I am writing on behalf of…

I am writing on behalf of the Windsor Chapter of the Ontario Archaeological Society to express my concern regarding the proposed updates to the Standards and Guidelines for Consultant Archaeologists.

First, it is deeply disappointing that this proposal was not shared more broadly with both the archaeological community and Indigenous communities prior to its posting on the ERO. Meaningful consultation requires early, transparent, and inclusive engagement. In this case, opportunities for such engagement appear to have been limited, with only a small number of in-person meetings held with Indigenous communities and even fewer with professional archaeologists. This approach does not reflect best practices for collaborative policy development in Ontario’s heritage sector.

More critically, among the many concerns we've heard from our members, the proposed updates do not adequately address the requirement for early Indigenous consultation within the archaeological process. This omission is inconsistent with the Provincial Planning Statement (2024), which clearly emphasizes early and ongoing engagement.

Policy 6.2.2 directs planning authorities to undertake early engagement with Indigenous communities, facilitate knowledge-sharing, and support the identification of potential impacts on Aboriginal and treaty rights.

Policy 4.6.5 further requires early engagement to ensure that Indigenous interests are considered in the identification, protection, and management of archaeological resources, built heritage resources, and cultural heritage landscapes.

The current proposal does not demonstrate how these principles will be upheld within the revised standards, particularly at the earliest stages of archaeological assessment.

Additionally, the limited duration of the ERO comment period does not provide sufficient time for meaningful consultation with the communities most directly affected by these changes. The scale and implications of the proposed revisions warrant a more robust and extended engagement process. Especially since this is the first time significant changes have been made to the Standards and Guidelines in over a decade. If the updated standards are to adequately reflect realities faced the field, a more thorough consultation process must take place.

Of particular concern are the proposed changes to the Stage 1 process, including the removal of the mandatory site visit. This change introduces significant inconsistencies with existing regulatory and planning frameworks outside of the archaeological unit, including municipal and provincial Environmental Assessments, as well as broader land-use planning and feasibility studies. The lack of alignment risks creating confusion among practitioners, regulators, and proponents.

We are especially concerned about the practical implications of implementing these changes in advance of the 2026 field season. Without sufficient clarity, transition planning, and sector-wide consultation, these revisions may disrupt ongoing projects and create uncertainty across the cultural resource management industry.

As archaeologists who work within this regulatory framework, we respectfully request that the proposed changes to the Standards and Guidelines for Consultant Archaeologists not be implemented until they have been thoroughly workshopped with Indigenous communities, professional archaeologists, and other key stakeholders. A more collaborative and transparent process is essential to ensure that the updated standards are effective, consistent with existing policy frameworks, and reflective of the interests and rights of those most impacted.

Sincerely,

Windsor OAS Executive