FAME, in consultation with its members working in Scottish archaeology, submitted the following responses to two consultations last week:
Consultation 1 – Implementing a museum processing fee for archaeological assemblages in Scotland
This report is a feasibility study only at this stage, with recommendations for how to go about establishing the costs of any such fee in consultation with the wider sector.
7.Do you agree with the recommendations included in the report? If not could you explain why?
Generally, FAME are agreeable to the principle of fees for depositing archaeological assemblages in Scotland, albeit with caveats (see below). We strongly agree that such fees should not be incurred for fieldwork that has already been commissioned.
The introduction notes the aim of ‘reducing the financial burden placed on museums’. ‘Burden’ is an interesting term here as this is generally how most museums feel about most developer-led archaeological assemblages, mostly because everything and anything was submitted and allocated. There is a financial and physical burden on most museums in Scotland, albeit intrinsic to their core purpose.
The financial/physical burden is created because:
- a significant number of developer-led assemblages were reported and allocated when they did need to be and overburdened the system.
- a significant number of developer-led assemblages did not fulfil the brief of ‘museum ready’ and so it took up resources to deal with them.
- few museums have the expertise to deal with these assemblages, are on reduced staff, or are mostly volunteers.
In short, a processing fee is not going to resolve any of those issues. The draft Guidance on the Minimum Standards for the transfer of archaeological assemblages to museums in Scotland will hopefully go some way to providing some baseline on what condition an assemblage should be in before it goes to a museum.
We agree that there needs to be an ‘understanding’ that the post-excavation process does not end at allocation, but there also needs to be an understanding from museums what an archaeological assemblage is.
Archaeological archives are an integral part of the process and the deposition of them at a suitable repository will require appropriate resources. However, there are fewer museums now who will accept archaeological assemblages because they do not have the expertise to deal with them. Much of this is due to the significant gap between units and museums which is not helped by the allocation process. Although rather than changing the process, TTU should be the ‘bridge’ between the two to increase communication so that museums have a better idea of what they were getting in the first place, and that in many cases it is an opportunity to expand their collections. Additional money for museums should always be supported because they need it, but we are concerned here that this fee is a strawman to resolve an issue that is more complex than just finances. It is also about communication, understanding, expertise, funding, staffing. One key thing we all need to do (archaeology companies, FAME, local planning authority archaeological advisers, TTU, CIfA etc) is to reduce the volume of material going into museums in the first place.
8.Do you feel that anything has been missed during the consideration of factors in introducing a museum processing fee for assemblages in Scotland?
The processing fee is almost similar to an ex-gratia award that goes to chance finders. Will it act like that to encourage museums to take archaeological assemblages? It could potentially be regarded as a source of funding for museums, but how will it be used? Will certain standards from the museum need to be met and who checks that these standards are being met? Will this give the client oversight beyond the excavation?
Museums can also take years to deal with allocated assemblages due to staffing and resources – again a processing fee may only act as a sticking plaster for this.
While we are not against the principle of fees for depositing archaeological assemblages in Scotland, the proposed changes do not address the core issue which is the significant undervaluing of archaeological expertise and capacity within museums in Scotland. The risk of introducing fees from developer-led archaeology is that if the museums opt to simply absorb these additional funds into their general budgets, commercial clients may rightly ponder if it is reasonable that developers take on this additional financial burden. Therefore, the proposals must also include regulation of the use of these fees.
9.Of the options for fee charging models listed under Section 6.1, which would be your preference?
Option 1 – Fee based on average curatorial rate
Option 2 – Sliding scale fee based on size of assemblage
Option 3 – Fee based on number of artefacts
Option 4 – One-off registration fee for each assemblage
10.Do you have any general comments or feedback on the report?
- Comments on fee-charging models.
Of the fee options given:
Option 1 (a standardised fee is paid, based on an average curatorial rate for accessioning and cataloguing) – The costs will vary wildly depending on the assemblage and may have no impact at all to help a museum struggling with resources. We are also concerned that some museums will not be able to cope with the additional administration costs of processing this, or be able to even provide information on how much such costs will be.
