To the Legislative Assembly,…

To the Legislative Assembly,
I am writing to you as a citizen concerned about this proposal, specifically regarding the Schedule 7 amendments to the Ontario Heritage Act. As a licensed archaeologist in Ontario, I have a legally mandated responsibility under the OHS to protect archaeological resources from unmethodical destruction. I consider this duty a privilege and one that deserves the entirety of my passion and integrity. I also believe that as an archaeologist and a Canadian citizen, I hold an ethical responsibility to the Indigenous communities of the land; to ensure their ancestral remains are identified, respected, and protected. For these reasons, it is naturally also my duty to speak out against this egregiously ill-informed piece of legislation that is being proposed.
While the schedules in the proposal herein concerning the environment are also abhorrent, I will focus on the impacts of amending the OHS on archaeological sites and the Indigenous communities:
Section 66.1 must be removed. The section dictates that archaeological assessments would no longer be obligatory for developers if the Lieutenant Governor in Council (on the advice of the Executive Council) determines that the exemption would “potentially advance one or more of the following provincial priorities: 1. Transit. 2. Housing. 3. Health and Long-Term Care. 4. Other infrastructure. 5. Such other priorities as may be prescribed.” This list essentially covers any and all development. Also, the language clearly expresses that cultural resources and Indigenous interests are not a provincial priority, as they did not make the list. Furthermore, numbers 4. and 5. are so vague that an exemption could be applied at the sole discretion of the LG and Council.
If this objective here is to accelerate economic development, this is sure to have the opposite effect. If this passes here are some likely outcomes:
1) The Province will be burdened and potentially inundated with applications for exemptions by developers in the hopes of avoiding costly archaeological assessments. The Province will then have to allocate more time and resources to process these applications.
2) This will lead to more conflict between developers and Indigenous communities. The Indigenous communities will not stand idly by as their ancestral lands are completely stripped of their archaeological presence, and their Nationhood completely ignored. As seen with the Oka Crisis in 1990 and the still ongoing conflict between Coast Gas Link and the unceded territories of the Wet'suwet'en, the Indigenous communities will protest and disrupt unconsented development of their lands.
3) Further erosion of the Provincial Government’s ethical credibility. This proposal blatantly ignores the TRC’s Call to Action 79 and Article 11 of UNDRIP. As archaeological projects employ many Indigenous people, creating a bypass for developers to avoid doing archaeological assessments would be removing economic opportunity for Indigenous peoples as a result.
Alternatives to this proposal:
1) Collaborate with the MCM to create new efficiencies in the archaeological assessment and report reviewing process. This could entail updating the Standards and Guidelines (2011) and the MCM offering clear direction for proponents and archaeological firms on Indigenous engagement.
2) The Province should provide take on more of the financial responsibility for archaeological assessments and Indigenous engagement to reduce the burden on developers.

I am sure there are many others that are writing to you in a similar vein of displeasure therefore, I will end my piece here. Please consider these comments. They are not intended to be attacks on the current political party but deeply considered concerns from your citizens for the ethical principles and success of our society.