For the past half a dozen years, I’ve worked quite a few times in a role described technically as an “independent environmental social consultant”. An IESC expert is retained by an international finance institute, or IFI, (for example, the World Bank, or the European Bank for Reconstruction and Development) to provide reviews on whether a project financed by the IFI is meeting certain basic standards of design and construction. The underlying premise is that projects done to predetermined standards should be less risky than projects that do not adhere to recognised standards. They are also often envisaged as a failsafe for projects in areas or contexts where national laws and standards may not exist or may not be easily applicable – such as a project that spans across several countries.
The three most widely used IFI Standards are (all accessed 17-02-2021):
International Finance Corporation (IFC) Environmental and Social Performance Standards (2012) of which PS 8 pertains to cultural heritage
European Investment Bank (EIB) Environmental and Social Standards (2018), of which PS 5 applies to cultural heritage
European Bank for Reconstruction and Development (EBRD) Environmental and Social Policy, of which Performance Requirement 8 applies to cultural heritage.
The standards also have, to varying extent, attached guidance notes to aid implementation by projects. But the usefulness of Standards or Guidance may be nullified at a stroke when an officer from a bank advises a project that the standard or guidance notes may be disregarded – an event that triggered my thinking today.
A particular example is this statement, taken from the IFC PS 8; Guidance Note 12
An internationally recognised practise is defined as the exercise of professional skill, knowledge, diligence, prudence and foresight that would reasonably be expected from experienced professionals engaged in the same type of undertaking under the same or similar circumstances globally. Where the client is in doubt on what constitutes internationally recognised practise, international peer reviewers are able to provide guidance.’
As a side note that will become clearly relevant, most robust quality assurance systems focus on quality of person, process and product as the three legs of a tripartite system – take one away and the system is unstable. So, for example, if quality of process may be disregarded from the outset, then everything rests upon quality of person and product.
It may be surprising to discover that the three international standards are really quite different. This is certainly very unhelpful for practitioners. In this brief discussion, I will focus on one specific aspect simply because it has arisen relatively recently. This concerns whether post-fieldwork analysis and reporting is necessary for works to mitigate impacts arising from a project upon cultural heritage assets. In the present case, this involves archaeological sites excavated in advance of construction, but the principles may apply to intangible heritage as well.
Post-fieldwork activities include, but are not limited to: urgent and subsequent long-term conservation of finds; cataloguing; archiving; technical analyses; technical reporting; publication for technical and lay-public audiences; museum exhibitions; site presentation and display; and other forms of valorisation. Not all activities will be equally present or equally emphasised for different sites or investigations – a common modifier is to relate the degree of emphasis and resourcing for the various tasks to the significance of the findings. But it might seem extraordinary for professionals to learn that an entire project involving some hundreds of excavations spread over hundreds of linear kilometres may simply dispense with these tasks and outcomes altogether.
How does this situation arise? One foundational point is to go back to the standards/requirements and see what each has to say about what Anglo-phonic archaeologists call post-excavation or simply ‘PX’.
IFC: “… field-based study, and documentation of cultural heritage are implemented…” [paragraph 6]
“… The client will not remove any nonreplicable cultural heritage, unless all of the following conditions are met:
Any removal of cultural heritage is conducted using the best available technique.“ [paragraph 12]
EIB Process: “Based on the results of the field surveys, expert assessment of the significance of cultural heritage, requirements of national legislation and relevant international conventions… the promoter will be required to develop appropriate mitigation measures… along with the implementation schedule and required budget for such measures.” [paragraph 14]
Product: “The promoter is responsible for planning and implementing, monitoring, evaluating and updating cultural heritage management procedures by…:reporting and communicating on the project’s cultural heritage plan and disclosing the cultural heritage management outcomes.“ [paragraph 17, bullet point 6]
EBRD Process: “The assessment and mitigation of impacts on cultural heritage will be conducted in accordance with relevant provisions of national and/or local laws, protected area management plans and regulations, national obligations under international laws and GIP. “ [paragraph 11]
Product: “The objectives of this PR are to:promote the awareness and appreciation of cultural heritage where possible.” [paragraph 4]
The Standards/Requirements for PX analysis are barely sketched out. The IFC expects that, “Field-based study, and documentation of cultural heritage are implemented”, although what that might entail is unspecified, and what if the linkage to good international industry experience in guidance note 12 is to be disregarded? The EIB requires that, “The promoter is responsible for… disclosing the cultural heritage management outcomes” and that they, “Promote the awareness and appreciation of cultural heritage where possible”. Even the most optimistic archaeologist might struggle to explain to a project promoter where precisely the standards say that the promoter has to finance analysis and reporting, rather than disbursing the money to the promoter’s shareholders. (One might also note that the clauses pertaining to heritage fieldwork are only slightly more explicit.)
A less charitable archaeologist might observe that the standards were written with little or no awareness of what cultural heritage management entails. Moreover, they appear to have been written on the assumption that all the interested parties are honourable and well-intentioned.
Back to the project that prompted me to write this case study – what happens when two participants have vested interests that militate against doing the ‘right thing’?