More Coiney Befuddlement from the ACCG

.
It is a painful sight to see how the coin dealers lost in the wilderness thrashing around trying to justify their dealings, but do everything except actually sit down and read and learn about what they are criticising. It is therefore not me who is bringing "ridicule and discredit" on their desperate attempts to maintain what coin-dealer Dave Welsh calls the "longstanding and legitimate rights" of the collecting community to continue to buy large quantities of dugup coins exported from the source countries like Bulgaria without export licences.

I now find that this dealer now asserts on the blog of paid dealers' lobbyist lawyer Peter Tompa (who did not correct him) that:

the State Department (sic) is attempting to restrict topics upon which the public may comment to those which harmonize with their bureaucratic agenda, which clearly is to seize every opportunity to issue import restrictions on "archaeological artifacts," whether or not such artifacts actually come under the intentions of the 1970 UNESCO Convention and the 1983 CCPIA implementing that Convention in the USA. The S[t]ate Department, of course, has no legal right to control what members of the public may say in their comments.

This is just getting totally ridiculous. First of all it is not the "State Department" restricting anything, is it? The State Department currently provides the administrative and technical backup for the CPAC, a Presidential advisory committee set up to serve the needs of the CCPIA. The State Department facilitates any public submissions to the CPAC which the President or his designee thinks fit (CCPIA 19 U.S.C. 2605(h)). That's what the law says. The CPAC is convened to evaluate certain aspects of a request from one UNESCO 1970 Convention state party to another (the USA) and section 303 (19 U.S.C. 2602(a) 1) sets out what this should encompass. In seeking public comment on this (despite the fact that the interests of the public - and trade - are already represented in the statutory composition of the CPAC), it follows that comment is invited on those issues that the CPAC itself evaluates. It is not the "State Department" restricting who says what to the CPAC during its deliberations, but the CCPIA in directing (limiting) what precisely those deliberations shall consist of. If dealers like Mr Welsh are unhappy with that, then they need to force a change in the wording of the 1983 CCPIA - which would be no bad thing, as written it is damaging and anachronistic crap. That however does not absolve antiquity dealers like Mr Welsh knowing what it actually says. Why doesn't he?

I leave the veracity and possible import of the rest of the dealer's comment to the reader to assess.