STATE DEPARTMENT GETS READY TO BETRAY US COLLECTORS
Dave Welsh
PRIVATE COLLECTING OF ANCIENT COINS IF IT GOES THROUGH --- MAKE YOUR VOICE
HEARD NOW!!!!
WHAT I FAXED TO THE CPAC: SEE http://www.vcoins.com/fax/
IF YOU CAN REDUCE YOUR OBJECTIONS TO THIS POWER GRAB TO ONE PAGE, MORE POWER
TO YOU.
**********
Ms. Katherine L. Reid
Chair, Cultural Property Advisory Committee
United States Department of State
Annex 5
2200 C Street, NW
Washington, DC 20522-0505
Dear Ms. Reid:
I am a professional numismatist concerned that any restrictions on the
import of coins from Italy would harm my business. There are many Italian
dealers who export from Italy, and the EU forbids any restrictions on the
transfer of historical coins within the EU. It would be unfair for the US to
restrict my business while Italy and the EU enjoy no such restrictions.
I desire to record my opposition to any attempt to use renewal of the
Memorandum of Understanding (MOU) with the Republic of Italy as an excuse to
impose new import restrictions on ancient coins. There is no logical or
valid reason for doing that, whereas there are many important reasons why
imposing such import restrictions on coins would be unjust,
counterproductive, foolish and ineffective.
Such poorly considered restrictions would effectively tend to destroy the
time honored, legitimate trade in and collecting of ancient coins (an
avocation of more than one US President). Ancient coins are very rarely sold
with provenance documentation of the sort required by US Customs under the
Convention on Cultural Property Implementation Act, because it isn't
practical for collectors to keep such records for common objects of low
value such as coins. For this reason I oppose imposition of import
restrictions on coins of possible Italian origin, because it would not be
feasible or even possible to document the actual find spot origin of most
coins traded today (which might conceivably be of Italian origin) to permit
their importation. In contrast to that approach, more effective and much
less onerous alternative ways to protect archaeological sites from looting
are available, including effective policing of archaeological sites,
educational programs, cooperative initiatives between collector and
preservationist organizations and enactment of fair laws encouraging members
of the public in source countries to report their finds.
The United Kingdom has instituted an effective system of doing that in the
Portable Antiquities System which (with the Treasure Act) has resulted in
very large numbers of artifacts being reported to archaeological authorities
and in many cases, being acquired by museums. Statistics compiled by
archaeologists administering this system demonstrate that it has been vastly
more effective than the rigid and ineffective approach prevailing in nations
such as Italy, where discoveries of artifacts are normally confiscated
without payment or other compensation of any sort to landowners or
discoverers. As one might expect, this latter approach has created such
public distrust and evasion that the Italian Prime Minister has been accused
of failing to comply with these confiscatory laws.
It is fallacious to contend that coin collectors contribute to any
significant extent to looting of archaeological sites. Those who assert such
a connection repeat uninformed, misleading media reports full of half truths
and outright lies, radical generalizations, and emotional appeals without
advancing verifiable factual evidence to validate their assertions. There
has never been (and in my opinion never will be) anything that could be
considered valid scientific proof of the assertion that collecting supports
looting. The truth is instead that those advocating restricting or
abolishing collecting of ancient artifacts wish to do that as one more step
in their ideologically driven efforts toward achieving a broader agenda, to
suppress all private collecting of antiquities. Will the CPAC again
contribute to this unjust, unreasonable campaign? It is important to observe
that when the CPIA was enacted, enabling accession to the 1970 UNESCO
Convention, the CPAC was established to protect US antiquities collectors
from the ideologically driven goals of archaeologists and to ensure that a
fair, balanced approach, respecting all interests of US citizens, would
prevail.
Part of the rationale advanced by supporters of restrictions of the sort
contemplated here is an assumption that only state institutions and allies
in the archaeological community are "worthy enough" to "protect" and "study"
ancient artifacts. However, this ignores the (in many respects
reprehensible) actual record of archaeologists and state museums (in Italy
and elsewhere) regarding the world's numismatic heritage. They have in fact
proven to be very poor, irresponsible custodians of what has been turned
over to them.
Most ancient coins in extant collections originally came from large hoards
found far away from archaeological sites. Usually, only corroded examples of
ancient "small change" are found at archaeological sites because hoards of
coins were normally concealed in secluded places far away from buildings.
When coins are found in excavating archaeological sites, many specimens are
neglected because archaeologists often don't use metal detectors or sieve
the earth they excavate. Local inhabitants often screen and sift residue
from archaeological digs to obtain coins and other small objects. These
practices underscore the fact that many archaeologists view coins as little
more than a means to date strata, not as important artifacts in themselves.
