Frequently Asked Questions

This section provides answers to frequently asked questions about the 2011 Standards and Guidelines for Consultant Archaeologists. Submit questions to archaeology@ontario.ca. This web page will be updated on a regular basis.

Fieldwork: General

What stage does ‘monitoring’ fall under when submitting a Project Information Form?

Monitoring may fall under several stages. To determine what stage to indicate on a Project Information Form, consider the purpose of the monitoring you will be undertaking.

For example, monitoring may be undertaken during the removal of fill when there is the potential for deeply buried archaeological resources:

  • in Stage 2  when making the initial determination of whether archaeological resources are present (Section 2.1.7 Standard 4),
  • in Stage 3  as part of assessing an identified site (Section 3.3.3 Standard 4), or
  • in Stage 4  during the excavation of a deeply buried or stratified site (Section 4.2.8 Standard 5).

Monitoring may also be undertaken during construction to ensure that there are no alterations to an archaeological site:

  • in Stage 2 or 3 , as part of implementing avoidance for a partial clearance strategy (Section 7.8.5 Standard 1 e), or
  • in Stage 4, as part of verifying avoidance for a long-term protection strategy (Section 4.1.1 Standard 2).

If it appears that two different standards apply and those standards are in conflict about the approach to be taken, what is the appropriate action?

In any apparent conflict between standards, the more rigorous standard will apply and must be fully met before the less rigorous standard can apply.

When should a site be considered ‘large’?

The meaning of ‘large’ varies depending on the standard. The term ‘large’ may apply in terms of area for some standards, but in others it may also apply in terms of associated factors such as complexity or productivity. For example, a site that is relatively small in area but produces several thousand artifacts could be viewed as a ‘large’ site for some standards.

In the Standards and Guidelines, sites may be considered large in comparison with other sites:

  • of similar age
  • of similar cultural characteristics
  • in the same definable region, or
  • at the same stage of assessment.

Where the criteria for application of a standard require that a site be ‘large’, and the site is not obviously large, a detailed evidence-based argument must be made. The argument must indicate why the site should be considered large within the context of similar sites and if possible, where similar standards or fieldwork strategies have been applied. If you are uncertain whether to apply standards or criteria relating to large sites, contact the ministry for advice.

What are my options in Stage 2 or 3 where there is the potential for a deeply buried archaeological site but the project will not result in excavation to a depth where the potential site is likely to be encountered?

The principles and requirements of Section 4.1.5 will also apply to Stage 2 and 3.  Section 4.1.5 provides that, where a site has been buried under later fill and thus preserved, it is permissible to either maintain or re-establish the existing or a comparable seal and/or uses. For potential sites, testing and/or monitoring as required in Sections 2.1.7 and 3.3.3, will still apply, but only to the depths required to address Section 4.1.5. In addition, avoidance and protection mechanisms (Sections 4.1, 7.9.9 and 7.10) must be implemented to an appropriate level.

For example, if a parking lot was in place before the project, then a parking lot (or comparable scale of impact) can continue in use after the project. If the parking lot is being re-built, you should undertake Stage 2 and/or 3 as appropriate and to an appropriate depth to ensure that the area of potential will not be disturbed. Long-term protection measures must then be put in place.

Do I have to comply with all parts of the Standards and Guidelines when working on a project where environmental contamination has been identified?

Where environmental contamination has been identified as a concern, you and your client's priority should be complying with any relevant laws or regulations relating to the contamination and its remediation. This includes any relevant health and safety standards, applicable requirements under the Environmental Protection Act, and requirements made by the municipality.

That said every effort must be made to mitigate the impacts to the archaeological site by following the usual standards and practices, unless it is impossible to do so and still remediate the contamination as may be required. However, this should never create a health or safety risk for you or anyone else. It is best practice to discuss any proposed alternative strategies with the ministry where those strategies may not comply.

Where concerns for environmental contamination have made compliance impossible, documentation must be provided in the project report package from a qualified person (e.g., engineer with appropriate experience and qualifications). The documentation should clearly demonstrate that the remediation can only take place in such a way that the mitigation of impacts to the archaeological site cannot take place following normal standards and practices.

