CPO counted 326 responsive comments on the regulations.gov website (not 321 as stated). Of this number, 308 either opposed renewal of the Italian MOU and/or restrictions on coins. The vast majority of these comments again come from coin collectors. Of the rest, 3 comments from museums and/or the AAMD supported the MOU with reservations. Another 15 from academics (most of whom likely depend on the Italian cultural bureaucracy to issue them excavation permits), bloggers associated with the archaeological lobby and an archaeological advocacy group (Lawyers Committee for Cultural Heritage Preservation) supported the MOU unequivocally.
By CPO's count that means approximately 94% of the public comments posted on the regulations.gov website either opposed the renewal of the MOU and/or restrictions on coins. While it's possible CPAC also received other comments by mail (one anti-collector academic has apparently used this method to avoid public scrutiny in the past), it's unlikely that there was a large number of such "off the record" comments.
The large percentages of the public comments opposed to MOUs that negatively impact coin collecting has been consistent over the past several years though the absolute numbers of those commenting has declined markedly over time given the equally widely held public perception that the State Department could not care less what collectors think. CPO nonetheless continues to believe silence will be taken as acquiescence so public comment remains important.
In any event, the low numbers of public comments supportive of MOUs and the fact that most comments come from academics with a vested interest in keeping the foreign cultural bureaucracies that issue excavation permits happy should raise another important question: Are MOUs merely a special interest program for a small group of politically connected academics and the foreign cultural bureaucracies they do business with?
Monday, March 23, 2015
94% of Public Comments Posted on Regulation.gov Website Opposed to Renewal of Italian MOU and/or Restrictions on Coins
Posted by Cultural Property Observer at 1:20 PM
Labels: AAMD, ancient coins, Collectors, CPAC, Import Restrictions, Italian MOU, State Department
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"Are MOUs merely a special interest program for a small group of politically connected academics and the foreign cultural bureaucracies they do business with?"
The People have spoken and the answer is a resounding YES. There will be a wailing and gnashing of teeth is the usual quarters followed by an outpouring of face-saving lies and propaganda.
In the wake of this victory, we must take another step forward to prevent, at all levels, the tail from wagging the dog.
John, thanks for your comment and that of Dick on regulations.gov. Every comment helps.
Yes, Bob Korver, who resigned CPAC in protest when they put restictions on coins of Italian types without CPAC's knowledge or consent, made the observation that the tail was indeed wagging the dog when the interests of a few academics and their government sponsors were put ahead of the interests of many coin collectors and the law for that matter. Anyway, thanks again.
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