The First Coiney Contributions to the Debate

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The first forty or so contributions have appeared on 19th October in the public consultation of the CPAC deliberations on Bulgaria's request for a bilateral cultural property agreement in response to the smuggling of looted artefacts on a massive scale. So far ALL of them have been from coin collectors and dealers, and ALL of them have been AGAINST THE Bulgarian MOU. I'd like to briefly discuss the trends they demonstrate, and consider these comments in two groups. The public were specifically and exclusively requested to share their reflections on issues raised in Section 303 (a).1 of the CCPIA and so I propose dividing the comments into two groups, those that do, and those that do not. The latter is the larger group so I'll begin with them.

Missing the 303 mark:
Norris Haden, MD ("common artifacts, often inexpensive, that have circulated in the coin market for many, many years")
John Robert Aitken ("millions and millions")
Brian Rowe a dealer from Canada (misunderstands what the purpose of the 1970 UNESCO Convention - sarcasm)
Wayne Melville (Texas) ("I have been privileged to have obtained many [coins] from suppliers in Bulgaria" - since the US became a state party of the 1970 Convention, has he the paperwork to show legal export? He does not say).
Spero Kinnas (coins circulated in the past, so why not now argument)
Robert Leonard (coins circulated in the past, so why not now argument),
Doug Hill (writes like an eleven year old, millions and millions)
Richard Bender (fails to understand the Convention, "Numismatism is an ancient, popular and harmless hobby")
Gary Niditch MD ("These are not rare art forms but dirt cheap common objects by and large")
Frank Robinson (Collecting [...]does no harm to archaeology, as the numbers of ancient coins discovered has been incredibly VAST. There is plenty for both archaeologists and coin collectors. ")
Eric Feder (a virulent anti-archaeological rant you can read for yourselves... totally missing the point being debated of course)
Traughber, P. (better argued than most, but misses the point)
Jack Brigham (in praise of coin collecting, misses the point)
Frederick Thies (brief, no reasons given, misses the point)
Bard Geoffrey ("coins [...] cannot be considered in the same light as unique archaelogical artifacts. In lower grades they typically trade for just over their melt value.")
Lawrence Hageman, somewhat inarticulate: "this restriction, if imposed on coinage, would make it impossible to legally import any coinage for collector purposes" - eh? The restriction would be to coins which HAD been legally exported, their import is wholly legal under both the conditions of the 1970 Convention and will be under the proposed regulation of the matter. What would not be legal is the ("minority", I am sure the trade would say) of coins arriving on American borders having been illegally exported.
Eric Karell, a coiney 'I know better than you' approach: ("This is the kind of regulation that sounds reasonable at face value but has aspects that only some people would appreciate" - but it is the writer himself who misses the point)
W.P. Lyon, does not seem to grasp what is involved at all: "I hereby state that I am completely against Bulgaria restricting any coins for import or export").
J. Conroy is "outraged that you have restricted some Roman coins from being imported from Italy". The CPAC is "destroy[ing] the hobby of coin collecting in the United States for the majority of ordinary collectors" and urges a reversal of the Italy MOU decision. Misses the point.
Bill Leubrie reckons himself a "scholar" ("This is ridiculous. No one needs to restrict the flow of ancient coins. They exist in their millions [...] Collectors of ancient coins are not criminals, but entirely a harmless, scholarly lot". He appears to think, but not be able to express properly, that the gubn'mint should "stay out of our hobby"). If coin collectors are not criminals, why do they support the opposition to this proposal to restrict US imports ONLY to legally exported coins? On whose side are they on, the responsible dealers who observe the applicable laws or those that deal with the antiquity SMUGGLERS? What is "harmless" in that? Misses the point.
Roy Iwata, ancient circulation, misses the point.
William Leitold,a longish, intelligently presented argument, worth reading for an insight into a mindset using the typical coiney pseudo justifications - see attachment for fuller text ("I hope that the US Government I voted for will not participate in this abuse of our rights"). Sadly it misses the section 303 point.
Wayne Hansen, ("Ancient coin collecting [...] is an important commercial enterprise. US access to coins is important to collectors worldwide").
Daniel Demeo, ("Not another mou with another country! [...] making it illegal to import ancient coins and artifacts from that area [...] We WILL REMEMBER in Novembers which administrations and which parties destroyed our enjoyment"). Forgetting of course that he is addressing his comments to the CPAC not the Democratic party. His point is keeping records of licit provenance is adding a responsibility and taking away the "pleasure" of collecting.
Steven Snyderman, "millions and millions", ancient circulation, "untenable", looks like cut and paste from Tompa.
Robert M. Harlick, believes there was an MOU with Turkey, "millions and millions", "ancient circulation", bloodline, "do they need all those coins"? Misses the point of the Convention, does not address section 303.
Daniel Owsen, pleads that coins not be included among the "protected" artefacts.
Constantinos Eliades, "This is to the State Department and CPAC". No it is not, it's to the CPAC. " because of the low price the vast majority of these coins will never have been through an auction and will have no verifiable provenance" - cut and paste from Tompa. Misses the point.
Robert Tromp, Conspiracy afoot: "Please look into the real issues involved, and you will find that there is a lot more right on the side of the collector than on the part of corrupt, cynical Balkan governments". Although this one too misses the point, it raises some questions I'd like to discuss tomorrow.
Jeffery Spier a "working numismatist" Fellow, American Numismatic Society (thanks to David Gill for reminding me this is a name connected with the Elmali hoard purchase). "Millions and millions", "ancient circulation", "Restrictions on collecting will certainly impoverish the long tradition of numismatic scholarship". Misses the point.
Col Dupont, C L Dupont Ancient Coin Jewelry, admonishes the Presidential advisory committee: "Come on; don't go there! It's just silly...".
Anthony Kurland, ("because of their low price the vast majority of these coins will never have been through an auction and will have no verifiable provenance" looks like cut and paste from Tompa). Misses the point.
Robert Crutchley, it is difficult to see what this guy thinks he is talking about ("The vast majority of coins found in grave robbing are of base metal and are not what the thieves are looking for because they have little value"), but it is certainly not section 303 of the CCPIA or what the CPAC is asked to give opinion upon.
Gregory Fairbanks, a mishmash of reasons not to observe the provisions (art. 3) of the 1970 UNESCO convention ("millions and millions", "ancient circulation" and they are not anyway "a part of a cultural heritage" - the latter failing to articulate with the reasons collectors give for collecting them)
Steve Benner, author, reckons restricting imports of illegally exported coins will harm numismatic scholarship.

