ACCG opposes import restrictions on coins from Italy
The ACCG has entered an official position statement with the Cultural Property Advisory Committee expressing opposition to any attempt to remove the exemption granted in the original request five years ago.
Wayne G. Sayles |
August 22, 2005
Mr. Jay I. Kislak, Chairman
Cultural Property Advisory Committee
United States Department of State, Room 334
301 4th St., SW, Washington, DC 20547
Re: Renewal of MOU with Republic of Italy and Possible Inclusion of Coins
Dear Mr. Kislak:
I am writing on behalf of the Ancient Coin Collectors Guild (ACCG)1 to oppose any effort to use the renewal of the Memorandum of Understanding (MOU) with the Republic of Italy as an excuse to impose new import restrictions on coins. While the ACCG supports all reasonable efforts to protect archaeological sites, as well as artifacts held in private and public collections, the ACCG opposes the “blunderbuss” remedy of import restrictions and urges the Cultural Property Advisory Committee (CPAC) to reaffirm its prior decision upholding the rights of American dealers, collectors and numismatic institutions to import ancient coins of potential Italian origin. It has been estimated that approximately 50,000 Americans, many of them of Greek or Italian heritage, collect ancient Greek and Roman coins. It should be remembered that many of the ancient coins claimed to be “Italian” are actually Greek coins struck by early Greek colonizers in southern Italy and Sicily. An identical situation exists with Byzantine, Norman , Islamic and even French coins of later periods. Indeed, it is difficult to ascribe some of these coins to a particular “cultural heritage” and impossible to do so in any sense of ethnicity or national/geographical boundary.
The ACCG is deeply concerned that any application of import restrictions to coins will adversely impact the long-standing legitimate trade and collecting of any such items. Typically, coins do not carry any provenance with them, particularly of the sort contemplated by US Customs under the Convention on Cultural Property Implementation Act. Under the circumstances, the ACCG opposes import restrictions on coins of potential Italian origin, and submits that more effective, and far less onerous means to protect the archaeological record exist. These would include better policing of archaeological sites, public education programs, cooperative initiatives between collector and preservationist organizations and passage of fair laws that encourage members of the public in source countries to report their finds with the prospect of a monetary reward.2 In fact, the ACCG has made several overtures of cooperation to cultural property protectionists including the Archaeological Institute of America and S.A.F.E., and to the government of a major source country. Unfortunately, none of these overtures have to date been embraced by the recipients. Rather, a spate of requests for restrictions on the importation of ancient coins into the U.S. is now emerging at CPAC and in the U.S. Legislature.3
The well worn and trite refrain that private collectors are the cause of archaeological site looting has not only become monotonous, it has no basis in fact where coins are concerned. In lieu of evidence, the advocates of market controls present sensationalized media reports, half truths or blatant lies in the form of quoted “experts”, radical generalizations, and emotional appeals with no correlation. The most recent of these being outlandish and scurrilous claims that the U.S. collector market is funding the insurgency in Iraq. These attacks are so lacking in merit that they cast a pall on the credibility and professionalism of those who initiate and support them. They would hardly be worth responding to, if it were not for the fact that legislation adversely affecting the honorable tradition of ancient coin collecting has already come to pass. Adding coins to the list of restricted items from Italy is simply one more step in a much broader agenda. Will CPAC further this injustice?
Part of the rationale behind imposition of import restrictions of the sort contemplated here is the assumption that only state institutions and their allies in the archaeological community are “worthy enough” to “protect” and “study” ancient artifacts. However, this canard ignores the woefully inadequate efforts of archaeologists and state museums (in Italy and elsewhere) as stewards of the world’s numismatic heritage.
1. Archaeologists Fail to Recover Most Ancient Coins and What Coins They Are Most Likely to Find Are of Least Interest to Collectors — Most collectors’ coins come from large hoards typically found outside of archaeological sites. Typically, only corroded examples of ancient “small change” are recovered at archaeological sites because large hoards of coins are mainly found in discreet locations having purposefully been secreted outside of built up areas.4 Even where coins are recovered, many others are missed for the simple reason that archaeologists tend not to use metal detectors or sieve the earth they excavate. In many cases the local inhabitants actually screen discarded residue from archaeological digs to obtain coins and small objects. These practices underscore the fact that many archaeologists view coins as little more than just one means to date archaeological stratum, and not as useful artifacts in themselves.5 In contrast, numismatists derive their own “context” from 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. In point of fact, numismatists care much more than most archaeologists about coins and hence the concerns of numismatists about continued access to historical coins should weigh heavily in the minds of CPAC.
