Comment
There are several strong arguments against allowing developers to bypass archaeological assessments before developing land, as proposed in Ontario's Bill 5 (Protect Ontario by Unleashing our Economy Act, 2025):
1. Loss of Irreplaceable Cultural Heritage
Archaeological sites are non-renewable resources. Once destroyed, they are gone forever. Bypassing assessments risks:
Destroying Indigenous burial grounds, villages, or artifacts.
Erasing significant evidence of Ontario’s pre-colonial and early colonial history.
Preventing future generations from learning about their past.
Example: Important Indigenous sites have been uncovered in areas now fully urbanized; without assessment, we’d never know they existed.
2. Violation of Indigenous Rights
Many archaeological sites are sacred to Indigenous communities. Skipping assessments:
Disrespects treaty rights and spiritual traditions.
Ignores the duty to consult Indigenous peoples (enshrined in Section 35 of the Constitution).
Risks escalating legal battles, delaying projects more than proper consultation would.
3. Short-term Economic Gain, Long-term Cultural Loss
The bill prioritizes speed over sustainability:
While it may save developers time, the long-term costs—legal disputes, community opposition, or lost tourism value—can be greater.
Ontario has previously benefited from showcasing archaeological discoveries (e.g. museum exhibits, heritage tourism).
4. Undermines Public Trust in Planning and Development
Public participation and transparency are already being eroded in environmental and heritage decisions. This move:
Sends a message that profit matters more than history, culture, or the public interest.
Reduces accountability by allowing fast-tracking without scrutiny.
5. Bad Precedent for Other Protections
Allowing developers to skip archaeological work opens the door to bypassing other regulations:
If we make exceptions for archaeology, what’s next? Water protection? Wetlands?
Weakening heritage oversight can cascade into broader deregulation that harms communities and ecosystems.
Submitted April 29, 2025 8:03 PM
Comment on
Proposed Amendments to the Ontario Heritage Act, Schedule 7 of the Protect Ontario by Unleashing our Economy Act, 2025
ERO number
025-0418
Comment ID
127519
Commenting on behalf of
Comment status