Jim,
I guess you've never hear of an outfit called Skelly and Loy in Pennsylvania. Not only do they exemplify everything Linda Derry expressed concerns over (out of expertise consulting) but they go much further. I was the firm's historical archaeologist from July 1994 through Sept. 1995 and not only was I ORDERED to use unqualified field directors, but my assessments of historical archaeological resources often were changed by my boss, Vice President for cultural resources, to reflect less significant resources to "make the client," i.e., PennDOT, happy. For instance, a ca. 1860s urban farmstead house site suddenly became "a barn that burned in 1895."
And if you are going to say that this situation is an exception, yes it may be, but it is a damned big one. Skelly and Loy is one of PennDOT's biggest consultants and they do A LOT of archaeology in Pennsylvania (and West Virginia). And if you think PennDOT cares whether qualified people are doing work for them, think again. Below is the text of a letter I received from PennDOT's head of Environmental Quality. Hell, not only does he not care if their consultants on historical archaeological sites are historical archaeologists, he doesn't even care if they meet the minimum professional qualifcation criteria in the state guidelines or 36 CFR 61.
David S. Rotenstein, Ph.D.
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WWW: http://www.city-net.com/~davidsr/crm.htm
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Attachment:
David S. Rotenstein, Ph.D.
70 Maplewood Street
Pittsburgh, PA 15223
Dear Dr. Rotenstein:
Thank you for your interest in the Department's archaeology program. In response to your letter of April 11, 1997, Chapter V - Professionial Standards of the Pennsylvania Historical and Museum Commission's (PHMC) State Guidelines draws an important distinction between requirements and recommendations in both the Principal Investigator and Field Supervisor Standards. Principal Investigators must minimally meet A, B, and C. Principal Investigators should also meet D; however, this is not a PHMC requirement. Likewise, Field supervisors should have an advanced degree, but again this is not a PHMC requirement.
With regard to Skelly and Loy's undertaking of 36 BK 588 without a trained historical archaeologist, the Department does not use the SOPA Code of Bthics in its contracting procedures. Neither the existing Department Procedures (SQL 430-92-29), the Consultant's Technical Proposal (June 25, 1992), nor the State Guidelines require an historical archaeologist as Principal Investigator on an historic site for fieldwork, or a field supervisor with an advanced degree.
Finally, the Department treats the State Guidelines as guidelines, which are not necessarily prescriptive. Unless specific provisions have been made a requirement in the scope of work, or the consultant has committed to specific conditions specified by the Guidelines, the Department will continue to interpret the State Guidelines flexibly within the context of Department policy and procedures.
Sincerely,
Wayne Kober
Director
Bureau of Bnvironmental Quality
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