Now, however, the State Department is inviting public comment about the Greek MOU on the following website: http://www.regulations.gov/
The website is user friendly. To comment on the Greek MOU, go to the site and type DOS-2010-0339 into the box under "enter key number or ID." Then, on the "search results" page, click on submit a comment, and fill out the form as directed.
More detailed instructions can be found on the Cultural Heritage Center web page at http://exchanges.state.gov/heritage/whatsnew.html
All comments [which can be read by others] must be posted by 9/22. Comments should generally relate to CPAC's determinations as set forth further on the above website.
Coin collectors may want to consider discussing the following points:
- The governing statute requires that restrictions only be applied on artifacts "first discovered in Greece." But hoard evidence demonstrates that Greek coins circulated extensively outside the confines of the modern Greek nation state.
- The governing statute requires restrictions only be placed on artifacts of "cultural significance." But coins -- which exist in many multiples-- do not meet that particular criteria.
- The governing statute requires that less drastic remedies be tried before import restrictions. But Greece has not tried systems akin the the UK Treasure Act before seeking restrictions.
- The governing statute requires that restrictions be consistent with the interests of the international community in cultural exchanges. But restrictions will diminish the ability of American collectors to appreciate Greek culture and could greatly limit people to people contacts with other collectors in Europe.
- Restrictions are unfair and discriminatory to Americans. Collectors in the EU--including Greece-- have no similar limitations on their ability to import ancient coins.