Numismatists however derive their own "context" from studying the
iconography and epigraphical devices used on coins, the number and
chronology of dies used to strike a given series, and the metallurgical
content of various issues. They care much more, in reality, than most
archaeologists about coins, thus the concerns of numismatists about
continued access to ancient coins should weigh very heavily and in my
opinion decisively in the minds of CPAC. Likewise, contentions advanced by
archaeologists about the importance of ancient coins to archaeology should
be taken "cum grano salis" in the absence of specific, sensible plans and
proposals as to how archaeology will use these artifacts. In the absence of
any such convincing plan, the whole attempt to present ancient coins as
being archaeologically important artifacts seems to be nothing more than a
"power grab" by archaeologists. It is in my view irresponsible and
reprehensible to allow archaeologists to arbitrarily determine disposition
of ancient coins, without consideration of the interests of numismatic
science.
The common view in archaeological circles - that coins are of little
importance beyond use as a possible dating tool - means that in most cases
coins are effectively discarded upon excavation. If retained at all, once
coins have fulfill this limited purpose, they are normally left to
deteriorate under negligent storage conditions - they would actually be
better preserved if left underground than in the usual archaeological
storage. Although there are some public coin exhibits in Italy, for cost and
space reasons these show only a few representative samples of the
collections. So far as I am aware, no major coin exhibits have been sent to
the United States from Italy as part of Italy's undertakings pursuant to the
current MOU. In any event coins in a display case in a museum cannot provide
the educational value of actually being able to handle and study such
artifacts.
Amateur numismatists are far better trained and more prolific in the field
of numismatic research than professional archaeologists, as is amply
demonstrated by the huge corpus of literature produced by amateur collectors
over many centuries forming the reference libraries that professional
archaeologists themselves use for identification and historical analysis.
Since most archaeologists are professional academics while amateur scholars
research and write in their spare time, the lack of publications about coins
found at archaeological sites is appalling, particularly when one considers
the number of numismatic publications on other aspects of the production and
use of ancient coins. This is a very good reason to believe that asserting
that import restrictions are necessary "to promote research" is not only
misleading but grossly insulting to the knowledgeable coin collectors and
coin dealers who have taken great pains to advance numismatic knowledge on
their own time and at their own expense. Amateurs collecting and studying
ancient coins are essential to continue the research that has sustained the
science of numismatics since the 17th century. Very few archaelogists have
the knowledge and experience necessary to meaningfully contribute to that
science. When it comes to discussing numismatic science, archaeologists are
amateurs whilst collectors are the real experts.
Most ancient Greek and Roman coins of the sort struck within the confines of
modern day Italy are very common, with millions of known extant examples.
They have been collected since the Renaissance and there are many more
specimens than can be studied, preserved or displayed by state museums and
archaeologists or other academics. Without the efforts of coin collectors
and dealers, numismatic research and preservation of these coins would
suffer greatly. There is no good reason to depart from CPAC's longstanding
recommendation against import restrictions on coins of potential Italian
origin. Serious harm would result from such import restrictions, both to
collectors and to individuals legitimately dealing in and collecting coins,
and to the science of numismatics.
Finally I wish to bring to your attention a very important practical issue
which tends to become lost amid the abstractions advanced by advocates of
import restrictions, i.e. that boundaries of modern nations do not align in
any practically enforceable way with those of ancient polities. In no case
is this more evident than in that of ancient Italian coinage, which
originated as a subset of Greek coinage and later evolved into a subset of
Roman coinage. In neither case did verifiably Italian issues dominate
(except perhaps briefly) amongst what was effectively an international or
imperial currency. Although the fascist Italian regime of Mussolini
attempted to assert inheritance of the cultural legacy of the Roman Empire,
I do not believe that this is still taken seriously and I do not believe
that there is good reason to assume that any coin struck in Italy is
necessarily Italian cultural property in the absence of specific evidence
that it was actually discovered there.
The recent, poorly considered imposition of import restrictions on coins of
Cypriot origin has made it clear that the State Department does not have a
legally correct understanding of US or international law regarding origin of
discovered artifacts. The legal origin of an artifact is not the place of
its manufacture, but the place of its modern discovery or first verifiable
location. Most Roman coins were not manufactured in Italy nor did they
circulate there.
Respectfully yours,
David Welsh
Classical Coins
Post Office Box 8722
Goleta, CA 93117
Phone 805-562-8619
dwel...@cox.net
Mr. Jaggers
While I might agree with what you have written above, you have ignored your
own advice, namely to keep it to one page. I learned in a college typing
class to do just that, as research at that time indicated a greatly reduced
readership rate, once the second page is started, and third page - don't
even bother. Is there any way to condense this down to a few well-chosen
and well-crafted bullet points?
Also, I am not in a position to evaluate the veracity of your very last
sentence, but I daresay that the reaction of most people upon reading it
would be "HUH?"
James the Editor