July 6, 2020 Subrnitted via Regulations.gov portal

Mr. Stefan Passantino Chair of the U.S. Cultural Property Advisory Committee Cultural Heritage Center (ECA/P/C) U.S. Department of State 2200 C Street, NW Washington, DC 20037

Dear Mr. Passantino and Cultural Property Advisory Committee Members:

On behalf of the Ancient Coin Collectors Guild, this responds to object to the proposed extension of the MOU and associated import restrictions with the Government of Italy, as it impacts ancient coins, that is being considered by U.S. Cultural Property Advisory Committee's Public Notice, as described at 85 Federal Register 34797 (June 8, 2020) at Docket ID: DOS-2020-0022. The Ancient Coin Collectors Guild is a nonprofit organization, whose mission is to promote and nurture the free and independent collecting of coins from antiquity through education, political action and consumer protection. It has 22 affiliate member organizations and advocates for the interests of thousands of ancient coin collectors and hundreds of small businesses of the numismatic trade. Our website may be found at http://www.accg.us/home.aspx (last visited June 12, 2020).

To begin with, we question why it is necessary to extend this MOU, when the real jeopardy to Italy's cultural patrimony seems to come from poor stewardship by the Italian State.' Further

' For example, the largest group of ancient coins ever found in Rome -- over 38,000 coins -- occurred during the 1877 — 1890 construction along the Tiber River and excavations in the city. Yet by the first decade of the twentieth century, only 11,300 of the coins that comprise the Sottosuolo Urbano I, had been sorted and included in the coin cabinet collection at the Museo Nazionale. "[T]here are indications that people were allowed to purchase coins from the Rome finds at the Museo Nazionale in the late nineteenth and early twentieth centuries." A smaller group of the coins that comprise the Sottosuolo Urbano II, are stored in the Capitoline Museum, but they have yet to have been sorted and a list of them still remains unpublished. Nathan T. Elkins, The Image of Political Power in the Reign of Nerva, AD 96 — 98, p. 94 (Oxford University Press, 2017)(footnotes omitted).

"The care for the coins in Italian museum collections is not always of the highest standard. Over the years, many thousands of coins have been stolen from museums without great difficulty." International Association of Professional Numismatists, Report on Roman Republican and Roman Imperial Coins, p. 22 (June 26, 2020).

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restrictions will negatively impact hobbyists who collect Roman Republic and Roman Imperial coins for its history and culture. It will also negatively impact the cultural understanding such coinage provides as well as diminish the people-to-people contacts that collecting provides. As we will detail, it is well known that that it is typically impossible to assume a particular coin (especially Rornan ones) was "first discovered within" and "subject to the export control" of Italy. Indeed, huge numbers of Roman Republic and Roman Imperial coins were minted and distributed outside modern-day Italy, and are nowadays found widely and legally available for sale elsewhere and even within Italy itself.

The 2020 Public Notice deals with a proposed extension of the MOU with Italy "Concerning the Imposition of Import Restrictions on Categories of Archaeological Material Representing the Pre-Classical, Classical and Imperial Roman Periods of Italy." However, the Public Notice fails to detail how the scope of current MOU's Designated List is to be extended to include other items in the "Pre-Classical, Classical and Imperial Roman Periods of Italy." Indeed, the current Designated List found at 76 Federal Register 3012-3014 (January 19, 2011), is limited at Subcategory F to six detailed subcategories of "Coins of Italian Types": 1. "Lumps of bronze," 2. "Bronze bars (Ramo Secco and Aes Signatum)", 3. "Cast coins (Aes Grave)" "from the 4" century B.C.", 4. "Struck coins" "of the Roman Republic and Etruscan cities ... from the 3rd century B.C. to 211 B.C.," 5. "Struck colonial coinage" "from the 3rd century B.C. to c. A.D. 37," 6. "Coins of the Greek cities" from "the late 6th century B.C. to c 200 B.C." By its terms, the 2011 Designated List did NOT include either struck coins of the Roman Republic after 211 B.C. or struck coins of the Roman Empire. If the 2020 proposed "extension" of the MOU intends to expand the Designated List to include struck coins of the Roman Republic after 211 B.C. or struck coins of the Roman Empire, however, then the U.S. Cultural Property Advisory Committee is legally required to reissue a revised Public Notice, to inform the public of an expanded proposed Designated List, so to afford the public with advance notice to allow for meaningful comments.2

