Getting a NSW Excavation Director's permit
Jack Mc Ilroy
With the Aussie dollar rising to parity with the greenback this expat archaeologist is looking at commuting from California back and forth across the Pacific to the world of Down Under contract work.
I’ve had a quick look at the requirements for obtaining an Excavation Director’s permit for NSW and if I am understanding things correctly, one of the applicant’s referees must already have an ED permit. This brings back memories of a similar requirement for full membership of AACA discussed online a year or so ago.
I would have thought that there are numerous highly experienced professional archaeologists within Australia and around the planet who are well qualified to act as referees to equally proficient and professional local archaeologists.
Having made some preliminary grapevine inquiries, I have heard of PhDs with international excavation experience being turned down for an ED permit on an historical period excavation because their reference did not come from a current ED.
Can anyone advise on why this rule was established, by whom, and what is the rationale for it?
It’s a remarkably limiting requirement if you don’t know such a person.
From an international perspective, it seems embarrassingly parochial.
Jack Mc Ilroy
IainS
http://www.heritage.nsw.gov.au/docs/excavationdirectors.pdf
My understanding and reading of the criteria is that it is fairly
straightforward: you need demonstrated experience relevant to the
archaeological work applied for. This includes basic archaeological
qualifications plus relevant experience and most importantly you need
to know the NSW legislation as this is the statutory environment you
would be doing your work.
The rationale behind this is surely because archaeological excavation
is destruction and the aim of the legislation is to protect the
heritage of NSW for current and future generations there is a need to
be cautions about authorising people to do excavation work. The
current system seems to provide a path where new graduates can gain
experience under supervision or by doing small jobs before progressing
to larger ones.
I cannot see anything about "referees" but if they are used them
clearly they must be people of good standing in the field otherwise
the whole system breaks down.
As for Ph0D personally I would be extremely sceptical of a PhD simply
conferring the skills and experience required in a excavation director
as it is possible to progress to a distinguished PhD in archaeology
without any fieldwork experience at all. In some Universities and in
some areas this is even seen as a virtue!
The Excavation Directors criteria replaced a system where permits were
handed out in an non-objective way.
Iain
Jeannette Hope
I’ve had a look at the Excavation Director (ED) criteria, and I’m curious about some things.
Here are the field experience criteria for getting permits as Excavation Director for Test excavations v. Open Area excavations:
Test Excavation
Demonstrated understanding of the meaning (date, type, common application in the past) of basic fabric types likely to be encountered;
• Demonstrated ability to recognise and interpret taphonomic processes and their meaning;
• Recognises their limitations re the above;
• Demonstrated ability to complete adequate recording of stratigraphy, soils, features etc. can proceed without re-excavation of previous trenches; and
• Demonstrated ability to prepare a report that clearly identifies what was done, why, what new information was recovered and what it means.
Open Area Excavation
• Has been the sole Excavation Director for more than five test excavation or monitoring permits and can demonstrate that these projects have been
completed in accordance with the permit consent conditions;
• Demonstrated excavation experience as an Area Supervisor on at least three sites subject to open area excavation;
• Demonstrated experience and/or clear evidence of a capacity to: (a) manage project timeframes, budgets,
clients requirements; as well as (b) manage community interest/Public Relations issues; and
• Demonstrated capability to synthesise excavation and post excavation analysis/historical research into a report that responds to identified research questions and makes a positive contribution to community understanding of the history and significance of the place.
Here are just a few questions:
1. What is the definition of a test excavation? How small can it be to qualify?
2. Imagine you’re applying for your first permit as ED for a test excavation, when would you have had an opportunity to ‘prepare a report etc.’ if you had never been ED for a Test excavation?
3. Can small subareas of a major project be designated as ‘test excavations’ with separate ED’s and permits so that people can build up their number of test excavation ED’s in order to apply for an Open Area ED permit?
4. What is the definition of Area Supervisor – not mentioned anywhere else in the ED criteria. What qualifications do you need?
5. So you’ve done your 5 test excavations, and a few area supervisions, but when have you had the opportunity to ‘demonstrate that you can manage community interests etc.’ or ‘to synthesise excavation and post-excavation analysis/historical research that responds to research questions etc.’? – you might have done this in your Honours or PhD historical archaeology project … except that … how would you have got a permit to excavate? (How many undergraduates have the opportunity to be sole ED on 5 test excavation or monitoring permits and 3 area supervisors?)
Iain’s response noted:
‘The current system seems to provide a path where new graduates can gain experience under supervision or by doing small jobs before progressing to larger ones.’ I still can’t see how they would get their first ED?
