CPAC Comment "Statistics"

.
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"?

AIA Leader Found "thinking" Coineyly

.
Wayne Sayles gives: "Kudos to a thinking AIA leader". He represents a CPAC comment from an AIA "leader" from Washington DC, a "blinding flash of light". Why? because he'd cut and pasted some of Peter Tompa's coiney nonsenses into this comment. According to Sayles this was

one AIA member who spoke clearly with an enlightened understanding of the situation on the ground and an obvious concern for truth. This gentleman, Gerard Casale, is a current member of the Board of Directors of the Washington DC Society (George Washington University) of the Archaeological Institute of America.

Because it contains so many Tompaisms, Sayles calls Dr Casale's account:

a very nice summary of the points that the ACCG and Numismatic Trade have made regarding not only coins from Bulgaria but from virtually all source countries that produced coins in antiquity.

It is indeed a very typical coiney text. I am unaware of the field Dr Casale specialises in, Google scholar is no help. I would not mind betting he collects coins.

Mr. Casale considers that since "coins from mints in what is now Bulgaria are both common and usually very inexpensive" this does not mean that they are looted on a massive scale. Even though there are already "tens or hundreds of thousands of these coins existing in collections around the world", he sees no reason to stop fresh imports of illegally exported (for that is what the 1970 UNESCO Convention and the CCPIA are about) into the US. The numbers of coins there already are "not enough' for him.

Furthermore, Casale adds they: "have never have been through an auction or other transaction where precise provenance has been recorded". Whoops, slight deviation from the Tompa prepared text. But Mr Casale WHERE in the CCPIA is any mention whatsoever mentioned of "provenance"? Where is an importer required to document "provenance"?

The hapless AIA "leader" goes on "Nor is it vital to the interests of scholarship inside Bulgaria that such provenance be demanded now". Eh? Who is demanding "provenance" for the "benefit of Bulgarian scholarship"? Has Mr Casale ANY idea what we are discussing here? This is an AIA "leader"?

More Tompaism still:

Regulations at 26 USC Section 2601 (2). provided that for an artifact to be restricted under the CPIA, it must be of both archaeological interest and cultural significance. These coins exist in many multiples, already well represented in Bulgarian state collections and are therefore not of cultural significance within the meaning of the rule.

If the AIA "leader" would read the Act (and let's give the proper reference, "Section 2601(32)(C)(1)(I)" with a little bit of understanding, he'd see it is talking about something else. Excavations produce many types of material which are of "archaeological interest", such as snail shells, pollen, charcoal samples and pig bone fragments. These are very interesting for an archaeologist, helping to reconstruct environment, diet etc. They are however excluded from the CCPIA by the above-mentioned Section 2601(32)(C)(1)(I) because they are not what would be termed "material culture". That's what that section means. Mr Casale can import as many Roman pig and horse bone fragments and charcoal samples as he likes bought on the black market and derived from looted Bulgarian, Greek, Italian and Cypriot sites for his studies. They are not covered by the CCPIA. That is what Section 2601(32)(C)(1)(I) does, likethe Art. 1 of the 1970 Convention, so badly misrepresented in US collecting circles ("the Article one lie").

Coins are indeed of "cultural significance", as it is one of the staples of the coiney argument that by their study one can learn so much about ancient cultures (this is the core of the coiney's "cultural property internationalism" arguments - that the study of other cultures is being prevented by "retentionism"). As archaeological evidence they too carry much cultural information - look at the mapping of celtic coins in the UK, the mapping of coins beyond the Roman frontiers in Scotland (or within them in Wales), or in eastern European barbaricum, the flow of Islamic silver and Merovingian gold in the Early Medieval period. It beats me how any INFORMED archaeologist could say that coins are not material culture, are not of cultural significance. That their removal from the archaeological record has no consequences for our understanding of the past and its cultures. I wonder what Mr Casale's field is, lithics?

