I, Beckerman, not Robot

January 2019

Pay equity is a term that is bandied about in numerous discussions, often involving issues of race and gender.  However, you don’t have to go very far to find an example of pay inequity in the profession of archaeology.  Those archaeologists who are working as Historic Preservation Specialists are clearly not being compensated properly for the work they do, and it is well beyond time that the Commonwealth correct this.

What do Archaeologists Acting as Historic Preservation Specialists Do?

Archaeologists who work as Historic Preservation Specialists are employed in two Agencies, the Pennsylvania Historical and Museum Commission (PHMC) and the Pennsylvania Department of Transportation (PennDOT).  All told, there are about a dozen or so employees who fill these positions as archaeologists and another dozen who work as architectural historians.  The PennDOT archaeologists operate under a Programmatic Agreement with the Federal Highway Administration (FHWA) and the PHMC, which delegates a great deal of decision-making authority from FHWA regarding the implementation of Section 106 of the National Historic Preservation Act.  If this all sounds like federal regulatory language, it is. In plain English, these archaeologists determine what kind of archaeology is done on PennDOT projects, review reports, decide which archaeological sites are important, and coordinates with all stakeholders interested in the archaeology on a project. They have a lot of latitude on those decisions and operate largely independently from Central Office Management, as they are also based in District Engineering Offices scattered around the Commonwealth.  (Despite this autonomy, there are numerous and effective safeguards to prevent the archaeological equivalent of Dr. Strangelove.)

The PHMC archaeologists are on the other side of the table in the conduct of this archaeology, as well as the conduct of all archaeology done in the State under Section 106. They also advise state agencies on the need to conduct studies under the State History Code.  Although the PHMC archaeologists operate in the same office under the same roof, they also have a lot of latitude on those decisions.  Both the PHMC and PennDOT Historic Preservation Specialist positions are highly technical and highly specialized, and for which expertise is the reward for extensive experience and knowledge. These men and women don’t learn their craft in a day, a month, or even in several years.

What Does it Take to Make a Professional Archaeologist?

There is some difference of opinion within the profession as to what makes a good archaeologist, and some difference even as to whether archaeology is a profession, a trade, a practice, or something else entirely.  What everyone does agree upon is that archaeologists are not made quickly and that years of experience are worth something in the form of expertise. There is no national licensing of archaeologists and no licensing within Pennsylvania. The closest anyone has to a national Standard is either the Registry of Professional Archaeologists (RPA), or the National Park Service’s Secretary of Interior (SOI) Standards. RPA registry is more of a good practice instrument than a qualifications instrument, and doesn’t align 100% with the SOI Standards. 

The Secretary of Interior Standards for a Professional Archaeologist is below:

The following requirements are those used by the National Park Service, and have been previously published in the Code of Federal Regulations, 36 CFR Part 61. The qualifications define minimum education and experience required to perform identification, evaluation, registration, and treatment activities. In some cases, additional areas or levels of expertise may be needed, depending on the complexity of the task and the nature of the historic properties involved. In the following definitions, a year of full-time professional experience need not consist of a continuous year of full-time work but may be made up of discontinuous periods of full-time or part-time work adding up to the equivalent of a year of full-time experience. 

The minimum professional qualifications in archeology are a graduate degree in archeology, anthropology, or closely related field plus:

1. At least one year of full-time professional experience or equivalent specialized training in archeological research, administration or management; 

2. At least four months of supervised field and analytic experience in general North American archeology, and 

3. Demonstrated ability to carry research to completion. 

In addition to these minimum qualifications, a professional in prehistoric archeology shall have at least one year of full-time professional experience at a supervisory level in the study of archeological resources of the prehistoric period. A professional in historic archeology shall have at least one year of full-time professional experience at a supervisory level in the study of archeological resources of the historic period.

It’s a lot, isn’t it? If you sit down with a calculator, even by doubling up on item 1 and 2, you still end up with the requirements of a graduate degree, plus an absolute minimum of 2 years of specialized experience. Coming out of college, a prospective professional archaeologists is looking at a 4 year commitment till they get their credentials.  This is longer than it takes to become a lawyer, the same amount of time to become a veterinarian or professional engineer.

Why is the Secretary of Interior Standard Important?

The SOI Standard is what the National Park Service uses to establish what is qualified staff at the State Historic Preservation Office.  By regulation (36 CFR 61.4.e), every SHPO staff must include at least one member who meets SOI Standards for Professional Archaeologist.  Failure to do so can lead to action by NPS against the SHPO.  At PennDOT, each archaeologist acting as a Historic Preservation Specialist under their Programmatic Agreement must also meet these same SOI Standards.  By meeting SOI Standards, PennDOT demonstrates that its staff has the knowledge and expertise to make findings of eligibility and effect on behalf of FHWA and can properly work with the SHPO and other parties to resolve issues related to archaeological resources found on PennDOT projects.  The Standards are so important that it would be safe to say not only would the current Programmatic Agreement be terminated, but there would be no other Programmatic Agreement without PennDOT staff meeting the Standards.

The State Employment Classification System

All state employees are classified according to a predetermined system.  Each classification sets a pay range; a definition of the position; examples of work; required knowledge, skills, and abilities; and, minimum experience and training.  Historic Preservation is in a progressive classification series, containing Historic Preservation Specialist (Pay Range 7), Historic Preservation Supervisor (Pay Range 8), and Historic Preservation Manager (Pay Range 9).  Each bump in pay range amounts to about an 8% increment.  Understanding that at least one archaeologist at the SHPO must meet the SOI Standards and that all of the PennDOT archaeologists must meet the same Standards, how does the minimum experience and training for the Series stack up against the Standards?

