I’m glad the ministry…

I’m glad the ministry finally is going to submit revisions to the S&Gs. Some things are good but some things are lacking. As a licensed archaeologist, here is my take.

Glossary and Terms: changes were a good choice and are meaningful. No issue here

Stage 1: Background Study and Optional Property Inspection (Section 1)
Removal of Section 1.2 “Property inspection (optional)
- This is a problematic decisions. Desktop analysis is sometimes not sufficient to entail a complete assessment of a Project Area, especially when ‘writing’ off areas as disturbed, sloped, or wet. I think giving archaeologists and the clients the option of a property inspection early helps in determining areas that are free of potential, or the opposite, more accurately, helping to plan scheduling and budgets of Stage 2s more effectively. How I see it, in this new standard we’re just more likely to give completely different determinations of Arch potential (or lack thereof) to the Client between the Stage 1 and the Stage 2 field work and it will just lead to more confusion, or change orders, etc.
- I think this comes more down to how the Ministry can’t build any consistency on how valid they think Desktop-only reviews are versus Desktop + Property Inspection Reviews are. My initial assumption is that AROs are going to now assume there is more Arch Potential everywhere now since there are no Property Inspections to clearly illustrate deep land alterations, permentaly wet areas, and steeply sloped areas. So in this case, no one is served better in this change.. I am very confused by this..

Stage 2: Property Assessment (Section 2)
- looks fine – still confused on the property inspection component
- Section 1 standard 4g (on letters from approval authority). This seems like a task that can delay a report submission too. Also, what kind of document does this take? Some kind of clearance from a City/Region that development can only happen in say a 25% southwest corner of a lot?
- Limits of archaeological site – this makes sense. I approve

Stage 3: Site Specific Assessment (Section 3)
- Section addition on “Continuing temporary avoidance and protection of archaeological sites” makes sense. Fine

Geospatial Data Documentation
-This is a good update. We are well into the wide-spread use of GPS systems and we should continue to uphold this standard that geopositioning data collection is well described and documented

Project Area versus Property Area new terms:
I think this is useful for in effect allowing for “partial clearance” in which was previously cumbersome. I have had to deal with different Archaeological Review Officers (ARO) that have interpreted the 2011 S&Gs differently on projects. One might say and entire property needs a Stage 2 assessment prior to submitting partial clearance (covering areas well over 50m from planned land impacts will occur) and reject my partial clearance recommendations for not test pitting and pedestrian surveying the ENTIRE property while others will say it is fine since these are not lands to be impacted. This clarity removes the vagueness that existed in the 2011 S&Gs while removing the risk of vigilante AROs or just general discrepancy between ARO decisions.

Proposed Criteria for Evaluating LCA Compliance:
My only comment when the Ministry decides on this is that they ensure everything can truly be demonstrable. Our industry, and many that participate in it, unfortunately rely on reputational conjecture and vibes rather than demonstrable facts on the quality of work of some licensed archaeologists. So there must always be clearly defined and TIMELY appeal processes too in response to non-compliance determinations. These are people’s livelihoods and false reputational attacks can lead to long term economic consequences for the person in question. However, at the same time, it is important that we find ways to monitor LCA compliance as there may be people out there that need greater scrutiny.

I feel this could have been an opportunity to better define or increase indigenous engagement but the recommended changes do not address anything meaningfully. This has been a failing.

I feel many other components of archaeologist assessment and site mitigation need an overhaul to what have in effect become best practice (e.g. MTR’ing an entire Woodland village is no longer accepted by First Nation groups and has been largely phased out). I do not see any of this in the proposed changes. This was a missed opportunity.