"Coiney" Win in Comment Quest Exposes Greek MOU as Limited Special Interest Program

The regulations.gov website has recorded 1347 public comments on the Greek MOU. Archaeo-blogger Paul Barford reckons that coin collectors and dealers (or "coineys" as he prefers to call them) were responsible for the clear majority of this number.
See http://paul-barford.blogspot.com/2010/09/numbers-numbers-public-submissions-on.html

Based on Barford's estimates and a quick look at the submissions on the last day for comments, it looks like coin collectors and dealers achieved numbers close to the 1100 who commented on the Cyprus MOU back in 2007. See http://www.accg.us/news/item/Note_from_ACCG_president.aspx

Though this number falls short of the 1900 or so who commented back in May on the Italian MOU, I suppose "comment fatigue" and the somewhat cumbersome nature of the regulations.gov website (at least compared to the ACCG Fax Wizard) might have something to do with it. In addition, it is quite possible that the fact that one's comments are posted on-line for all to see might have discouraged some.

Perhaps more significant is the fact that so few individuals commented in favor of the MOU. The AIA claims 200,000 members (from subscriptions to their Magazine). Yet, only 400 or so wrote in support of the AIA's appeal. Of those, many excavate in Greece. And it appears many of these individual only decided to comment after a direct appeal from the Greek Embassy. See
http://culturalpropertyobserver.blogspot.com/2010/09/greek-embassy-urges-us-archaeologists.html

Given these small numbers and the fact that some of the proponents might have felt compelled on some level to comment, one can only question the claim that "the proposed MoU will benefit the Greek nation, the American public, as well as citizens of all countries who value knowledge about the past." See http://www.prnewswire.com/news-releases/looting-matters-protecting-the-archaeological-heritage-of-greece-102628664.html

Rather, the broad proposal as made in the Federal Register Notice for import restrictions on everything and anything "Greek" from Neolithic times to the 18th Century should now be seen for what it is: a State Department Bureau of Educational and Cultural Affairs special interest program for archaeologists that excavate in Greece and the Greek cultural bureaucracy that offers them excavation permits.

That is not to say US law enforcement should not help Greece. Customs and Border Protection ("CBP") already has ample authority to seize smuggled or improperly declared artifacts, including coins. CBP can also seize artifacts stolen from museums or other collections. Finally, Courts have already blessed efforts to repatriate artifacts traced to illicit excavations in another country where that country has unequivocally declared such material to be state property. In the appropriate case, CBP can, therefore, already seize coins or other artifacts taken from archaeological excavations in Greece and repatriate them to Greek authorities.

Simply put, import restrictions, and their effect of treating artifacts as "presumptively Greek" are not only controversial for their impact on legitimate collecting, they are also largely unnecessary if one is ONLY interested in preserving Greece's archaeological sites. And given the exceptionally low level of discernable public support for the MOU, are such controversial new import restrictions and all the problems they visit on CBP, collectors, dealers and museums really worth it or is it time to negotiate a MOU collectors, dealers, museums and archaeologists can all live with?