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INSIGHTS

THE MANY FACES OF CRM


Issues Concerning Consulting Archaeologists

Edited by Robert G. Elston

Table of Contents

In fall 1994 the SAA Executive Board established the Task Force on Consulting Archaeology (TFCA) "to develop recommendations on how consulting archaeologists can be fully engaged in and served by the SAA." Formation of the task force recognized that (1) 60 to 70 percent of the membership of SAA, the Society of Professional Archeologists (SOPA), and the Society for Historical Archaeology (SHA) are engaged in cultural resource management (CRM); (2) most archaeology in North America is related to CRM; and (3) CRM is the largest job market for emerging postgraduate students. Fourteen archaeologists from CRM firms in various parts of the country, along with ex-officio members of the SAA Executive Board (William D. Lipe and Ralph Johnson), were appointed to the task force; Michael J. Moratto chaired the group.

The first meeting was held in Washington, D.C., on January 7, 1995, to identify topics for study and discussion. After soliciting input from SOPA, SHA, and the membership of SAA (through the SAA Bulletin), we met in Minneapolis on May 5, 1995, to refine the list of topics to be addressed, identify important issues, and develop recommendations. Chairman Moratto compiled the drafts, and Joel Klein edited and produced the report for submission to the Executive Committee in February 1997 (M. Moratto and J. Klein, 1997, Front Line Archaeology: A Report on Issues of Concern to Consulting Archaeologists in the United States. Report of the Task Force on Consulting Archaeology to SAA Executive Board. Washington, D.C.). Its work completed, TFCA was dissolved, and the standing Committee on Consulting Archaeology (CCA) was created, charged to "assist the Board in determining how the needs of consulting archaeologists could be better met by SAA."

The table of contents of the 28-page task force report closely follows the original list of topics agreed on in our first meeting:

Some of these topics, such as those involving insurance and relations between SAA and ACRA, address issues particular to consulting archaeology, but many concern a much broader archaeological constituency. Several topics are closely related. For example, relationships between consulting and academic archaeology influence curricula and training. The topics of certification, procurement, costs, Section 106 review, and need for innovations in research all address the problem of increasing the quality and scientific relevance of consulting archaeology. Many of the issues we raised in TFCA are parallel to issues identified by the Task Force on Renewing Our National Archaeology Program (B. Lipe, 1997, Report of the Second Conference on "Renewing Our National Archaeological Program." Report to SAA Executive Board. Washington, D.C.), which is soon to be designated the standing Committee on Renewing Our National Archaeology Program.

The major issues and recommendations of the TFCA report are summarized in the following sections. Admittedly, our report focuses more on issue identification than on concrete suggestions for action. Consequently, we solicit comments and suggestions from the SAA membership.

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Relationships between CRM and Academia

 TFCA members were well aware and deeply appreciative of the contributions to CRM by scholars holding academic positions. Unfortunately, however, there are in academia those who ignore or openly denigrate consulting archaeology and its products. This is offensive to nonacademics, divisive and destructive to archaeology as a field, and disheartening to archaeological graduates, most of whom will have careers in CRM. Academic archaeologists ignorant of historic preservation law, regulations and guidelines, ethics, and business aspects of CRM cannot provide guidance to students in these areas. Recognizing that many academic archaeologists are active outside the ivory tower, we wish that more of them were involved in establishing and maintaining regulations and performance standards, preserving local historic properties, and interacting with the public and agencies. We are also concerned with the use of field schools for labor on CRM projects when this results in a poor educational experience for students and less than professional performance in fieldwork.

TFCA urged SAA to make strenuous efforts to break down barriers between academia and CRM. We note that while there is little that SAA can do directly to curb individual prejudice against consulting archaeology and archaeologists, the board has taken steps to recognize the importance of consulting archaeologists in American archaeology and to better integrate them into the SAA community. It is SAA policy to increase the number of consulting archaeologists in the membership and to find ways to increase their presence in elective offices and on committees. Anyone wishing to comment on some aspect of CRM now has a forum in the Insights column of the SAA Bulletin. CRM reports are also reviewed in American Antiquity. We urge teaching archaeologists to acquire or refresh their background in professional ethics, business practice, and historic preservation law, and to incorporate these topics in their curricula. For their part, consulting archaeologists can help bridge the academic-CRM gap by offering to organize colloquia on these topics in local academic departments or in the departments from which they graduated. Academic archaeologists can contribute to effective resource planning by assisting with the task of defining and prioritizing research questions and promoting the organization of regional databases, syntheses, and frameworks for archaeological research.

