23rd February 2012, 12:47 PM
I'm a (pension grabbing) curator and personally I would want to see some major revisions to the Standard & Guidance before I could support it. That's not to say that I'm against the principle of such a document, just that in my opinion there are some major flaws in the standard currently being promoted.
An over-riding and fundamental issue that the proposed S&G seems not to have understood is what the actual role and position of a curator is and who we are answerable to. There seems to be much confusion within the document about what areas are within a curator's control. Much of what is required by the S&G is out of a curator's direct control. There are many examples of this throughout the document, for example:
Advisors should ensure that policies in neighbourhood development plans and orders take into account the significance of heritage assets and their settings, the potential impact of proposed development upon them, and appropriate measures to offset that impact.
But we cannot ensure, where consulted we can recommend but we cannot require that the LPA accepts this advice. Personally I am also unhappy with the word offset in the above sentence as well - mitigate yes, not offset.
The S&G also needs to remember that Local Authorities are democratic bodies led by elected members. These members could choose to apply policies that are in contradiction with the S&G and this could make adoption difficult or impossible.
The S&G in general seems to place the aspirations of the IfA and Southport Group in general above the primary role of the curator, whose core function must surely be to provide expert planning advice. Outreach and other such activities are aspirational. Whilst we encourage, seek out and take part in such activities, they remain an add-on, but are not a curator's core function.
The RO stance in the document heavily favours the IfA's vision for it's RO scheme, but I cannot see that any curator could support the current tone of the document on this aspect. In this aspect the S&G also includes some phrases that I feel are disingenuous, for example the S&G states:
In England and Scotland, planning policy and supporting guidance require that archaeological work is undertaken in accordance with IfA standards and guidance
As far as I am aware PPS5 never refers to IfA standards and that compliance with these standards isn't a requirement of the PPS. There are also confusing sections that seem to suggest that there is a connection between the significance of an asset and the need to have a RO contractor:
Where proportionate to the significance of the asset and the impact of the proposed change to it, advisors should consider recommending or requiring work to be done by an accredited IfA Registered Organisation to ensure the quality management of the work
I know of many excellent contractors who, for whatever reasons, choose not to be a RO. Likewise I am aware of RO whose work has failed to meet our own local standards. I cannot support a document that promotes me to require work be carried out by an RO. Personally even if this was the path the industry wanted to go down I don't think the IfA is anywhere near robust enough in enforcing its own standards (either for individual or organisational members) to be considering pushing this agenda at this time. Until the IfA is robustly enforcing its standards within its own membership its not in a position to try and foist these standards on others.
The S&G also states:
Advisors must be competent for their roles, and employed in line with relevant legislation and IfA by-laws. Where required to commission, specify or monitor development-led archaeological work carried out by IfA corporate members or Registered Organisations, advisors should be corporate members of the IfA.
This seems to be promoting a closed shop, and unless I am reading it wrongly, also seems to be saying that only IfA members may monitor other IfA members. This is unenforceable and seems to be leading to a process of self-regulation. I can not see any curator supporting self-regulation and to do so would be neglecting our primary role, which is to advise the LPA whether their planning conditions are being satisfied - the only way to do this is through active monitoring.
There are also too many paragraphs in the S&G which are little more than IfA trumpet-blowing and advertising, such as:
Accredited suppliers under the IfA Registered Organisation scheme reduce the risk to applicants of selecting a supplier who will not meet industry standards, and ensure that there is recourse to a third party (IfA as accreditation provider) in the instance that quality criteria are not met.
I cannot see any relevance or need for such a statement in a document that is designed to provide professional S&G for archaeological curators. Paragraphs such as this could be omitted wholesale and there is no need or reason for them to be included.
Sorry for the long winded reply, but hopefully this shows that not all curators are happy with the S&G and this is not the line that curators themselves are necessarily seeking.
An over-riding and fundamental issue that the proposed S&G seems not to have understood is what the actual role and position of a curator is and who we are answerable to. There seems to be much confusion within the document about what areas are within a curator's control. Much of what is required by the S&G is out of a curator's direct control. There are many examples of this throughout the document, for example:
Advisors should ensure that policies in neighbourhood development plans and orders take into account the significance of heritage assets and their settings, the potential impact of proposed development upon them, and appropriate measures to offset that impact.
But we cannot ensure, where consulted we can recommend but we cannot require that the LPA accepts this advice. Personally I am also unhappy with the word offset in the above sentence as well - mitigate yes, not offset.
The S&G also needs to remember that Local Authorities are democratic bodies led by elected members. These members could choose to apply policies that are in contradiction with the S&G and this could make adoption difficult or impossible.
The S&G in general seems to place the aspirations of the IfA and Southport Group in general above the primary role of the curator, whose core function must surely be to provide expert planning advice. Outreach and other such activities are aspirational. Whilst we encourage, seek out and take part in such activities, they remain an add-on, but are not a curator's core function.
The RO stance in the document heavily favours the IfA's vision for it's RO scheme, but I cannot see that any curator could support the current tone of the document on this aspect. In this aspect the S&G also includes some phrases that I feel are disingenuous, for example the S&G states:
In England and Scotland, planning policy and supporting guidance require that archaeological work is undertaken in accordance with IfA standards and guidance
As far as I am aware PPS5 never refers to IfA standards and that compliance with these standards isn't a requirement of the PPS. There are also confusing sections that seem to suggest that there is a connection between the significance of an asset and the need to have a RO contractor:
Where proportionate to the significance of the asset and the impact of the proposed change to it, advisors should consider recommending or requiring work to be done by an accredited IfA Registered Organisation to ensure the quality management of the work
I know of many excellent contractors who, for whatever reasons, choose not to be a RO. Likewise I am aware of RO whose work has failed to meet our own local standards. I cannot support a document that promotes me to require work be carried out by an RO. Personally even if this was the path the industry wanted to go down I don't think the IfA is anywhere near robust enough in enforcing its own standards (either for individual or organisational members) to be considering pushing this agenda at this time. Until the IfA is robustly enforcing its standards within its own membership its not in a position to try and foist these standards on others.
The S&G also states:
Advisors must be competent for their roles, and employed in line with relevant legislation and IfA by-laws. Where required to commission, specify or monitor development-led archaeological work carried out by IfA corporate members or Registered Organisations, advisors should be corporate members of the IfA.
This seems to be promoting a closed shop, and unless I am reading it wrongly, also seems to be saying that only IfA members may monitor other IfA members. This is unenforceable and seems to be leading to a process of self-regulation. I can not see any curator supporting self-regulation and to do so would be neglecting our primary role, which is to advise the LPA whether their planning conditions are being satisfied - the only way to do this is through active monitoring.
There are also too many paragraphs in the S&G which are little more than IfA trumpet-blowing and advertising, such as:
Accredited suppliers under the IfA Registered Organisation scheme reduce the risk to applicants of selecting a supplier who will not meet industry standards, and ensure that there is recourse to a third party (IfA as accreditation provider) in the instance that quality criteria are not met.
I cannot see any relevance or need for such a statement in a document that is designed to provide professional S&G for archaeological curators. Paragraphs such as this could be omitted wholesale and there is no need or reason for them to be included.
Sorry for the long winded reply, but hopefully this shows that not all curators are happy with the S&G and this is not the line that curators themselves are necessarily seeking.