Tuesday, July 11, 2017

Comment Fatigue Can't Mask Special Interest Nature of MOU Program

Given the short (7 day) comment period over the July 4th weekend, CPO is not too surprised that there were so few comments posted on the regulations.gov website concerning a proposed MOU with Libya:  https://www.regulations.gov/document?D=DOS_FRDOC_0001-4160

After eliminating duplicates and a few unclear comments, it appears that only 19% or 7 of the commentators supported the MOU with the remaining 34 opposed in whole or part.

Four of the proponents represented group interests.  Of these, one was a University and another was an archaeological group that also is a State Department contractor.  Six trade associations or collector advocacy groups were among those opposed to any MOU in whole or in part.  Most of the individual comments came from coin collectors or dealers.

No doubt some proponents will spin these the low numbers as a lack of public opposition to any MOU.  But what really should be asked is whether the whole enterprise is really nothing more than a special interest program for archaeological groups either tied to source countries where they excavate or the State Department which funds them.  Maybe there needs to be a rethink whether scarce State Department resources should be earmarked for other programs that further our national interest or promote American business abroad.


Wayne G. Sayles said...

The general public's painfully weak response to this call for comment, a growing trend it seems, could tell a story. On one hand, collectors, dealers and those who just love the past are perhaps fed up with time-wasting efforts to enlighten the bureaucracy. Everyone seems to know where an MOU request is headed these days before it's even announced. CPAC doesn't matter, truth doesn't matter, law doesn't matter, justice certainly doesn't matter and arrogance reigns supreme in the world of Cultural Property Nationalism. An even weaker response here from the Archaeological community and proponents of MOU sanctioned import restrictions might represent among their rank and file a complacent view of the endless drumbeat. On the other hand, among some, it may also reflect such blatant self-assuredness that they feel little compulsion to act. In any case, the whole process has seriously drifted from the intention of Congress in 1983 and the prospects of fidelity to the law as negotiated and enacted are depressingly bleak these days. The Rule of Law has become the Law of Rule.

John H said...

Hi Peter:

WGS has it right on the nail once again, exampled by the following 24-carat tosh from one clearly proficient in Junior Common Room politics:-

"...portable antiquities collectors are notable for not being able to see things clearly through the intellectual fog that clouds their brains, they prefer to 'touch the past' rather than think about it. Every few days the internet provides yet another example to confirm this general rule. Peter Tompa, one would have thought, would be better equipped than most, he has a degree and wears a suit."

Clearly, the ignoramus who penned that drivel ought to follow your example, by getting himself a degree closely followed by a suit; then by his own criteria he will be "better equipped" to engage with the adults in debate.

Don't hold your breath.

Best regards

John Howland
UK Collector, Relic Hunter & Detectorist
(with 20/20 vision too)