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Preparation and Capabilities of Graduates

 Several aspects of this topic overlap with the previous one. While it has only been during the last 20 to 25 years that consulting has come to prominence in the discipline, archaeologists outside academia now constitute a majority in American archaeology. Unfortunately, many academic programs have not recognized the need for corresponding changes in curricula, or the changes are prevented by institutional inertia. Some programs apparently discriminate in admissions policy against individuals currently employed as consulting archaeologists and/or who state that they intend to pursue a career in consulting archaeology.

The result is that TFCA members, all of whom are employers and supervisors, were unanimous that significant numbers of archaeological graduates at all levels lack skills in writing, archaeological technique, and knowledge of CRM ethics, law, and regulations [for a list of common deficiencies, see R. Elston, 1992, Archaeological Research in the Context of CRM: Pushing Back in the 1990s. Journal of California and Great Basin Anthropology 14(1): 37-48]. It is currently possible for students to obtain advanced degrees with very little field experience or practical background.

The task force strongly urges all graduate programs in archaeology to include training in the following areas:

TFCA suggests that internships with academic credit developed in collaboration with the private sector and government agencies could provide valuable work-study opportunities for undergraduate and graduate students alike. Recruitment of new faculty with strong CRM backgrounds could greatly facilitate proper training at all levels; adjunct faculty appointments and cooperative teaching agreements with local consulting archaeologists would also strengthen CRM teaching in academic programs. Consulting firms can help by offering internships and participating in colloquia on the curricula of local academic departments.

The CCA will ask the Committee on Renewing Our National Archaeology Program, SOPA, and university representatives to join in development of a recommended curriculum checklist for CRM programs.

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Certification

 Certification of professionally trained and qualified archaeologists is crucial to the health of American archaeology. Without certification there is the risk that unqualified individuals will conduct CRM research, or that archaeologists guilty of unethical behavior will continue to operate without sanction. Certification is a vital component in improving the performance of CRM research and should be mandatory for the professional business and practice of archaeology, as well as for the conduct of archaeological field schools. TFCA's concern with certification is shared by the Task Force on Renewing Our National Archaeology Program.

Archaeological certification is currently in a state of flux. SOPA has voted to eliminate the various specialty categories of accreditation, and an effort is underway to establish a Register of Professional Archaeologists (ROPA). However, TFCA finds much merit in certifying archaeological specializations and keeping these separate from standards of ethics and performance. The TFCA position is closer to the first National Park Service draft of proposed "Professional Qualification Standards" in that the draft includes categories of expertise. The Task Force on Renewing Our National Archaeology Program calls for registration of consulting firms in SOPA or in the proposed ROPA, but TFCA recommends limiting certification to individuals.

TFCA observed that certification is ineffective without grievance procedures and sanctions. For example, SOPA grievance procedures are rarely and weakly enforced, partly because of cost. There is considerable resistance to universal certification; achieving and maintaining it can be costly and time consuming. The difficulty of making universal certification a reality should not be underestimated. Imposing it at the state level (equivalent to licenses required for practicing attorneys, engineers, and physicians) would require lobbying in all 50 state legislatures.

TFCA recommends that SAA, through the CCA and the Committee on Renewing Our National Archaeology Program, cooperate to make certain that certification standards are adopted, are uniform, and reflect essential academic preparation, relevant applied experience, specializations, substantive research, and timely completion of reports. Particular attention should be devoted to reconciling the requirements of SOPA certification with the proposed Professional Qualification Standards now under review by the National Park Service, which include categories of expertise. TFCA notes that lack of professional categories may impact any grievance process and make it more difficult to establish whether an individual is or is not qualified to render CRM opinions. Specific recommendations by TFCA include seeking support among state historic preservation officers (SHPOs), public agencies, and professional organizations for:

The Task Force on Renewing Our National Archaeology Program recommends a slightly different, but parallel, approach involving:

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Procurement Practices, Unfair Competition, and the Costs of Doing Archaeology

 SAA consulting archaeologists are concerned that the present system of solicitation, procurement, and review of archaeological services frequently does not result in the best archaeology for the money. Unless changes are made in this process, pressures generated by shrinking archaeological budgets are likely to make the situation worse. Consulting archaeologists often complain about federal procurement and contracting procedures, citing problems ranging from unfair solicitations to incompetent contract administration and the blind acceptance of low bids. SAA's potential role in addressing these problems may be limited overall, but could be helpful in specific circumstances.