Fieldwork: Stage 2

Is it acceptable to use ‘artificial weathering’ to prepare a site for pedestrian survey?

Yes, for either Stage 2 pedestrian survey or Stage 3 controlled surface pick-up. The process used must not reduce the possibility for finding sites or negatively affect known sites (e.g., by flooding, excessive erosion, making the area too muddy). The process used must be documented in detail to demonstrate that there was no possibility of negative impacts.  You will be held responsible for all aspects of managing the process and providing a complete and detailed report that confirms positive results to the satisfaction of the ministry.

If a single isolated non-diagnostic artifact or a very small number of non-diagnostic artifacts are identified, that may not be of further cultural heritage value or interest, am I required to report them? Do I have to collect and retain them?

Yes to both. During fieldwork, the ministry considers you to be applying your professional judgment when you initially identify an artifact. Once identified, an artifact is by regulation an archaeological site and you are then required to report your finds.

The identified artifacts are the only physical evidence of the site. They must be retained to fully document the site and provide a complete record of the site and fieldwork. The artifacts should also be retained to demonstrate compliance with the terms and conditions of an archaeological licence.
A process is set out to assist in making a recommendation as to whether or not a site is of further cultural heritage value or interest. Your report must support that recommendation with a fully articulated argument based on available evidence. At a minimum, that argument should provide the information asked for in Section 7.8.3 Standard 2.

What is a fixed reference landmark?

A fixed reference landmark is an object that is unlikely to move and will likely remain in place over the long term. The object should be marked (or previously marked) such that the mark can provide a precise datum point. The ideal fixed landmark is the nearest available monument placed by an Ontario Land Surveyor. If one is not available, then choose the most permanent available feature. Examples include corners of buildings and other structures, solid iron bars, very large rocks, etc. It is a best practice to establish more than one fixed reference landmark because even seemingly permanent landmarks may be removed or obscured. Refer to Section 2.1 Standard 4c.

Fieldwork: Stage 3

For Stage 3 controlled surface pick-up of large and dense surface scatters, do individual coordinates need to be recorded for each find as well as the five metre unit from which the finds were recovered?

No. It is acceptable to only record the locations of artifacts by five metre grid unit. Refer to
Section 3.1.

When undertaking Stage 3, is there a standard number of artifacts produced by excavating a test unit that will require the excavation of additional test units?

No. In Stage 3, this is a decision related to determining the limits of the archaeological site. Guidance is found in Section 3.2.3 Guideline 1.

Sterile test units or permanent physical constraints are the most obvious means of determining limits. Where these are not present, the focus may often be on obtaining evidence for repetitive low yields on the periphery of the site. Whether yields are ‘low’ and ‘repetitive’ will be a matter of professional judgement and will require a clearly stated supporting argument in the report. Arguments for site extent or for stopping Stage 3 excavation that are based solely on standardized artifact counts may not be accepted.

What are the Stage 3 fieldwork requirements for an isolated find of a diagnostic Paleo-Indian or Early Archaic artifact?

At a minimum, fieldwork will require a controlled surface pick-up and excavating five test units, which is the minimum that can be viewed as a ‘grid’. Section 3.2.2 Standard 7 requires the use of three millimetre mesh for at least one of the units (this should be the unit located over the find spot). If nothing is recovered from both the controlled surface pick-up and the test units, then no additional test units need to be dug. A recommendation can be made that there is no requirement for Stage 4 mitigation of impacts.

Does Stage 3 assessment have to extend into areas of slope surrounding a site, or other areas not surveyed in Stage 2?

Yes. If a site is identified in Stage 2, the Stage 3 testing to establish its limits must extend into any areas of slope or into any area where the site could have possibly physically extended and it is possible to test for its presence. For example, a slope may not have been surveyed during Stage 2 but the areas of the slope adjacent to an identified site must be tested during Stage 3 to identify any hillside middens or other deposits.

Section 3.2.3 Guideline 1a should only be interpreted to apply to situations where the physical constraint makes it clearly impossible for the site to have extended into or beyond the natural or cultural barrier.

If a site has been identified on one side of a property line or a narrow linear disturbance (pipeline or sewer trench), does the other side have to be assessed to the same level?

