Featured Renewal of restrictions on coins from Italy - CPAC Meeting

Haha! Despite some of what you can read in that article, it was actually a compliment. Smurfette is easily one of the most fun and interesting characters in the Smurfs. I watched a lot of Smurf episodes with my son when he was younger. There are various very valid sociological criticisms that could be made of the Smurf series, but as a kid (and a parent), I always had a lot of fun watching them!

 

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Is there a similar arrangement for Canada? I’m assuming there is....Some faculty in the classics dept at my university would certainly support this.... Can I sign this or is this limited to U.S. residents?

 

My comment on the renewal, submitted 29 June 2020:

Members of CPAC,

My name is Jordan Montgomery and I am writing regarding the renewal of the MoU with Italy. I have been a collector and researcher of Roman Republic coins for 6 years, from the earliest proto-money of the Roman Republic and Kingdom, down to the final issues of the Imperatorial period. This of course includes many types restricted by the current MoU with Italy such as aes grave, aes rude and various Italian civic issues such as those of Paestum. Because of this, I am very familiar with the current MoU and the significant burden it places on American collectors, researchers and institutions.

For this reason, I am asking that no additional restrictions be placed on Roman coins. Alternatively, instead of simply extending the existing restrictions, I think CPAC should explore whether or not Italy has held up its responsibilities under Section 303, a.1.A: “(B) that the State Party has taken measures consistent with the Convention to protect its cultural patrimony;”. I would argue that Italy has not taken appropriate measures in this regard. Specifically, they have not implemented any sort of system like the PAS in the United Kingdom, which equally weighs the protection of cultural property with the realities of the global market in antiquities. The success of this system is borne out by the fact that the United Kingdom has never, to my knowledge, requested any sort of import restrictions from the United States or any other party of the 1970 UNESCO convention. One cannot follow archaeological news sources without seeing the regular reports that come out of Britain of find initially uncovered and reported by amateur finders. One does not find such news out of Italy and anecdotally from colleagues in Italy I am lead to believe that even most chance finds are not reported because there is little incentive in the current system to do it.

Because of this, I would argue that Italy is not taking appropriate measures to protect its own cultural patrimony. I would urge members of this committee to refuse to extend existing agreements, and especially to expand these agreements, until such time that Italy takes appropriate measures, such as those advocated for above. I would also point out, as a final example, that in many cases coins which are illegal for import to the US are fully legal for import and private ownership in Italy. Italy has not even placed the same restrictions on their own citizens that they are today asking CPAC to continue applying to American citizens. This is yet another example where Italy is not taking appropriate measures with respect to their own cultural patrimony, if we are to believe that the restrictions being enforced on American citizens are truly about protecting Italy’s cultural patrimony. One can only speculate as to why Italy would request other countries place stricter restrictions on their citizens than are placed on Italian citizens, but this is yet further evidence that CPAC should strongly reconsider placing such restrictions on Americans.

Respectfully,
Jordan Montgomery

 

What a fantastic letter. All that and you still have time to pitch for the Yankees!

 

There is a character limit on these comments and one can only submit so much, but I would encourage those who have not yet submitted a comment to highlight a few things I neglected to mention in mine. Namely, Italy in no way has a monopoly on the current restricted types. The existing MOU mentions "Coins of Italian Types" and specifically names "1. Lumps of bronze (Aes Rude)", "2. Bronze bars (Ramo Secco and Aes Signatum)", "3. Cast coins (Aes Grave)", "4. Struck coins—Struck coins of the Roman Republic and Etruscan cities produced in gold, silver, and bronze
from the 3rd century B.C. to c. 211 B.C.,"(this includes, for instance, quadrigati).

A naive collector or archaeologist who hasn't deeply studied these types of coins might think this all sounds like stuff you'd only ever find in Italy but that is not the case. Italo Vecchi, in Italian Cast Coinage pp. 25 & 28 cites published finds from Illyria(modern-day Bosnia & Croatia) containing aes rude and bronze bars. Furthermore, Pierluigi Debernardi and Olivier Legrand, in "Roman Republican Silver Coins of the Quadrigatus Period Struck in Spain", RBN 2015 pp. 273-292, publish multiple series of pre-denarius Roman coins reliably linked to Spanish mints. To suggest that these are only found in Italy is patently false and the evidence against this is out there and easily accessible, so there really is no reason they should have blanket restrictions applied like this. And even for the series reliably linked to Italy, realistically coin types should be looked at not from their mint location but from their areas of circulation. The Italian economy stretched far outside of Italy even before the arbitrary 211 B.C. cutoff point that the MoU references. It is intellectually dishonest to treat pre-denarius Roman coins as "coins of Italian types" when the Roman and Italian economies had such wide influence. It is as if one called a Denver mint quarter, a coin of "Colorado type", that's just not how money works.

 

I understand that people's comments, including identifying information within the comments themselves, will be posted online, but does that extend to their addresses and phone numbers that are submitted in the required areas outside the "comments" area of the webform?

 

I agree a note in your words is better than a copied note. I submitted my comments today. My Comment Tracking Number: 1k4-9hji-rw9r

I did a lot of reading and rereading. It is not easy to find the list of restricted items. The list in 2001 did not restrict coins. It did restrict metal items and stretching the words could include some coins.
https://eca.state.gov/files/bureau/it2001dlfrn.pdf
The list in 2011 restricted lots of coins and included aes rude, cast bars and cast coins.
https://eca.state.gov/files/bureau/it2011dlfrn.pdf

I looked back a bit to the original agreements. They are dated 1970. I copied a few quotes below. I think 5.d supports my theory that some archaeologists want coins to stay in the ground so they can date dig sites. I also wonder if Article 11 means that Rome should send trophy items from _____ back to _____?