While there is an ongoing and spirited debate on the possible numbers of coins that could have been minted, it has been estimated that during the Roman Republic some 13,000 coins could be produced for each obverse die. Michael Crawford, Roman Republican Coinage, pp. 694-695 (Cambridge University Press, 1974). There certainly is no question that hundreds of millions of coins were minted in the far larger Roman Empire. "In the most elaborate attempt yet to calculate total mint production in the Roman empire, Duncan-Jones estimated that the central mint in Rome could produce as many as 52 million silver coins per year, under the emperor Elagabalus, and that over the course of eleven imperial reins between AD 64 and 235 it averaged some 22 million silver coins per year.... Under Septimius Severus alone, according to these estimates, the mint produced 532 million silver coins; under Antoninus Pius, 443 million."

2 The Administrative Procedure Act requires an agency's notice must "provide sufficient factual detail and rationale for the rule to permit interested parties to comment meaningfully." Fla. Power & Light Co. v. United States, 846 F.2d 765, 771 (D.C. Cir.1988). Moreover, any proposed departure that extends the import restrictions of ancient coins must be fully explained. The failure of an agency to comply with the procedural requirement to provide a reasoned explanation for its action is "arbitrary and capricious" under the Administrative Procedure Act. Dept. of Homeland Security v. Regents of the University of California, No. 18-857, 591 U.S. (U.S. June 18, 2020).

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Carlos F. Noreria, Imperial Ideals in the Roman West: Representation, Circulation, Power, p. 193 (Cambridge University Press, 2011)(footnotes omitted).

In any event, to the extent that the proposed MOU intends to restrict coins of the "Pre-Classical, Classical and Imperial Roman Periods of Italy," scholarly evidence demonstrates that struck coins of the Roman Republic after 211 B.C. and struck coins of the Roman Empire were minted, and have been typically found, outside the confines of modern-day Italy. International Association of Professional Numismatists, Report on Roman Republican and Roman Imperial Coins, (June 26, 2020). This means that such struck coins cannot be restricted under a proposed MOU with Italy, since 19 U.S.C. § 2601(2)(C) of the Cultural Property Implementation Act (CPIA) requires that any restriction be applied on artifacts that are "first discovered within- in the affected country.

I. Many mints of the Roman Republic and Roman Empire were located outside modern-day Italy. A. During the early stages of the Roman Republic, its mints were located in modern-day Italy. Around 118 B.C., however, the minting of coins was expanded to Rome's colony at Gallia Narbonensis (modern day Narbonne, France). Towards the end of the republic, huge quantities of Roman Republic coins were produced by various Roman military contestants, who travelled outside Italy with their troops and military mints. While the first was L. Cornelius Sulla's military mint coinage in 84-83 B.C., other military mints were used decades later during the civil wars that eventually marked the end of the republic. In these civil wars, each of the combatants issued coinage from their military mints while they travelled with their troops outside Italy. These civil wars began with the military campaigns between Julius Caesar against Pompey and his sons and Senate supporters from 49-45 B.C., each of whom used traveling mints to pay their troops. Then, after Caesar's assassination, mints traveled with the military campaigns of Marc Antony, Octavian and Lepidus against Brutus and Cassius from 44-42 B.C. It concluded with the mints that traveled with the military campaigns of Octavian against Antony from 42-36 B.C. David R. Sear, Roman Coins and their Values: The Republic and the Twelve Caesars 280 B.C.-96 A.D., pp. 102-103, 123-124 (Spink, 2000) and David R. Sear, The History and Coinage of the Roman Imperators 49-27 B.C., pp. 4-12, 31-38, 93-98, 119-132, 228-249 (Spink, 1998).

