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March 3, 2021 Cultural Heritage Center (ECA/P/C) SA-5 Floor C2 U.S. Department of State 2200 C Street NW Washington, D.C. 20522-05C2 Dear Members of the Cultural Property Advisory Committee: The Archaeological Institute of America (AIA), with its membership of approximately 200,000 professional archaeologists, corresponding members, students, and enthusiasts, all united by a shared passion for archaeology and its role in furthering human knowledge, expresses its strong support of the request by the Government of Albania to impose U.S. import restrictions on certain categories of archaeological material from the Middle Paleolithic to the Ottoman Period and ethnographic material from the Byzantine, Middle Age, and Ottoman periods under Article 9 of the UNESCO Convention (1970) and the Convention on Cultural Property Implementation Act (1983). At the core of its mission, the AIA promotes archaeological inquiry and public understanding of the material record of the human past to foster an appreciation of diverse cultures and our shared humanity. The AIA supports archaeologists, their research and its dissemination, and ethical professional practice; educates people of all ages about the significance of archaeological discovery; and advocates for the preservation of the world’s archaeological heritage. The modern country of Albania encompasses ancient Illyrian settlements, Greek colonies, and Roman cities that were part of the provinces of Dalmatia, Macedonia and Moesia Superior. Port centers along the Adratic coast served as critical locus points for international trade throughout antiquity. Archaeologists study the development of social complexity in the ancient Mediterranean world, and the interaction of diverse groups and polities in this region helps us to understand how provincial interactions shaped the development of empires and regional cultural traditions. These are core subjects of study for the AIA’s membership. Current excavations continue to provide new knowledge about the about the distribution of ancient settlements and cities, mortuary customs, trade networks across the ancient Mediterranean, and the lives of everyday people outside of the Italian peninsula and Greek mainland. Albania has three sites on the World Heritage List with significant archaeological finds: Butrint (an ancient Greek and later Roman city and bishopric in Epirus, with a Greek theater, Late Antique Baptistry, and surviving fortifications); the Historic Centres of Berat and Gjirokastër (which include Byzantine churches and Ottoman castles); and the Natural and Cultural Heritage of the Ohrid Region (which include Illyrian settlements, remains of the Via Egnatia Roman Road and the Paleo-Christian Church of Lin). Despite the presence of dramatic fortifications, burial tumuli, amphitheaters, and palace architecture archaeologists interpret the social history of the ancient world through regular and ordinary artifacts. For this reason, the AIA is particularly interested in continuing to include in the MOU such mass-produced items as coins, ceramics, worked stone, metal ingots, glass, worked wood, organic materials, and other items of exchange. These artifacts provide crucial information—when found in their original archaeological context—about mechanisms of communication, commerce, and the circulation of goods in antiquity. The Cultural Property Advisory Committee must undertake a review of four statutory determinations when reviewing the request by a State to enter into a memorandum of understanding imposing import restrictions on certain classes of looted cultural property. This letter will address the first, second, and fourth determinations in the case of Albania. The first determination requires that the cultural patrimony of the requesting State be in jeopardy from the pillage of archaeological materials. The current extensive pillage of archaeological sites in Albania dates to the Albanian Civil War in 1997, which seems to have prompted extensive looting for ancient goldwork and other salable finds. Much of the archaeological research that followed the Albanian Civil War was a “rescue archaeology” of looted cultural heritage sites.1 Despite heroic efforts by Albanian authorities to curtail archaeological site looting and illicit trafficking in the intervening years, significant pillage continues— especially of underwater cultural heritage sites. Recent news reports have noted extensive looting of shipwrecks, in particular of Roman amphorae.2 The AIA has been concerned with the looting of archaeological sites in Albania for some time. In 2009, the AIA hosted Lorenc Bejko, a faculty member at the University of Tiranë, as its Kress Lecturer, specifically to draw attention to the looting of archaeological sites such as the Tumulus