Option 2 (A standardised sliding scale fee is paid, based on the number of boxes / volume / size of the assemblage being deposited) – This will be hard to gauge at the time when the post-excavation fee is agreed with the developer client, as this will normally precede the actual processing of finds and environmental samples which generates the final volume of the assemblage. Given the difficulties in agreeing post-excavation fees with developer clients, it is not practical to require archaeology companies to go back cap-in-hand at the end of the post-excavation process, which will usually be several years after the work was commissioned. This is impractical because by that time the developer’s planning condition will have already been signed off, which routinely occurs at the beginning of the post-excavation process upon confirmation that the works have been commissioned. However, it may be that this fee can be included in project post-excavation budgets at the outset, if a fair, reasonable and standard scale of rates is implemented that takes account of these variables.
Option 3 (A standardised fee is paid, based on the number of artefacts from the deposited assemblage that will need to be accessioned) – This could have an impact the integrity of an assemblage if it is felt ‘too expensive’ to deposit them.
Option 4 (A standardised one-off museum registration fee is paid) – It is not clear how this is different from Option 1
Given that proposals in both current consultation documents (Implementing a museum processing fee for archaeological assemblages in Scotland and New draft guidance for the minimum standards for the transfer of archaeological assemblages to museums in Scotland) follow the ‘re-imagining Scottish archaeology’ proposal, there does seem to be an agenda of sorts to use Scotland’s Archaeology Strategy as a means to address perceived problems related to commercial archaeology (whether or not these perceptions are accurate or address the core underlying issues) but fail to address other sectors of archaeology. For instance, we would question if university-led fieldwork should be exempt from this proposed system of assemblage deposition fees but instead should be included at the outset as a measure to encourage university archaeologists to adopt the same standards of work (eg CIfA standards) that FAME members – professional contractors – do. There is a wide gap between the skillsets new graduates are leaving universities with and the skillsets and qualifications that FAME members require from these same graduates upon entering the profession.
Consultation 2 – New draft guidance for the minimum standards for the transfer of archaeological assemblages to museums in Scotland
6.Do you support the introduction of minimum standards guidance for the transfer of archaeological assemblages to museums in Scotland?Required to answer.
Yes
No
Maybe
7.Under Section 2 ‘Fieldwork, Excavation and Recovery’ do you have any comments or propose any amendments/changes?
Relevant to consideration of the related new draft guidance for the transfer of assemblages is a failure in the 2020 Feasibility Report on Implementing a Museum Processing Fee for Archaeology in Scotland draft – an apparent retreat from developing an approach that can meet the tests in Planning Circular 4/1988 and hence embed the accessioning fee into the elements of the PERD controlled through the condition. To meet these tests, it is essential that TTU flex their process flow-chart for excavated assemblages to one that gives Provisional Claim status to an assemblage post-fieldwork but pre-analysis. This would enable the archaeological contractor to advance an accession fee within their costed PERD much as they would publication fees (where relevant). Hence making this a controlled element of the planning process and ensuring the condition is not discharged without accessioning fess committed to where relevant – and indeed discussion of the destination of the assemblage where Provisional Disclaim occurs. To leave it as a ‘goodwill’ structure would be a recipe for non-compliance and ultimately either abuse or the collapse of the structure.
A Provisional Claim status would also assist in a problem of the one-size approach adopted in the Museum_Archaeological_Archiving_Standards_CONSULTATION DRAFT 1.0 – the standards identified may appear reasonable for significant assemblages but are punitive for ‘dross’ sites that will never be claimed. FAME appreciates that our members can pitch their behaviour to the likely outcome of the TTU process, but this introduces significant uncertainty (and hence financial risk) for borderline projects – here we are thinking especially of these where we recommend no further work … what if TTU Claim and suddenly, long after the Client has left, we are advised of accession fees and analytical/conservation work required on multiple bags of 19th-century metalwork? If the Draft Standards migrate to a document for those assemblages that have a Provisional Claim set against them, the funding is established to meet all standards and fees at the start of the process. Yes, there remains a degree of risk, but this is suppressed and placed within those projects that remain subject to fees.
8.Under Section 3 ‘Conservation, Post-excavation, and Packing’ do you have any comments or propose any amendments/changes?