B. At the beginning of the Roman Empire, while the primary mint was in Rome, there were other mints located outside modern-day Italy. The mints outside Italy began at 15 B.C. at Lugdunum, Gaul (modem-day Lyon, France) and then Caesarea, Cappadocia (modern-day Kayseri, Turkey), until the Civil Wars of 68-69 A.D. when Roman military contestants coined money at Tarraco (modern-day Catalonia, Spain), Narbo (modern-day Narbonne, France), Nemausus (modern-day Nimes, France), Lugdunum, Carthage, Alexandria, Tyre, Antioch, Ephesus (modern-day Efes, Turkey), and Aquileia. The joint reign of Valerian and Gallienus (253-260 A.D.) saw the beginning of the total decentralization of the Imperial mint system, with mints established at Cologne, Antioch, Viminacium (near modern-day Kostolac, Serbia), Cyzicus (modern-day Balkiz, Turkey) or Emesa (modern-day Homs, Syria). Later, Aurelian (270-275 A.D.) had at least eleven mints, while Diocletian (286-305 A.D.) added mints at Trier, Germany and Heraclea (modern-day Eregli, Turkey). Indeed, of the 24 mints of the Roman Empire during and after Diocletian's reign, 19 of the mints were located outside modern-day

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Italy. David R. Sear, Roman Coins and their Values: The Republic and the Twelve Caesars 280 B.C.-96 A.D. pp. 65-71 (Spink, 2000).

II. Large numbers of Roman Republic coins are found outside modern-day Italy. A. Large numbers of Roman Republic coins are found outside modern-day Italy. This fact is widely known and confirmed by "Coin hoards of the Roman Republic Online" that is hosted by the American Numismatic Society. Found on the Internet at http://numismatics.org/chrr, this is a "database of Roman Republican coin hoards mainly from the period 155 BC to AD 2." Its map, viewed on June 9, 2020, contains a partial3 lists of hoard locations where Roman Republic coinage has been found -- both inside and outside modern-day Italy:

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As one example, to illustrate the wide geographic range where one type of a Roman Republic coin has been found, we researched in Coin Hoards of the Roman Republic Online the "findspots" of one coin type that one of our Guild members has in his collection. The coin is a Roman Republic silver denarius, minted around 110-109 B.C., and designated as RRC 301/1 in Michael Crawford, Roman Republican Coinage (Cambridge University Press, 1975). The coin's obverse depicts the helmeted head of Roma with an X below the chin and the words ROMA and PLEACA. The coin's reverse depicts a Roman soldier placing a hand on citizen's head with lector standing behind, with the word PROVOCO. The term provoco has been translated as "I challenge," which illustrates the right of appeal to the people against a magistrate's decision.

3 According to Coin Hoards of the Roman Republic Online at http://numismatics.org/chrr/pages/faq, number 5, "Kris Lockyear has been slowly adding more hoards to the database over 25 years [who] will continue to enhance his personal research database which will then be uploaded to the CHRR Online system about once a year." See also Kris Lockyear, "The Coin Hoards of the Roman Republic Database," American Journal of Numismatics, Vol. 28, pp. 159, 160 (2016)(Examines the origins and scope of the evolving CHRR database, which "at the time of writing contains some information about 718 hoards containing 120,177 coins of which 106,771 are well identified. Of these 510 hoards have detailed information concerning their contents and 208 only have limited information included in the main FINDSPOT table of the database.")

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Coin Hoards of the Roman Republic Online documents 101 examples of the Roman Republic coin type designated as RRC 301/1 in its database, with their "findspots" located in 11 nations throughout Europe and North Africa: Italy 52, Spain 9, Germany 1, Romania 21, Portugal 6, Greece 4, France 3, Bulgaria 2, Hungary 1, Tunisia 1, Yugoslavia (now the modern-day country of Bosnia-Herzegovina) 1. A photograph of the coin, along with a summary of the 11 national "findspots" from Coin Hoards of the Roman Republic Online http://numismatics.org/chrr (viewed June 12, 2020), is included as Attachment A.

B. Large numbers of Roman Imperial coins are found outside modern-day Italy. Large numbers of Roman Imperial coins are found outside modern-day Italy. This fact is widely known and also confirmed by "The Coin Hoards of the Roman Empire Project," found on the Internet at http://chre.ashmus.ox.ac.uld. This Project, a joint initiative of the Ashmolean Museum and the Oxford Roman Economy Project, "aims to collect information about hoards of all coinages in use in the Roman Empire between approximately 30 BC and AD 400." The Project's map, viewed on June 9, 2020, contains a partial4 list of locations where Roman Imperial coinage has been found -- both inside and outside modern-day Italy:

4 According to The Coin Hoards of the Roman Empire Project at http://chre.ashmus.ox.ac.uk/content/about "[t]his website are constantly being updated and expanded and should not be considered comprehensive." In Phase 1 (2013-18) the Project "aimed to collect summary hoard data from all Roman provinces, as well as inputting a selection of hoards at the level of the individual coin [, during which they] "succeeded in putting online summary records for 12,144 hoards and single gold coins, amounting to no fewer than 3.5 million coins." The aims of Phase 2 (initially 2019-2023) are to complete geographical coverage and to undertake the daunting task of systematically recording hoards at the level of the coin (including RIC numbers and full descriptions), where such data are available."