‘As for PhD personally I would be extremely sceptical of a PhD simply conferring the skills and experience required in a excavation director as it is possible to progress to a distinguished PhD in archaeology without any fieldwork experience at all. In some Universities and in some areas this is even seen as a virtue!’ The ED system appears to entrench this since it would seem impossible for a PhD student to get a permit to do any excavation … unless they had spent a lot of time working as a subbie on several major open area excavations (they have to have worked .as Area Supervisor on 3 open area excavations). Are there enough open area excavations under way to cater for people who might want to become historical archaeologists who can qualify for ED permits?
Some implications:
1. More people will do historical archaeology PhDs without excavation, and academic positions / research in this field will become non-field work oriented (which along with Iain, I deplore). This will mean less opportunity for undergraduates to get academic based / research field excavation experience.
3. Research-based historical archaeology will effectively stop in NSW; those academics (or non-academics) who want to excavate for research purposes will have to do it somewhere else when they can get a permit.
2. Those consultants who have already built up the experience to get an ED permit before these new rules came in, who, according to Iain, may have got their permits in ‘an non-objective way’ will become the de-facto arbiters of who gets to be accepted in the future by the Heritage department, because they are the ones who select who works as a subbie, who gets to be Area Supervisor, and who gets to build up experience to get their first Test Excavation ED.
If this was business…
Cheers
Jeannette
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IainS
Heritage Office which was abolished in early 2008 and I think they
were in use several years earlier weren't they?
Surely the path to the nirvana of Excavation Directorship is through
joint holding of excavation permits with a more experienced
archaeologist as a co-director. Perhaps this issue is more the failure
of archaeologists to mentor their staff and junior archaeologists?
Iain
Jeannette Hope
Hi Iain
The criteria make no mention joint permits as an option. Indeed they say you must be the ‘sole Excavation Director for more than five test excavation or monitoring permits’. So my question still stands: how do you get the first one?
And even if that were possible, it still means that newcomers, however experienced, have to depend on the grace and favour of the small number of people who are eligible to be ED’s. It doesn’t really matter how new or old the system is, those who qualify under the criteria must have started before they came in, otherwise how could they have got their first ED permit?
Cheers
Jeannette
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IainS
are better than another's and how I got my first excavation permit (as
I recall it was in a Christmas Cracker, I also got a paper hat and a
whistle but that was before these Guidelines were in force) I note the
following:
"If a practitioner cannot meet all the required criteria and still
wishes to undertake the
proposed work, they can (with the agreement of their client) nominate
a Co-Director who
does meet the required criteria."
"The Heritage Office will have the discretion to consider
special cases that do not meet the criteria and will if necessary
refer the application to the
Heritage Council Archaeology Advisory Panel."
Perhaps others on this list might care to comment.
Iain
Jeannette Hope
My questions are seriously meant, and not personal:
1. How does someone now get their first sole excavation director permit?
2. A person may be acceptable as co-director under 'discretion'. Does this
count towards the 5 sole director permits needed? If so, it should say so.
3. If not, how does someone get their first excavation director permit.
There needs to be some achievable process that does not depend on
discretion, or grace and favour.
Yes, please, can we have some other contributions!
Regards
Jeannette
-----Original Message-----
From: oza...@googlegroups.com [mailto:oza...@googlegroups.com] On Behalf Of
IainS
Sent: Monday, 8 November 2010 1:34 PM
To: OzArch
Subject: Re: {OzArch} Getting a NSW Excavation Director's permit
Iain
--
Mac
twice a year, I have run into a problem in relation to the "Co-
Director" issue.
Last year I was required to put one of my subcontractors on the permit
as a co-director in circumstances where I was potentially going to be
(and ultimately was) overseas for part of the excavation works. The
concern I expressed to the Heritage Branch at that time was that, by
requiring the co-director to sign onto the permit they were creating a
potential contractual and liability issue, as the co-director was not
an employee of mine and had no contractual relationship with the
client. So in terms of the enforceability of permit conditions in that
circumstance I was at a loss, as under the Heritage Branch's co-
director model the co-director could be expected to monitor permit
conditions that they were in no position to enforce, as they had no
contractual relationship with the applicant (my client). It also meant
I had to select a different subconsultant, as my initial choice did
not carry professional indemnity insurance.
Ultimately I had no choice but to accept a co-director on the permit,
despite these concerns, in order to get on with the job - and
thankfully no issues arose. But when I wrote to the Heritage Branch
seeking clarification on this issue and their views on enforcing
permit conditions, liability and contractual matters with regards co-
directors, I heard nothing. So I still think it is an open issue.
I'd be interested to know if anyone else has had similar experiences
or concerns.