2. Archaeologists and State Museums Cannot be Trusted to Preserve and Display the Millions of Ancient Coins Extant — The common view in archaeological circles that coins are of little importance beyond use as a possible dating tool means that all too often they are sacrificed upon excavation.6 Moreover, once coins fulfill this limited purpose, they typically are just dumped in plastic bags and left to deteriorate further in poor storage conditions.7 In fact, they were better preserved underground than they are in archaeological storage. While there are indeed coin displays in Italy, they are few in number and for reasons of cost and space they tend to show only representative samples of the collections.8 Moreover, the ACCG is unaware of any major coin exhibits that have been sent to the United States from Italy as part of Italy’s undertakings pursuant to the current MOU. In any event, a few coins put up in a display case in some museum cannot provide anywhere near the educational value of actually being able to handle and study such common artifacts from the past.9
3. The Number and Value of Archaeological Publications on Coins is Limited — That amateur numismatists are better trained and more prolific in the field of numismatic research than professional archaeologists is amply demonstrated by the huge corpus of literature which has been produced by amateur collectors over the past several centuries and which forms the reference libraries that professional archaeologists themselves use for identification and historical analysis. The lack of publications about coins found at archaeological sites is appalling, particularly when one considers the vast number of numismatic publications examining other aspects of the production and use of ancient coins—and the fact that archaeologists are professional academics while many other amateur numismatic scholars research and write in their spare time.10 Under the circumstances, claims that import restrictions are necessary “to promote research” are downright misleading as well as being highly insulting to the many knowledgeable coin collectors and coin dealers who have taken great pains to advance numismatic knowledge on their own time and at their own expense. In short, the continued ability of private, non academic, individuals to trade in ancient coins can best provide the basis for research that has sustained the science of numismatics since the 17th century.
In summary, most ancient Greek and Roman coins of the sort struck within the confines of modern day Italy are extremely common, certainly with millions of examples extant. They have been avidly collected since the Renaissance, particularly in Europe and by the descendants of Europeans residing throughout the rest of the world. There are far too many such coins available to be adequately recovered, recorded, studied, preserved or displayed by state museums and archaeologists or academics associated with them. Indeed, without the substantial efforts of collectors and dealers both numismatic research and preservation of these tokens from the past would suffer greatly. Under the circumstances, there is simply no good reason that can be advanced to depart from CPAC’s prior, well reasoned, recommendation against imposing import restrictions on coins of potential Italian origin. This is particularly the case given the grave harm that imposing import restrictions would cause to collectors and individuals legitimately dealing in and collecting coins and the adverse effect such restrictions would have on preservation of the world’s numismatic heritage.
Wayne G. Sayles, Executive Director
Ancient Coin Collectors Guild
1 The ACCG is a nonprofit organization committed to promoting the free and independent collecting of coins from antiquity. The ACCG has approximately four hundred fifty (450) individual dues paying members as well as a greatly extended constituency through fourteen (14) independent dues paying affiliated member clubs from coast to coast.
2 In the past Report of the Cultural Property Advisory Committee on the Request from the Government of Italy Recommending U.S. Import Restrictions on Certain Categories of Archaeological Material (Feb. 7, 2000) (CPAC Report), CPAC suggested that Italy adopt a law akin to the U.K.’s Treasure Trove law, that Italy make it easier to export artifacts, and that it adopt deaccession policies for excess artifacts in state collections. While the ACCG understands that the Italian Parliament has recently passed legislation allowing export of most ancient coins, the exact details of the law and how it will be implemented remain to be seen. In addition, despite CPAC’s recommendations, Italy has to date failed to adopt a law akin to the U.K.’s Treasure Trove law, and has similarly failed to have deaccessioned inventories of excess artifacts.
