Response to the DDCA Draft Recommendations

BY BETTINA FRANKHAM — Thank you for the opportunity to respond to these important recommendations. I offer this feedback as an individual researcher whilst noting my appreciation for the significant work undertaken by ASPERA and other peak bodies in this consultation process.

I am generally supportive of the recommendations’ intent to move beyond the problematic traditional/non-traditional binary. However, I have concerns about some fundamental assumptions that may limit the transformative potential of the proposed framework.

1. Nomenclature and the Question of Activities vs Objects

Recommendation 1.1-1.2: I strongly support ceasing the use of NTRO terminology and agree with the critique of ‘tradition’ as insensitive in Australia’s colonial context. The call for nomenclature that is “capacious enough to include ongoing changes” whilst being “specific enough to maintain important differences” is particularly astute.

However, I question whether ‘artefact’ terminology truly addresses the underlying issues. The continued focus on objects (whether called outputs, artefacts, or products) may perpetuate evaluation challenges rather than resolve them.

Consideration: Would a more radical positioning that focuses on research activities rather than research artefacts permit the inclusiveness the recommendations seek while avoiding the persistent problem of how to categorise diverse creative research outcomes? This shift from nouns to verbs might better capture the dynamic, process-oriented nature of creative practice research.

2. The Practice-Enabled vs Research-Enabled Distinction

Recommendation 2.1: While I appreciate the attempt to clarify “where the knowledge resides”, I have concerns about the fundamental practice-enabled knowledge vs research-enabled practice distinction.

This distinction may not fully account for the expert knowledge and understanding required to perceive knowledge contributions in specialised research activities. The difficulty in “knowing where the new knowledge resides” often occurs due to the layered and embedded processes involved in realising creative ideas that are networked into broader aesthetic and technical practices associated with disciplinary specialisation.

I remain convinced that the move from practice to text is productive in revealing knowledge to both creator and external audience. Rather than seeing this as evidence that knowledge doesn’t reside “in” the creative work, this textual articulation can be understood as part of the knowledge-making process itself – a necessary step in moving specialist, embedded knowledge into forms accessible to broader scholarly communities.

The risk is that this distinction recreates a binary (practice-enabled vs research-enabled) that may be as problematic as the traditional/non-traditional division it seeks to replace.

I agree that there needs to be a clear distinction between professional practice and research. However, institutional assessments often blur these boundaries problematically, with professional practice required to perform as research to gain validation. Similarly, research may be diminished when public recognition becomes the key measure of value. This reinforces the importance of academic peers, from closely aligned disciplinary fields, in assessing research dimensions.

3. Reporting Pathway Concerns

Recommendation 3.1: The proposed reporting pathway relies heavily on the practice-enabled/research-enabled distinction I have questioned above. This makes it difficult to assess whether this pathway effectively replaces the TRO vs NTRO opposition or simply recreates it in different terms.

Alternative consideration: If we shifted focus to “research activity” rather than “research artefact”, how might this impact the reporting pathway? Would “contribution type” need to be broadened beyond the current categories?

My thinking here gets circular as I attempt distinctions between objects and textual explications of ideas, but this seems to return to the binary of traditional vs non-traditional outputs. My response is that I do not think this reporting pathway is as yet sufficiently resolved to effectively replace the TRO vs NTRO opposition.

4. Research Statements and Expert Knowledge Requirements

Recommendation 4.1-4.3: I strongly support longer research statements (400-600 words) as critical for understanding creative research contributions. However, the framework needs to better acknowledge that certain levels of expert knowledge are required to perceive knowledge contributions in specialised creative research activities.

Given the sophisticated, embedded processes involved in creative research, this argues strongly for:

  • Peer reviewers with closely aligned disciplinary expertise
  • Recognition that research statements, whilst essential, cannot fully substitute for specialist knowledge
  • Avoiding the problematic expectation that creative research be “clearly understood by educated but non-expert reviewers” – a demand not generally directed at writers of peer-reviewed journal articles

Missing element: The recommendations don’t address gatekeeping or esteem measures as proxies for peer review. How would research validation through peer-reviewed scholarly audiovisual journals and similar specialist outlets be considered?

5. Who are the Peers and Expert Knowledge Requirements

Recommendation 5.1: This gets back to my earlier point regarding expert knowledge and understanding being required to perceive knowledge contributions in specialised research activities. While research statements can go some way to ameliorate this, I have strong memories of instructions that such statements needed to be clearly understood by educated but non-expert reviewers – a demand not consistently applied across different forms of scholarly communication.

Industry peer recognition demonstrates quality and relevance, but it does not necessarily demonstrate scholarly contribution. This raises important questions: Is this an argument for not requiring public recognition or exhibition as validation of research quality? Does this endorse outlets such as peer-reviewed scholarly audiovisual journals that enable publication/presentation of creative practice outputs alongside appropriate peer review processes?

