Archaeology Risk Management Plans?

 

In a previous blog post, I wrote about how remediation and archaeological impact assessment pose very similar problems, from a technical perspective. In both cases, there is something in the ground, and we need to figure out where, how much, and what to do about it. My impression is that remediation is well ahead of archaeology on both the technical and regulatory fronts. This is actually a good thing. It means we can borrow and adapt methods and procedures that have been proven to work.

Alberta Environment and Parks (AEP) recently released a draft Risk Management Plan guide to update their guidance on the requirements for Risk Management Plans for Exposure Control. Exposure Control is an alternative to traditional remediation of contaminated sites when full remediation is not technically feasible. AEP’s preferred approach to contamination is remediation (removal of the contaminants), but they’re willing to entertain leaving contaminants in the ground as long as an adequate risk management plan is in place. Both Exposure Control and full remediation have parallels in archaeology; exposure control is very similar to avoidance and remediation is akin to mitigative excavation. In archaeology, the preference is for avoidance over mitigation, because excavation is destructive and archaeology is a non-renewable resource, so we opt for site avoidance whenever we can. This poses a number of challenges:

  • A commitment to avoidance doesn’t provide the clear regulatory closure that site clearance or a completed mitigation does.
  • Once an archaeological site is in-situ within a crown disposition or development footprint there are no regulatory mechanisms to trigger review if development plans change.
  • Long term, theoretically perpetual, avoidance of an archaeological site requires some mechanism to ensure that commitment is communicated to future operators and owners.
  • Ongoing monitoring of hundreds or thousands of avoidance commitments would require substantial regulatory resources.

Too often, avoidance commitments are made and resources are left in-situ, only to be disturbed by later development through miscommunication or human error. The Historic Resource Management Branch of Alberta Culture and Tourism (ACT) has recognized this problem, and has begun requesting more details when proponents opt for site avoidance, but hasn’t yet developed the regulatory mechanisms to address it. Fortunately, Alberta Environment and Parks has had to deal with a lot of contaminated sites and has developed a very detailed and robust draft Risk Management Plan Guide that addresses a lot of the same risks.

AEP has identified several core components of an adequate Risk Management Plan:

  1. Administrative information, including the identification of the person(s) legally responsible to maintain and monitor the plan until the site meets remediation guidelines.
  2. A detailed background to provide the context of the site; essential to ensure that the Risk Management Plan will survive regulatory and operational personnel changes.
  3. Identification of the contaminants (resources) of concern.
  4. Identification of risks associated with the site under current conditions.
  5. A Conceptual Site Model, which is a detailed visual and written description of the site, incorporating all currently known information. (This is another tool archaeologists could borrow from the remediation world to improve how we communicate about sites.)
  6. A summary of current land-use and zoning, which are factors that can dramatically affect the level of risk to a site.
  7. Complete Delineation. Again, remediation is far ahead of archaeology when it comes to standards and methods for accurate delineation and evaluation of sites. In order to accurately evaluate risks, we need a better understanding of the site than is currently obtained at the archaeological survey (HRIA) stage.

AEP also systematically breaks down the Exposure Control Plans to ensure that they will address all of the challenges we raised above. In addition to the detailed exposure control (avoidance) methods that will be implemented, and the rationale for their selection, the Plan has to include:

  1. Timelines and organizational requirements to ensure continuity.
  2. An evaluation of the remaining risks.
  3. A monitoring plan, which is explicitly the proponent’s responsibility, in perpetuity, and must include a schedule and reporting and record keeping mechanisms.
  4. A contingency plan in the event of failure.

Finally, an adequate Risk Management Plan includes a communication plan to ensure that all stakeholders (such as regulators, land owners, municipalities, and First Nations) are aware of the plan, informed of monitoring results, and notified in the event of a failure.

As archaeological mitigation costs continue to rise, our ability to predict and detect the location of sites improves, and community interest in sites of all types increases, proponents will be opting for avoidance and other alternatives to mitigation more often. AEP’s Risk Management Plan model may seem overly prescriptive to archaeological professionals used to fairly open standards and a lot of regulatory freedom, but the continued occurrence of avoidance failures indicates that the current system isn’t working. Fortunately, we don’t have to reinvent the wheel. Techniques, procedures and regulatory models for the long-term management of risks on the land already exist. AEP will be releasing their final guide for Risk Management Plans in the near future. Archaeology Consultants could easily adapt AEPs template to provide our regulators with the information and tools they need to manage and monitor long-term avoidance and other innovative historic resource management options.

