Archaeological report review process

Overview

This information provides an overview of Ontario’s process for reviewing archaeological reports.

How we decide which reports to review

The ministry selects archaeological reports for technical review based on two criteria:

• the potential risk to archaeological sites as a result of land development activities
• archaeological licensing needs

The ministry reviews most reports that document archaeological sites. This helps ensure decisions and approvals about land development are informed by appropriate recommendations for archaeological sites.

While the ministry reviews most reports, most low risk reports are entered into the Ontario Public Register of Archaeological Reports (the Register) without a technical review. Low risk reports include:

• research reports
• reports that do not document archaeological sites.

The ministry may audit low risk reports that meet the criteria for no technical review. The ministry audits these reports to check the archaeologist’s compliance with the terms and conditions of their licence, including compliance with the Standards and Guidelines for Consultant Archaeologists (Standards and Guidelines).

Types of report reviews

Reports that receive a technical review are subjected to either a detailed or a focused review.

The level of review depends on the associated risk to archaeological sites, ministry priorities and licensing needs.

Detailed review

A report will receive a detailed review if any of the following are true:

• it was prepared by a new archaeological licensee, so that the ministry can provide mentoring
• it is being reviewed for the ministry to help the archaeologist meet the Standards and Guidelines
• it is a high-risk report

High-risk reports include those that meet any of the following criteria:

• they document complicated assessment projects or complex archaeological sites
• they document one or more archaeological sites but recommend that no further work is required
• they recommend no further work for sites documented

The ministry will complete a detailed review of high-risk reports to ensure compliance with ministry requirements for fieldwork and reporting as outlined in the Standards and Guidelines. A detailed review evaluates the report against every relevant standard and ensures recommendations for no further work are appropriate and based on good evidence.

Focused review

The ministry will complete a focused review of moderate risk reports to ensure the fieldwork, reporting and the recommendations for further work comply with the Standards and Guidelines. A focused review involves reviewing the report against a selection of standards.

Moderate-risk reports include archaeological assessment reports that:

• document archaeological sites
• recommend further work for the sites documented

Reports initially subjected to a focused review may be ‘bumped up’ to a detailed review if the Archaeology Review Officer (ARO) finds that a significant number of fieldwork or reporting standards have not been met.

How decisions are made

AROs review archaeological reports, using the Standards and Guidelines as the basis for their review. They compare the information provided in the report against relevant standards. For each fieldwork standard, there is an accompanying reporting standard, both of which the report must address.

AROs also use guidance materials that clarify how the ministry has interpreted the standards, including:

• technical bulletins
• fact sheets
• frequently asked questions
• manager’s memos
• the ministry’s website

An ARO may also consult with other reviewers, the archaeological data coordinator, the licensing officer, the team lead or the manager of the Archaeology Program Unit.

AROs may also consult a wide range of available resources, including:

• maps and aerial images, such as Google Earth
• the ministry’s internal GIS which includes the locations of archaeological sites in the Ontario Archaeological Sites Database
• information on archaeological sites and resources held by the ministry such as site record forms, reports, correspondence and requests for advice
• available historical documentation
• fieldwork inspection reports, if an inspection has been completed

AROs also:

• meet as a team regularly to discuss interpretation of the Standards and Guidelines and review case studies
• recognize that, in some instances, there is a range of acceptable practice depending on how a licensed archaeologist has applied a standard or combination of standards

Potential outcomes of a report review

When they have completed their review, the ARO will send a letter to the licensed archaeologist to tell them the result of the review. A report review can have one of the following results:

• the report is entered into the Register
• there are concerns with the report and the archaeologist must file a revised report
• there are outstanding concerns with a revised report and the archaeologist must file another revision
• the report is incomplete, and the ministry’s review has been terminated
• the report has been deemed non-compliant, and the ministry’s review has been terminated

If the ARO identifies concerns with the report, the letter will list the concerns.

Report revisions

Requests for revisions are most often requests for more information or clarification of points made in the report.

An ARO will request revisions when they have completed their review of the report. Most requests will require that the archaeologist file a revised report.

The ARO may request clarification or further information before completing a review, by email or phone.