The Tompaisms continue: Since ancient coins circulated widely beyond the borders of modern Bulgaria, even in ancient times, one cannot assume that all coins of Bulgarian types, “were first discovered in” Bulgaria, as required by the CPIA. (26 USC Section 2601 (2) (c).)
Well, again, let us give the whole phrase: "was first discovered within, and is subject to export control by, the State Party". So, I assume that Dr Casale accepts (he does not say) that items dug up and illegally removed from Bulgaria (ie shipped directly to the US from a culture-criminal in Bulgaria) should be stopped by US customs under the CCPIA, yes or no? Certainly if he says "no" then he would be in clear opposition to AIA policy over the illicit antiquity trade.

What about antiquity 'laundering'? How does AIA "leader" Dr Casale and his fellow supporters of a no-questions-asked approach propose dealing with that? What Dr Casale is saying is if a Bulgarian looter can dig up some stuff and put it in a car boot and drive across to - say - Thessalonika, it should be perfectly legal and proper to import it into the US on the grounds that it "was not actually shipped from Bulgaria"? Even if the objects quite obviously came from Bulfgaria (like a tombstone with an inscription identifying the burial site?). What about artefacts which are found exclusively, almost exclusively, most frequently on sites with the borders of modern Bulgarian territory? (Like some of the coin [and 'primitive-money'] issues of the Greek colonies there which were for internal use, like some of the provincial issues of the Roman period). Should US authorities simply shrug their shoulders to the 'laundering' of antiquities through their illicit transfer on their way to the US markets? We've seen the use of Free Ports in this sort of antiquities laundering before, we've heard that some dealers may have been using a middleman in Dubai to cover the origins of material allegedly looted from Egypt (and one of those dealers was expelled from the ACCG before his case even came to court), we've heard that material looted in surrounding countries taken across the borders is laundered by being exported from Israel with an Israeli export licence. Metal detectorists claim that material being sold as "British antiquities" on eBay UK comes from other countries where metal detecting is illegal, and thus being "laundered" through the British system. Basically if Tedor Kradets the Bulgarian metal detectorist finds a hoard of solidi of Honorius in the ruins of the principia of a Danubian fortlet in Bulgaria, sticks it in a hollowed-out pumpkin and drives it in his little car to Herman Munzenwangler the notorious Munich fence who sends it to auction in New York, there is basically no way that the US barrier of bubbles which is its border control is going to spot its illegal export. If the hoard was of silver issues of a local despot of limited circulation primarily within the area of modern Bulgaria, then yes, the US border authorities should be stopping it and investigating what this freshly surfaced material is doing on its way to the US market. If it gets through the barrier of bubbles, it would be nice to think that somebody in the US would still be investigating freshly surfaced material on the open market (but they don't, do they?)

So, Dr Casale ends up by saying lamely:

"Less severe remedies must be considered before import restrictions are placed on Bulgarian coins."

Why? What about the arrowheads, encolpions, pendant crosses, finger rings, harness bosses, military fittings, earrings and all the rest of the Roman bric-a-brac metal detected on Bulgarian sites being sold at this moment [by the kilogramme some of it] by US sellers on ebay? What remedies can the US (the US) apply to deal with this? Why should the US NOT do something to resolve this scandalous discrepancy between what it says it will do (as a state party of the 1970 UNESCO Convention - see its article 3) and what it actually does?

I imagine we can all think of more severe remedies (involving questioning of dealers and collectors, detentions, arrests and seizing of computer hard discs and business records) that would certainly do more to resolve this problem. Most coin collectors seem happy to quote the report linking the trade in this material and organized crime networks, which seems sufficient reason why Homeland Security and the FBI should be looking very carefully at this trade which it seems they've virtually ignored (say it ain't so) for all these years.

It seems to me that US customs examining import documentation to check the proper export procedures have been followed is not exactly a measure that could be termed either "severe" or "drastic". Especially as all coin dealers say they are responsible and respectable businessmen who do everything they can to avoid dealing in smuggled and looted artefacts.

Sayles ends:

The statement of Mr. Casale is not only a ray of light, it is a very brave appeal for reason. I sincerely hope that it does not come back to haunt him.

