Comments on the Bulgarian Request: Why Bother?

The State Department has announced another short comment period for proposed import restrictions that may include coins from Bulgaria. See http://exchanges.state.gov/heritage/whatsnew.html

Given recent import restrictions imposed on coins from Italy and Cyprus though, why bother to comment?

Coin collectors and members of the small businesses of the numismatic trade have certainly dominated public comment when import restrictions on coins have been at issue.

Most recently, 1347 individuals commented on the Greek MOU on the regulations.gov website. Of these, approximately 70% (942) opposed the MOU or its extension to coins with 30% in favor (404). Virtually all those opposed were coin collectors.

The next most recent request was the renewal of the Italian MOU. A FOIA request reveals that while some 2000 collectors opposed the extension of import restrictions to coins only some 13 or so comments were in favor of it. (About 100 public comments favored an extension of the MOU but did not mention coins).

Prior to that there was Cyprus. If memory serves, there were some 1200 or so public comments against import restrictions on coins generated in a short 10 day comment period.

Yet, based on recent trends, I can certainly see how some might question whether public comment really matters when the State Department Cultural Heritage Center seems to be run as little more than an adjunct of the AIA and the rest of the State Department bureaucracy seems to value the wishes of foreign cultural bureaucracies over the interests of American citizens who collect and deal in ancient coins.

Indeed, despite the lopsided number of public comments opposed to import restrictions on coins, the fact that such coins had been exempted before and the recommendations of CPAC, the State Department bureaucracy nonetheless recently imposed new import restrictions on Greek, certain Republican and city coins of "Italian types." Yet, despite the calls from the AIA, no import restrictions were imposed on most Roman coins.

While an MOU has agreed to with Greece, we still do not know whether coins will be included in any restrictions.

And as for Cyprus, import restrictions were indeed imposed despite the number of public comments and CPAC's recommendations, but only after behind the scenes lobbying evidently convinced the State Department's third ranking official, Nicholas Burns, to take up the archaeological cause.

So do comments matter? I think they do, despite the fact that the deck appears to be obviously stacked against anyone not associated with the archaeological community.

At a minimum, public comments do show the State Department bureaucracy that real people do care about this issue, and hence perhaps do some good in moderating outcomes.