Coiney Teacup Storm

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I asked ('Coiney Silence: Capitulation or Calm Before Storm?') whether the several days' silence from the coiney camp on the Bulgarian MOU request was the calm before another storm of philistinic coineyish protest. Now we've seen what they intend to do, it is difficult to say. It's all a bit pathetic really, and of course once again shows that they are being induced to write about things that are not in the CPAC's request for comments and indeed not in the CPIA. (What's new?) They complain that their comments have not been listened to by the CPAC on previous occasions where coin imports have been discussed. There is a very good reason for that, when you look at what they actually wrote (where that is available, and I spent a while posting about them on this blog) virtually NONE of it was actually on topic. In any administration, that will lead to it being binned rather than considered.

This time is no different. This time though the coineys are being urged to comment mainly on the alleged "maladministration" of the Department of State. The "evidence" for this is that "they" did not consider coiney complaints and that they gave "short notice" of the comment gathering period. Two weeks is however not really all that short for a person of adequate literacy to submit a comment. These pathetic individuals however are being urged to write comments to a presidential advisory committee containing a complaint against the DoS. Where is the logic in that? More to the point, if you look at the CCPIA with any care, you will see that nowhere in the description of the operation of the CCPIA is there any mention that it has to be swayed by any public input. In its composition, both the public and the antiquities trade are adequately represented in the statutory composition of the Committee. When the Act was written internet-lobbying was still unthought of.

With reference to the text I discuss below, coineys might like to look at the CCPIA (section 305) to see at what stage of the process the definition of what is and what is not covered is added or revised, and by whom. They might be surprised, because lawyers for the coin trade apparently do not consider they need to be kept informed of details like that in order to make a meaningful contribution to the public debate. that seems not to be their function in the tactics of coiney lobbying.

The coin trade's professional lobbyist Peter Tompa has created a text called: "Bulgaria: Call to Comment" which begins "Please consider sending this to any coin collector you know". One wonders why he only wants coineys to comment, surely this affects anyone who deals in and collects "minor antiquities" coming from recent metal detecting in the Balkans and Bulgaria in particular, why does Tompa feel that these collectors will not support the coineys? Tompa's text has the following sections:

What is at issue? [which of course fails to say what is at issue in fact, which is restrictions on import of coins which cannot be documented as legally exported from the Bulgaria]

Why bother? [...]
and the all important for those with sawdust instead of brains:

"What should I say?"
This section for the collectors unable to work out for themselves why they are writing to the CPAC is priceless:

Tell the State Department and CPAC what you think about the bureaucracy’s efforts to deny you the ability to collect common ancient artifacts that are available worldwide. You might also consider noting that coins from Bulgarian mints are common and often very inexpensive. Tens of thousands or hundreds of thousands exist in collections around the world, and because of the low price the vast majority of these coins will never have been through an auction and will have no verifiable provenance.

Comments:

1) Perhaps sawdust-for-brains folk might need some prompting to work out why these particular coins are so plentiful on the market. Is it because Petrarch and nineteenth century Maryland rural parsons collected coins from Bulgarian ploughmen? Or is it because sites in Bulgaria have been trashed on a massive and industrial scale in the last two decades to allow hundreds of thousands of freshly (and illegally) dug up coins and other artefacts to enter the global (but most especially the US) market? Is it because at least one container-load of such dugups is known to have passed through Frankfurt on its way to the international market, of which the US sector has been estimated by an ACCG dealer as comprising a half? Let's have long lingering look at the Google Earth pictures of Archar. Let sawdust-for-brain people unable to work it out for themselves have a long lingering look at the Wikipedia Commons photo gallery showing the massive scale on which this site has been turned over by gangs with metal detectors and bulldozers to produce the coins and "minor antiquities" that not just one of the US "small businesses" supporting the ACCG and V-coins was started with. Then let them write to the CPAC what they think about that.

2) These coins may be "available worldwide" on a market that is notorious for asking no questions. In which country or countries, the lawyer does not say, are coins illegally dug up and illegally taken out of the country (without an export licence) on sale licitly? Could Peter Tompa provide us, either via his blog of as a comment here, with the names of the other countries that would go on this list:

Table 1: Countries where selling freshly dugup artefacts smuggled out of Bulgaria is licit
(UNESCO 1970 Art. 3 and 8)

3) While he is at it, Peter Tompa can no doubt supply his coiney protégés with the actual reference within the CCPIA which speaks of "provenance". All that is of issue in the whole CCPIA is in fact when an item left Bulgaria. Nothing to do with "auctions" or how much an artefact "costs" or where it was dug up. It is precisely the mass scale of the removal of items (the factor which lowers the cost) which is the problem.

4) Somehow Peter Tompa has forgotten to keep coineys appraised of just what specific aspect of the request the Presidential Advisory Committee has asked for public comments on. Comments on anything else will not be taken into consideration. Get your section 303 thinking caps on coineys - Tompa's not going to help you out there, he wants you writing something else... (his motives for that are not easy to guess).

Finally, how many fresh coins do Tompa and his dealer mates want to see on the market? If people in the US have been collecting coins "since Petrarch", and we hear of container loads of them arriving there (and from another dealer mentioned on this blog about a "tonne") then when is enough is enough? Can the US coin trade quantify roughly how many freshly dug up coins imported from Bulgaria it will need in the next decade? How many have been coming in over two decades? How sustainable is that by current mechanisms?

Why are the dealers and their supporters not urging the coiney community to insist Bulgaria install a Portable Antiquities Scheme in places like Archar (Ratiaria) to voluntarily record the coins and artefacts coming out of the ground of this heavily trashed site? This is surely what they were suggesting for other countries instead of closer US scrutiny of imports, why not here? A little consistency please guys...

In an earlier post, dealers' lobbyist Tompa grumbles:

One must again unfortunately conclude that the State Department and its Cultural Heritage Center really are not looking for informed public comment from the broadest number of stakeholders possible. And doesn't such a tact merely confirm the suspicions of many that the State Department bureaucracy views CPAC as little more than a rubber stamp for imposing the broadest import restrictions possible? While I'm sure Bulgaria's former Communist rulers would have approved of such a farce, what does it say about our own State Department's commitment to the democracy it preaches so loudly to others?

Bulgaria ceased to be a "Communist" state quite a long time ago, and a lot has happened there since. It seems going more than a little too far to compare the US DoS with the totalitarian regime of Todor Zhivkov on present evidence. Methinks Tompa has not the slightest idea what he is talking about here. To what extent are the coineys commenting on the bilateral cultural property agreement well informed by people such as Mr Tompa about what it involves? We will see.

Vignette: Bulgarian ethnic ceramic teacup; Photo, what is left of the archaeology of Ratiaria after the artefsct hunters have been over it (photo by Widintourist Wikipedia Commons do have a look at the whole gallery, it is quite shocking)