I write to voice my support for the request made by the Government of the Republic of Cyprus to extend the July 19, 2002 Memorandum of Understanding with the United States and include pre-1750 coins with verifiable Cyprus mint marks that are discovered on the island of Cyprus within the definition of “cultural property” and “archaeological material” under the Cultural Property Implementation Act (CPIA).
I write to you as an interested lay person and member of the non-profit organization SAFE / Saving Antiquities for Everyone. I have no economic, professional or career interest at stake in this matter, nor do I have a client relationship with anyone who might be affected by the outcome of the Cyprus request. I am not a collector or an archaeologist.
CPAC should recommend that pre-1750 with Cyprus mint marks which are found on the island of Cyprus be included in the Cyprus MOU renewal for the following six reasons:
1. The American public strongly favors cultural protection regulations and source country rights. The most recent Harris poll on attitudes about cultural heritage preservation, conducted for SAA in the year 2000, show that:
• 96% of Americans believe there should be laws to protect archaeological resources, and
• 64% of Americans believe that archaeological objects should not be removed from a foreign country without that country’s permission.
2. Ancient coins are among the most important of all archaeological artifacts. Our ability to identify and date the coins reveal innumerable details about the site (approximate start and end date of the settlement based on the dates of the coins found, commercial activity, political spheres of influence, secular and religious practice and myriad other details). Denying protection to ancient coins will likely destroy vital information, which archaeologists and historians need, in the rapidly-dwindling number of ancient coins that remain in the ground. Denying protection to ancient coins that Cyprus has requested will fuel the continued destruction of ancient sites in Cyprus by treasure hunters who scatter and destroy non-numismatic material while searching for coins - activities that take place in clear violation of the country's antiquities law of 1935.
3. Ancient coins are cultural property worthy of protection. Pre-1750 coins are included in the definition of cultural property in Article I (e) of the 1970 UNESCO Convention.
4. The Cyprus request could not be more tightly defined, making it easy to monitor and implement. A temporary (five-year) import restriction is being sought only for pre-1750 coins with Cypriot mint marks that are found on the island. All other Cyprus mint-marked coins found elsewhere are not affected. All other ancient coins with no mint marks or non-Cyprus mint marks found on the Island are not affected.
5. The “coin trade restrictions do not work” argument cannot be judged until we have empirical evidence. Many people who oppose the Cyprus request argue that import restrictions on coins are not practical and will not achieve the desired result. But there is no evidence to that effect, and no evidence to make the counter-argument, because the Committee has never granted any protection to ancient coins. Present members of the Committee owe it to future Committee members to conduct a “test” in order to develop a knowledge base; study the effect that a temporary import restriction will have; limit the test to a small, easily identifiable, subset of the ancient coins found in one of the smallest countries in the world; survey market participants, archaeologists, and law enforcement to law enforcement; use the evidence gathered to make future decisions. The ideal test case is the Cyprus request.
6. The US should not be perceived as having selectively repealed a key element of the Convention. After nearly a quarter century of UNESCO Convention implementation under CPIA, the US is, in fact, alone among parties to the Convention in consistently excluding ancient coins from the type of protection that the UNESCO Convention was drafted to provide. If the US cannot grant the very narrow request that Cyprus is making, the US will appear to be saying to all other parties to the Convention that no ancient coins will ever be afforded protection under CPIA, effectively ignoring a fundamental aspect of a treaty to which the US has declared itself a party.
If site looting on the island is curbed during that five-year timeframe, allowing the discovery of just one intact site, the information that can be gleaned may reap significant benefit to Cyprus, to scholars and students worldwide — and even to collectors and dealers in the US who oppose the Cyprus request. Knowledge benefits all.
I ask CPAC to grant the Cyprus request with regard to coins as a matter of simple equity and an example of good public policy.
Sincerely yours,
Stephanie Dodaro