Well, let us reason through it then. I invite his reply here.

The Heritage of Heritage Salvage

.
Over on Meg Lambert's blog is posted a comment which merits drawing attention to. It highlights the problems of treating unique archaeological complexes as artefact mines. The text is a report of Mr Agus Sudaryadi (Coordinator for Underwater Archaeology, Office for Cultural Heritage Preservation of Jambi, Ministry of Culture and Tourism, Indonesia) referring to The Belitung shipwreck site after commercial salvage in 1998

The Belitung Shipwreck Site, located at 17 m depth in Belitung waters, Indonesia, is a shipwreck site containing Tang Cargo Treasure that was lifted by private salvage companies, PT. Sulung Segara Jaya and Seabed Exploration Company in 1998. The salvaging process [wa]s done without involving Indonesian archaeologist. The ship is an Arab dhow with 15.5 m long that includes 60,000 pieces artifacts from Tang Dynasty period. At present these artifacts are under the management of Singapore Sentosa Leisure Group. In 2010, the Office for Cultural Heritage Preservation of Jambi conducted the first underwater archaeological survey at the Belitung Shipwreck site in order to find out the recent conditions of the site after salvaging in 1998. The result shows that the site is extremely ravaged, where unidentified ceramic fragments spread out in a radius of ± 20 m². It seems clear that the ceramics fragments have been removed by the company then thrown back into the sea because they were considered non-commercial. Meanwhile, the shipwreck was not found anymore. It was only a big form hole with 6 m wide and 15 m long, which seems to be the ship place. The remaining wrecks are now just a few small wood fragments and a sizable chunk of wood sitting, seems as a mast foundation.

Coiney Lassitude

.
The final batch of coiney "protests about the expected inclusion of ancient coins in the forthcoming Memorandum of of Understanding whose details have unquestionably already been negotiated with Bulgaria" have yet to appear on the US government website where public comments were sought. At the moment there are 355 comments, so a final total of about 500 (assuming a spurt at the end) seems likely. So that's about a quarter of what it has been before. Perhaps coineys are becoming wise to the tactics of the dealers who try to coerce them into campaigning on their behalf by alarmist claims which do not tally with the facts. Perhaps they see that the ACCG is leading them down a path which can only lead to the whole milieu being compromised through association. If 48000 collectors remained silent before, now we see 49500 unwilling to raise a voice in support of importation of illegally exported coins. The number of commentators holding out for no-questions-asked dealing of the worst kind is now just 1% of the estimated 50 000 collectors in the US.

"There's Big Money And The Need For Reform In The Antiquities Trade" - Forbes

.
Robert Lenzner writing in Forbes magazine notes that "Theres Big Money And The Need For Reform In The Antiquities Trade". He writes that the "number of newly minted billionaires everywhere including Russia and the Middle East means more would-be collectors wanting to show off the fruits of their fortunes on the walls or alcoves of their palatial homes". He reports on a conversation he had with an old friend Peter Aldrich, a retired real estate investor from Boston who is a Trustee of the Museum of Fine Arts in Boston and a donor there ("who began collecting Greek and Roman artifacts in emulation of the late Leon Levy and his wife Shelby White (donors of the new Greek and Roman galleries at the Metropolitan Museum of Art in New York)". Aldrich told him of his concerns about the cultural heritage of the ancient civilizations which form the body of the Forbes article (discussed in this post) and then sets forward some ideas about reforming the antiquities trade (discussed in my post below this). Aldrich writes:

Watching the Greek financial meltdown, and the struggles of a society fighting a diminished standard of living made me realize that an unintended consequence of the crisis will most probably be the acceleration of the despoiling of Greece’s treasured “cultural heritage”. Not only will the government cut the already meager expenditures for conservation and preservation in its museums, but certainly what little policing of archeological digs that exists will disappear altogether. But even more worrisome will be the desperation of rural households that will lead unemployed men to crawl back underground to find the treasures of the past, at night, in secrecy, illegally to harvest what “belongs to everyone” and is managed by no one. Black markets are fueled by desperation, greed, neglect, and ill-conceived prohibitions. Greece is about to have all in abundance.

