CPAC Comment "Statistics"

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Over on the US coin fondler's blogs they are discussing the end and final results of the online comment-gathering session on the Regulations.gov website for the Cultural Property Advisory Committee on the request from Bulgaria for the US to enter into a bipartite cultural property agreement to more fully respect the principles of the 1970 Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Cultural Property. Dave Welsh reports (Thursday, November 03, 2011 "Bulgarian MOU Comment Statistics") on the basis of a summary created by ACCG employee John Hooker that:

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.

As though this was some kind of popularity contest (or viewers' votes in "Dancing with the Stars" - ugh) he reports: "353 commented disapproving of the MoU" and among them "342 commented registering an objection to coins being included in the MOU". On the other hand: "146 commented approving of the MoU" and it was presumably among them that "13 commented [specifically] supporting coins being included in the MOU". Thus: "The result to the nearest percentage point is 71% Against, 29% For". The coineys still manage to spin the figures, despite the falling numbers of coineys commenting: "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". You have to laugh.

Both Welsh and Sayles jubilate that at least one person wanting to see an exclusion of coins from import controls is an AIA member (more on this below since the coineys made such a meal of it)One has to laugh at the next bit of Welsh's tub-thumping: 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.No they do not. They repeat the same claptrap they were told by dealers that they should consider (in a text drafted by Peter Tompa disseminated by several major dealers). Most of them contain the telling phrase "that tens or hundreds of thousands of these coins existing in collections around the world have never have been through an auction or other transaction where precise provenance has been recorded". of course the CCPIA says nothing about provenances or auction houses, it is merely about proper export procedures. What is perfectly clear is that the vast majority of those that tried to go beyond the schema supplied by Tompa and frame their thoughts in their own words, in fact had no real idea what the CCPIA says, what it is about, what it is for, and what the issues are. Most of them (probably as a result of earlier ACCG "cultural property nationalism" claptrap) clearly see the issues as the "retention" of loose "antiquities" in "museums", rather than efforts to curb commercial looting of sites. These people exhibit a total lack of real knowledge abouyt the archaeological side of the issues, probably because they only go on what they are told by the dealers and their lobbyists (reading around an issue clearly not being the forte of most of these collectors). The dealers and lobbyists of course have an interest in keeping them uninformed (I see Sayles claiming he did archaeology 101 - from what he now shows of his "knowledge" by what writes, I suspect he'd not have passed any exam I marked).

Also amusing is the comment on the "late AIA responses", of which nine were noted as having "mentioned coins", and one AIA member did not want coins to be included in the MOU.

In all, only 14 members of the AIA seem to have understood the issues well enough to mention coins,

Of course whether coins go in the MOU or not is in effect a minor issue (either the MOU covers all the sorts of things looters are extracting from archaeological sites with metal detectors and bulldozers, or it does not) - the question is whether an MOU is the best way to deal with the problem under consideration which is what the CCPIA section 303(a)(1) on which comments were invited was about. The next much more important question for America is whether the 1983 CCPIA is in fact the best way to "implement" the Convention. I think we all, all countries, need to look much more carefully at the ancient (1970) Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Cultural Property and the way we all "implement it" and make some changes in response to the way the market has changed since the 1970s and 1980s. All of us, not just America (but that is no reason why the USA cannot start now). Looking at the other UNESCO Conventions, it is striking that the 1970 Illict antiquities Convention is one of the few of the older ones that has no updating and clarifying protocols. Let's press for one or two before a complete and effective rewrite.

I agree with Welsh that the response of the AIA was:

a really pathetic response, considering their huge claimed membership (the circulation base of Archaeology magazine).

Really, really pathetic. It seems that when faced with actually thinking about and doing something about portable antiquity issues, archaeologists both sides of the Atlantic feel no compunction to get involved in any way at all. Yes, they are complex issues - is that any excuse for sitting back and let others do all the work? Just 146 had anything positive to say to the CPAC in response to this request. The rest obviously cannot give a monkeys. Unlike the coineys they have no personal interest in stopping any illegal trade in artefacts from far-off Yurope.

Europe is a country and everyone speaks French there(You tube video posted by Makulature)

Welsh's conclusion seems drafted to become the mainstay of future antiquity dealer opposition to the implications of the US being a state party to the 1970 UNESCO Convention:

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.

The facts are that among those "interested in ancient artifacts" in the US are the collectors of the hundreds of arrowheads, Roman fibulae, Byzantine crosses and encolpions, finger rings, earrings harness bosses and military equipment fittings (etc.) which also come off these Bulgarian sites by the same process of metal detecting and bulldozing and are shipped to the US in the same containers as the coins and sold on the same internet venues. These collectors on the whole did not come out in "strong disapproval" of import restrictions. it seems they have more of a conscience than coin dealers and maintained an embarrassed silence, with only a few individuals weakly protesting that what they do does no harm to the European archaeological record (Mark Hogan: "I do not beleive that coins, bronze crosses, Byzantine religious metals, etc. should be classified as culturally significant").

Welsh adduces not a single shred of proof that (let's quote that again):

[DoS] 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

. Since the first meeting of the newly-constituted CPAC will be taking place a few days from now, I really do not see how they can have been "instructed" what recommendations to make. I suspect coins will be in the list, but not because Washington bullied Bulgaria into putting them there, but because the metal detecting of ancient sites for saleable minor objects for sale on the international market is doing unacceptable damage to archaeological sites in the region. The flow of coins onto the international market are part and parcel of that destruction. What is a more important question is how it is possible that in a nation which has a large educated middle class (though see above) and is a state party f the 1970 Convention, how the trade in coins and other artefacts which everybody knows have been coming from Bulgaria has been going on on such a scale
for so long without anyone doing the slightest thing about it. What image of the United States of America (freshly rejecting its obligations to UNESCO too) does all this present the outside world? Certainly not one that I'd be proud of if I lived and worked in archaeology there. Do something about it, wake up America. Take this trade down and all who are involved in it.

Vignette: What 'American' ideals lie behind the US no-questions-asked trade in artefacts taken without any kind of documentation of licit origins from foreign "source countries"?