Monday, March 02, 2015

Italian MOU Extension Update

How to make your voice heard:

To submit comments electronically, go to the Federal eRulemaking Portal (, enter the Docket No. DOS-2015-0010-0001, and follow the prompts to submit a comment. (for a direct link see!docketDetail;D=DOS-2015-0010 .) Please note comments may be posted only UNTIL MARCH 20, 2015 at 11:59 PM. Submit comments yourself and ask friends and family who reside at different addresses to also submit comments.

Thus far comments submitted have focused upon the impact of these restrictions upon collecting of ancient coins in the USA. That has been noticed in the archaeological blogosphere, specifically here:

This observer welcomes Mr. Barford's observation, believing that it will do a great deal toward aiding US collectors  of ancient coins in coming to understand the contempt and animosity which radical archaeologists feel toward collectors, and the relentless war that the Archaeological Institute of America is waging against US collectors of ancient coins and other antiquities.

It is entirely appropriate for US collectors of ancient coins to restrict their comments to that subject, contrary to Mr. Barford's implications that you should instead be addressing the "four points of the CCPIA on which the CPAC will deliberate ... specifically to the determinations under 19 U.S.C. 2602, pursuant to which the Committee must make findings".


Here is what I submitted in my own comment:

If the Committee decides to recommend extension of the MOU with Italy, it should specifically and strongly recommend the removal of coins from the Restricted List.

Ancient coins are unique among antiquities in that they were manufactured in large quantities as instruments of commerce, for the purpose of circulating not only within the issuing political entity, but also between citizens of different political entities. In that sense they were no more part of "cultural heritage" than US paper money is today. Athenian tetradrachms were the equivalent of US $100 bills in their time, a globally accepted currency that was in its way an advertisement for the power and glory of Athens. Likewise Roman Imperial coins were advertisements for the power and glory of Rome, circulating to lands as distant as China and India.

Including ancient coins in the previous extension of the MOU with Italy has had a serious adverse impact upon the interests of US collectors, the importance of which in their view greatly outweighs any effect inclusion of these coins might have had upon protecting Italian archaeological sites.

Any extension of the Restricted List to include additional types of ancient coins, specifically Roman Imperial coins, would have a disastrous impact upon the interests of US collectors and would be viewed by them as an unjustifiable outrage.


It is not appropriate for collectors to include any remarks regarding political implications and resultant consequences of continued inclusion of ancient coins in the Italian Restricted List, particularly any extension of the coin types included therein.


Blogger Cultural Property Observer said...

Yes, more Barford foolishness. The fact is that most collectors can only comment on what they know. They know the impact of restrictions on their hobby. That's an entirely appropriate basis for comment, and I would note the Fed. Register Notice does not suggest otherwise. In any event, such comments generally go to issues of cultural exchange.

4:12 PM  

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