Low Public Support for MOUs with Bulgaria and China

There are 67 comments posted on the regulations.gov website following the close of the exceptionally short 4-day comment period regarding proposed MOU renewals with Bulgaria and China. CPO reviewed 63 different comments which suggests that 4 were duplicates. All the comments can be reviewed here:  https://www.regulations.gov/document/DOS-2023-0016-0001

 The vast majority (51) were from coin collectors or members of the small businesses of the numismatic trade. The coin collector and dealer organizations that opposed the MOUs or their application to coins were the American Numismatic Association, the Ancient Coin Collectors Guild, the Anti-Counterfeiting Task Force, and the International Association of Professional Numismatists. Each submitted detailed comments in support of their position.   

 Three groups opposed the China MOU, the Committee for Cultural Policy (CCP), Global Heritage Alliance (GHA) (1 combined submission), and the Uighur Human Rights Project.  

The CCP and GHA have already posted their comments on the Internet here:  https://culturalpropertynews.org/special-report-2023-china-mou-building-chinas-art-monopoly-and-destroying-minority-culture-and-identity/

There were a mere 5 comments supporting the MOU with Bulgaria and only 4 supporting the MOU with China.  The Antiquities Coalition submitted an additional comment that supported both MOUs.  The Archaeological Institute of America supported both MOUs in separate comments included in these totals.   The 4 comments in favor of the MOU with the PRC, included ones submitted by the Association of Art Museum Directors.   Those comments conditioned support for that MOU on changes related to museum loans.  Dr. Robert E. Murowchick of Boston University and Dr. Anne Underhill of Yale were the only individuals supporting a renewal of the current MOU with the PRC. 

Update 6/8/23- On initial review, CPO missed the testimony of Dr. Rowan Flad of Harvard, who also supported the MOU with the PRC.  Both he and Dr. Underhill also indicated that they were speaking on behalf of the Society of American Archaeology.  Their testimony, as well as that of the other speakers, can be found in CPO's 6/7/23 post.