3 Coins were specifically added to the recent request from China for import restrictions. Some have argued for the inclusion of coins in a renewal of import restrictions from Italy. Coins were not exempted in the recently passed H.R. 1047 which potentially restricts their importation from Iraq. Coins from Afghanistan have been specifically identified for import restriction under the proposed H.R. 915 currently before Congress. In regard to ACCG overtures of cooperation, (A) Excerpt from a letter by fax, email and USPS (unanswered in any form) from Wayne G. Sayles, Executive Director, ACCG to Prof. Jane C. Waldbaum, President, Archaeological Institute of America: (Sayles) “The ACCG is ready and willing to support the archaeological community in its quest to eliminate the pillage and destruction of cultural heritage.” (B) Excerpts from email exchanges between Wayne G. Sayles and Cindy Ho, Founder/Executive Director of Saving Antiquities for Everyone: (Sayles) “I think it might be worthwhile developing a joint position paper that outlines our mutual commitment to preservation of history and heritage, while recognizing the legitimacy of collecting and trading in objects which have not been stolen, looted or illegally exported from a source country.” (Ho) “Our defined goals for 2005 do not permit us to undertake new projects this year. Nevertheless, I continue to appreciate your interest in SAFE’s mission to ending the destruction of our shared cultural heritage and undiscovered past by raising public awareness about the irreversible damage that results from looting, smuggling and trading illicit antiquities.” (C) Excerpts from correspondence between Wayne G. Sayles and Mr. Hekmat Karzai, First Secretary, Embassy of Afghanistan: (Sayles) “Rather than restricting the right of Americans to collect coins that teach them about the history of Afghanistan, we should be seeking ways for the collector community to assist in the preservation of that great heritage.” (Karzai) “Clearly it is vital for Afghanistan to preserve its heritage, yet we also recognize the need to teach individuals about the wonderful history of Afghanistan. We have to find a balance where both of the objectives are met.” (Sayles in reply) “ ...the loss of coins from the Kabul Museum is a loss to all of us, western collector and citizen of Afghanistan alike. Although some of the most significant coins have fortunately been located, others were obviously dispersed in the marketplace. Some collectors have acted independently to retrieve coins that were published as being resident in the Kabul Museum, and we know that such coins are being held for repatriation. The ACCG would like to help in this regard by sponsoring a diligent, continuing, search for such coins and getting them back into the Kabul Museum.”
4 See e.g., Theodore Buttrey, Kenan Erim, Thomas Groves, and R. Ross Holloway, Morgantina Studies II The Coins at xi (Princeton University Press 1989) (“The coins found at Morgantina are most entirely of bronze, as is usual in most excavations. The metal, less durable than gold or silver, has suffered not only from wear during the circulating life of the coins, but from the corrosive action of the soil, so that many have remained illegible even after cleaning.”).
5 See e.g., John Casey, Understanding Ancient Coins: An Introduction for Archaeologists and Historians, p.7 (B.T. Batsford 1986) (“An archaeologist was heard to remark that ‘Coins are only well dated pieces of metal’. He was of course wrong: coins are not usually well dated nor are they necessarily of metal. But these small technical points aside, the drift of the comment well reflects the place coin studies have occupied in the archaeological world. Coins are perceived as dating evidence, as art objects and as unique species of evidence that is best left to the numismatist and confined to the museum strong room at the earliest possible moment. It is the purpose of this short book to bring to the attention of archaeologists and historians something of the full potential of coin evidence.”).
6 See Frank L. Holt, Thundering Zeus: The Making of Hellenistic Bactria, p. 109 (University of California Press 1999) (“Even some advocates of the ‘New Archaeology,’ which treats every shred of evidence (even stray seeds and splinters) with utmost care, seem all too willing to sacrifice bronze coins. At Kourion, for example, the excavation director speaks of a ‘power struggle’ over the handling of stray coins: ‘I needed the coins cleaned as soon as possible for purposes of dating and identification; but the conservators, as is their wont, lobbied for the safest and slowest methods. The reader will perhaps not be surprised to learn that the dig director won out, particularly since the coins were hardly art treasures, and were in very bad shape.’ Bronze coins have long been valued as chronological indicators and little more; old habits die hard.”). In any event, given the typical circulation of ancient coins for hundreds of years, their use for dating purposes is dubious.
