It is clear that the…

It is clear that the Standards and Guidelines for Consultant Archaeologists has been overdue for an update for quite some time now. It is a discussion that has happened countless times within the consultation community, from archaeologists, first nations field liaisons, clients, developers, First Nations people, and landowners alike. The proposed changes to the S&Gs however, address little of the concerns that typically come up in these discussions. While I am aware that there was a call for consultation regarding an updated document, I do not see any of the major concerns from people working within this sector being reflected within the proposed changes, outside of the much overdue language update from "Aboriginal" to Indigenous. I am convinced some level of consultation must have occurred in order for the document to have reached this stage, but I do not see any impacts said consultations.
The limited time to review and comment on these changes also feels disingenuous. The turn around feels more akin to trying to push something through quickly and with limited time for people to review the proposed changes, than a sincere opportunity for people to voice their concerns or comments.
The recent discussion of rolling out said changes so quickly also makes this comment period feel performative.
The S&Gs (2011) is in dire need of an update, but the proposed changes do not touch upon many of the major issues with the original document (vagueness of language, outdated or easily misconstrued statements, arbitrary statements, etc.). The major change of no property inspections during a Stage 1 seems baffling and I am at a loss over what problem this change is supposed to be rectifying, by all accounts it will be an issue to both the consultation community, as well as a later issue for the developer when we invariably have to force a "Stage 2" in order to do a property inspection to confirm disturbance or not. Or, even worse, when archaeological work must occur because a Stage 1 was not as thorough as it could have been, due to the loss of a property inspection, and archaeological materials invariably are encountered. This will cause a slowdown on the development project itself, as well as an increased cost, as salvage will now need to occur within the impacted portion of the property.
As a millennial working within the CRM industry and active within the broader archaeological community, I am passionate about any proposed changes within a governmental document that seemingly controls our ability to be archaeologists. Many of the proposed changes feel like overreach
and provide the opportunity for those acting within the MCM (specifically AROs) the ability to be the arbiters of a site's designation, regardless of their professional experience or knowledge. There are also concerns regarding bias and personal vendettas regarding those within these positions of the MCM who will be in a position to abuse their power.
The Ministry was in a position to provide real meaningful change to a badly outdated document, and appears to have acted in their own interests, instead of everyone else's. Increasingly, I feel that Indigenous peoples should be in a considerably more involved position regarding their own history and ancestral lands and the lack of any meaningful update to Indigenous engagement within the document feels intentional and off-putting. Sending a mass email of PIFs with no information to Nations and expecting them to have people fulltime to weed out which projects are relevant to them is not engagement. It is not a complicated thing to automate a notification system through systems already in place in PastPortal especially given how many dropdown menus are available when selecting a study area. The lack of any real "how-to" for PastPortal generally also feels intentional. With several links just leading to the government of Ontario's home page, instead of actually explaining how to use the Portal and its antiquated menu system. Overall, I am disappointed and increasingly worried about my future within a career I love so much, and these proposed documents just increase that sentiment.