Generally, yes. If a certain level of assessment, excavation or protection has been undertaken for the site on one side of the line or narrow linear disturbance, the same level should be considered for the other side. Your decision will depend on:

  • the type of site,
  • the internal characteristics of the site as they are known in proximity to the line (e.g., drop-offs in artifact yield), and
  • recommendations in the previous reports on the site.

Where a cemetery is adjacent to the project limits, how far should topsoil stripping extend out from the cemetery limits?

Mechanical topsoil removal is required to extend “a minimum of 10 metres beyond uncovered cultural features” (Section 4.3 Standard 1 Table 4.1). This standard also applies to mechanical topsoil removal adjacent to cemetery limits.

Is it ever possible to proceed directly to Stage 4 without completing all Stage 3 requirements?

No. Stage 3 is necessary to:

  • obtain a complete and accurate understanding of the site (external limits and internal characteristics),
  • complete Aboriginal engagement,
  • give due consideration to the possibilities for avoidance and protection as opposed to excavation (even where this is clearly not an option in the development plan), and
  • formulate and recommend a detailed Stage 4 excavation strategy that will meet  requirements.

Fieldwork: Stage 4

For small Woodland sites with no identifiable middens and only a small collection of artifacts after Stage 3, is it acceptable to excavate the site solely by mechanical topsoil removal with no further hand excavation?

No in most cases. Section 4.2.3 Standard 1c requires that mechanical topsoil removal only take place where “the extent of the archaeological site is large.” The term ‘large’ is meant to be applied in comparison to other Woodland sites of a comparable age and within the same general region. It is also meant to be applied both in terms of area and productivity (i.e., usually meaning producing a large number of artifacts).

Therefore, if a Woodland site has produced a small number of artifacts, we expect that the Stage 3 report will:

  • recommend a strategy that will make best efforts to acquire a larger artifact collection from Stage 4 through further hand excavation, or
  • provide a clear and evidence-based argument for not doing so.

There should be discussion with the ministry before proceeding with a Stage 4 strategy that consists solely of mechanical topsoil removal since that will make it impossible to pursue hand excavation.

Do I collect a soil sample from each quadrant of each stratum, or from one quadrant of each stratum and the quadrant number recorded?

“Collect soil samples from each root cellar quadrant or privy, by stratum” (Section 4.4 Standard 3) means taking a sample from each of the strata in each quadrant. For example, if one stratum extends into two quadrants, two samples (one from each quadrant) must be taken from that stratum.

GPS

Do GPS coordinates always need to be provided for the limits of a property?

No. The property will often have been mapped by professional surveyors and their maps will accurately define the property limits. You are only required to provide GPS coordinates for the property limits where such maps are not available (e.g., early in the development process, unorganized territories).

If I do not consider that the identified artifacts constitute a site that should be registered or recommended for Stage 3, do GPS coordinates still need to be recorded?

Yes. As defined in Ontario Regulation 170/04, if an artifact is present then it is an archaeological site.  The GPS requirements of Section 2.1, Standard 4, therefore apply.  

Analysis

What level of analysis is required for lithic debitage in the report catalogue?

The analyzed lithic debitage must be catalogued according to the descriptive categories found in Table 6.1 Standard 1. It is acceptable to have separate sub-tables within the catalogue to provide greater levels of detail, provided that there are clear linkages in terms of provenience. Where the sampling provisions of Table 6.1 Guideline 2 have been applied, the level of analysis for unanalyzed lithic debitage can be limited to no greater detail than counts of lithic debitage per provenience unit. However, these must still be broken down by raw material and heat alteration.

How much of the collection from a 19th century site needs to be depicted in images? (Section 7.5.11 Standard 2c)

Use your professional judgement to provide enough information to support your conclusions and to provide “representative” documentation of the collection. If it is a close call whether the site should proceed to the next stage, it is best to provide more evidence to support your conclusion. The key is to provide full “representation.” This should include at least one example from any class of decorated ceramic that occurs in larger numbers, and at least one example from any class of decorated ceramics that is referenced in the text as part of the argument for the dating (or other characteristic(s)) of the site. The ministry does  not expect to see an example of every variation of colour for classes such as transfer printed or sponged wares.