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Remarkedly, "[o]f the 2,199 hoards mapped in C[oin] H[oards of the] R[oman] E[mpire], only 62 (2.8%) [of Italian minted coins] were found within the borders of the Republic of Italy." International Association of Professional Numismatists, Report on Roman Republican and Roman Imperial Coins, p. 14 (June 26, 2020).

As one example, to illustrate the wide geographic range where one type of a Roman Imperial coin has been found, we researched in Coin Hoards of the Roman Empire Project the "findspots" of one coin type that one of our Guild members has in his collection. The coin is a Roman Imperial silver denarius, minted around 117 A.D., and designated as RIC 332 in Edward A. Sydenham and Harold Mattingly, Roman Imperial Coinage (Spink, 1968). The coin's obverse depicts the laureate head of Trajan facing right with the letters IMP CAES NER TRAIAN OPTIM AVG GERM DAC. The coin's reverse depicts Felicitas standing left holding caduccus and cornucopiea with the letters PARTHICO PM TR P COS VI PP SPQR. The Coin Hoards of the Roman Empire Project, at http://chre.ashmus.ox.ac.uk/ (viewed June 15, 2020) documents that it has 84 Roman Imperial RIC 332 coins in its database, with their "findspots" located in the six nations of: Bulgaria (1), Bosnia-Herzegovina (69), Cyprus (1), Jordan (5), Netherlands (1) and Serbia (7).

There can be no question that numerous hoards of Roman coins, and collections, are found outside Italy. International Association of Professional Numismatists, Report on Roman Republican and Roman Imperial Coins, (June 26, 2020). Carlos F. Norefia's Imperial Ideals in the Roman West, Representation, Circulation, Power (Cambridge University Press, 2011) Appendix I details a selection of the larger hoards that contain 148,421 Roman silver coins. They include 34 coin hoards in Britain, 17 coin hoards in western Europe (excluding Italy and the Danube region), 37 coin hoards in the Danube region,5 14 coin hoards in eastern Europe, Turkey and Syria. By the 1830's the Duke of Northumberland collected 1,718 Roman Republic and Imperial coins, each of which was detailed in William Henry Smyth's Descriptive Catalogue of a Cabinet of Roman Family Coins Belonging to the Duke of Northumberland (Savill & Edwards, London, 1856)(visited at https://www.google.com/books on June 22, 2020).

III. Further, if applied to struck coins of the Roman Republic after 211 B.C. and struck coins of the Roman Empire, we believe such an expansive import restriction will run afoul of at least four statutory provisions of the CPIA and should be denied:

A. To begin with, the governing statutory provision at 19 U.S.C. § 2601(2)(C)(i)(I) of the CPIA require any restriction be placed only on artifacts of "cultural significance." Coins are the first truly "massed-produced" objects in the ancient world, created by striking etched obverse and reverse dies onto hot blank metal disks. Yet the individual ancient coin is essentially a duplicate

5 This includes the Reka Devnia Hoard, which is largest find of Roman silver coins of the period from 64 to 251 AD. Found in 1929 near the ancient town of Marcianopolis (modern-day Devnya, Bulgaria), the hoard consisted of 81,044 denarii. The earliest coins from this hoard was of Roman Imperator Marc Antony with the latest of Roman Emperor Herennius Etruscus. See Mouchmov, N.A., Le Tresor Numismatique De Reka-Devnia (Sofia, 1934) and the Reka Devnia Hoard at Coin Hoards of the Roman Empire, at http://chre.ashmus.ox.ac.uk/hoard/Coins (visited April 1, 2020).

