Tuesday, April 6, 2010

State Department Provides Short Notice to Public for Comments on Renewal of Italian MOU

Tomorrow's Federal Register will carry this notice from the State Department Bureau of Educational and Cultural Affairs about a May 6th public hearing on the renewal of the Italian MOU. Public comments are now due a mere two weeks from now, on April 22, 2010.

Why the rush? The current MOU with Italy does not expire until January 19, 2011. And why only two weeks for public comment? Certainly, the Italian MOU potentially impacts more American collectors, museums and antiquities dealers than any other, except perhaps the China MOU.

Is this a thinly disguised effort by the State Department bureaucracy to limit public comment despite President Obama's promises of open government?

In any event, here is the notice which the State Department Cultural Heritage Center sent today to parties on their e-mail distribution list:

The Department of State’s Cultural Heritage Center would like to draw your attention to an announcement that will be published in tomorrow’s Federal Register (http://www.federalregister.gov/OFRUpload/OFRData/2010-07898_PI.pdf).

[Billing Code: 4710-05]
[Public Notice 6945]

Notice of Meeting of the Cultural Property Advisory Committee
In accordance with the provisions of the Convention on Cultural Property Implementation Act (19 U.S.C. § 2601 et seq.) (the Act) there will be a meeting of the Cultural Property Advisory Committee on Thursday, May 6, 2010, from 9:00 a.m. to approximately 5:00 p.m., and on Friday, May 7, 2010, from 9:00 a.m. to approximately 3:00 p.m., at the Department of State, Annex 5, 2200 C Street, N.W., Washington, D.C. During its meeting the Committee will review a proposal to extend the “Memorandum of Understanding Between the Government of the United States of America and the Government of the Republic of Italy Concerning the Imposition of Import Restrictions on Categories of Archaeological Material Representing the Pre-Classical, Classical and Imperial Roman Periods of Italy” signed in Washington, D.C. on January 19, 2001 and amended and extended in 2006 through an exchange of diplomatic notes. The purpose of this review is for the Committee to make findings and a recommendation regarding the proposal to extend this Memorandum of Understanding.

The Committee’s responsibilities are carried out in accordance with provisions of the Act. The U.S. – Italy Memorandum of Understanding, as amended and extended, the Designated List of restricted categories, the text of the Act and related information may be found at

Exercising delegated authority from the President and the Secretary of State, I have determined that portions of the meeting on May 6 and 7 will be closed pursuant to 5 U.S.C. § 552b(c)(9)(B) and 19 U.S.C. § 2605(h), because the disclosure of matters involved in the Committee’s proceedings would compromise the Government’s negotiation objectives or bargaining positions on the negotiations of this Memorandum of Understanding. However, on May 6, the Committee will hold an open session, 9:30 a.m. to approximately 11:30 a.m., to receive oral public comment on the proposal to extend the Memorandum of Understanding. Persons wishing to attend this open session should notify the Cultural Heritage Center of the Department of State at (202) 632-6301 by Thursday, April 22, 2010, 5:00 p.m. (EDT) to arrange for admission, as seating is extremely limited.

Those who wish to make oral presentations should request to be scheduled and submit a written text of the oral comments by Thursday, April 22, 2010, to allow time for distribution of these comments to Committee members for their review prior to the meeting. Oral comments will be limited to five minutes each or less to allow time for questions from members of the Committee and must specifically address the determinations under section 303(a)(1) of the Act, 19
U.S.C. § 2602(a)(1), pursuant to which the Committee must make findings. This citation for the determinations can be found at the web site noted above. The Committee also invites written comments and asks that they be submitted no later than April 22, 2010. All written materials, including the written texts of oral statements, should be faxed to (202) 632-6300, if 5 pages or less. Written comments greater than five pages in length must be duplicated (20 copies) and mailed to Cultural Heritage Center, SA-5, Fifth Floor, Department of State, Washington, D.C. 20522- 0505. Express mail is recommended for timely delivery.

Date: MAR 29 2010 _______________________
Judith A. McHale
Under Secretary
Public Diplomacy and Public Affairs
Department of State
[FR Doc. 2010-7898 Filed 04/06/2010 at 8:45 am; Publication Date: 04/07/2010]

Addendum: A review of the Federal Register Notice for the September 8, 2005 CPAC hearing on the last Italian renewal confirms that the public was given from August 1-24, 2005 to comment on the extension. Here, the State Department has only afforded the public a little over two weeks to comment. The 2005 notice can be found at 70 Fed. Reg. 44146-47 (Aug. 1, 2005).


Prashant Kulkarni said...

The import restrictions on Roman coins is unwarrented and unrequired. The Roman coins are found over half the world countries. It was in Arikmedu in India that thousands of coins were discovered in 1800s. It will be difficult to distuingish such coins found in Rome and in India. The roman coins is iondeed a world heritage and hence it should be legal to move them anywhere in the world.

Prashant Kulkarni

Giulio Bernardi said...

mediante il presidente Giulio Bernardi esprime il seguente parere in merito alla eventuale richiesta italiana di restrizioni all'importazione di monete romane negli USA:

L'Italia non è il solo paese in cui le monete romane fanno parte del patrimonio culturale. Esse sono state infatti prodotte in tutto l'Impero (oggi frazionato in più di una dozzina di Stati) e hanno circolato fino all'Estremo Oriente.

