Greetings Environmental…

Greetings Environmental Registry of Ontario,

I am an archeaologist currently employed in the Cultural Resource Management industry in Ontario working to preserve cultural resources for the people of this province. For the past four years I have been working on the side of major highways throughout the province completing stage 2 test-pitting and any required expansions, in busy downtown Toronto neighbourhoods completing stage 4 excavations, and on private properties working with landowners to ensure the responsible preservation of sensitive heritage contexts and materials. Throughout this time I have had the distinct pleasure of working to preserve aspects of our history, which would not otherwise be known to us as paper records and secondary literature have significant gaps as a result of these histories being a patchwork of sources often reflecting a particular social vision of whose story is worth being told.

The Ontario Heritage Act provides some of the only safeguards against the last material remains of these histories being entirely erased. I have often worked on assessments within development projects where construction companies have disregarded legislation and bulldozed large, archaeogically sensitive areas without having completed proper assessments. If these safeguards are removed under the pretence of making construction more efficient in pursuit of expanding the housing stock and other important projects these companies will undoubtedly aggressively remove archaeological remains in order to save on costs and to increase profits rather than ensuring the best interests of the people of Ontario. The most significant group this will disadvantage are the many Indigenous peoples with whom I work on a daily basis through the many liaison programs, which place communities such as Alderville, Curve Lake, Pikwàkanagàn and many others at the centre of cultural resource management and contribute to the revitalizing of locals knowledges, cultures, and territorial integrity, which have been devastated by this same development industry.

Just this past week my crew found Indigenous pottery on the side of the 401 next to an industrial property as we were completing stage 2 excavations in service of the prospective expansion of this highway. The Indigenous liaison who had just recently started in his position learned a tremendous amount through the process of expanding 1 metre by 1 metre units on these finds, which he will bring back to his communities as well as inform future knowledge of the area around Grafton, On. Additionally, this particular pottery find is adjacent to a major archaeological site known as the Grafton Site and despite this knowledge the industrial site has no records of completing an archaeological assessment, suggesting significant heritage materials were likely destroyed in the industrial usage of this land at the expense of Indigenous history. This same destruction of Indigenous history is routinely uncovered in my work and rather than weakening these legislative safeguards it is my professional opinion existing legislation needs to be properly enforced in order to compel compliance and safeguard these resources.

The Truth and Reconciliation Commission of Canada stipulates for the preservation of Indigenous heritage and this ongoing, routine destruction of material history amounts to a continuation of the cultural genocide outlined in this document. I believe the goals of the Ontario government to increase the speed of development are commensurate with the goals of the Truth and Reconciliation Commission as long as safeguards are left in place and properly enforced. However, if these amendments of the Protect Ontario by Unleashing our Economy Act, 2025, are brought into law this will amount to a significant degrading of the human rights of Indigenous peoples of this province to access heritage resources. It will also put out of work many professionals who have studied and worked for decades in this knowledge intensive industry, which would be difficult to recover if and when any such changes to the Heritage Act are challenged in courts or politically. This would benefit no one who shares a pride in being from this great province and is interested in knowing more about the landscape connecting us as a people.

Thank you for taking my comment on this proposal and I trust the human rights of Indigenous peoples of this province will take priority over the imperatives of the development industry.