THEME 3
Complex Procedures. There are sections of the S&G that attempt to convey complex or alternate approaches to a specific context that remain unclear to some members. In comments on these sections, it appeared that the lack of clarity arose from the blending of the intent of the standard, on the one hand, with advice on variable ways of achieving that intent, on the other. This emerged in comments for standards such as what should be done when a positive test pit is found in Stage 2, Stage 2 determinations of heritage value or eliminating more than just low potential from survey, Stage 3 extent of test excavations, combining Stage 3 and 4, Stage 4 excavations of very large lithic scatters, guidelines for testing longhouses in Stage 4, and protection strategies and the reporting of same.
Recommendation: We would recommend some effort be put towards disentangling intent of a standard from advisory options. There are a number of ways to approach this, but given the Ministry’s preference to use technical bulletins, perhaps this would be the way to proceed. For example, we point to the standard for investigating an isolated test pit (though similar strategies could be adopted for any other complex part of the S&G): The intent of the standard for what to do with a single positive test pit is to undertake additional fieldwork to confirm whether that pit is an isolated find or something more. How that is done is really at the licensee’s discretion to use one of the following allowable methods: increased number of test pits, test pits and a test unit, or multiple test units. Perhaps the standard should be focussed on what the intent is (
The licensee will undertake additional testing around the positive test pit to determine whether or not the find is isolated). Then direction could be given to the licensee on how to achieve that intent (e.g.,
The licensee is referred to the Ministry’s Technical Bulletin on “Stage 2 Acceptable Practices,” to review the range of acceptable methods available to meet this standard). The advantage of this is two-fold: intent and outcome for the standard is stated concisely, while the long range of variable and acceptable methodologies to achieve that outcome are accessed in another document. This also has the advantage of being able to be continually revise as practices evolve because a technical bulletin will be more flexible to evolving practices (e.g., adoption of nonintrusive, geo-physical methodologies that prove to be a viable approach), while standard intent remains unchanged.