Some of the more common procurement problems include inadequate funding for the required work, unreasonable technical specifications compared to the project's work scope, use of inappropriate contractor-selection criteria, use of low-bid procurement for technically complex archaeological jobs, use of firm fixed-price contracts where significant technical variables are undefined, acceptance of absurdly low bids and then the issuance of change orders for more funds, agency noncompliance with historic preservation law, and nonresponsiveness to legitimate requests for debriefing. Finally, consulting archaeologists object to unfair competition by public and other nonprofit institutions.

In times of tight budgets, agencies may be more often tempted to stretch dollars to obtain the maximum amount of archaeology for each dollar spent. At the same time, agencies regulating archaeological investigations funded by the private sector often demand a higher level of archaeological output. In combination with minimal archaeological budgets, these approaches dissipate effort, returning a very thin kind of archaeology in which a great many topics are considered, but little is learned about any of them.

Unethical low bidding occurs when the intention is to maximize profit through substandard performance, allowing the resource to suffer as a consequence, or by making a bid too low to complete the scope of work with the intention of asking for more money later. Low bids made by consultants incompetent to make bids or carry out contracted work are just as unethical and pernicious. For those clients and regulators who are truly interested in conserving archaeological resources, a focus on low bids rather than high performance is a poor strategy in the long run because it will allow the bad to drive out the good.

Although these issues may be beyond the direct control of SAA, TFCA recommends that SAA, through the CCA and the Committee on Renewing Our National Archaeology Program and with the help of the American Cultural Resources Association and SOPA, pursue the following:

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Research and Sampling in Archaeological Consulting

 One of the realities of consulting archaeology is the imposed research universe. Because survey is usually confined to a development project or an artificially bounded resource management area, sampling must be designed to accommodate these restrictions and still return data relevant to scientific problems. Although each area is unique with regard to its archaeological content and distribution of cultural resources, frequently these can be estimated from previous studies in the same region. In combination with a set of well-thought-out research questions, such estimates should suggest the appropriate type and level of sampling needed. All too often, however, consulting archaeologists are hobbled by regulations specifying particular survey methods and intervals, with insufficient consideration given by resource managers as to whether significant issues are adequately served by the most time- and cost-efficient means possible.

On the other hand, managers may receive little guidance from the professional community concerning how to decide which issues are most important for each region, what methods are best for investigating those issues, or how to determine when specific issues have been sufficiently investigated. The unfortunate results may be that time, money, and effort are wasted on over-sampling and obsolescent research issues, important issues may be investigated by inappropriate data recovery strategies, and opportunities for more efficient sampling and the investigation of new issues in new ways may be overlooked.

TFCA suggests that SAA, through the CCA and the Committee on Renewing Our National Archaeology Program, can improve this situation and increase the efficiency of consulting archaeology in the following ways:

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Publication of Results

 An important issue is that potential users of CRM reports are often not aware of their existence and availability. State historic preservation offices, federal and state agencies, and private institutions serve as regional repositories for reports, but there is inconsistency in how data and reports are archived. Consequently, CRM reports are effectively unavailable and are referred to as "gray literature." The perception that the gray literature is not good research needs to be dispelled, and this large body of data made more readily available to and utilized by archaeologists in both CRM and academia.

Several task force recommendations regarding publication of CRM results are presently in force. American Antiquity accepts CRM reports for review and listing in the Book Notes section. Current Research has been reinstated as a page at the SAA web site (http://www.saa.org/Publications/CurrentResearch/index.html). The CCA will look into the possibility of adding sections to the Current Research page that list current CRM reports, the repositories that hold them, and the means to acquire them.

The task force called for looking into supporting a special publication similar to the old journal Contract Abstracts and CRM Archaeology, but, as the SAA board pointed out, we need to understand the reasons why that publication folded before we start another.

The Task Force on Renewing our National Archaeology Program recommends establishing electronic access to collections data, publishing site reports electronically, developing a standard report data page for submission to the National Archaeological Data Base, and developing a guidance document regarding the submission of primary data reports in electronic form.

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Section 106 Review Process

 The lack of objective reviews focused on the relevance and quality of archaeological research diminishes the returns of compliance research, encourages shoddy work, and conveys to clients the notion that archaeological studies are not important. Improvement of Section 106 review is critical for improvement of research because this review is all that controls the quality of CRM research and reporting. However, the lack of peer review, the obscurity of the gray literature, and the unwillingness of some SHPOs to comment critically on deficient work may encourage the production of low-quality research and reporting. While many Section 106 reviews are fully competent and thoughtful, in some cases agencies lack personnel with the education and experience necessary to perform good reviews. In other cases, SHPOs may insist on excessive archaeological work, thereby compromising their roles as stewards of cultural resources and advocates of reasonable public policy. One problem is that review usually comes at the end of the compliance process when the opportunity is lost to encourage good archaeology from the onset of the project.

