Quote: The two commem limit is why the mint turned to striking silver medals in 2003 for the NWF series, which were struct on proof silver dollar planchets. They later turned to striking medals on
ASE planchets, like this year's American Liberty medals.
I'm sorry, but this is not an accurate statement. Neither the striking of the National Wildlife Refuge silver medals by the US Mint in 2003 nor the medals struck in subsequent years has a direct cause-and-effect connection to the limit placed on US commemorative coins years earlier.
Congress imposed the two-program per year limit for commemorative coins in 1996 via a bill that would become Public Law 104-208 when it was signed by President William Clinton. This bill was specific to commemorative coins.
The Mint has long had the authorization to strike medals without case-by-case Congressional authorization (such authorization dates back to 1873). It is free to collaborate with other Government Agencies and Departments on medal projects; such was the case with the National Wildlife Refuge medals.
The medal route was not chosen, however, because commemorative coins were not an option. As Congress had only authorized one commemorative program for 2003 (the Wright Brothers' First Flight Centennial), a program for the National Wildlife Refuge centennial could have also been considered. No bills calling for a NWR commemorative coin program were introduced, however.
This year's American Liberty medal is not specifically a commemorative medal. While it does celebrate the concept of liberty in America, the medal is part of the Mint's new Liberty-themed gold coin and silver medal series that is expected to become an annual program - it is a thematic or topical series rather than a commemorative series and is not sponsored by a private organization (as all NCLT US commemorative coins are) or a vehicle for fundraising via surcharges (as all NCLT US commemorative coins are).