Our FOIA administrative appeal contends that our FOIA request, which was divided into three parts and contained almost two pages of supplementary information, did reasonably describe the records sought. The two "art trade" members were recently posted as additions to the Cultural Property Advisory Committee, after the ACCG filed repeated complaints with Department of State and then to its Inspector General. While the two "art trade" members purport to have expertise, however, there is nothing in the public record that they are "experts in the international sale of archaeological, ethnological, and other cultural property" as required by the Cultural Property Implementation Act. Since the Act requires such members to be experts, and that appointments be made to ensure "fair representation" of the interests of various private sectors, the ACCG filed the FOIA request on November 26, 2021, seeking documents on how the two members qualified as experts and as "art trade" representatives.