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minted from coin dies, which are produced in the thousands, and do not meet the "cultural significance" requirement. There is "a lot of debate as to whether or not nations and scholars should consider coins as culturally significant.... Coinage, in a general sense, provides evidence to historians about the monetary systems of ancient civilizations, various historical events, information about the art styles of ancient civilizations, and more. Individual coins, however, are 'by their very nature duplicates.' Nothing new about a culture can be learned from a duplicate coin if a single, viable copy of that coin has been studied." Cody Wisniewski, The Currency of History: The Possible, and Improper, Restriction on Ancient Egyptian Coinage, 17 San Diego Int'l L.J. 329, 346 (2016)(footnotes omitted and emphasis added).

B. The governing statutory provision at 19 U.S.C. § 2601(2)(C) of the CPIA also require that any restriction be applied on artifacts be that it is "first discovered within" in the affected country. Ancient Coin Collectors Guild v. U.S. Customs and Border Protection, 801 F. Supp. 2d 383, 407 n. 25 (D. Md. 2011)("Congress only authorized the imposition of import restrictions on objects that were 'first discovered within, and [are] subject to the export control by the State Party."). As detailed above, however, scholarly evidence demonstrates that struck coins of the Roman Republic after 211 B.C. and struck coins of the Roman Empire were also minted, and are now typically found, outside the confines of modern-day Italy.

Extending import restrictions of ancient coinage from the "Classical and Imperial Roman Periods of Italy" is impermissibly vague, excessively broad, and unwarranted under the CPIA. Over the course of thousands of years of human history modern-day Italy had been parts of a larger Roman Republic as well as an even larger Roman Empire, which minted coins there and in other locations. Indeed, such "Roman- coins were minted, and can be found, in areas other than modern-day Italy. No one can assume all such coins -- or even a substantial percentage of them -- were "first discovered within" just modern-day Italy.

C. The governing statutory provision at 19 U.S.C. § 2602(a)(1)(C)(2) of the CPIA also require that before any restriction can occur that "remedies less drastic than the application of the restrictions set forth ... are not available." Yet Italy has not adopted the "less drastic- system that exists such as with the United Kingdom's Treasure Act and Portable Antiquities Scheme.6 Fully detailed at www.finds.org.uk, the United Kingdom's system is well regarded, effective, and is clearly "less drastic" than Italy's system. The United Kingdom's system promotes the maximum public interest and benefit from the recovery, recording and research of portable

6 The British Museum's 8-page Portable Antiquities & Treasure Strategy: 2020, at https://finds.org.uk/documents/file/PAS-strategy-2019.pdf (visited June 27, 2020), lists many of the key accomplishments of the United Kingdom's Portable Antiquities Scheme. This includes that it "has recorded over 1 million archaeological finds discovered by the public on its online database, helping to identify new archaeological sites and help rewrite our understanding of the past[; that o]ver 10,530 Treasure fmds have been reported via the PAS, of which 37% have been acquired by 215 museums across England and Wales for public benefit[; that] PAS data is important to archaeological research, and has been used in at least 455 research projects, including 20 pieces of large-scale research and 95 PhDs[; the t]he Code of Practice for Responsible Metal Detecting in England and Wales provides the baseline for best practice for those searching for archaeology[; and that t]he PAS provides a model for other finds recording systems, such as those being established in Flanders, Denmark, the Netherlands and Finland."

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antiquities; promotes best practice by finders/landowners and archaeologists/museums in the discovery, recording and conservation of finds made by the public; in partnership with museums and others, raises awareness among the public; creates partnerships between finders and museums/archaeologists to increase participation in archaeology and advance our understanding of the past; and increase opportunities for museums to acquire archaeological finds for public benefit.

D. According to the Bureau of Educational and Cultural Affairs, found at https://eca.state.gov/cultural-heritage-center/cultural-property-advisory-committee/foreign-government-requests, a Foreign Government's request for cultural property protection must "include a statement of facts that addresses the matters on which the Department makes the determinations specified in the CPIA, 19 U.S.C. § 2602(a)(1)." These determinations must include... "4. Credible enforcement efforts, including monitoring for compliance and appropriate sanctions, documentary evidence of which should include data of sufficient duration and scope to provide the information necessary for a reliable determination."

