Late SAFE Petition Drive Highlights Weak Public Response for Proposed Greek MOU

The State Department ran another all too quick comment period for the proposed Greek MOU. Coin collectors and dealers followed the State Department's directions for public comments. It was the all too usual scramble but it looks like some 70% of the public comments on the regulations.gov website were from coin collectors worried about the impact of an MOU on their hobby or coin dealers worried about the impact of the MOU on their small businesses. See
http://www.accg.us/News/Item/Summary_of_Greek_MOU_Public_Comment.aspx

The folks at Saving Antiquities for Everyone (SAFE) must be displeased with this result, and what it says about the nature of the support for the proposed MOU. See http://culturalpropertyobserver.blogspot.com/2010/09/coiney-win-in-comment-quest-exposes.html

What to do then? Well, if you don't like the result, change the rules! And it appears SAFE plans to try to do just that with an on-line petition, which SAFE will no doubt seek to submit to CPAC as "proof" of the actual wide-ranging support for the Greek MOU that SAFE members are certain exits, though it may be hard to find. For more about the petition, see http://www.savingantiquities.org/pdf/greecemouflyer.pdf

There are, of course, a few problems with this approach. First, the State Department Bureau of Educational and Cultural Affairs was quite clear about how and when public comments would be accepted. Everyone was working under the same time constraints as well as those imposed by the somewhat cumbersome regulations.gov website. If anything, the fact that the regulations.gov comments are available for all to see probably scared off some critics of the MOU and encouraged others who excavate in Greece to comment, even if they were actually lukewarm about the proposal. Second, there is no way to verify if the signatories to this petition are real people. Typical petitions used for official purposes require one to include an address or at least a town of residence. I'm not suggesting that SAFE is manufacturing names, but it is also true that there is no verifiable personal information on the face of their on-line petition. Finally, I note some petition signatories have also commented via the regulations.gov website, raising the issue of multiple "votes" for the MOU.

All in all, I would suggest this petition just highlights the proponents' weak response during the sanctioned comment period. SAFE would be well advised not to try to introduce this petition as "evidence" during the upcoming CPAC meeting, but if it does, I'm sure there will be objections, and for good reason.