Hi there. I’d like to keep…

Hi there. I’d like to keep this brief rather than getting out too far “into the weeds” on archaeological practice.

First, I think it is a mistake to assume that Stage 1 and 2 assessments carry the lowest risks. The bad actors in our profession do most of their “dirty deeds” at these stages. Later on, there are usually Indigenous monitors present. It’s hard for them to get away with anything. But saying a property doesn’t need assessment at Stage 1? Or that nothing of significance was found at Stage 2? That is a way to slide under the radar with poor practice (and to monetize it).

My second, and main concern with these proposals, is that that original Standards and Guidelines for consultant archaeologists (2011) came out 7 years after the Haida Decision (2004) established the Duty to Consult and Accommodate with First Nations (arising from Section 35 of the constitution). So the original “S&Gs” were deficient when it comes to engagement and these new ones are no improvement. Simply put: after Haida, after the Calls to Action arising from the final report of the Truth and Reconciliation Commission, and after Canada’s adoption of UNDRIP, it is astonishing that the province of Ontario continues to insist that engagement is not necessary until quite late in the archaeological assessment process. You are one court challenge away from the land use planning process being entirely upended. It would be better to find an incremental way to acknowledge that and to get there with some agency to shape the process rather than having it imposed on you.

https://www.thespec.com/opinion/contributors/preserving-indigenous-arch…