To address these problems, the task force recommends that SAA, through CCA:

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Relationships with Native Americans

 Historic preservation legislation has attempted to involve Native American tribes in archaeology through the Section 106 process at the consultation level, although the definition of consultation is sometimes interpreted differently by archaeologists and the tribes. If they have differing expectations regarding consultation for a specific project, conflict may occur, creating hostility between archaeologists and tribes. In a worst case scenario, this may result in legal action against the project proponent.

The addition of Traditional Cultural Properties to the list of cultural resources eligible for listing in the National Register of Historic Places and the passage of the Native American Graves Protection and Repatriation Act (NAGPRA) have forced rapid creation of tribal cultural resources policies. These policies are not always consistent with the Section 106 compliance responsibilities required of archaeologists. This comes at a time when many Native Americans want more than token involvement in archaeology and question not only the terms of their legislated participation, but some of the basic precepts of archaeology.

Native American tribes are stakeholders in archaeology, although each tribe may have a different idea regarding the nature of the stakes. The ignorance of some consulting archaeologists and the unwillingness of others to honor consultation requirements on tribal terms, especially related to burials and human remains, creates distrust that impacts subsequent archaeological consultations. Native American people are questioning the relevance of archaeology to their lives and the survival of their communities. If archaeologists cannot provide answers to the tribes regarding the value of preserving and studying their cultures, the profession will lose an important ally. This could ultimately eliminate a body of archaeological research.

SAA could help ease tensions between the consulting archaeology community and tribal groups by promoting alliances and communication between consulting archaeologists and Native Americans, training tribal personnel regarding cultural resources processes, and educating consulting archaeologists about the cultural values, political factors, and/or other interests that tribes consider when making cultural resource decisions. Any attempts by SAA to create better relationships between consulting archaeologists and tribes should involve direct participation of tribal people, preferably by tribal members with experience in CRM or by the tribes' cultural representatives.

The task force recommends that SAA, through CCA:

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SAA and ACRA

 The task force believes that it is in the best interest of SAA to develop a mutual relationship with the American Cultural Resources Association (ACRA). SAA and ACRA are on parallel but separate paths to represent the interests of their constituents: SAA is dedicated to the archaeological research interests of its members and to the interpretation and protection of archaeological resources; ACRA's mission is to promote the professional, ethical, and business practices of the cultural resources industry for the benefit of the resources, the public, and the members of ACRA. In developing this mutual relationship, we may find that other opportunities for professional development and understanding will grow out of the diversity of each organization's interests.

There are several areas where collaboration between SAA and ACRA would be beneficial to consulting archaeologists. Clearly, the pragmatic training of archaeologists is a high priority to both SAA and ACRA. Collaboration between the two groups to develop an outline of a curriculum for teaching CRM in departments of anthropology would draw on the strengths of the organizations to help train archaeologists as consultants. Training SHPO and federal agency staff to better understand the business of procuring professional consulting services is another area where the collaboration between SAA and ACRA would lead to mutually beneficial goals. Jointly sponsored workshops designed to address these problems could be held during the annual meetings of SAA; this suggestion is supported by the SAA board (L. Sebastian, 1997, SAA Board Response to Front Line Archaeology, Report of the Task Force on Consulting Archaeology).

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SAA's Potential Involvement in Member Insurance Programs

 The task force was concerned about the quality and extent of various categories of insurance coverage that consulting archaeologists and firms require to perform their work. Types of insurance discussed in the task force report included worker's compensation, unemployment insurance, health and life insurance, automobile insurance, general liability, and professional liability. In its response to the task force report, the SAA Executive Board observed that very few take advantage of the comprehensive life and health insurance available to members, and worker's compensation and unemployment insurance are not within its purview. I believe the board feels that insurance coverage specific to consultants would be better pursued through ACRA.

Conclusions

No doubt we have failed to recognize or address other important issues. If so, we hope these will be brought to the attention of the Committee on Consulting Archaeology. Any suggestions for action will be gratefully received.

Robert G. Elston, who is the chair of the Committee on Consulting Archaeology, is with Intermountain Research in Silver City, Nevada.

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