Paul Legutko Defends Coin Collecting

US collectors of dugup ancient coin do not see antiquities smugglers as their enemy, rather it is those that want to curb antiquities smuggling (personified in their cardboard cutout world as "archaeologists") who are portrayed as the enemy. So it is that the editor of Coin World magazine ("Balancing cultural property protection and private collecting") is gratified to see that an archaeologist wrote something in the public comments on the proposed MOU and sees this as some kind of vindication for opposing US measures against antiquities smuggling. Dr Paul Legutko (Polish name) wrote:

I hold a PhD in classical archaeology and have taught at Stanford University, Berkeley, and U of Maryland. I have participated in archaeological excavations in Greece and Italy. I am also an avid collector of ancient Roman and Greek coins. 

Yup. Coiney classicist. Uh-oh. Dr Legutko, he did his PhD at Michigan in 2000, after his three-year postdoctoral fellowship at Stanford University has been working for a search engine marketing company called SEMphoni (here's his blog). His excavations (Agora and Paestum) seem to be restricted to his student years. Anyway, what he writes in defence of ancient coin collecting is way off mark when considered within the narrow frame of what the CCPIA defines as the subject of the public contributions. From what he has written, he has not read the notice at the head of the docket. In addition, here is another one who's not actually read the MOU and designated list (designated List pub. in the Federal Register by the Department of the Treasury on January 23, 2001, amended Designated List - published in Federal Register by the Department of the Treasury on January 19, 2011) which he is writing about. He seems to think that the CPIA is in some way intended to curb "the private ownership of antiquities", rather than what it actually is intended to deal with (about which he says nothing in his contribution).  He writes: 

 It is usually impossible to prove that any given coin was illegally or illicitly excavated from a specific site.  Many of these coins were not struck in what is now Italy, but rather in diverse parts of the Roman Empire. Much of the metal in these coins came "originally" from Spain or Africa, or as a result of conquest. To take this line of reasoning to its absurdity, should Italy now return to Israel any coins it struck in the wake of the fall of Jerusalem in 70 AD?

Yes, Dr Legutko, you are being absurd because the 1970 UNESCO Convention quite clearly was never intended to apply to this. As for the rest of what you wrote which the editor of Coins Weekly finds so fascinating, firstly if you had first read the CCPIA, you'd have seen it's nothing whatsoever to do about which "specific site" anything was dug up on. The CCPIA (like the convention it implements) is about exports and imports and little else. Secondly, the specific coin types that are included on the designated list were chosen specifically because their place of production and circulation was limited and their significance to the local culture of Italy. Where the metal came from is wholly irrelevant to anything we are discussing here. All the rest of the stuff you write is wholly irrelevant to 19 U.S.C. 2602 which is what you were asked to comment on.