Requirement	SOI Standards	Historic Preservation Specialist Job Classification
Is any knowledge of archaeology required?	Yes	No
Is an advanced degree required?	Yes	No
Professional experience or equivalent specialized training in archeological research, administration or management	1 year	None
Supervised field and analytic experience in general North American archeology	4 months	None
Is there a demonstrated ability to carry research to completion?	Yes	No
Professional experience at a supervisory level in the study of archeological resources	1 year (full-time)	None

Particularly troubling is the fact that the Historic Preservation Specialist Classification was designed for an architectural historian or historian and makes no reference to archaeology at all.  The Historic Preservation Supervisor Job Classification also has none of the SOI Standards in its requirements. The Historic Preservation Manager is the lowest classification that requires an advanced degree.

PennDOT Historic Preservation Specialists necessarily work with a great deal of independence and have authority to sign off on findings of eligibility and effect on behalf of the FHWA. As part of the definition of work for the Historic Preservation Specialist:

Work is performed under the directionof the Historic Preservation Supervisor. Work is reviewed while in progress and upon completionfor compliance with procedures, regulations, policies and results. (my emphasis)

To summarize:

• Neither the Specialist nor Supervisor Classification require the advance degree that the SOI Standard requires.
• None of the Classifications in the Historic Preservation Specialist Series have the experience requirements of the Programmatic Agreement or Federal Regulation to employ a professional archaeologist.
• On paper, the SOI Standards require two more years of education and/or experience beyond that which is required for the Historic Preservation Specialist.
• Historic Preservation Specialists employed by PennDOT exercise a qualitatively greater degree of independence than what is defined in the Classification.

Oh, by the way.  The Historic Preservation Specialist Classification was created in 1986, over 30 years ago.  It is certainly due for a review, regardless of the number of state employees it covers. 

Is there a better series under which to hire professional archaeologists? The Museum Curator, Archaeology 2 Classification does reference archaeology and does require an advanced degree:

One year of curatorial work in the field of archeology, and a master’s degree in Archeology or Anthropology, including or supplemented by either a museum studies course at the graduate level recognized by the American Association of Museums or a museum internship

However, the job experience must be in the field of museum work, and the description of work is entirely curatorial.  Neither the SHPO nor PennDOT have museums nor the need for curators.

Conclusions

Archaeologists employed as Historic Preservation Specialists at PennDOT require significantly more education and experience than the Classification requires, have greater responsibilities and act with greater independence than the Classification describes, and require specialized knowledge in archaeology that the Classification ignores. The archaeologists employed at the SHPO could be exercising the same degree of independence and follow the regulatory requirements on staff qualifications. This would allow SHPO archaeologists to be free of confinement to a central office, and be located in different parts of the state, closer to their projects. The only reasonable conclusion that can be drawn is that all of the archaeologists employed in the Commonwealth as Historic Preservation Specialists are mis-classified with no suitable substitute and are also underpaid for the work that they do.  And they are long overdue for redress.

Solutions

One could simply say that we are in a free market and that people take jobs voluntarily, including jobs that pay less.  I think this misses the point.  The Commonwealth Classification system is after all, a system and that it should maintain some internal logic.  One aspect of that logic is to expect that jobs with comparable educational and training requirements at comparable responsibilities should command comparable wages.  Isn’t that what pay equity is about?

FHWA and PennDOT might assume that regardless of the wages being paid and benefits being slashed in an open market, there will be an endless supply of qualified candidates to fill vacancies.  That is a shaky assumption.  As having had the privilege of hiring about a dozen archaeologists over the years, I do believe that PennDOT and the Commonwealth is reaching the point where the pipeline of highly qualified archaeologists will dry up.  This may not happen overnight, but inevitably the managers at PennDOT will be faced with longer vacancies, a more poorly qualified candidate pool, and some risk that the Programmatic Agreement that confers so much efficiency on Department projects will be terminated, if not by lack of staff then by implementation of the Agreement by inept and unqualified employees.  Prospects for the SHPO are to have less qualified staff making more rigid and formulaic recommendations at an ever slowing pace.  The Section 106 process will slow down.

The short term solution could be to give every Historic Preservation Specialist a 3-step bump, which is equivalent to the 8% differential between classification, and to start all future staff at Step 4 instead of Base salary.  This is suggested only as a band-aid until the root cause of the pay inequity can be addressed – the substantial revision of the Historic Preservation Series.  One important revision that should be considered is the creation of a new Classification, being the Historic Preservation Professional Archaeologist which would align minimum education and training requirements with the SOI Standards, and would update the Definition and examples of work to conform to the cultural resource management duties undertaken by most staff.  It would be reasonable to peg the Historic Preservation Professional classification at a Pay Range 8, bringing it in line with other specialized jobs that require extensive education and training.

This is my blog and my space and my rules, but you may well ask to whom is this particular blog addressed?  I don’t count any employees at the Office of Administration as followers of this site, and these are the people that need to read this, especially the upper management. I am aiming my words at the archaeological community in hopes they will contact the Governor and the Office of Administration to push for this change.  Having Commonwealth archaeologists who know what they’re doing and operating with some level of job satisfaction and presumably job stability can only benefit the entire archaeological practice in the Commonwealth.