What is an appropriate description and measurement of worked bone?

Where the Standards and Guidelines are silent, use your  professional judgment and experience to employ a suitable approach to the matter. Where you may have encountered an unusual or unique artifact, the ministry expects more detailed reporting, including photographs or other forms of illustration.

How should I write up the analysis of float samples in a Stage 4 report?

In the Field Methods section, briefly describe the process used to collect the samples and how you met the soil sample collection standards in Section 4.4. In the Record of Finds section, state how many flotation samples were taken and address the manner in which the requirements were met for flotation samples. Present any conclusions in the Analysis and Conclusions section.

Reporting: General Requirements

Is background research sufficient to determine that there is no potential for part or all of a project?

Yes. However, you must present a strong argument and provide documentation sufficient to support the conclusion. Use information sources listed in Section 1.1, Guideline 1 (e.g., aerial photos, testaments from recent land owners) to support the conclusion.

For small projects where there are no finds, do I need to do any more historical investigation beyond examining the historical atlas map for the area?

The ministry strongly recommends you research other available and relevant sources. As a best practice, historical research should be done before starting fieldwork.

Are Project Information Form numbers required in citations of reports on related or adjacent projects, or on earlier or concurrent stages of the same project?

It depends. For various legal and administrative reasons, Project Information Form numbers cannot easily be made available to consultant archaeologists. Title, author and year are readily available and provide effective means for documenting relevant reports. Therefore:

  • You do not need to cite Project Information Form numbers to document related and relevant reports in a report’s bibliography or reference list.
  • Whenever available, you do need to cite Project Information Form numbers for earlier or concurrent stages within the same project on the associated cover letter as part of a complete report package.

Can images from Google Street View be provided as documentation in reports?

It depends:

  • Yes, in cases where past disturbance or other past conditions of the property are being documented. Provide the image date and clearly identify Google Street View as the source.
  • No, in cases where Google Street View would be used as a substitute for photographs documenting a site visit or current site conditions.

Are Borden numbers required when documenting or referencing sites in reports?

It depends. Borden numbers are not required in Stage 1 and 2 reports unless you are referring to a previously known site. Newly discovered sites can be referred to by an identifying number.  Borden numbers are required in Stage 3 and 4 reports.

Section 7.5 Standard 2 requires that all measurements be reported in metric units. Wouldn’t using the original units of measurement be more appropriate for historical contexts?

The use of non-metric measurements is appropriate in cases when those measurements were used in the original source material and there is no need to make comparisons to information in metric measurements. For example, a discussion relating to the historical context of a 19th century archaeological site can be in British Imperial measurements given that the archival and historical source information is usually in that measurement system.

However, metric equivalents should be provided if the information discussed: 

  • relates to information acquired during the fieldwork for the project,
  • is applied in the analysis to support conclusions, or
  • forms part of the basis for recommendations relating to the project as a whole.

Can I simply state in the report that I complied with or satisfied the Standards and Guidelines requirements without providing detailed descriptions?

No. The report must include “explicit descriptions” about how you addressed each relevant standard for the assessment. This verifies your compliance with regulations and provides a relevant statement for any reader of the report.

I believe my work addressed all the relevant standards which I confirmed in my report. Why is the review letter asking me for more information and an explanation?

Some standards are very straightforward (e.g., pedestrian survey at five metre intervals) and it can simply be stated that the activity was undertaken.

However, many standards are based on the use of professional judgement (e.g., sufficient surface visibility). If there is any degree of decision-making involved, it is necessary to provide a clear, detailed and evidence-based argument to support the choices you made in your fieldwork. As other stakeholders and interested parties may read your report, it is also essential to ensure that non-archaeologists will understand the reasoning behind your fieldwork strategies and your decision-making process.

Report Format and Structure

Will the ministry accept a Project Report Package where the dates on the cover letter and on the cover page are different?

Yes. Consultants often finish a report and then submit it several days later.

Section 4.8.3 of the Project Information Forms and the Archaeological Report Review Process bulletin states that reports should not include information that was included in reports on earlier stages of work. Section 7.5.5 Project Context requires summaries of previous work. Other sections require information relevant to the analysis of the site that was included in previous reports. Can I repeat information and to what degree?