While I have no real issue with there being standards for excavation
directors, commensurate with the significance and complexity of the
site, given that much of this work is undertaken in a commercial
context with potentially severe contractual consequences, I do feel
that the co-director requirement is an unnecessary and potentially
disastrous intrusion into the commercial relationship between the
consultant and the client.
Katrina
Dear All,
This email responds to a number of recent OzArch post re the
Excavation Director Criteria in NSW.
I note that a number of relevant points were made in the initial
response by Iain Stuart (who has been on both the regulator and
consultant side of the fence as have I).
Jack McIlroy asked:
“Can anyone advise on why this rule was established, by whom, and what
is the rationale for it?”
The NSW Heritage Council has had ‘Procedures for the Evaluation of
Excavation Permits’ publicly available since at least 1981. One used
to visit a large government building to collect the Guideline but now
the latest version can be accessed from the comfort of one’s keyboard
thanks to the wonders of the internet.
Updates of the Criteria are developed by the Heritage Branch staff (or
whatever they are called that year) and are referred for comment to
the NSW Heritage Council Archaeology Advisory Panel. This is currently
9 people, appointed for a 3 year term 2010-2013 after a public EOI
process. The Panel includes a mix of skills – consultants, academics,
regulators, etc. After endorsement by the AAP and legal advice, the
Criteria are sent to the Heritage Council and if /when endorsed go up
on the web. There have been some more recent revisions to the Criteria
currently on the web to clarify terminology and the Branch would
expect that the revised version would make it onto the web in 2011.
Iain Stuart correctly explained that because the legislation is to
protect ‘relics’ there is a need to be careful about authorising
people to do excavation work when excavation is destruction, etc etc.
Referees are only sought if the experience is unclear or more
information/substantiation would be helpful in assessing the
experience presented or claimed against the scope of the work.
When the Heritage Act says ‘get a permit’ before destroying relics,
then policy such as the ED Criteria is one mechanism which may help
prevent pillage of historic sites by bottle-collectors or otherwise
interested and enthusiastic, but inappropriate or unqualified people.
I can also advise that since the current Criteria were put on the web
in 2004 that a number of people have made the progression which is
implicit, ie from junior excavator to Co Director or Ex Director for
Local and then State significant sites. I also note that in NSW we
issue about 150 archaeology approvals each year and most of those are
pretty straightforward.
The Criteria therefore also hope to encourage a culture of mentoring
whereby junior or less-experienced people can be supervised and
‘trained up’ over time. That has happened sporadically for decades in
places like Sydney where consultant firms have needed to accumulate
large teams of skilled people for major urban excavations, but the ED
Criteria seek to ‘formalise’ this pathway.
Otherwise we can have situations where a skilled person runs the dig
and writes the report etc etc for a more senior person and then the
junior person receives no recognition for their role as de facto
Excavation Director. Hence, the focus on mentoring and notional
progression. The NSW Heritage Branch has also witnessed some messy
versions of the scenario where people leave their employers and there
are claims and counter-claims about who did the work and who should be
responsible for the final reporting, etc etc.
In regard to the specific comments posted, the Heritage Branch won’t
be commenting in public in relation to specific Permit applications or
discussions. The obvious point here though is that there are two sides
to any specific circumstance.
In general response to Mac North’s comments, however, I also note that
Dr North was himself a member of the Archaeology Panel (term
(2004-2006) which ENDORSED the version of the ED Criteria currently
posted on the website.
In regard to Jeanette Hope’s comments re ‘how can you demonstrate
completion of prior requirements if you haven’t held a permit’ ?? etc
etc. it is also possible to discuss the specific headings with the
Heritage Branch, and we have had First Time Directors address these
requirements by demonstrating equivalent experience.
I also note that the ED Criteria also reflect an interest in obtaining
a product at the end, for example a final report. Far be it from me to
say anything more about why that requirement would appear in Criteria
on an august list such as this, BUT the Criteria exist not just for
the circumstance of “First Time” Directors, they are also relevant no
matter how many permits one may have held.
For example:
- If I’ve held 50 permits over the past 10 years and have only written
up 5 reports should I be continuing to apply for new approvals without
completing the requirements of the prior ones ?
- Similarly, if I say I want to excavate a site a particular way and
then explain that I’ve got no experience in doing that, would it be
appropriate to perhaps think about involving additional expertise in
the project?
- Or should I sign up to be the Director for a Permit knowing I have
no intention of ever doing the fieldwork – that will be left to some
one else whose contribution may or may not ever be recognised.
Don’t worry – the above questions are all hypothetical – there is no
need to reply.
Finally, the Heritage Branch is pleased to see discussion of the
Criteria amongst the profession as better knowledge of the
requirements is likely to enhance the outcomes for the significant
archaeological heritage of NSW.
I’m not actually a member of this list, so I won’t be responding to
any further posts.