Black markets are instead primarily fuelled by the people who will buy commodities on it. We note the trotting out of the "ill conceived prohibitions" argument so favoured by collectors in the USA. Are all attempt to regulate something by their nature "ill conceived" if they stand in the way of the greedy and the commodity they want, be it booze, kiddie porn, elephant ivory or an armoury of AK47s? Surely one way to help Greece cope with the problems ahead (of which artefact smuggling is one of the least important - which does not mean we have to fold our arms and let it happen) is surely stop people buying the proceeds. Increased border vigilance all round.

Aldrich reports that when he set out to buy "museum-quality ancient art from private hands", instead of the lofty aims he claims he had, he "received an expensive education about the destruction and looting of historically significant artifacts and the illicit international trade in antiquities":

I found that the current market system stimulates, enables and creates looters, black marketeers, and unscrupulous middlemen, dealers and purchasers. Sadly, the more that nations claim ownership of all “cultural heritage”, and the more they attempt to prevent trading of such, the greater becomes the corruption and level of violence in those suppressed markets.

Really? So, again, the fault is on the side of those that try to stop something bad going on, rather than those involved in it? I do not see the logic in that. It is like saying kiddie porn and rhino poaching are the fault of the lawmakers who try to stop them. Ergo, if we legalised them, there would be no problem, no incentive for corruption. But then who'd protect the abused children? What about the dead rhinos? Aldrich uses the term "radical archaeologists" does he also consider that those who oppose child pornography and rhino poaching "radicals"? It seems to me Aldrich sees here loose artefacts, and does not see the trashed sites they come from. He thinks the aim of legislation is solely to "retain artefacts" rather than prevent them being dug out of otherwise unthreatened sites.

Thus he proclaims:

The process of preserving antiquities, so crucial to our understanding of history, demands a plan for the sensible discovery and preservation of cultural heritage...

...by which it seems clear he means only loose artefacts, collectable antiquities. Let's take a look at this "cunning plan" in the next post.

UPDATE 4th Nov 2011:
David Gill also discusses this text from a slightly different angle: "Trustee of Boston MFA talks of the joy of collecting". I had not realised that the "something I wrote earlier" had actually been published. Gill has some background information on "Aldrich's association with recently-surfaced (and returned) antiquities" which he says makes it hard to take his seven point plan to reform the antiquities market seriously.

Perhaps a more [sic, surely" "less" PMB] radical solution would be for collectors like Aldrich to insist on seeing properly authenticated documention before making their acquisitions. And in this spirit, I hope that he will publish the full collecting histories of the objects in his collection and include the pieces that he has donated to public museums.

Seconded.

Mr Aldrich's cunning Plan to Reform the Antiquities Trade

.
In the article discussed above published in Forbes, collector Peter Aldrich makes a number of suggestions in a "seven part plan to modernize and reform the antiquities trade" which merit comment. The first point is that most of them do not refer to reforming the TRADE at all, but nations facilitating it rather than protecting sites from looting. The collector suggests that his plan "would only work if it were based on solid grounds in economics and ethics, and were applied by all UN member countries, and by local governments, courts, universities, and archeological communities". Note that collectors do not figure in this list, it is just everybody else who is required to go along with it which is a pretty typical attitude from the milieu. So what are these "solid ethical grounds" and to whom do they apply if not to collectors?

1. The first step would be to amend national laws to vest primary ownership of subterranean treasures with the proper owner of the land where the find is made.

2. Each nation need govern the conduct and supervision of excavations, create procedures and fees for issuing recordable “provenance” deeds, license conforming archaeological digs, and determine what sensible “partage” (portion of the finds) should belong to the state. (The greater the State’s share, the higher the incentives by all toward cheating, and ultimately violence and corruption.)

