I sent my message to Congress

Here is the text of my comment on the Bulgarian MOU request:

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The Cultural Property Advisory Committee process is, in reality, a deceptive sham. No facts are actually found. No verification of specific statutory criteria is actually carried out. Recommendations are predetermined before the CPAC process even begins. The legislative intent of Congress has been thwarted, and rights of concerned citizens interested in ancient artifacts are ignored - as are DOS responsibilities to evenhandedly administer the CPAC so as to ensure fair representation and judicious balancing of interests of all concerned parties.

Prior to US accession to the 1970 UNESCO Convention, antiquities experts worried that it would create a "blank check" which would be used to benefit foreign countries and to destroy the US antiquities market, and that the statutory requirement to reach certain findings through consultation with a panel of experts before imposing restrictions would in practice be ritualistic and pro forma. These concerns have become realities. The Cultural Heritage Center bureaucracy, pursuing its ideology-driven agenda to promote interests of US archaeologists in collusion with foreign governments, continually and overtly ignores both the legislative intent of Congress and the legitimate interests and rights of concerned US citizens.

As an interested citizen, I now express my disgust with this disgraceful maladministration in the public record, where it will be visible to elected officials, Senators, Representatives and their legislative staffs.

The Bulgarian request should be rejected. No further import restrictions or renewals should be granted until DOS administration of the CCPIA is reformed, so that the legislative intent of Congress and the rights and interests of collectors are fairly and justly weighed in an open, verifiable process - as DOS indeed promised when accession to the 1970 UNESCO Convention was under consideration.


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This comment focuses entirely upon the CPAC process itself and its administration. Reforming this process is an essential precondition to eventually arriving at a US policy on cultural property law which collectors can live with. It is important to build a clear public record of public discontent with the CPAC process and its maladministration.

By now there have been many cogent and well worded comments submitted that focus on the prospective details of the MOU, especially the prospect that it will include ancient coins. In my view full justice has already been done to that subject.

I urge that every collector who has not yet commented now do so, and please use whatever you like from my remarks to indicate your own disgust with the biased maladministration of the CPAC process. Everyone on every side of the antiquities collecting issue ought to be able to agree that collectors are entitled to a fair hearing. We are obviously not getting it, and that injustice should be a much more important concern to everyone than preserving cultural heritage or the archaeological record. If we don't have a genuine rule of law, in which all citizens are treated evenhandedly and fairly by their government, then nothing is really safe - including cultural heritage and archaeology.