But please contact the Heritage Branch directly if you would like any
further clarification.
Dr Siobhan Lavelle OAM
Senior Heritage Officer (Archaeology)
Conservation Team ~ Heritage Branch ~ Department of Planning
3 Marist Place PARRAMATTA NSW 2150
Locked Bag 5020 PARRAMATTA NSW 2124
P: (02) 9873 8546| F: (02) 9873 8599 | M: 0434 606 735
E: siobhan...@planning.nsw.gov.au| W: www.heritage.nsw.gov.au
>
> - Show quoted text -
Mac
> Posted on behalf of Siobhan Lavelle...
>
> In general response to Mac North’s comments, however, I also note that
> Dr North was himself a member of the Archaeology Panel (term
> (2004-2006) which ENDORSED the version of the ED Criteria currently
> posted on the website.
the existence of standards for Excavation Directors. My comment
relates to the transfer of liability and enforceability in a
contractual sense of the Co-Director requirement (which I think may be
a revision to the ED Guidelines which post-dates my time on the AAP,
but it is really beside the point). Opinions are allowed to change
once the practicality of certain things is challenged through testing
them in implementation and to my recollection these were not issues
which were discussed at the time.
In any respect, this does not negate the fact this I raised my
concerns with the office formally in writing and, for more than a
year, have had no response.
> > Ultimately I had no choice but to accept a co-director on the permit,
> > despite these concerns, in order to get on with the job - and
> > thankfully no issues arose. But when I wrote to the Heritage Branch
> > seeking clarification on this issue and their views on enforcing
> > permit conditions, liability and contractual matters with regards co-
> > directors, I heard nothing. So I still think it is an open issue.
>
> > While I have no real issue with there being standards for excavation
> > directors, commensurate with the significance and complexity of the
> > site, given that much of this work is undertaken in a commercial
> > context with potentially severe contractual consequences, I do feel
> > that the co-director requirement is an unnecessary and potentially
> > disastrous intrusion into the commercial relationship between the
> > consultant and the client.
Brad Duncan
Are you making trouble again? How are you mate?
They are about to advertise those govt jobs in Vic soon - check the Victorian Govt website under employment - will let you know when they come out.
B
On Sat 06/11/10 07:58 , Jack Mc Ilroy jakma...@yahoo.com sent:
With the Aussie dollar rising to parity with the greenback this expat archaeologist is looking at commuting from California back and forth across the Pacific to the world of Down Under contract work.
I’ve had a quick look at the requirements for obtaining an Excavation Director’s permit for NSW and if I am understanding things correctly, one of the applicant’s referees must already have an ED permit. This brings back memories of a similar requirement for full membership of AACA discussed online a year or so ago.
I would have thought that there are numerous highly experienced professional archaeologists within Australia and around the planet who are well qualified to act as referees to equally proficient and professional local archaeologists.
Having made some preliminary grapevine inquiries, I have heard of PhDs with international excavation experience being turned down for an ED permit on an historical period excavation because their reference did not come from a current ED.
Can anyone advise on why this rule was established, by whom, and what is the rationale for it?
It’s a remarkably limiting requirement if you don’t know such a person.
From an international perspective, it seems embarrassingly parochial.
Jack Mc Ilroy
Shaun Canning
Do tell Brad?
Regards,
Dr Shaun Canning M.AACAI, M.ICOMOS, F.AAS, M.AIPM*
BA, B.App. Sci (Hons), PhD
Principal Heritage Adviser
General Manager - Victoria
Australian Cultural Heritage Management (Vic) Pty Ltd
GPO Box 5112, Melbourne, VIC, 3000
Phone: 1300 724 913 Fax: (03) 5781 0860 Mobile: 0400 204 536
Email: shaun....@achm.com.au
website: www.achm.com.au
*Full Member, Australian Association of Consulting Archaeologists Inc.
*Full Member, International Council on Monuments and Sites (ICOMOS).
*Fellow, Australian Anthropological Society
*Member, Australian Institute of Project Management
*Associate Member, ICOMOS International Committee on Archaeological Heritage Management
ACHM has offices in Adelaide, Melbourne and Perth, and provides services throughout Australia.
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From: oza...@googlegroups.com
[mailto:oza...@googlegroups.com] On Behalf Of Brad Duncan
Sent: Thursday, 11 November 2010 3:30 PM
To: oza...@googlegroups.com
Subject: Re: {OzArch} Getting a NSW Excavation Director's permit
Are you making trouble again? How are you mate?
Brad Duncan
Sorry for the last email - was meant for Jack!
Brad
On Thu 11/11/10 15:29 , Brad Duncan brad....@graduates.jcu.edu.au sent: