The updated standards have…

The updated standards have exempted assessments of partial parcels of lands for projects that meet the criteria for Linear Corridors and Limited Small-scale Impacts projects. Many projects triggered by the EA act will be affected by these definitions. These criteria are very constrictive which may impact archaeological assessments of portions of parcels based on limit of impacts. This may result in being required to assess larger areas than necessary/impacted which may increase budget and project timelines. These criteria only seem to take into consideration those projects under the Planning Act or a narrow segment of projects under the EA act. For example - there are MANY linear corridors that are not 50 times longer than width. What is the point of including this ratio as a criteria? Also note that public sector entities also undertake limited assessments - so to have a criteria that only privately owned lands can be subject to limited assessments is not helpful.

The removal of optional property inspection from Stage 1 assessments is a regressive move that will make Stage 1 assessments an ineffective tool for land use planners. More Stage 2 assessments may be triggered because of this change which may impact project timelines and may increase budgets for archaeological clearance. This will affect public and private sector proponents. This move is not going to save anyone money nor make things more efficient.

The Standards for Stage 1 project reports asks for images to support the analysis, conclusions and recommendations of the report. What images are to be provided if a property inspection cannot be undertaken? Google Earth images that only go back to 1985 and the historic aerial images that are sometimes available?

Stage 3: Site-specific Assessment - Continuing temporary avoidance and protection of archaeological sites - Standards 1 - so are all sites subject to 20 m buffer after stage 1? Other sections of the report suggest the previous 10 and 20 m buffer depending on site type. This is confusing.

Can MCM provide better and more rigorous standards for PERs?

Clarification is needed whether PIFs taken out prior to the finalization of the 2026 standards can follow the 2011 S&Gs.

The implementation of these new updated standards needed to be preceded by consulting with the archaeology community. It is not enough to drop these on licensees a month before the field season starts. The new standards seem to have been added to the 2011 S&Gs in a very hasty manner without any engagement with the regulated community. It would be appreciated if the implementation of these updates are pushed back until appropriate steps and engagement has occurred.