Dear Prof. Gerstenblith and CPAC:
I am writing on my own behalf, and will be submitting comments on behalf of IAPN and PNG shortly. CPAC recommended against import restrictions on Cypriot coins twice. There is no reason for this to change, and if anything, there is every reason to recommend that the current MOU with Cyprus be terminated.
As to coins, scholarly evidence proves that one cannot assume that coins of Cypriot type only circulated within the Island as has been claimed to justify restrictions. If one cannot assume that Cypriot coins only circulated on the Island, one cannot legally impose import restrictions which by law must apply only to artifacts first discovered in and be subject to the export control of Cyprus.
Moreover, there is no reason to renew the MOU for another 5 years. Cyprus has already had the benefit of restrictions since 1999 on ethnological artifacts and 2002 on archaeological artifacts. Cyprus claims that restrictions are needed because of looting on the occupied side of the Island, but a Swiss scholar who has studied the issue indicates most looted material from both the Turkish and Greek sides of the Island goes to wealthy Greek Cypriot collectors, and not as has been maintained to collectors abroad. In addition, all this appears to be done with the full knowledge and acquiescence of Greek Cypriot authorities. Under the circumstances, why should the US burden its own citizens and small businesses with such restrictions? To do so will only reward Cypriot authorities for their own considerable hypocrisy and thus make a mockery of the supposed purpose of such MOU’s to protect archaeological context.
Thank you for your consideration of my views.