DORIS: 1. Transfer birth records on Jan 31 of the year following 100 years after the DOB. 2. Transfer death records on Jan 31 of the year following 50 years or less after the DOD. Thank you.

Mary C. Zingerella Tue, 10/24/17 - 17:11 I object to the changing of the time limits. Pls do not make access to records to genealogists more difficult.

Elysa Wallingford Tue, 10/24/17 - 17:25 All my family came from New York back in the mid 1800- mid 1900. It’s very hard to search NY for records of any kind. This new restriction would be very hard to get any kind of family information. Please reconsider this move.

William Kusy Tue, 10/24/17 - 17:41 My Dad and His Mother have passed away over 10 years ago and Knowing the bilogicall dad of my dad would maybe help explain the health problem that have been experience by myself, brother, granddauughter and neices and nephews. My Dads birth was reissued in 1937 but no knowledge of the Father. Need the original to find out nationality of biological father of my dad. Please do not hinder my search with this new program Thank you William

Teri Hanke Tue, 10/24/17 - 18:02 I have reviewed many of the previous comments and rather than reiterate all that has been said before, I will say that I agree complete with the comments of Kathleen Naylor. Her eloquent comments regarding how vital these records are to family member, geneologists, etc. are right on target. My family members all came to this country through New York, some stayed and continued raising families there, others moved on to other areas. The NY records are invaluable to those of us without family members left to question and the time limits you are considering to impose will make it much more difficult for those of us trying to find out how we got where we are.

Karen Massari Tue, 10/24/17 - 18:05 I am an adult adoptee with no access to my vital records otherwise knows as an Original Birth Certificate. I have had difficulty renewing my passport and I have been denied my civil rights of knowing my heritage and genetic lineage. I have spent thousands of dollars and have been able to find my birth mother who unfortunately had passed away before I found her. I know everything that is on my OBC but at the age of 49 still do not have access to it. Other then those in the witness protection system adoptees are the only ones in NYS that have their identity locked away from them causing major issues wit the Federal Government especially when it comes to getting our passports renewed. The idea of privacy for the birth mother and/or father is moot with DNA testing. I used the DNA test from Ancestry and found my 1/2 sister and plenty of cousins. So even though my father is not listed on my OBC according to my non-id all of his 2nd and 3rd cousins know I am looking for him. So this idea of privacy is fundamentally flawed. Adoptees really do require access to their OBC.

Sylvia Prast Tue, 10/24/17 - 18:57 I disagree with the proposed records restrictions. They are unnecessary.

Rochelle Wyatt Tue, 10/24/17 - 19:34 Please do not change the existing rules for accessing birth and death records. As a genealogist with ancestry in New York, access to these records is important. At a minimum, the death records should be made available after 50 years.

Don Rauch Tue, 10/24/17 - 20:32 As a genealogist I am opposed to this rule proposal. More realistic timing should be considered.

Adam Turner Tue, 10/24/17 - 23:19 It doesn't appear that DORIS has any clear empirical evidence that a more open vital records policy actually leads to an increase in identity theft or other abuses of people's private information. Declaring what is good for the public by fiat, without clear data on the likely effects of policy changes, is usually a terrible way for governments to make policy. Additionally, I note that the people who are the subject of death records are...dead. As such, they have no privacy rights to violate. In addition to the ample points others have made about the public's interest in keeping death records widely available, I see no reason to believe that there are a meaningful number of people out there who think that their interests are being served by having their death records kept secret for 5-10 years after their death, let alone 75 years.

Pamela Rose Tue, 10/24/17 - 23:50 For many of us New Yorkers who have family that have lived in this area for decades or even hundreds of years...these records are VITAL for us. WHY ARE YOU MAKING IT SO DIFFICULT???? Stop trying to make it the record inaccessible to citizens and genealogists. They are a vital part of research and should be made accessible to the public, NOT restricted like this proposed Ammendment.