Process, Roles and Approvals for Developing Commemorative Integrity Statements

3.1 Process

The process for developing a Commemorative Integrity Statement (CIS) will depend on whether a site is administered by Parks Canada or not. The material in sections 3.1 and 3.2 is specific to Parks Canada-administered sites. Sites not administered by Parks Canada which wish to develop a CIS suitable for approval by Parks Canada should contact the Director, System Development Branch, National Historic Sites Directorate at 819-953-9345 for further information. Section 3.3 addresses approval requirements for both sites administered by Parks Canada and those administered by others.

The process of developing a CIS can be considered in four stages:

• getting started.
• confirming the designation.
• preparing the CIS.
• recommendation and approval.

3.1.1 Getting Started

The schedule for production of a CIS is identified in field unit business plans. In the case of sites not administered by Parks Canada, the decision to do a CIS is at the discretion of the site owner.

The field unit, or the service centre on the request of the field unit, appoints the team that will develop the CIS.

Preparation of a commemorative integrity statement for a site involves a multi-disciplinary team of cultural resource management specialists. The team includes not only functional specialists (for example, historians, archaeologists, and planners) but also those who are knowledgeable about the site and representatives from the site's management and operations.

Representatives of Friends or co-operating associations, partners from the community, or other relevant organisations or individuals may be part of the CIS team.

A planner or cultural resource management specialist is often designated by the field unit to lead development of the CIS. This person provides the CIS workshop participants with appropriate background information.

The field unit may invite staff from the National Historic Sites Directorate to participate in a CIS exercise to provide functional expertise in history, archaeology, heritage presentation, architecture, or policy. As team members, functional staff are able to provide specialized cultural resource management input based on their area of expertise but do not represent all functional areas of the National Historic Sites Directorate.

Requests for workshop participation of National Historic Sites Directorate staff with policy expertise are managed on a priority basis. Consideration is given to:

• the degree to which the CIS is expected to be precedent setting,
• its potential impact on policy,
• the intricacy of the policy issues,
• the complexity of the site, and
• the need for specialised functional expertise.

Employees in the National Historic Sites Directorate are available for consultation on issues arising throughout the CIS development process.

3.1.2 Confirming the Designation

A draft Statement of Commemorative Intent and Designated Place are prepared by the field unit or its designate in accordance with Guidelines No.6 - Developing the Statement of Commemorative Intent and Guideline No. 7 - Designated Place .

These statements are not established through negotiation. The HSMBC has appointed the Status of Designations Committee to resolve outstanding questions relating to designated place and commemorative intent.

Early confirmation of the Statement of Commemorative Intent and Designated Place are essential for the smooth development of the CIS.

The draft Statement of Commemorative Intent and Designated Place are sent to the System Development Branch for confirmation by the National Historic Sites Directorate.

Within an agreed-upon period of time, the results of this review are communicated to the team and, where required, a discussion takes place regarding a final version of the Statement of Commemorative Intent and Designated Place.

Occasionally the review of Statement of Commemorative Intent and Designated Place results in the identification of a need to refer the questions to the HSMBC for more guidance. Further information on returning to the HSMBC can be found in section 3.4 - Referring Statement of Commemorative Intent and Designated Place to the HSMBC .

3.1.3 Preparing the CIS

With the Statement of Commemorative Intent and Designated Place in hand, the full team meets and develops the CIS. This usually takes place during a workshop.

The draft CIS is then written by members of the team, reflecting both the discussions at the workshop and the direction outlined in this Guide . Often the draft is re-circulated to the team for comment.

The draft of the completed CIS is sent to the System Development Branch for review. Representatives of the history, archaeology, policy, heritage presentation, and system development branches, as well as members of the Heritage Conservation Program, review the draft in order to ensure that it is consistent with all relevant policies and direction, including the requirements contained in the CIS Guide and Guidelines .

Within an agreed-upon period of time, the results of this review are communicated to the team. There may be further discussion between National Historic Sites Directorate staff and members of the CIS team on issues raised by the review.

The final version of the CIS is prepared by members of the team.

The CIS should be grammatically correct and all information should be accurate. Once integrated into a management plan or posted on the Parks Canada web-site, the CIS becomes a public document and must then meet associated official language and corporate identity standards.

3.1.4 Approval by the Field Unit Superintendent and the Director General

The CIS is approved by the Field Unit Superintendent and any other signatories in the field. The signed CIS is then submitted to the System Development Branch for approval by the Director General, National Historic Sites. The final CIS is verified against issues identified in the National Historic Sites Directorate review before it is forwarded to the Director General.

The approved CIS is returned to the field unit. Copies of the CIS are kept in the System Development Branch. A signed copy of the final CIS is also sent to the lead on the CIS team.

3.2 Roles

In developing the CIS, the field unit, service centre and National Historic Sites Directorate each have distinct roles and responsibilities (see box).