I agree that academic peers from closely aligned disciplinary fields are best placed to assess the research dimensions of creative work. This argues for considerable capacity building and recognition of peer reviewers, particularly where, as in smaller creative practice communities, the pool of peers is relatively limited.

6. Scale, Impact and Portfolio Assessment

Recommendations 6.1-6.3: I strongly agree that size, scale and impact relationships cannot be assessed through one-size-fits-all approaches. The particularities of different forms and disciplines require nuanced understanding.

However, rather than either/or thinking between individual artefact vs portfolio assessment, there could be benefit in allowing advanced practitioners to demonstrate field impact through retrospective showcases charting development over longer periods. Supporting longer arcs of research would be positive in our increasingly fractured academic environment.

Resource concern: Will every institution be adequately resourced to enable the disciplinary expertise required for equitable and fair assessments? As previously mentioned, some peer reviewer pools can be very limited, and this is likely exacerbated within individual institutional contexts.

7. World Standard and Local/Contextual Excellence

Recommendations 7.1: I support reconsidering world standard markers, particularly given western-centric ideals and global inconsistencies in creative practice research evaluation.

Rather than abandoning excellence measures entirely, we might consider frameworks for local/contextual research excellence that acknowledge the situated nature of creative practice research whilst maintaining rigorous evaluation standards. This could provide meaningful alternatives to Eurocentric ‘world standards’ without diminishing scholarly rigour.

8. Data-Driven Evaluation

Recommendation 8.1: The emphasis on data-driven evaluation needs careful consideration. The “it depends” reality of creative practice research evaluation reflects genuine complexity that data-driven approaches may not capture, particularly the layered and embedded processes I’ve referenced above.

While data can provide useful indicators, the complex, contextual nature of creative practice research cannot be reduced to metrics without losing precisely what makes this research valuable.

9. Indigenous Knowledges

Recommendation 9.1: I strongly support Indigenous practitioners and researchers participating in writing this framework as a key priority. Whilst I defer to experts in Indigenous research on the specific methodological and protocol requirements, I can see significant value – ethical, social, cultural and more – in Indigenous contributions to framework development.

Just as Indigenous concepts of Country are enabling broader shifts in relationships to land, environment and ideas of home, there is important potential to expand understandings of knowledge, contribution and impact through listening to First Nations practitioners and researchers. This connects to my earlier argument about locally contextual, culturally specific research – Indigenous ways of knowing, being and doing may offer vital alternatives to the Eurocentric evaluation frameworks we’re trying to move beyond.

The framework’s success in truly moving away from colonial knowledge hierarchies will depend significantly on meaningful Indigenous participation, not merely consultation.

10. Learned Academies

Recommendation 10.1: I strongly support the establishment of a learned academy for creative practice research and endorse the DDCA taking a leadership role in this space. The absence of explicit representation in existing learned academies has been a significant gap that needs addressing.

However, I emphasise the critical importance of discipline-based peak bodies as keepers of specialist understandings. Bodies like ACUADS, ASPERA, AAWP and IDEA hold invaluable disciplinary expertise that must inform any overarching framework. The challenge lies in creating structures that genuinely accommodate, value and recognise the differences and specificities these bodies represent.

I advocate for a non-hierarchical relationship between stakeholder peak bodies and the DDCA. Rather than a top-down model where the DDCA is the final decisionmaker, there is considerable promise in truly collaborative structures where disciplinary voices can be genuinely heard and integrated into framework development. This connects to my earlier argument about expert knowledge requirements – the sophisticated, embedded processes of different creative practice disciplines cannot be adequately captured without deep disciplinary engagement.

This is particularly crucial for capacity building among peer reviewers. Effective peer review in creative practice research requires reviewers with closely aligned disciplinary expertise, not generic “creative practice” knowledge. The learned academy structure must facilitate this specialist knowledge exchange while building broader understanding across the sector.

The success of any new framework will depend on whether it can hold these disciplinary differences in productive tension rather than flattening them into generic categories.

Conclusion

These recommendations represent important progress and open valuable conversations about moving beyond problematic binaries. To fully realise their transformative potential, continued dialogue will be important – particularly around how we conceptualise and evaluate the dynamic, process-oriented nature of creative practice research as well as research more broadly. The collaborative engagement these recommendations invite offers genuine promise for developing more nuanced and inclusive evaluation frameworks.


Dr Bettina Frankham is Senior Lecturer and Deputy Head of School (Academic) within the School of Communication at University of Technology Sydney, with research interests in creative practice methodologies and interdisciplinary collaboration.