The objective in the Project Context section is to summarize the relevant information from previous reports that will contribute to a reader’s understanding of the analysis, interpretations and decisions in the current report. This should be a summary and not an excerpt or restatement of all or large parts of previous reporting.  It should meet the various standards in Sections 7.5.6, 7.5.7 and 7.5.8 of the Standards and Guidelines. Information should be repeated in later sections only to the degree necessary to support a conclusion.

In a report that combines multiple stages, is a separate Stage 1 Analysis and Conclusions section required? Can the information be combined in the report’s overall Project Context or Analysis and Conclusions sections?

A separate Stage 1 Analysis and Conclusions section is not required but may be used when summarizing a more complex analysis. In a Stage 1 and 2 report, background research or a potential determination can go in either the Project Context section or in a separate Stage 1 Analysis and Conclusions section. They should not go in the report’s overall Analysis and Conclusions section, which should focus on the findings from Stage 2.

What needs to be included in the Project Background section of a Preliminary Excavation Report?

The project background section should be a very brief summary of the project - one paragraph that puts the preliminary excavation report into context.

Do I still need a Record of Finds section if there were no finds?

Yes. The Record of Finds section is required. However, you only need to state that there were no finds. The section must also include the inventory of the documentation record.

Does the artifact catalogue or inventory of documentation need to be in the Record of Finds section?

No. The Record of Finds section should describe the recovered artifact assemblage. The artifact catalogue for small assemblages (i.e., fewer than 20 artifacts) may be included as a table. Catalogues for larger assemblages should be appended to the end of the report with a reference to the appendix in the Record of Finds section.

Similarly, append a longer inventory of documentation to the end of the report and refer to it within the Record of Finds section.

When there are many sites to document in one report, can the relevant Table 7.1 sections be combined on a site-by-site basis, or must all sites be re-discussed as a group under each section?

Use your professional judgement to determine the appropriate and effective combination of the sections on Stage 3 Field Methods, Stage 2 and 3 Record of Finds, and Stage 2 and 3 Analysis and Conclusions. Generally, where the sites are few and simple, the report should have only one of each section and all sites should be discussed as a group.

When some sites are complex or there are many sites to be discussed, possible approaches include:

  • discuss all the simple sites as a group section by section, and provide all three sections individually for more complex sites,
  • discuss field methods that apply to a group of complex sites, then discuss the results for each of those sites under separate Record of Finds and Analysis and Conclusions sections, or
  • discuss a mix of simple and complex sites as a group where the same field methods were applied to all the sites in that group, then provide Record of Finds and Analysis and Conclusions sections separately for each individual site or each appropriate grouping of sites.

Do not provide separate Recommendations sections. Recommendations for all sites should be provided as one section.

Do locations of isolated finds or sites recommended to be of no further cultural heritage value or interest have to be excluded from the report and shown only in supplementary documentation?

No. Descriptions, coordinates, maps and images showing the location of isolated finds and sites can be incorporated into the appropriate sections of the report.
The requirement that detailed site location information be included in supplementary documentation applies only to sites that are of further cultural heritage value or interest. The purpose is to protect those sites until it is determined that they are of no further cultural heritage value or interest.

Is it acceptable to place maps and images at the end of the report in sections identified as Appendices?

Yes. The requirements of Table 7.1 are met as long as the necessary sections are present. All sections must be in the report (which includes its appendices) and not in the supplementary documentation.

Conclusions and Recommendations

Why do I need to compare my analysis and conclusions for each archaeological site with the current knowledge about that type of site? (Section 7.9.3 Standard 3)

Current archaeological knowledge about the relevant type of site is required in order to support conclusions about a specific site’s cultural heritage value or interest. This may be a minimal statement if the current knowledge supports the conclusion. However, a detailed and clear justification is required for any conclusions or recommendations that do not conform to current archaeological knowledge.

Can I make one recommendation that covers all finds for which there are no further concerns?

No. Statements about cultural heritage value or interest, or whether further work is necessary, are required in the Recommendations section for each archaeological site. This is particularly important for the letters the ministry issues for Renewable Energy Approval applications, which cite your recommendations word for word. If your letter is missing a statement, it will not get transferred into the Renewable Energy Approval agreement.