7 For more general concerns about the archaeological community’s failure to store artifacts adequately, see Zimmerman, Vitelli and Hollowell-Zimmer eds., Ethical Issues in Archaeology, p. 109 (Society for American Archaeology and AltaMira 2003) (“For all too long, archaeological collections have been treated as one-dimensional with respect to their needs. For far too long, any manner of building has sufficed as an archaeological curation facility, as long as it has had open shelf space and someone to unlock the door.).
8 The largest display of coins in Italy is at the Palazzo Massimo alle Terme in Rome. There are also more limited displays in various regional museums. However, given the large holdings of most museums and the difficulty of displaying coins, typically only representative samples can be displayed if any coins are displayed at all. This problem is not unique to Italy. Indeed, the United States recently lost its largest display of historical coins with the closing of the venerable exhibit at the Smithsonian Institution.
9 Numismatics has been a bridge between peoples from different countries for centuries. In fact, the numismatic trade puts American collectors and dealers in direct contract with their peers in other countries, most notably those in Europe. Moreover, because ancient coins are so common, they are excellent teaching tools. One of the ACCG’s affiliate member organizations is Ancient Coins for Education, a not-for-profit group which exposes students to classical history through the use of ancient coins. (http://www.bitsofhistory.com/ace/About/aboutACE.pdf).
10 See Ann Johnston, “Questions of Survival” in Studies in Greek Numismatics in Memory of Martin Jessop Price, p. 155 n. 3 (Spink 1988) (“In any case, few of the major sites have been excavated and the coin finds have been published from even fewer. For example, virtually nothing is known of the coin finds at Ephesus during a century of excavation, and only a tiny part of the Pergamum finds have been published. It is at least 20 years since coin finds were last published from Sardis, Aphrodisias or Side.”) In comparison and by way of example, within the last 10 years three members of just one ACCG affiliated numismatic club, the Ancient Numismatic Society of Washington, D.C., have published a total of five scholarly books on ancient numismatics: Victor Failmezger, Roman Bronze Coins: From Paganism to Christianity (Ross and Perry 2002) (collector); Arthur Houghton and Catharine Lorber, Seleucid Coins: A Comprehensive Catalogue Part I (ANS and CNG 2002) (collector); Brian Kritt, Seleucid Coins of Bactria (CNG 1996) (coin dealer); Brian Kritt, The Early Seleucid Mint of Susa (CNG 1997); Brian Kritt, Dynastic Transition in the Coinage of Bactria (CNG 2001). Further evidence of this fact may be found in A Survey of Numismatic Research 1996-2001 (International Association of Professional Numismatists 2003). The chapter about coins of Magna Graecia and Sicily in this comprehensive bibliographic survey lists some twenty-seven (27) titles on coins at archaeological sites among one-hundred sixty (160) studious works on coins of the area (Id. at 23-38). In other words, approximately one out of six scholarly works in this field were related to archaeology. It must also be noted that archaeologists are notorious for their extreme delay in publishing research when they bother to published at all. For example, the coins published in the Morgantina studies volume were excavated from 1955-1963, 1966-1971 and 1980-1981 yet the work was not published until 1989 or over thirty years from when the first group of coins were excavated! Moreover, it is unclear, what, if any efforts, have been taken since. In contrast, collectors and dealers publish widely in both scholarly and popular journals and several prominent coin dealers (most notably CNG, Spink and NAC) also act as publishers of scholarly numismatic books. To the extent CPAC makes recommendations to Italy in this regard, CPAC should suggest that Italy bar archaeologists from further excavations if they do not adequately conserve and publish their finds within a short time frame. Such rules have recently gone into effect in Egypt and there is no reason why Italy should not hold archaeologists to a similar standard. See Zahi Hawass, Dig Days: Foreign Expedition, Al-Ahram Weekly On-line (Jan. 13-19, 1995) (HYPERLINK "http://weekly.ahram.org.eg/2005/725/hr2.htm" (“Another rule is that every excavation team is responsible for conserving and restoring anything they discover. Publication is also essential: preliminary reports must be produced in the journal of the antiquities service, the ASAE, both in English and Arabic. A full scientific report must be published within five years, or the project will be suspended. This is very important. There are many expeditions that have been working here for 20 years, and have never published their work. Scientific results that are not available to scholars are useless and contribute nothing to our knowledge of the past.”).
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