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Castle Byers?

We never know what we are going to find when out walking in the woods. This summer we came across this neat modern cabin with a roof that doubles as a tree stand. The cabin overlooks a pretty stream and has nice fire pit with split log benches around it to boot.

Jack’s and Jane’s of all trades

Working in the field of archaeology requires more than a good eye to spot artifacts and a willingness to work away from home. Archaeologists are required to be a “Jane of all trades” meaning we have to be able to keep a cool head when things don’t go our way and  problem solve our ways out of it. Whether this means fixing a tire on the side of the highway, MacGyvering an ATV repair or getting our ATVs out of sticky situations.

Careers in Archaeology

Consulting

The most common career in archaeology is that of a consulting archaeologist. Consulting archaeologists work in the field of Historic Resource Management or Cultural Resource Management (CRM). People in this line of work generally work on Historic Resource Impact Assessments of planned developments before construction is started. The responsibility of consulting archaeologists is to identify historic resources and make recommendations as to how to manage those resources when they might be impacted by proposed developments. Most work conducted by consulting archaeologists is archaeological survey, rather than excavation. This work is typically done between the months of May and November and the winter months are spent writing reports. In some jurisdictions (northeastern British Columbia for example) field work can continue year-round with adaptations made to conduct work during the winter months. Supervisors and project managers typically have a Masters degree level of education. There are often seasonal positions for archaeologists with a Bachelor’s degree.

digging
Tim Allan digging a shovel test in 2015

Universities

Some archaeologists work in universities as professors who teach classes during the school year. Over the summer and throughout the year they publish articles about their research. This may involve conducting detailed excavations of known archaeological / historic resource sites to learn about the lives of people in the past and to answer research questions. Some academic archaeologists focus on artifact reproduction and other experimental techniques to learn about past lifeways, while others use scientific methods such as isotopic analysis or ancient DNA to learn about specific topics, for example past human migration and diet. Academic archaeologists tend to do less field work, and often because they are restricted in time owing to teaching responsibilities they revisit the same site to excavate for short periods year after year (for example L’Anse aux Meadows was excavated over the course of eight summers). The focus of academic archaeology tends to be more theoretical and analytical work. Archaeologists working in universities generally have a PhD level of education and post-doctorate experience.

Museums

Jobs in museums are less common for archaeologists but do exist. These archaeologists work as curators creating exhibits at the museum for the general public, lead tours of the museum and special collections and conduct research and publish journal articles of their findings. Research projects done by museums tend to be smaller in scale than those done by universities as funding is less available (university research is often funded by grants that are only available to students or academics) and free student labour is harder to come by. Conservators are specialized archaeologists who work to preserve artifacts and maintain optimal storage conditions for those artifacts (appropriate humidity and temperature are examples). Most artifact conservation positions are at museums. Conservators often do a more in depth analysis of artifacts after they are received at the museum than the researcher may do as they need to know the exact chemical make up of the artifact in order to best preserve it. An archaeologist may only need to state in their research that an artifact is metal, but a conservationist needs to know exactly what kind of metal that is to best protect it. Conservators often have a background in archaeology but attain specialized graduate degrees in conservation or museum studies specifically related to conservation of artifacts. These positions are usually held by persons with a Masters degree or PhD.

Government

The provincial government employs archaeologists to oversee the work of the archaeologists within the province. Archaeologists working for the government review permit applications, grant archaeological research permits and they review the work of the consulting and academic archaeologists by means of a review of the reports submitted upon the completion of a project. The folks at the government provide guidance to field archaeologists and manage the Archaeological Site Inventory, where all the site information is submitted and compiled into a searchable database. The federal government also employs a handful of archaeologists to do research projects. These research projects are usually done though Parks Canada or the Canadian Museum of History. A recent example is the underwater archaeological investigation to find the missing ships from the Franklin expedition. These positions are usually held by persons with a Masters degree or PhD.

excavation_resized
Kurtis Blaikie-Birkigt volunteering on an Alberta government research project in 2012.