Regional Variation in Standards. We heard a great deal of concern over the need for the S&G to reflect regional realities. This mostly manifested itself in comments related to Stage 1 and 2 Standards. In other words, regional concerns centered on variable determinations of archaeological potential (i.e., where sites are likely to be found), and the nature of the archaeological site record to be found during survey. These regional concerns were overwhelming articulated for eastern and northern Ontario. Regional concerns generally were not heard around excavation strategies, artifact analysis or reporting (concerns were raised over some of these standards, but they appeared to be less due to perceived regional differences to how one excavates a site, analyses a collection, or reports on it, and more tied to differing preferences or the articulated view of the APA’s northern group that the draft S&G generally was not workable for them).
Practical constraints for northern Ontario contexts were also repeatedly identified as severe restrictions to any kind of adherence to standards. This included concerns over 100% survey coverage, at 5 m intervals, of remote locations in heavy forested conditions, when transport in and out of the site severely limited the amount of time within which to do the survey. Likewise, while Stage 1 property inspections of these remote locales would be a viable strategy a licensee could use in these situations to focus where survey should be conducted, unless there is a reasonable proxy to on site property inspections in such remote locations, this strategy itself is not viable as a standalone undertaking (e.g., impracticality of a second helicopter ride in).
Recommendation: Practical concerns in the North are a reality that needs to be accounted for in the S&G. The Forestry Bulletin attempts to account for these realities within the particular context of Forestry Management. We would suggest the bulletin could be expanded, or a second northern bulletin be developed, that speaks more broadly to Stage 1 and 2 standards for lands away from settled or built up areas in the north. In other words, many of the practical limitations for northern settings do not apply around urban centres like Thunder Bay, Kenora, Timmins, close proximity to the Trans-Canada Highway, etc. But constraints emerge away from maintained roads and for fly-in parts of the province. A bulletin for these areas, developed through the full participation of northern archaeologists and area First Nations, could articulate broad Ministry expectations that reflects the broad consensus of practice for these areas. Such a bulletin could allow for more focussed surveys through an allowance for managing constraints of location, for example through use of documentation as a proxy in Stage 1 to on-site property inspections, in order to facilitate a justifiable narrow focus for both zones of potential and impacts of most concern. Likewise, a relaxing of regularised survey transect intervals, and standards to allow for more targeted test pit survey clustered around discrete locales of concern, would better reflect northern contexts.
In terms of regional variation over potential, site types and frequencies, there needs to be a balance between conserving the resource and broad experiential assumptions about where sites are and are not in the east and north, as well as the recognition that extensive data is not readily available in these areas to inform that prediction, as is the case in the south and southwest. We do note that the S&G includes effective tools for eastern and northern Ontario to develop alternate strategies, but members had difficultly recognising these as tools to accommodate regional difference. For example, the alternate Stage 2 survey strategy in Standard 2.1.3 for eastern and northern Ontario, listed as a guideline, led some members to assume that option would not preclude Ministry staff from demanding the more general test pit survey standards listed in 2.1.2 in northern and eastern contexts. Likewise, members did not generally see the standards in 1.2 for Stage 1 property inspections as a tool that would allow them to modify survey and potential strategies to accommodate northern or eastern differences (or felt that it did not go far enough to accommodate those differences). We would recommend making the test pit strategies outlined in 2.1.3 an “alternate standard” not guideline. We would also recommend including text to specifically link property inspections as the means for using alternate, reduced coverage survey strategies in the north and east to substantiate licensee judgement and experience. This will require revising Standard 1.4.1 to accommodate more licensee judgement and past experience in defining minimal distances to features of potential. Clearly the compiled results of consultant work to these more regionally specific standards would then inform further refinement, once additional data and a better understanding of the archaeological record from this part of the province is gained.
| 1. Interpretation of Standards | 2. Regional Variation in Standards | 3. Complex Procedures |
| 4. Dispute Resolution | 5. Technical Bulletin on Aboriginal Engagement |
| INTRODUCTION | OAS CONSULTATION EFFORTS | OVERVIEW OF FEEDBACK |
| KEY MESSAGES | THEMES |