With regard to materials for any packing replacements, this is likely exasperated by the archaeological contractor not knowing where or if an assemblage is to be allocated. There will always be specific requirements that cannot be met because this is not known when the post-excavation fees are agreed with the developer client.
We are concerned by Appendix 4 of the draft Guidance on Minimum Standards… – not by its intent, but the way the text implies this is a minor consideration while the proforma in the Appendix (also requiring a spreadsheet for every material type) is a major undertaking. This is thrown in as a task at the end of the entire post-ex programme. It sits with the structure for the accessioning fee in a classic receiving organisation mentality – here is what we want, we have not thought about helping you improve your processes nor how you secure these monies consistently. The Appendix 4 proforma should be examined as a document that is interleaved/interdependent with OASIS reporting, PERD agreeing, Provisional Claim securing – it becomes less of a burden if it is partly how you communicate with your specialists, an organic document that grows and is enhanced as the assemblage travels from DSR, through PERD, analysis, publication and culminating in accession. It could have been a tool to help re-establish inter-specialist communication and information sharing within the post-ex process (for those who do not have that luxury) – but instead, it is currently a huge submission form just to Museums.
9.Under Section 4 ‘Reporting and Allocation’ do you have any comments or propose any amendments/changes?
With regard to making suitable provision for archive deposition, the issue here is that archaeological contractors do not know where an archive is going to be deposited. This is due to how the allocation process is communicated between both commercial and museum sectors. This includes not knowing if it is actually going to be allocated at all, and may end up back with the contractor for ethical deposition. Has the fee already been paid at that point or budgeted in? What happens to it if it is disclaimed?
10.Under Section 5 ‘Transfer to a museum after allocation’ do you have any comments or propose any amendments/changes?
FAME is very concerned by the statement in paragraph 4.2 of the Guidance on Minimum Standards … that ownership goes to the finder (excavator) if disclaimed or claimed and not bid on. We do not know the legal basis for this statement.
We consider that it more likely reverts to the landowner or failing that to the excavator’s Client. Likewise, these documents are silent (not even cross-referencing other guidance) on the thorny issue of human skeletal material that does commonly make up part of assemblage. They do touch upon ecofactual material and soil samples quite late on, but do not address ownership of this material and on what legal basis it is being accessioned into the Museum.
Underpinning all of this material needs to be a review or recommended approach as to how archaeological companies secure title to soil samples, ecofactual material and disclaimed artefacts through prior agreement so that their position to act in depositing material is secure.
11.Is there anything missing or needs amending/explaining within the draft templates?
12.Do you have any general comments or feedback on the guidance?. Multi Line Text.
FAME wishes to emphasise an important fundamental of archaeology in commercial practice: these are not our assemblages.
Commercial practice is transactional – FAME members provide archaeological services to those who need them, we do not initiate projects, we do not secure funding for projects, rather we charge clients for the provision of archaeological services they need.
The records and reports we produce are constrained in part by our intellectual rights – but this does not make an assemblage ‘ours’. It must be recognised that Landowners/Clients/Applicants are the primary agents.
The challenge is not for Museums to build an obligatory/ethical/regulatory relationship with commercial archaeologists: but they need to build one with our Clients whose material it is (or whose actions have released the materials from the ground in the case of Ownerless Goods).
Given that proposals in both current consultation documents (Implementing a museum processing fee for archaeological assemblages in Scotland and New draft guidance for the minimum standards for the transfer of archaeological assemblages to museums in Scotland) follow the ‘re-imagining Scottish archaeology’ proposal, there does seem to be an agenda of sorts to use Scotland’s Archaeology Strategy as a means to address perceived problems related to commercial archaeology (whether or not these perceptions are accurate or address the core underlying issues) but fail to address other sectors of archaeology. For instance, we would question if university-led fieldwork should be exempt from this proposed system of assemblage deposition fees but instead should be included at the outset as a measure to encourage university archaeologists to adopt the same standards of work (eg CIfA standards) that FAME members – professional contractors – do. There is a wide gap between the skillsets new graduates are leaving universities with and the skillsets and qualifications that FAME members require from these same graduates upon entering the profession.
