Given the inconsistencies…

Given the inconsistencies and variability to the review of archaeological reports by the Archaeological Review Officers (AROs) at the Ministry of Citizenship and Multiculturalism (MCM), which has long been known in the industry as highly inconsistent, and was also recently detailed in the Ontario Archaeological Society’s newsletter (Volume 30, Issue 4, dated December 2025), there should be more effort to have consistency and remove inherent variability within the review of archaeological reports submitted to the MCM.

Rather than address the documented issues with the archaeological report review process, the proposed changes give the ARO’s more power to issue Revision, Incomplete and Non-Compliant report reviews, but without any oversight. Having Revision, Incomplete or Non-Compliant reports issued to a Professional Licensee, especially when the ARO may have mis-understood or mis-interpreted the context, can have serious ramifications on the industry, which already has insufficient licensed archaeologists to meet the industry demands. Many Professionally Licensed Archaeologists in Ontario have, and are continuing to, leave the industry specifically due to the issues and inconsistent revision letters issued by the MCM. The archaeological report review process is significantly broken, and the proposed changes will make an already over regulated process much worse and will cause more issues. Please reconsider these proposed changes and allow Licensed Archaeologists in Ontario an opportunity to voice their concerns and opinions in an open forum before implementing any changes.

At the very least, there should be an audit process to identify the AROs who consistently issue Revision Request Letters, Incomplete and Non-Compliant reviews to address any inconsistencies. Given the significance of Incomplete and Non-Compliant judgements, there should also be an option for an appeal of the decision. The appeal board should include an MCM ARO (but not the original reviewer), a professionally licensed Consultant archaeologist and a third person, perhaps a member of the First Nation whose treaty land the project was completed on.

Giving the AROs more authority and power without implementing sufficient oversight and appeal processes, especially when there are known and documented inconsistencies within the ARO review process, will overburden an already depleted archaeology industry in Ontario.