That closes the contributions visible on the website at the close of the working day in the US on 19th October. Let us look at the comments which actually address section 303 of the CCPIA which is what the CPAC asked the public submissions to address. Unsurprisinly there are very few, as coineys apparently cannot themselves read the notices put out on behalf of the CPAC and the coin dealers'; lobbyists failed to inform them of what issues are open to public discussion. US Coineys allow themselves to be led by the nose at every turn, and a large proportion of them seem unable to enquire or think for themselves. the result is that just two even mention something which may vaguely relate to Section 303 of the CCPIA:

Brian Rowe a dealer from Canada- so outside the pernicious influence of the ACCG, says that Bulgaria and Belize should "police their borders" better.

Gregory Fairbanks might be trying to address section 303 issues writing: "Furthermore, the track record of countries protecting their so called cultural heritage is quite poor", but does not enlarge on the means it could institute to achieve the same aims as import restrictions on smuggled goods.

So basically the first thirty or so "informed contributions" to the public debate by US and Canadian coin collectors suggest so far a complete misunderstanding in those circles of what the 1970 UNESCO Convention is about. The reference to the "millions and millions" of these coins on the market betrays a lack of awareness (or concern) that this means millions and millions of HOLES in the archaeological record created so they can have their collectable geegaws to flash about (Wayne Melville). It is precisely the "minor antiquities" that are being recovered on an industrial scale that are the symptoms of the greatest damage being done to archaeological sites in Bulgaria. Furthermore the majority of these collectors write as though they are talking of a wholesale "ban on imports" rather than restrictions on coins not accompanied by paperwork verifying export from Bulgaria in accordance with the relevant laws. This not-so-subtle difference seems to be lost on the majority of collectors taking part in this campaign.

The arguments being trotted out are the same weak ones used against the other MOUs involving coins (Cyprus, China, Italy and probably Greece). Nothing new here.

Neither has anyone actually directly addressed section 303 as asked, so the first thirty six "informed" contributions to the debate on section 303 deserve to be binned. This proportion should be noted by all those that accuse the CPAC of ignoring public comments. They may or may not be ignoring them, but - as in the case of any public consultation on any issue - they will be entirely justified in doing so when the comments do not address the issue which the Committee specifically opens to public discussion.

Now, I know coineys read this blog. Why do you not go back to Mr Tompa and ask him why he is telling all of you this crap about "provenance", but failing to tell you what (Section 303) the CPAC have SPECIFICALLY asked for comment upon? Why not? Are the ACCG achieving anything useful for the hobby by NOT telling you this, when it is quite clear that the vast majority of US coin collectors have not the foggiest idea even of what the 1970 UNESCO Convention is about, or what the CCPIA actually says (even though both are a mouse-click away)? Why are you collectively following these pied pipers who are obviously and openly - and it now is very clear deliberately - misleading you about what is actually the subject of discussion? Can you be surprised that anyone observing this, and observing the scale of the resulting phenomenon, can only arrive at a certain conclusion about the intellectual abilities of virtually the entire dugup coin collecting milieu in the US? Why should any nominated member of a presidential advisory committee pay the slightest attention to flat-earthers who have not even bothered to find out what it is they are commenting upon?