Per la loro implicita e palese funzione di mass media, prevista e voluta all'epoca della coniazione, le monete devono essere diffuse in tutto il mondo. Perchè disubbidire a quanto volevano gli Imperatori? E' bene che le monete portino in tutto il mondo il loro messaggio, è male che vengano nascoste dove quasi nessuno può andare a cercarle, come avviene nella maggior parte dei musei italiani.

In Italia le monete provenienti da scavi e ritrovamenti entrano quasi tutte nelle collezioni pubbliche, dove poi giacciono ignorate per tempi infiniti, salvo rare eccezioni. Tuttavia i collezionisti numismatici di tutto il mondo sono sospettati e, in Italia, perseguitati, causa il pregiudizio che tali monete pervengano alle collezioni private in quantità paragonabili alle collezioni pubbliche.

I musei italiani sono strapieni di monete romane non registrate e non classificate: secondo i nostri calcoli milioni di esemplari. La gestione del patrimonio numismatico pubblico quasi mai è affidata in Italia a personale professionalmente adeguato. Quindi la collezione pubblica diventa una prigione esposta a furti, dimenticata, invisibile, spesso peggiore del collezionista privato più geloso e irragionevole. 

In tutto il mondo i collezionisti che pagano di tasca propria i loro acquisti sono, a nostro parere, i custodi più affidabili.

E' ingiusto e inaccettabile che lo Stato Italiano tormenti i collezionisti senza aver messo ordine in casa sua.

Anonymous said...

Since the Renaissance time a Roman coins was collected. Since then a millions of Roman coins and from 28countries came into private, museums (also in American) and Royal collections. Roman Coins are part of human heritage and tradition, part of our Occident, European and American history. Roman coins waking up in humans intrest for their roots, collecting coins increasing philosophical thinking,and are educational. Including coins into the Italian MOU will be crime against humanity, freedom of American citisens, and will bring USA one step further from the rest of the FREE WESTERN AND EASTERN WORLD!
Anton Tkalec, collector since 1954 and since 1977 a director of
A. Tkalec AG
Limmatquai 48
CH-8001 Zürich
+ 41 - 44 - 251 82 29 *
Fax.: + 41 44 251 82 39
E-Mail: coinstkalec@aol.com
Web:  www.coinstkalec.ch

fabrizio rossini said...

Letter from the President of Società Numismatica Italiana (Italian Numismatics Society);
Italy's leading and oldest numismatists association.

The letter was signed and sent by post to Prof. Reid.

Prof. Katherine L. Reid
Chair, Cultural Property Advisory Committee
United State, Department of State
2200 C Street, NW
Washington, DC 20522
Fax 1-202-632-6300 April 26, 2010.

Re: Memorandum of Understanding between the Republic of Italy and
the United States

Dear Prof. Reid and Members of the Committee:

Società Numismatica Italiana (Italian Numismatic Society) is the most prestigious and longest serving numismatic association still active in Italy.

Società Numismatica Italiana was created in 1892 under the presidency of Francesco Gnecchi, who together with his brother Ercole, have been two of the most famous Italian numismatist. Among the Society’s founders was also the Prince of Naples, the future King of Italy Victor Emmanuel III.
Among its other illustrious members, presidents and councilors of the Society, Count Niccolò Papadopoli, Prof. Serafino Ricci, Raffaele Castellani, Oscar Ulrich-Bansa, Prof. Panvini-Rosati and Athos Moretti can be mentioned. Several of these names are historical numismatists figures also recorded and celebrated in the specially dedicated Numismatists’ Hall of Fame preserved at the numismatics section of the Museum of American History of the Smithsonian Institution in Washington DC.

All international numismatic congresses, since the establishment of this institution, have seen the active participation of the Society (Paris in 1900, Bruxelles in 1909, London in 1936, Rome in 1961, New York in 1973, etc.).
Likewise, the Society maintained strong ties, in its early days, with public institutions, such as the Ministry of Education, to assist in the re-organization of important public collections, suggesting the cataloging criteria of public collections for the benefit of scholars and visitors alike.

The Society has always been an advocate of independent research and its review (Rivista di Numismatica and Scienze Affini – RIN) is today one of the oldest serving numismatics reviews still active in the world, having started its publications in 1888 (a few years before the Society itself was effectively founded).

Finally, the Society has regularly been promoting conferences and seminars dedicated to specific themes, like the celebrations for the first centenary of Corpus Nummorum Italicorum, the catalogue composed by twenty in-folio volumes, of the collection of King Victor Emmanuel III, the only example of a complete catalogue of the entire series of coins produced by a nation.

With its long standing tradition and also conveying the sentiment of its affiliates, the Society today advises this Honorable Committee to reject the restrictions to the importation of Italian coins in the name of the free trade principle that regulates trade flows within the EU as well as most countries in the world.

It is precisely with the free exchange of goods, of ideas, of initiatives and of cooperation between institutions, that the cultural progress of numismatics has been made possible and that it has grown to today’s sophisticated standards and reach.

Moreover, it is to be reminded that most of the public collections that we can today admire and study in museums, have been the heritage of private ones, formed over decades, in some cases centuries, by individuals and families who devoted precious resources to their search and formation. Had a ban on the commerce of ancient coins been raised, that would have, de facto, hindered their making with a fatal detriment to the cultural treasures we can share and enjoy today.

With our most respectful regards,

Ing . Ermanno Winsemann Falghera
President of the Società Numismatica Italiana