1. Process and Practice Must be Predictable
A common sentiment expressed was that efforts to improve the existing, unsatisfactory Technical Guidelines have taken over a decade and it is time to complete the task and move on to other issues, because this extended transition period has created much uncertainty in the consultant archaeologist’s day to day efforts to meet Ministry expectations. The hope is that, with a final version of the S&G implemented, common expectations will be in place that will quickly standardise what have increasingly become variable practices by individual licensees and Ministry reviewers. For consultant companies, this consistency of expectation addresses their clients’ key concern of managing risk in the process (i.e., all parties will know what to do to get sign off at conclusion of work done). It was also hoped that, with these S&G in place, the Ministry would be able to dial down the detailed level of report review, thus freeing staff and resources to tackle many other issues and service delivery demands (e.g., online forms, data access and report submission; collections management; First Nations relations; research and avocational support).
2. Ministry Review. Many concerns that were raised about the S&G proved to be less about content, and more about Ministry staff interpretation of the S&G during after-the-fact report review, and variable preferences that have emerged among staff since 2006 (and the perception that these preferences have drifted away from even the draft S&G content). A common underlying and unanswered question among members was that, with well over a hundred pages of standards, are the S&G going to work as a document that sets broad expectations for licensees to follow, alongside their experienced judgement, or are they going to work as 100+ pages of potential “gotchas,” whereby reports are reviewed to find missed or minor variations, with no allowance for licensee judgement and project specific context? The strong hope was that the answer would be the former, though the strong anxiety was that the latter would prove to be the case. Universally, the sentiments expressed were that with implementation, the Ministry needs to allow for licensee judgement in the field, shift away from policing report content for the sake of report content, and focus more on ensuring that broader outcomes of practice (i.e., good conservation and management of Ontario’s archaeological heritage) are achieved.
3. The S&G Must Be a Living Document. Another common message heard was that whatever the content of the S&G, moving forward there will be disputes and problems with what the content of the S&G includes and excludes. This will occur because practices will evolve over time. As such there was a concern that innovative approaches that emerge will not be allowed only by virtue of the fact they had not been anticipated in the document, or that differing interpretations of existing standards and their dispute resolution would operate by Ministry fiat. Most licensees indicated they felt the S&G should be a living document, with the Ministry flexible to recognising emerging innovative practices and changed approaches, and to be prepared to consult with the community to resolve differences of professional opinion, revise content and/or issue technical bulletins to address overlooked or revised practices.
| INTRODUCTION | OAS CONSULTATION EFFORTS | OVERVIEW OF FEEDBACK |
| KEY MESSAGES | THEMES |