If anything in the ground belongs to the landowner and the state has no say in what happens to it, what is to prevent the owner simply destroying any site that happens to be in the way of his swimming pool, supermarket, sewage disposal plant, gravel quarry, or digging up destructively and flogging off to collectors? The laws which assign curation of the buried archaeological record to the state in many countries are there for a purpose.

Mr Aldrich clearly sees excavations as artefact mines, rather than a controlled investigation of stratigraphic context. Like most collectors he has very foggy ideas of what archaeology is all about ("..'s all about diggin' up fings innit?"). His first and second points are mutually exclusive as written. How does Mr Aldrich intend the state "governing" the way a landowner digs up his own property on his own property? The word "partage' has a different meaning. What he means is vesting legislation. In what way is a fee payable for "provenance"?

3. Each nation would establish a registry, akin to a land registry, for the issuance and control of the deeds to properly registered cultural heritage artifacts.

Again, if sole ownership is vested in the landowner, who assigns "deeds" and on what legal basis? Who pays for the maintenance of such a register of thousands of individual objects? The taxpayer of each nation? What happens when an object leaves that country and goes to another, where is it then registered? What happens to all the objects currently in collections ("since the days of Petrarch don't ya know?"), how do they get registered and on what grounds?

4. The nations would be well advised to regulate and tax all trade in deeded cultural property. Every change in ownership would need to be recorded (and presumably taxed). Tax proceeds could finally give poor countries the resources to administer vigilantly the business of discovering and displaying cultural heritage. Landowners would now have the state as an ally rather than an enemy. All trade in untitled assets would remain illegal. Regulations could create a mechanism to prohibit the export of significant national treasures, with fair compensation to the registered “owners”.

This is wholly unclear in the light of the first point. Why would the changes in ownership have to be recorded if objects belong to the owner of the land on which they were found? By what law would the state mandate such a registration, and declare illegal the selling of a landowner of his own property? Likewise, how is collecting tax on registered items going to encourage their registration? Again, what about objects in collections before the institution of these registers? Who pays for them to be registered, so when they are sold a tax can be gathered on the transaction? In what way will the private ownership of unregistered artefacts be controlled? Let us note that the collector sees these taxes going, not to the preservation of the archaeological heritage from looting, but the "business of discovering and displaying cultural heritage". So we are back to the "archaeological record as an artefact mine" model.

In point 2, does the 'partage' not account for the disposition of 'significant national treasures'? Surely the collector should be aware that such regulations already exist.

5. All excavations would be best if conducted under the direction of qualified and licensed archaeologists skilled in not only the art and discipline of excavation, but also in the administration of proper title and deed registration. Finally, funds from taxes would be able to create real and exciting fieldwork for hundreds of trained archeologists.

I am not sure what to call an excavation carried out by an archaeologist who is not qualified in "the art (sic) and discipline of excavation". Looting probably. Archaeology is not the partitioning of the excavated archive in the hands of private collectors, deeded or not. That is not archaeology. Who is going to look after the snail shells, animal bone fragments, slag samples and waterlogged wood from any decent excavation? And the excavation records? Obviously the collector fails to realise that the aim of protecting sites is not to use them all up, no matter how opportunistically and exciting that may be. Again, though the archaeologist is presented here only in the role of artefact miner, getting the excitement of the "find" which is then sold off to collectors.

6. States could also create public “heritage trusts” with the proceeds from the sale of antiquities. This would give the public a resource for preserving, studying, and displaying its own antiquities.

Oh, look. The PAS. Paid for by ripping up the heritage for saleable artefacts. But wait, how does the state get to be selling the "antiquities" if they belong to the landowner (point 1)? What kind of state-funded "heritage trust" does the US collector actually have in mind? How would it be constituted and what would it do?

7. Landowners, tenants, farmers, and developers would be compensated by the state, or its “heritage trust”, for the expenses and lost revenues arising from excavations.

