Comment
The 2026 draft introduces formal “limited assessment” standards for Stage 1 and Stage 2 work, intended to streamline smaller or discrete projects.
Deficiency for Class EAs
While helpful for small footprints, these standards:
• Are designed for contained areas, not linear systems
• Require justification that entire portions of a project area require no further work
In Class EA corridors:
• Archaeological potential and disturbance change repeatedly along the route
• A corridor may be:
o Low potential at km 0–2
o High potential at km 2.3
o Fully disturbed again by km 3
The standards do not clarify whether multiple, repeating limited assessments within one corridor are acceptable under a single PIF, nor how they should be documented spatially. This could result in:
• Excessive conservatism (eroding supposed streamlining benefits), or
• Inconsistent ministry interpretation at report review
Submitted March 27, 2026 4:23 PM
Comment on
Heritage Framework Transformation: Proposals related to Ontario’s Archaeology Program, including targeted changes to the Standards and Guidelines for Consultant Archaeologists
ERO number
026-0216
Comment ID
183784
Commenting on behalf of
Comment status