UNESCO CONVENTION ON THE MEANS OF PROHIBITING AND PREVENTING THE ILLICIT IMPORT, EXPORT AND TRANSFER OF OWNERSHIP OF CULTURAL PROPERTY

Article 5; (d) organizing the supervision of archaeological excavations, ensuring the preservation "in situ" of certain cultural property, and protecting certain areas reserved for future archaeological research;

Article 11
The export and transfer of ownership of cultural property under compulsion arising directly or indirectly from the occupation of a country by a foreign power shall be regarded as illicit.

 

I took the trouble to submit a letter. I think it is a very good one , and it is also a long one. I got around the character limit for the in-form submission simply by attaching my letter as a .docx file. The web-form then autopopulates the field in question with "See attachment(s)."

There is also a statement on the State Department's website that says there is no maximum length for submissions. In other words, the maximum character rule on the webform is probably just an arbitrary number input by some technical person.

So don't be afraid of character-maximums!

Also, I read on the State Department's website that the decision-making process is not decided by the number of submissions, or by how many people feel about a given issue. They are aware that various communities will encourage their members to send form letters, and they very clearly do not want form letters. They say one, detailed, supported, logically-argued letter is more powerful than many form letters. In other words, be detailed, logical, and so on in your own words.

 

Providing your name is optional. You may remain anonymous, if you wish. There are no fields for address or phone number.

*Edit - I just went back to look again and using the link supplied in the OP there are fields for address, phone number, etc. These were not present when I did it. These should not be required fields.

 

I looked at the comment page and noticed that of the 154 comments submitted only 26 are posted on line. All of the posted comments oppose extending the MOU or favor ending the MOU. Where are the folks who support the changes? The note below explains why some comments are not posted.

* This count refers to the total comment/submissions received on this document, as of 11:59 PM yesterday. Note: Agencies review all submissions, however some agencies may choose to redact, or withhold, certain submissions (or portions thereof) such as those containing private or proprietary information, inappropriate language, or duplicate/near duplicate examples of a mass-mail campaign. This can result in discrepancies between this count and those displayed when conducting searches on the Public Submission document type. For specific information about an agency’s public submission policy, refer to its website or the Federal Register document.

 

I can now answer my own question! Only the name of the submitter is shown, and it is possible to submit anonymous comments, though I think it is better to use a name. The phone number, email, and street address are not shown.

For convenience, here's the page on which you can read all the submitted comments.

--
EDIT: David Sear's comment is on that page. I hope mine goes through properly so I can be on the same page as him!

 

I posted mine 2 days ago but dont see it. There was nothing bad in the comment and it definitely was not a canned letter. I also never recieved an email confirmation. Maybe I'll resubmit.

 

I don't believe the email confirmation was automatic. Did you see a screen with a confirmation number? If not, then I don't think their system received it.

 

I did get the confirmation number but stupid me didnt take a screen shot.

 

Despite being bogged down by pressing domestic affairs I did submit a short comment about the latest MOU, responding to an email from CNG & Peter Tompa. As of today the website lists only 154 comments . Many CoinTalk members & notable numismatists have submitted comments, never the less, that's a poor showing ! We can do better than that . The CPAC has done enough damage to our hobby, so lets stick together & try & defeat this latest MOU .

 

"That government is best which governs least..." - Henry David Thoreau

 

And, as for a non-European discovery, the Chinese, earlier in the 15th Century.

 

In that case, I wouldn't worry about anything. I do worry a bit for me, though, because I used the attachment option to submit the entirety of my comment. Hopefully, that won't cause a problem.

Anyway, on another note, here's a link to the page that shows how many comments have been received. I'm really putting that here mostly for my own benefit (and those like me), as it took me ages to find what everyone else seems to have found earlier.

Currently, on the link in a previous comment of mine above, I still see only 26 comments posted. At the moment, 154 have been submitted. There's probably a backlog to clear the large remainder for posting.

 

I have been waiting since late November 2019 for a lot that I won. A German
coin
in an auction conducted by an Italian auction house in Italy.
At the time the auction house told me it would take 4-6 weeks for the
export papers to be approved. Then they told me by the end of February. Then
Italy shuts down due to Covid 19. Since then I've had very little communication
from the auction company. When I Email them it takes them several days to
respond and then it is with "attitude". Italy has since been open for at least
4 weeks and still nothing. I hope this will be resolved soon. Even though I need
this coin for my collection, I don't know that I would have bid on it had I known
the difficulty I would experience obtaining the coin. When and if I receive
said coin I will make a brief post here. End of rant!!

 

Buying coins from Italy is always like this, in my experience (minus covid, of course.) I mainly collect Italian coins so I've gotten used to it-- although I really prefer to buy from the auction houses based in San Marino, since it is much simpler.

Apparently some of the export offices have re-opened, but not all of them. And they all have a huge backlog from before the outbreak... so I would just try to be patient.

My experience with Italian auction houses has always been that they get a bit snippy when you badger them about this, because they have absolutely no control over the process. I was about to buy a very expensive coin from one recently, but I didn't after the dealer suggested I try and find it from somewhere else because he didn't want to deal with the hassle of the export offices right now...