Well, again, totally at odds with the first point. If the landowner owns all the loot, then surely costs are recouped by selling the loot to collectors, and the archaeologists in this model are just there to mine the stuff and issue the authenticity certificates. So let me get this right, instead of developers paying for the excavations their development necessitates, the state is going to pay them, they get the land free of archaeological encumbrances and the collectors get the finds? And the archaeologists get... what precisely? Who pays for their work and from what? Suppose the site is a flint knapping site with few whole tools, and the sale of the artefacts raises a few hundred dollars, but the excavation and post-excavation work costs tens of thousands of dollars and at the end there are no displayable artefacts for the local (or site) museum because they've all been sold off by the state? Where is the sense in that?

Mr Alrich says that his plan

"could beneficially reform the structure and economics of the antiquities markets, lower the level of violence and corruption that afflicts poor and rich countries alike, and increase dramatically the employment and research opportunities of the archeological profession".

One of the things it does not even set out to do is protect sites from artefact mining. I do not see here any evidence that the "structure' of the antiquities market would be altered, since it claims to be dealing all the time with "material from old collections" and until every single piece worldwide is entered onto an Aldrichian register, there will be no change in the amount of fresh material entering the market and masquerading as such. The creation of a register of this material should be given priority over any legislative changes leading to any massive influx of new material onto the market.

Likewise I cannot see how increasing the material coming onto the market from every new excavation will improve the economics of the antiquities market. it will lead to a fall in the cost of antiquities which would no doubt delight the collector, but dealers with overheads will have to seek a wider and wider market to meet them. The scale of damage caused by collecting will again increase.

The "level of violence and corruption" engendered by the antiquities market is a matter for the police, not an excuse for adopting an "anything goes" approach so that thieves get what they want without coming into conflict with the law.

There seems little point in dramatically increasing (sic) "the employment and research opportunities of the archeological profession" if that profession is to be reduced to the level of artefact miner for the antiquities trade. If we wanted to prostitute ourselves, I can think of more comfortable places to do it than the middle of a muddy field. Not all archaeologists are prostitutes - though Mr Aldrich may consider us "radical" for not taking this way in life.

Aldrich considers his plan would restore the "joy and honor" to collecting. But at what cost? What about the millions of people who are also stakeholders in the past and yet are not collectors. What does the Aldrich model offer them? The opportunity to become history gobblers too?

I wonder whether Forbes sees everything in such simplistic and black-and-white tones as is presented in this article they have just published?

Fox News: Benghazi Treasure, "One Of The Biggest Heists In Archaeological History"

.
It is difficult to sort out fact from hyperbole here. Fox news describes the theft from a bank vault of this "Treasure" "One Of The Biggest Heists In Archaeological History", while archaeoblogger Dorothy King tries to play down the nature of the missing objects. Here is a selection of the news items where this is being discussed, the newspapers seem to be making a bit of a meal of the loss of two boxes of stored artefacts:

Martin Bailey, 'Interpol confirms Libyan treasure was looted', The Art Newspaper 31 Oct 11

BBC News, 'Looted Libyan treasure in Egypt', 31 October 2011 ("Libya's National Transitional Council says it believes several hundred ancient coins stolen from a bank in Benghazi during the Libyan uprising have turned up in Egypt").

Brian Rohan, 'Hunt is on for treasures looted in Libyan uprising', Reuters, Oct 30, 2011.

Fox News, 'Treasure Of Benghazi Stolen In One Of The Biggest Heists In Archaeological History', November 2, 2011.

Voice of Russia, 'When the cannons roar, the muses stay silent', November 2, 2011

ABC News, 'Hunt on for Libya's looted treasure', October 31, 2011

UPI.com, 'Treasures stolen from Libyan bank', November 2, 2011.

Huffington Post, 'Priceless Libyan Treasure, Including 7,000 Ancient Coins, Plundered In Benghazi During Uprising'
November 2, 2011

Dorothy King, 'Antiquities Missing From Libya', October 31, 2011.

What I think is worth noting is that among the stolen objects are a lot of coins, and while the artefacts might be difficult to pass off on the market, due to the nature and state of the market, the seller of the coins seems likely to have no problems at all in getting rid of them.

Vignette: Benghazi is associated with goats in a private old archaeological joke.