Learn to let go gracefully

Now that the dust of the The Three Graces affair has settled, George Go ldner considers, from an American perspective, the strange phenomenon of Europe's burgeoning cultural protectioni sm

The recent sale and attempted export of Canova's The Three Graces has once again focused attention on the subject of British art heritage and on the methods employed to prevent its export. The exaggerated behaviour of most of the main protagonist s in this case might lead a casual observer to the conclusion that the issues are confused and contentious.

In fact, the underlying issues are relatively straightforward. First of all, it is clear that certain objects are of national importance on account of their quality and historical significance. Less obvious is whether, and to what extent, efforts should be made to retain them.

In a time of easy travel and worldwide cultural integration it would seem that a strong case exists that art should be freely exportable from one country to the next. This is all the more true since the vast majority of major objects are already in museums: with a few exceptions, little is really at stake. One may indeed wonder why the issue is of more than passing interest to the press and public.

The answer probably lies in the need people have to maintain the distinctive character of their culture, even more strongly at a moment of historical internationalism. A society whose culture is threatened by television, tourists and tunnels will naturally react by holding on to its symbols, just as the French are now struggling to preserve their pastoral tradition and language.

To say that the issue is driven in part by emotion is not to deny its merit. Cultural symbols have always been important and when they are benign there is no reason not to endeavour to preserve them. But there is another side of the debate. No reasonableperson can deny the value of making art available to different cultures beyond the one that produced it. Is it not a good thing for artists, scholars and the public worldwide that not every Turner is kept in Britain? Would it truly be a hardship if one or two more left? Works sent abroad have an ambassadorial function, promulgating the values they express.

Balance should also be sought because many individual cases lack the kind of theoretical purity that should serve as underpinning for an extreme position. To give one example, years ago I was visited by a British colleague who noticed a poster in my office in Malibu, where I was working for the Getty foundation, showing a Mantegna drawing I had bought from Chats- worth. He remarked that he hoped that if the Getty ever returned the art it was acquiring to its homes, the Mantegna would be high on the list. I replied that a drawing made by a Paduan artist for an altarpiece in Verona and that probably spent half its life in Italy should probably be returned there, rather than to England. Equally, though no rational person will support the notion put forward by Melina Mercouri that the Elgin Marbles should return to Greece, what makes this so is practical reality - not the principle of national heritage.

it is best, therefore, to deal with the issues in practical terms, recognising that principle exists on both sides. Extreme solutions are to be avoided. The Italian approach is a model of how to achieve a uniformly negative result. All works of art that are even of fairly good quality are effectively unexportable. In addition to the inherent injustice of this system (which offers no compensation to the owners), it has led to a situation in which collectors either hide objects in Italy or smuggle them out for sale or safekeeping. Only those luckless owners whose collections are known to state museums officials are prevented from selling their art abroad. Worse, the approach actively discourages the formation of new collections, e xcept by those willing to see their art only on visits to the Swiss free ports.

It is also important to recognise the true dimensions of the problem, which have been exaggerated at times, perhaps to dramatise the heritage position. In fact, not a single truly great painting has left Britain since Velasquez's Juan de Pareja, bought by the Metropolitan Museum of Art in 1971. Several good pictures have been exported, but few that would have made much impact in the National Gallery. The only serious loss has been in the field of drawings, where the two Chatsworth sales dispersed the la st of the great private collections. This resulted from what appeared to be an inability to properly value the drawings or to consider the inevitable consequences of failing to negotiate a purchase. The failure was not in the system and the problem is un likely to recur.

But if the system is - generally - working, it is perceived to be under stress. Funding has probably been inadequate, and the tax programme is ungenerous. To put the matter more starkly, if I were to give a painting to the National Gallery in London through its Americansupport group, I would receive a greater tax benefit from the American government than an English person who does the same from his own country Campaigners have occasionally exaggerated the problem, and this may give an impression that itwill require great steps to solve it. In fact, with a generous income from the new lottery and a simple tax reform, the issue would almost disappear.

Seen in this light, The Three Graces presented a false sense of the issues. But it did point up some deficiencies in the system: who was the seller, and why did the price quadruple in the period between its initial sale and the offer from the Getty? It also raised the question of whether objects closely connected to a specific location should not remain there rather than being sent to a museum, or in this case two. Lastly, it revealed that export cases are not played out on a level field. Only the naivewould have thought so before and this case surely makes clear that the advantage goes to the nation attempting to retain its heritage. This is probably as it should be, but it is a point to be borne in mind when the British museum officials look abroad,with lottery money in hand, to start a new stage in the history of British collecting.

n George Goldner is the Metropolitan's Drew Heinz Chairman, Dept of Drawing and Prints