of Kamenica (a Bronze Age and Iron Age burial mound, with some 200 internments). Bejko’s research found that some 15 percent of the overall mound had been damaged by looting. This pillage damaged the integrity of the monument and resulted in the irreversible loss of important contextual data. Bejko publicized the looting of the site widely in Albanian media, showing the loss to the country. His work highlighted the role of professional archaeologists and the role of law enforcement, which generated new interest in protection initiatives and educational programs. Bejko also founded the Albanian Rescue Archaeology Unit as part of the International Center for Albanian Archaeology with the support of the Packard Humanities Institute to promote documentation and salvage research. The second determination requires that a requesting State have “taken measures consistent with the 1970 UNESCO Convention to protect its own cultural patrimony.” Such measures include adopting and enforcing legal provisions to protect the cultural patrimony, creating a national inventory of protected cultural property, establishing an antiquities service (or similar government agency), establishing scientific and technical institutions, such as museums, taking educational measures, and organizing the supervision of archaeological excavations.3 The Ministry of Culture of Albania sets national policies in cultural heritage management. It coordinates with several institutes with specific domains of responsibility. The National Cultural Heritage Safeguarding Inspectorate serves as the official inspector of archaeological investigations, manages preservation and restoration projects, and implements cultural property registration. The National Cultural Heritage Institute focuses on research, study, conservation, and preventative and salvage archaeology. The National Cultural Heritage Registration Institute maintains the official register of cultural property in Albania and works to prevent cultural property trafficking by coordinating with Albanian state institutions, law enforcement, and international organizations. Altogether, this infrastructure for heritage protection demonstrates Albania’s implementation of “measures consistent with the 1970 UNESCO Convention,” as required by the second determination. 1 See Diana Michelle Fox, “Under Albanian Soil,” Archaeology, Online Features, 12 August 2004, accessed at https://archive.archaeology.org/online/features/albania/ 2 See Briseida Mema, “Looters Plunder Albania's Sunken Treasures,” Phys.org, 18 November 2018, accessed at https://phys.org/news/2018-11-looters-plunder-albania-sunken-treasures.html; and Philip Chrysopoulos, “Dozens of Ancient Greek Shipwrecks Found Looted off Albanian Coast,” Greek Reporter, 20 November 2018, accessed at https://greekreporter.com/2018/11/20/dozens-of-ancient-greek-shipwrecks-found-looted-off-albanian-coast/. 3 This list is based on Article 5 of the UNESCO Convention (1970). It illustrates those measures that the Convention expects States to take and is the basis for the second determination under the Convention on Cultural Property Implementation Act. The fourth determination looks to whether import restrictions are “consistent with the general interest of the international community in the interchange of cultural property among nations for scientific, cultural, and educational purposes.” Among other criteria, this determination looks to whether a requesting State is receptive to collaboration with foreign, especially American, researchers and whether it is willing to lend cultural objects to foreign, particularly American, institutions. Albania has been open to American archaeological investigations. The first American research project in Albania was an investigation of Konispol Cave, co-directed by Karl Petruso (University of Texas, Arlington) and Muzafer Korkuti, with the assistance of Curtis Runnels (Boston University) and Lorenc Bejko. The first large-scale American project was the Malakastër Regional Archaeological Project (MRAP) at the Greek colony of Apollonia, co-directed by Jack Davis (University of Cincinnati), Sharon Stocker (University of Cincinnati), Michael Galaty (University of Michigan), Muzafer Korkuti and Skender Muçaj. Investigations at Dyrrachium-Epidamnus (an ancient Greek city in Illyria founded in the 7th century BC by colonists from Corinth and Corcyra) were co-directed by Davis and Stocker together with Iris Pojani and Afrim Hoti. The Bonjaket Temple excavations, which emerged from MRAP, were co- directed by Davis, Stocker, Pojani, and Vangjel Dimo. Galaty also co-directed the Shala Valley project together with Ols Lafe and Zamir Trafilica. The project data, archived at the Archaeology Data Service, is freely available to both the American

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