Yet, the 2020 Public Notice does not document — much less even allege -- that Italy has either requested an extension or expansion of cultural property protection. The 2020 Public Notice also does not document — much less even allege -- that Italy has engaged in "credible enforcement efforts." Finally, the 2020 Public Notice does not document — much less even allege -- that Italy has provided to the U.S. Cultural Property Advisory Committee the required "data of sufficient duration and scope to provide the information necessary for a reliable determination.-

IV. Conclusion The Ancient Coin Collectors Guild urges the U.S. Cultural Property Advisory Committee to reject the proposed "extension" of the MOU and associated import restrictions with the Government of Italy, as it impacts ancient coins. Insofar as the 2020 proposed "extension" of the MOU also intends to expand the Designated List to include - Pre-Classical, Classical and Imperial Roman Periods of Italy," however, then the U.S. Cultural Property Advisory Committee is legally required to reissue a revised Public Notice, insofar as the term "Pre-Classical, Classical and Imperial Roman Periods of Italy" is impermissibly vague and fails to inform the public of the scope of proposed expanded import restrictions. Indeed, it is unclear to the extent the 2020 proposed extension of the MOU would include struck coins of the Roman Republic after 211 B.C. or struck coins of the Roman Empire, thereby failing to afford the public with advance notice to allow meaningful participation and to submit comments.

The issues regarding ancient coins are very important to the large numbers of collectors like our members of the Ancient Coin Collectors Guild, who collect coins out of love of history and as an expression of our own cultural identity. And while the American Numismatic Association at www.money.org/consumer-awareness/ancient-coin-import-restrictions, "fully supports the idea of protecting cultural property,- it has "consistently argued that ancient coins should not be included in MOUs for a number of reasons. First, coins are among the most common and durable of artifacts (with a few notable exceptions), and therefore the information they contain is in no danger of being lost to historians or archaeologists in the way unique or rare objects would be if not preserved in cultural institutions. Additionally, there is no shortage of coins in

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museums in nations that have ancient specimens as part of their history, particularly Europe, the Middle East and China. Finally, coins are excellent teaching tools. Their durability — and the large number of specimens available — make them ideal collectors' items. They encourage interest in the past, which in turn promotes educational programs in museums and universities, many of whose collections were formed or financed by hobbyists."

lly submi ,

Randolph J. Ancient Coin ol cto W Guild P.O. Box 911, Gainesville, MO 65655 tel: 417-679-2142 email: director@accg.us Web Site: http://accg.us

Attachment A: Photograph of Roman Republic RRC 301/1 coin and that Coin Hoards of the Roman Republic Online's database has 101 coin types with "findspots" located in 11 nations.

Attachment B: Photograph of Roman Imperial RIC 332 coin and that The Coin Hoards of the Roman Empire Project's database has 84 coin types with "findspots" located in 6 nations.

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ATTACHMENT A

I. Photograph from a personal collection of one Roman Republic silver denarius, minted cir. 110-109 B.C.

Obverse is a Helmeted head of Roma facing right with X below chin ROMA PLEACA.

Reverse is a Roman soldier placing hand on citizen's head with lector standing behind, PROVOCO.

(Crawford RRC 301/1)

II. Coin Hoards of the Roman Republic Online at http://numismatics.org/chrr (viewed June 12, 2020) documents that it has 101 Roman Republic RRC 301/1 coins in its database, and that their "findspots"

are located in eleven nations: Italy 52, Spain 9, Germany 1, Romania 21, Portugal 6, Greece 4, France 3, Bulgaria 2, Hungary 1, Tunisia 1, Gajine,

Yugoslavia 1 (now the country of Bosnia-Herzegovina).

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ATTACHMENT B I. Photograph from a personal collection of one Roman Empire silver

denarius, minted cir. 117 A.D. Obverse is a Laureate head of Trajan facing right

IMP CAES NER TRAIAN OPTIM AVG GERM DAC. Reverse is Felicitas standing left holding caduccus and cornucopiea

PARTHICO PM TR P COS VI PP SPQR. [Roman Imperial RIC 332]

II. Coin Hoards of the Roman Empire Online at http://numismatics.org/chrr (viewed June 15, 2020) documents that it has 84 Roman Imperial RIC 332 coins in its database, and that their "findspots" are located in six nations:

Bulgaria (1), Bosnia-Herzegovina (69), Cyprus (1), Jordan (5), Netherlands (1) and Serbia (7).

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