Revision of the Standards…

Revision of the Standards and Guidelines for Consultant Archaeologists is an important opportunity to reflect on the lessons and experiences gained since they were implemented in 2011. It is not clear that the most has been made of this opportunity nor, given the proposed timetable for roll out, that there is any desire to do so.

I have many concerns with many aspects of the proposed changes to the Stage 1 and 2 archaeological assessment sections related to the status of property inspections, definition of project areas, the increased administrative burdens that will arise from many of the changes, and the likelihood that costs to proponents will only go up as a result. But I expect that these issues will be pointed out by most commentators and will not go into further detail on those matters. Rather, I would prefer to focus on what has, in my experience, been one of the most problematic elements of the 2011 document and which has not been addressed at all in the current revisions.

The Standards and Guidelines are overwhelmingly biased towards the conduct of archaeological assessments in rural or green field settings and the methods of investigation of the sites that are found there. There is little recognition of practice in urban contexts, which requires different modes of thinking as well as methods of investigation and evaluation. This has meant that, as they stand, the Standards and Guidelines have never provided a basis for consistently sound practice in the Stage 1 and 2 assessment processes, or indeed in Stage 4 excavation and mitigation projects.

Ministry staff and some parts of the archaeological consulting industry have long recognized this shortcoming and developed approaches to make the Standards and Guidelines conform to the unique character and concerns of urban archaeology, rather than letting them constrain, or distort, how this work is undertaken, often to the detriment of the archaeological resources. This led to the Ministry sponsoring a workshop on these issues at the Ontario Archaeological Society symposium in 2019.

Sadly, little good seems to have come from that effort. The proposed 2026 revisions do nothing to address the shortcomings of the relevant sections of the 2011 document. Standard 2.1.7 is the most problematic in this regard, leading as it often does if applied uncritically, to unnecessary, or unnecessarily costly, lengthy and invasive assessments. With essentially an entirely new cohort of Archaeology Review Officers at the Ministry, these problems will only increase if the 2026 document comes into effect with no attempt to address its shortcomings in terms of work in urban contexts. This flies in the face of many of the stated objectives of the Heritage Framework Transformation.