The most common concerns with a report arise from a lack of clarity about decisions made in the field, or insufficient information to support the statements in the report. These concerns can often be addressed through the submission of a revised report.

A request for a revised report will include a concern that the archaeologist has not met either the terms and conditions of their licence or a standard that is specific to the conservation of archaeological sites. An ARO may decide not to request a revised report if only a small number of standards that are more administrative in nature have not been met (for example, if the report is not formatted according to Table 7.1 of the Standards and Guidelines).

If an ARO requests a revised report, they will list all standards that have not been met in their review letter. However, it may not be possible to evaluate whether a standard has been met in their initial review.

Additional revisions

An ARO will make every effort to ensure they identify all concerns in the initial review of your report. However, in some cases, the information in the original report may not allow the ARO to determine whether all relevant standards have been addressed. The ARO may ask you to make additional revisions to a report that you have already revised.

For example, the original report may be missing information and when this information is provided in a revised report, the ARO identifies concerns with it. For this reason, a reviewer officer may identify points in the review of a revised report that did not appear in the review of the original report.

Tips to pass the review

In addition to meeting the fieldwork and reporting standards relevant to the stage of assessment you have completed, you can help ensure that your report passes the review by:

• clearly describing the decisions you made during fieldwork, why you made them and how they affected fieldwork strategies or reporting
• encouraging your field directors to take detailed field notes so you can provide clear descriptions of decision making in the report
• ensuring the person who made decisions in the field (either you or your field director) reviews the report before it is submitted to the ministry
• having a colleague review the report before submission
• submit a request for technical advice to archaeology@ontario.ca if you are unsure about how to meet certain standards

Report deemed incomplete

A report may be deemed incomplete when the ministry has identified concerns with a report and requested revisions, and the revised report meets one or both of the following criteria:

• the revised report is not filed with the ministry by the assigned deadline
• the revised report does not address all the concerns identified to the ministry’s satisfaction

An ARO will only deem a report incomplete after there has been a least one request for revision. Often, multiple requests for revision will precede a decision that a report is incomplete.

Before deeming a report incomplete, the ARO will consult the team lead or manager. The team lead or manager will review the concerns with the report and will instruct the ARO to send a letter to the archaeologist detailing the outstanding concerns. This letter will either:

• request further revision
• provide notification that the report has been deemed incomplete

Report deemed non-compliant

A report will be deemed non-compliant when either of the following conditions are met:

• the ARO has identified concerns with an archaeologist’s compliance with the terms and conditions of their licence (including failure to notify the ministry of a planned fieldwork project by submitting a Project Information Form before fieldwork begins)
• the fieldwork documented in the report has been found to be severely incompetent or destructive to the archaeological site

An ARO will only deem a report non-compliant as a measure of last resort after there has been a least one request for revision. Often, multiple requests for revision will precede a decision that a report is non-compliant.

Before deeming a report non-compliant, the ARO will consult their manager. The manager will review the concerns with the report and will instruct the ARO to send a letter to the archaeologist detailing the outstanding concerns. This letter will either:

• request further revision
• provide notification that the report has been deemed non-compliant

If a report is deemed non-compliant, the ministry will not accept further reports submitted under the associated Project Information Form number.

Report reviews and licence compliance

A request for a revised report is not considered equal in severity to an incomplete or non-compliant report. The request for revisions is the first step in determining whether an assessment was completed in compliance with the Terms and Conditions for Archaeological Licences and the Standards and Guidelines.

Reports are deemed incomplete or non-compliant when the ministry has determined that the standards have not been met. They have a greater impact on an archaeologist’s licence record and may trigger a review of their licence.

Conduct a self-assessment

Consider conducting a self-assessment of your compliance with the Standards and Guidelines to ensure your fieldwork and reporting have met the standards. This can help:

• identify opportunities for improvement
• reduce the possibility of your report requiring revision
• reduce the possibility of your report being deemed incomplete or non-compliant

Appeal a report review

If an archaeologist disagrees with the outcome of the review of a report, they can contact the ARO.

If the concerns cannot be resolved with the ARO, the archaeologist can request a meeting with the team lead or manager of the Archaeology Program Unit.

If you don’t understand the ARO’s concerns or what they have requested, contact the ARO to ask for clarification.