Wednesday, July 9, 2008

Saving Antiquities for Everyone: Grassroots or Astro Turf?

Saving Antiquities for Everyone (SAFE) has a very professional looking website known for it provocative coverage of museums, collectors and dealers in historical artifacts.

Recently, SAFE has decided to take on the coin trade and collectors of ancient coins. In particular, it has spent much time and effort critiquing the Ancient Coin Collectors Guild (ACCG), a group with which I am affiliated. That, naturally, has prompted me to think more about SAFE and what it really represents.

While the name "Saving Antiquities for Everyone" may suggest a broad based effort, a look at its membership suggests otherwise. The vast number of members are young academics in the fields of archaeology or anthropology. For more see: Certainly, its advisers are virtually all senior members of the archaeological establishment, many of whom are well known for their "hardline" positions against collecting. See:

SAFE has claimed ACCG's efforts are motivated solely by profit, a proposition with which I disagree. In any event, that claim begs the question about SAFE's own motivations. Certainly, while SAFE is highly critical of collectors, dealers and museums, particularly concerning the collection of unprovenanced antiquities, SAFE is strangely silent about state sanctioned collecting practices in source countries and, indeed, poor source country stewardship of archaeological resources in general.

Why? Is this a mere oversight? Or, could it possibly be that SAFE is wary of offending the very same countries that control access to sites for archaeological research? What else could explain SAFE's failure to criticise the collecting habits of "connected" private museums like the Poly Art Museum in Beijing or the Bank of Cyprus Cultural Foundation? And what about a SAFE members' kudos for China's treatment of Tibet's cultural heritage at the CPAC hearing on the Chinese request for import restrictions? Or, just recently, how else can one explain the unwavering support on the SafeCorner blog for Iraqi Government control over Jewish holy books, even though successive Iraqi governments have campaigned to destroy all vestiges of that country's ancient Jewish culture?

There may be another factor at work, one mentioned to me by another academic. Let's face it. Getting a job in academia is very difficult. Under the circumstances, what better way to become "noticed" than to become an "activist." Don't get me wrong. I don't doubt the sincerity of the views of SAFE members. I just wonder sometimes if they go too far to make a point, because the need to "stand out" is on their minds.

SAFE's modus operandi raises some other questions. The first relates to finances. SAFE has criticised ACCG because coin dealers are major contributors. But where exactly does SAFE get its funding from? It would certainly be interesting to learn about SAFE funding sources. One would particularly like to learn the extent to which SAFE has received government funding or in-kind assistance or if SAFE has received any any funding or in-kind assistance from abroad.

Finally, given the provocative nature of SAFE's website along with its links to the archaeological establishment through its advisers, one cannot help but think SAFE in effect acts as a "cat's paw" for "hardline" elements within the AIA. Certainly, I suspect many in the AIA would be uncomfortable with the tone and content of much of what is on the SAFE website. However, both groups do share common goals.

In sum, SAFE may paint itself as a "grassroots advocacy group," but I have come to consider it as little more than an "AstroTurf" or phony grassroots organization that operates as the "cat's paw" of hardline elements within the archaeological establishment.


Cultural Property Observer said...

SAFE responded to my comments on a story about the ACCG Benefit Auction with this information. While I appreciate SAFE's explanation, it would not seem to be 100% accurate:

Dear Mr. Tompa:

Thank you for your interest in SAFE and its activities. Your observation that we are a 501 (c) (3) is indeed accurate. The other points you raised about SAFE, however, need corrections.

1. SAFE is not a "lobbying shop".
In order to maintain its tax-exempt status under section 501(c)(3) of the Internal Revenue Code, SAFE is organized and operated exclusively for exempt purposes set forth in section 501(c)(3). None of SAFE's earnings inure to any private individual. In addition, SAFE is not, and never has been, an action organization, as defined under section 501(c)(3); i.e., the organization does not attempt to influence legislation as a substantial part of its activities and does not participate in any campaign activity for or against political candidates. Section 501(c)(3) organizations are restricted in how much political and legislative (lobbying) activities they may conduct. The IRS website defines lobbying as "attempting to influence legislation." and states that "Legislation includes action by Congress, any state legislature, any local council, or similar governing body, with respect to acts, bills, resolutions, or similar items (such as legislative confirmation of appointive office), or by the public in referendum, ballot initiative, constitutional amendment, or similar procedure. It does not include actions by executive, judicial, or administrative bodies." SAFE has not to-date performed or devoted any organizational resources to lobbying activity. Should such activity occur in the future, any expenditure or organizational resources in that effort shall become subject to the substantial part test as outlined under IRS guidelines.

