Professor Gerstenblith and Committee Members,
We should all be troubled that both the New York Times and Egyptian state media have already proclaimed that a MOU with Egypt is a “done deal” and what that says about our own State Department which is so fond of lecturing the Egyptians and others about “democracy” and “rule of law.” Even without such news reports, the dubious proximity of this request to Egypt’s much criticized presidential election should pose a basic question: Is the aim of this MOU to foster cultural heritage preservation or to help “legitimize” General Sisi and his government by recognizing its rights to control all artifacts from Egypt’s glorious past?
The archaeological lobby portrays import restrictions as a necessary expedient to protect Egypt's cultural patrimony. But, from whom or what? “Cultural racketeers?" No! Actually, poor stewardship, corruption and an absolutely Pharaonic view of state ownership devalues artifacts so thoroughly within Egypt itself that they are either destroyed or smuggled from the country, presumably more often than not with "inside help."
Frankly, Egypt is such a mess, restrictions won’t help there, but they will certainly damage small businesses and collectors who cannot come up with documentation necessary to import minor artifacts that typically don’t carry any provenance information. So, at most, CPAC should only recommend restrictions on Pharaonic material of cultural significance and site specific material from later “foreign” Hellenistic, Roman and Islamic cultures.
Of course, coins should be exempted, and not only because import restrictions on them impact the most American citizens. First, there is no indication metal detectors are in widespread use in Egypt, so it is highly unlikely that coins are being illicitly excavated there in any significant numbers. Certainly, no large influx of ancient “Egyptian coins” has arrived onto our shores since the Arab Spring degenerated into first Islamic and now military dictatorship.
Second, individual coin types typically exist in many multiples. It’s hard to conclude they are generally “of cultural significance” under the Cultural Property Implementation Act. And please, let’s not conflate “archaeological interest” with “cultural significance.” They are two distinct things.
Third, the CPIA only allows restrictions on artifacts "first discovered within" and "subject to the export control" of Egypt. “Closed monetary system” or not, Alexander, the Ptolemy’s, the Byzantines, and the Ottomans all struck coins in Egypt for use throughout their Empires which encompassed land both inside and outside the confines of modern day Egypt. Maps don’t lie. Look at this one of Ptolemaic “Egypt.” It stretched into Libya, Israel, Lebanon, Syria, Cyprus, and Turkey. And this one of Hellenistic coin finds of Alexandria Mint coins. It shows coins found throughout this Empire and beyond. Seeing is believing.
While a “closed monetary system” argument may be of greater validity when we speak of Roman Egypt, new research based on finds recorded under the Portable Antiquities Scheme also demonstrates that Roman Egyptian Tetradrachms --which had the value of one Roman silver Denarius-- travelled as far away as Britain. I’d also refer you to the public comments of numismatist Shawn Caza (ID: DOS-2014-0008-0247) which speak about finds of similar coins in Germany, Denmark, Switzerland, Austria, Belgium, Morocco, East Africa, Central Europe and the then USSR. Roman Egyptian Tetradrachms—like their Greek counterparts that have been exempted from import restrictions –also appear to be items of international commerce. Certainly, there can be no issue at all about the few Roman Imperial coin types –denarii and late Roman bronzes—also struck at various times in Alexandria. Like similar coins struck elsewhere, they circulated throughout the Empire and beyond.
And what of the notion that all that really matters is that such coins may said to be found “predominantly” in Egypt? First, we would question any such factual assumption based on any limited evidence that may be provided. Second, the plain meaning of the CPIA requires more—that such coins are only found within the confines of modern day Egypt. CPIA Section 2604 requires that designated lists can only encompass material covered by a particular agreement, i.e., “first discovered” there.
So, despite any pressure to “Say yes to Egypt,” please pay heed to facts, the law and the 91% of the public comments which either oppose the MOU or the extension of restrictions to coins. If we really want to be models to Egypt for what “rule of law” and democratic process means, you can do nothing less. Thank you.