Will the ministry be satisfied with a Stage 2 report that includes a recommendation of “no further concerns pending Aboriginal engagement”?

No. Aboriginal engagement could identify further concerns and those concerns could affect the Stage 3 strategy. The ministry needs to review a report with the full applicable information from engagement.

When considering a diffuse pre-contact artifact scatter in relation to Section 2.2 Standard 1a, how is the 10 metre X 10 metre area applied to determine whether a site should go to Stage 3?

The consideration of artifact density within a 10 metre X 10 metre area is intended to provide a minimum threshold for requiring a Stage 3 assessment. Sites that do not meet the minimums in Standard 1a can be recommended to have no further cultural heritage value or interest without providing a further rationale. This assumes that the site does not meet any of the other criteria found in parts ‘b’ or ‘e’. Therefore, for highly diffuse sites that do not meet any of the criteria found in parts ‘b’ or ‘e’, use your professional judgement as to whether to recommend Stage 3.

Note that the 10 metre X 10 metre area is meant to be applied as a ‘box’ to all areas of the site. If any part of the site to which that ‘box’ is applied contains the minimum artifact counts according to the criteria, the site should go to Stage 3.

This standard is not meant to be applied as a density measurement for the overall site. For example, for Section 2.2 Standard 1a(i)(3), it is not meant to be applied against the overall site as a density threshold of one non-diagnostic artifact per 10 square metres (or 0.1 artifacts per square metre). If there is one 10 metre X 10 metre area within the overall site that has 10 non-diagnostic artifacts, then the site must go to Stage 3, even if the overall density of the site is lower than 0.1 artifacts per square metre.

What do I do when I have identified a site during Stage 2 within a narrow linear project area (e.g., access road, trail) and the site appears to extend outside the project limits, but the available evidence does not clearly support recommending Stage 3?

Given the uncertainties involved, in most situations the ministry will expect a recommendation to go to Stage 3. Note that only the part of the site within the project limits must be assessed and, if necessary, mitigated. Avoidance mechanisms as appropriate must be implemented to ensure that the site area outside the project limits is not impacted by activities within the project limits.

I would like to follow a different strategy for Stage 3 or 4 than was recommended in a previous report. This different strategy will still comply with the Standards and Guidelines. What do I do about the previous recommendations?

Your current project report must include previous recommendations from reports on file with the ministry. If you don’t plan to follow the previous recommendations, you must address them in your formulation of alternative strategies. Your rationale for following the alternative approach must be explicitly justified and rationalized.

How do I formulate the strategy for a multi-component site where the components have differing requirements under the Standards and Guidelines?

Each component must be addressed as though it existed separately. If a more rigorous standard applies to one component, that standard must be met for the entire component to which it applies before applying the less rigorous standard to the remainder of the site.

For example, if hand excavation is required to address Component A and mechanical topsoil removal will be sufficient to address Component B, then the necessary hand excavation of Component A must be undertaken before proceeding with mechanical topsoil removal of Component B.

What is meant by “contemplate” in Section 4.1.6 Standard 1?

When considering long-term protection of an archaeological site, the best practice is for the site to come under the ownership of a single, publicly accountable landowner. The intent of Section 4.1.6 Standard 1 is to ensure that transfer to a public body is given serious consideration. If the decision is to not transfer to a public body, the ministry expects that the Stage 3 report will demonstrate that transfer is not viable within the context of the specific project, including documentation from the development proponent.

Does the Advice on Compliance with Legislation have to be quoted word-for-word in the report?

Yes, the Advice on Compliance with Legislation section of your report must include the standard statements word-for-word as they appear in Section 7.5.9. Remember to include the statement from Standard 2 in that section of your report if you recommend further fieldwork for any sites.

Can I include my own advice on complying with legislation?

Yes, you may choose to include your own advice on legislation or other cautionary legal statements. Include these statements in the Cover Page, the Executive Summary or as an appendix. Do not include such statements in the Advice on Compliance with Legislation section (to avoid confusion regarding legal matters) or the Recommendations section (which will be quoted in letters from the ministry).