I have a PhD in archaeology,…

I have a PhD in archaeology, and hold an Ontario Professional Archaeological Licence. I have been doing archaeology for over 40 years, having worked as a consultant, as a manager at Parks Canada, and as an advisor to First Nations. 

The proposed targeted revisions to the Standards and Guidelines for Consultant Archaeologists are deeply flawed, and will prove unworkable if they are implemented. I recommend that Ontario pause its implementation and instead undertake meaningful consultation with Indigenous communities, licensed archaeologists, and professional planners. The province should return with a new draft and a phased implementation, instead of this rushed incoherent chaotic process.

On the whole, many revisions are ever more prescriptive, they seem to be intended to limit choice of action in edge cases, reducing the effective scope of an archaeologist’s professional judgement. They certainly have not been developed with any input from archaeologists. Some global changes to the S&Gs have clearly not been thought through, which will lead to conflicts with other heritage planning instruments, for example “property” becoming “project area,” or “archaeological resources” becoming “archaeological sites.”

The worst biases of the 2011 version are still present, many standards are written assuming that the area to be assessed is a ploughed field. The fixation on edge cases does not extend to situations where professional judgement is actually necessary, such as the Canadian shield, sand dunes, cobble beaches, and lands that have never been ploughed.

Also woefully lacking is any guidance for complex urban archaeological sites that feature imported fills, multiple overlapping areas of disturbance, complex stratigraphy, and constraints upon excavation because of existing structures and utilities.

One possible positive change has been ignored in this revision, despite repeatedly being requested by First Nations and archaeologists. Stages 1 and 2 still do not require Indigenous engagement. Engagement at every project stage is necessary to level the playing field so that all consulting archaeologists and all proponents work to the same expectations.

Finally, any changes to the S&G must articulate with other changes proposed in the Heritage Framework Transformation and other planning legislation such as Bill 5. At present, the policy dissonance between these streams will mean that these initiatives will fail, land use planning and approval for infrastructure development in Ontario will not be predictable, streamlined, or timely. The economic costs will mount, and the province’s heritage will not be adequately protected and managed.