Bulgarian MOU Comment Statistics

The latest comment submissions all appear to be recorded now. There were a number of website problems on the last two days of the comment period which resulted in some comments being recorded as having been posted on 11/3. Here is the statistical breakdown:

342 commented registering an objection to coins being included in the MOU

13 commented supporting coins being included in the MOU

Overall,

146 commented approving of the MoU;

353 commented disapproving of the MoU.

The actual total of relevant comments was 499 (not 504 as recorded on the DOS website) -- a couple of people (including one AIA member) were so confused that their comments indicated they thought they were replying to the Belize request instead of the Bulgarian request.

The result to the nearest percentage point is 71% Against, 29% For.

Especially significant is this response from one AIA member requesting that coins should NOT be included:

http://www.regulations.gov/#!documentDetail;D=DOS-2011-0115-0503
< http://www.regulations.gov/#%21documentDetail;D=DOS-2011-0115-0503 >

This courageous AIA member, Gerard Casale, did not run with the herd but remained an independently thinking individual.

That was not typical of most others in the archaeology camp. Most of the late AIA generated responses were due to a late email campaign by the AIA -- the majority clearly having been hastily written by cut and paste methods from templates provided for them by the AIA.

That sharply contrasts with the clearly thought out posts from US collectors (and a few coin dealers such as myself) protesting the expected inclusion of ancient coins in the forthcoming Memorandum of Understanding. These pro-collecting comments are well worth reading. All of them express genuinely sincere, individually composed opinions.

There was no robosigning in any of this public pro-collecting commentary, no easy and unthinking adding of one's name to a carefully composed and organizationally drafted petition. Instead we here confront a body of sincere, deeply felt and individually composed evidence attesting to the reaction of US coin collectors outraged by the unreasonable and unfair manner in which the US State Department maladministers the 1983 CCPIA implementing US accession to the 1970 UNESCO Convention.

A greater number of the late AIA responses (9) mentioned coins, as it was obviously important for them to do so if they looked at the comments made up to that point. In all, only 14 members of the AIA seem to have understood the issues well enough to mention coins, and one of these did not want coins to be included at all! That's a really pathetic response, considering their huge claimed membership (the circulation base of Archaeology magazine).

Responders opposing the Bulgarian MOU and its prospective inclusion of coins improved slightly upon the 70% of responders who had objected to the Greek MoU.

John Hooker compiled these statistics for the ACCG.

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COMMENTARY
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Once again, US citizens interested in ancient artifacts have made it clear that they strongly disapprove of import restrictions, especially the prospect of import restrictions on coins.

Once again, the State Department's Cultural Heritage Center had already negotiated the details of recommendations that will eventually be made by the CPAC supporting what the Bulgarian government has asked for, prior to the submission of Bulgaria's request. There is every reason to expect that it has long since been decided that ancient coins will be included in the Designated List.

Once again, the Cultural Property Advisory Committee process has been nothing more than a deceptive, dishonorable, ritualistic pro forma sham. No facts were actually found. No verification of specific statutory criteria was actually carried out. The legislative intent of Congress will once again be thwarted, and rights of concerned citizens interested in ancient artifacts will once again be ignored - as will be State Department 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 expressed my own intense disgust with this disgraceful maladministration in the public record, where it will hopefully be visible to elected officials, Senators, Representatives and their legislative staffs.

If by some miracle our elected and appointed officials responsible for this process should finally decide to see that justice is actually done to the interests of concerned US citizens, the Bulgarian request will be rejected - and no further import restrictions or renewals will be granted until 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 the State Department indeed promised when accession to the 1970 UNESCO Convention was under consideration.