Any activity SAFE has performed from time to time with respect to public hearings conducted by the State Department's Cultural Property Advisory Committee is not considered lobbying under IRS guidelines for the reason stated above. The aforementioned IRS web page further states: "An organization will be regarded as attempting to influence legislation if it contacts, or urges the public to contact, members or employees of a legislative body for the purpose of proposing, supporting, or opposing legislation, or if the organization advocates the adoption or rejection of legislation." SAFE has never contacted or directed anyone else to contact members or employees of a legislative body for the purpose of proposing, supporting, or opposing legislation. Nor has SAFE contacted or directed anyone else to contact any members or employees of a legislative body for the purpose of advocating the adoption or rejection of legislation. The aforementioned IRS web page also states: "Organizations may, however, involve themselves in issues of public policy without the activity being considered as lobbying. For example, organizations may conduct educational meetings, prepare and distribute educational materials, or otherwise consider public policy issues in an educational manner without jeopardizing their tax-exempt status."

2. SAFE's finances:
SAFE is a nonprofit 501(c)(3) organization, and contributions are tax deductible under section 170 of the Internal Revenue Code. Upon request, a copy of the last financial report filed by SAFE may be obtained by writing SAFE at 123 Town Square Place, #151, Jersey City, NJ 07310 or the NY State Attorney General at The Capitol, Albany, NY 12224-0341.

3. Income sources:
Please see here and here
Additional funding comes from fundraising activities listed here
And we also solicit private donations via the website.

We trust this matter has been fully explained can now be put at rest.

Thank you,

Here is my response,

Thank you for your explanation, which I will post on my own blog.

I must, however, take issue with the following statement:

"SAFE has never contacted or directed anyone else to contact members or employees of a legislative body for the purpose of proposing, supporting, or opposing legislation."

In fact, the Hearing Archives of the House Ways and Means Committee reflects a that Cindy Ho of SAFE sent a letter to the Committee regarding HR 915, dated 9/06/05. It may be accessed here:


Peter Tompa

Cultural Property Observer said...

Here is SAFE's response:

The letter you refer to was written long before SAFE's application of 501 (c)(3) status, so in the context of your statement "...SAFE, is a 501 (c) (3). Sometimes one wonders whether it is acting as such or rather as lobbying shop that should have been created as a 501 (c) (4)" our response "SAFE has never contacted or directed anyone else to contact members or employees of a legislative body for the purpose of proposing, supporting, or opposing legislation." is emphatically CORRECT.

Lastly, let us refocus valuable time, energy and attention on matters more deserving. Much destruction is going on around the world that threatens our shared cultural heritage. Surely, none of this will bring anyone closer to the solution

I guess we can quibble about this more, if we wanted to. I would suggest however that the last statement says more of about the the "ends justifies the means" mentality of SAFE than anything else.

Cultural Property Observer said...

SafeCorner posted this response to my blog:

Nice to know SAFE is reading this blog, though I suspect they like the content about as much as I like the content of their web site.

Anyway, here is my rejoinder:

I find this post to be curious on several levels.

1. The most curious point is that "SAFE has made no statement about the Ancient Coin Collectors Guild."

Frankly, I only decided to blog about SAFE given Nathan Elkins' numerous posts on the SafeCorner blog as well as his article on your web site. In these posts, Nathan specifically takes on the "tactics" of the Ancient Coin Collectors Guild and the "coin dealer lobby" as he sees them.

I should note that while I strongly disagree with the way Nathan paints the ACCG (and coin dealers in general), I do respect Nathan and acknowledge that he does really care about the study of ancient coins.

I suppose you are indicating that Nathan's views about ACCG are not specifically endorsed by SAFE. If so, fine. However, you will have to excuse me if I find this position perplexing. Certainly, Nathan is a SAFE "Team Member" and his views about ACCG are plastered on the SAFE web site, including in a "Feature Article." Under the circumstances, anyone viewing your web site would have to assume that SAFE has adopted them.

2. Thank you for pointing out where SAFE's funding sources can be located on the SAFE web site. (The information is not as easy to find as it is on the ACCG site.) I was aware that SAFE has had various fund raisers, but it was not clear to me that the donor information provided there was complete.

That said, the statement that SAFE has received no government funds does raise a question for me. It is my strong recollection that at one time SAFE received some money from NY City Arts authorities (something that was touted on the SAFE web site). I would appreciate it if you could clarify.

3. I think you are taking my statements about SAFE's evident support for Iraqi Government control over Jewish holy books out of context. You view my concerns too narrowly. The issue is not whether it is currently legal to import Jewish Holy books from Iraq into the US (it certainly is not without official approval). Rather, it is my view that SAFE takes an uncritical stance to source country control over "anything old," even in extreme circumstances. If you read Alex Joffe's post to the IraqCrisis list (also posted on my blog) my point should become crystal clear.

4. In my opinion, a SAFE member did give "kudos" to China for its treatment of Tibet's cultural heritage at the CPAC hearing on the pending Chinese request for import restrictions. On pages 88-89 of the official transcript, Jen Makrides (identified as representing SAFE) praised the creation of a "Tibet Museum" and a "Tibet and Autonomous Region Relics Protection Organization." It is clear from the context of her remarks that she did so to counter considerable testimony about China's depredations of Tibetan culture. (I must also note that a number of commentators (including the NY Times) have dismissed that museum as a "propaganda tool" for the Chinese government. See, e.g., my opinion, putting a "happy face" on Chinese control over Tibet and Tibetan cultural relics is exceptionally misguided.


Peter Tompa