I am deeply concerned by the…

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025-0418

Comment ID

126911

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Individual

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Comment

I am deeply concerned by the changes proposed to the Ontario Heritage Act that would allow for properties to be exempted from conducting archaeological and built heritage assessments. Ontario's history is important and deserves preservation, which this change would prevent.

While there is an understandable desire to promote the construction of affordable housing and necessary infrastructure, this is not the best way to do so. All that this change would do is put the Province in violation of the Duty to Consult under UNDRIP, as well as destroying decades of progress that has been made through the archaeological process towards Reconciliation with Ontario's First Nations and Indigenous Communities.

There are better methods that would reduce the onus that archaeological assessments place on the development and construction sectors. Specifically, there are changes that could be made to the Standards and Guidelines for Consulting Archaeologists, as well as to the structure and oversight of the Archaeology Programs Unit that would go a long way towards easing the assessment and review process.

Most of the time in the development process, it is not the archaeological assessments themselves that cause significant delays. What causes the delay is the review process and navigating the at times contradictory and inconsistent advice and direction provided by the Archaeology Review Officers at the Archaeology Programs Unit. Creating a more consistent approach on the review side, with better communication of expectations and expedited review processes would be much more affective and prevent the Province from committing an egregious mistake.

I am sure that many people in the consulting archaeology field, such as myself, that would be happy to provide input on better ways to improve this process. Consulting with experts in the field before drafting legislation that would introduce drastic changes such as this would avoid issues in the future.