Field Unit	Service Centre	National Historic Sites Directorate
Policy Development	Provide advice on the CIS Guide and Guidelines	Provide advice on the CIS Guide and Guidelines	Prepare the CIS Guide and Guidelines
Knowledge and Interpretation of Policy	Know the CIS Guide and Guidelines, including the latest changes	Know the CIS Guide and Guidelines, including the latest changes	Provide policy advice and program direction, as required
	Ensure there is appropriate expertise in place to complete the CIS in accordance with the CIS Guide and Guidelines	Provide policy advice and program information, as required	Provide guidance on submission to the HSMBC, if necessary
Training and Communication about Policy	Obtain policy and program direction, as required	Obtain policy and program direction, as required	Communicate the content of the CIS Guide and Guidelines and subsequent up-dates
	Provide expertise in planning and the use of the Guidelines
Policy Implementation	Identify a contact person for communicating with National Historic Sites Directorate	Provide functional expertise and advice	May provide functional experts to the CIS team
	Ensure that Statement of Commemorative Intent & Designated Place are in place before beginning the CIS exercise	Assist the field unit and National Historic Sites Directorate as requested	Identify a contact person for communicating with the field
	Leave enough time to return to the HSMBC, if necessary	May assume any of the field unit roles, at the request of the field unit	Provide advice from functional experts on specific issues
	Prepare the CIS
Policy Monitoring	Review and confirm draft Statement of Commemorative Intent and Designated Place
	Review draft CIS for compliance with Guide

3.3 Approval

On the signature page of the CIS, a signature block should be included for each person who is to sign the document.

The CIS must be approved by:

• the Site Superintendent, if one exists, and
• the Field Unit Superintendent, and
• the Director General, National Historic Sites, and
• in the case of sites not administered by Parks Canada, by the owners of the site or their representatives.

The CIS may be signed by representatives of:

• third party operators, or
• a shared management board, or
• other stakeholders involved in the preparation of the CIS.

Whether such parties should be signatories to the CIS is at the discretion of the Field Unit Superintendent.

3.3.1 At sites administered by Parks Canada:

The approval of the Field Unit Superintendent indicates that the CIS:

• is an accurate reflection of what constitutes a state of commemorative integrity at the site;
• was prepared in accordance with CRM Policy principles and practice and the CIS Guide and Guidelines ;
• will be applied in the management of the site.

The approval of the Director General indicates that the CIS:

• is consistent with program direction and policy;
• conforms with the CIS Guide and Guidelines .

The signature of a representative of the site's Third Party Operator or Shared Management Board indicates that the CIS:

• was developed in consultation with them;
• will be applied in the management of the site.

The signatures of representatives of Stakeholder Groups indicate that the CIS:

• was developed in consultation with them.

3.3.2 At sites not administered by Parks Canada:

The approval of the Field Unit Superintendent indicates that the CIS:

• will guide the field unit in its relations with the national historic site.

The approval of the Director General indicates that the CIS:

• is consistent with program direction and policy;
• conforms with the CIS Guide and Guidelines .

The approval of the Owner or operator indicates that the CIS:

• is an accurate reflection of what constitutes a state of commemorative integrity at the site;
• was prepared in accordance with the CIS Guide and Guidelines ;
• will be applied in the management of the site.

3.4 Referring Statement of Commemorative Intent and Designated Place to the HSMBC

A reference to the HSMBC is warranted under the following circumstances:

• when commemorative intent cannot be determined with assurance from the HSMBC minutes or plaque text.
• when Designated Place cannot be inferred with assurance from the HSMBC minutes in accordance with the HSMBC guidelines on determining Designated Place.
• when some aspect of the designation which has an impact on Statement of Commemorative Intent or Designated Place is factually wrong.
• when the site's status as a NHS is not clear in the minutes (national historic significance is not stated, or the category of designation – site, person or event – is unclear) and national historic site status is not conferred by other means (for example, having been set aside under Section 42 of the Canada National Parks Act). Depending on circumstances, this may need to be treated as a new submission.

These questions will normally be considered by the Status of Designations Committee of the HSMBC.

When the Statement of Commemorative Intent can be inferred with assurance from the HSMBC minutes or plaque text, and Designated Place can be derived from the approved minutes, they stand until altered by a subsequent approved recommendation of the HSMBC. Changes to the Statement of Commemorative Intent or Designated Place can be proposed to the HSMBC and will be dealt with in accordance with HSMBC priorities and workload.

In cases where substantial additions or changes to an existing designation are desired, it will be necessary to make a formal submission for a new designation to the full HSMBC.

The decision to refer to the HSMBC is taken following the review of the draft Statement of Commemorative Intent and Designated Place by National Historic Sites Directorate staff. In questions of Designated Place, the site owner must also be consulted.

Once the decision to refer to the HSMBC has been taken, the field unit contacts the Executive Secretary of the HSMBC to initiate the process of bringing the question to the HSMBC. The field unit, service centre, Executive Secretary, and either Historical Services or Archaeological Services Branch in the National Historic Sites Directorate will then confer on the exact question to be put to the HSMBC and the timing of the submission. This group will also determine who will write the submission and co-ordinate vetting of the draft report.

The submission to the Status of Designations Committee should follow the approved report form and be vetted by members of the CIS team and functional experts at National Historic Sites Directorate who were involved in identifying the need for clarification. All reports to the HSMBC require the support of the appropriate Director (either Historical Services or Archaeological Services).

The HSMBC meets only twice a year and has a heavy agenda. It may therefore be many months before it can consider issues relating to commemorative intent or Designated Place. Depending on the complexity of the issues involved, work on the CIS may continue while awaiting the HSMBC's determination. In all cases, however, the CIS can not be approved if issues relating to commemorative intent or Designated Place remain unresolved.