Heritage Framework…

Heritage Framework Transformation: Proposals related to Ontario’s Archaeology Program, including targeted changes to the Standards and Guidelines for Consultant Archaeologists

ERO number: 026-0216
Notice type: Policy
Act: Ontario Heritage Act, R.S.O. 1990
Posted by: Ministry of Citizenship and Multiculturalism
Notice stage: Proposal
Proposal posted: March 6, 2026
Comment period: March 6, 2026 - April 5, 2026 (30 days) Open

Proposed changes to the Standards for Consulting Archaeologists in 2026 do not reach the objectives of the Heritage Framework Transformation Proposals. Rather than increase efficiency of the process, the proposed changes introduce further complexity in adhering to the minutiae of previous Standards. There is a lack of clarity (and numbering) in the proposed new Standards which will increase demand for interaction with staff of the Archaeology Programs Unit. The professional archaeologists of Ontario were not provided with opportunity to assist in the writing of Standards, only provide comments. This token approach to inclusion needs to change in recognition of the accomplishments of the professional community. Please provide direct involvement of professional archaeologists and their organizations in the drafting of any further Standards changes. A full interactive review of the 2011 Standards was originally promised to us to take place in 2016 - ten years ago.

Some suggestions for improving the administration of archaeology in Ontario.
1. Stop judging archaeologists from an administrative compliance framework and interact with them to learn what it is that they do.
2. Immediately implement a dispute resolution mechanism so that consulting archaeologists can express differences of professional judgement as the people on the ground actually dealing with complex archaeological sites.
3. Implement Ontario Public Service Standards properly - answer phones and respond to e-mails in reasonable time frames. Hold review officers and the Ministry accountable for mistakes the same way that they treat us - the people without any dispute resolution mechanism.
4. Performance standards for APU staff - discussions with APU staff indicate that service expectations are not high and that reviews take too long because they are deeply concerned with rigorous adherence to standards rather than looking at archaeological outcomes. Perhaps once in a while, comment on something good and informative in a report which exceeds Standards.
5. Inaugurate discussions with concerned archaeologists and First Nation organizations about misperception of the archaeological engagement system as Consultation (Duty to Consult). Engagement was never intended or legally designed to fit the concept of engagement. It is an interactive process for archaeologists and First Nations to share information and learn from each other. Review provincial processes which mistakenly give the understanding that the province can download its Crown obligations without designating agents for limited purposes. Municipalities have no authority to prescribe engagement or to dictate which First Nations are to be engaged by archaeologists.
6. Licencing statistics tied to report reviews incorrectly evaluate licence holders as complicit in mistakes when no licence holder can do all work themselves. Archaeological firms must delegate. Once a licence is given it should be regarded as something that only egregious errors can impact, much like any other profession in Ontario.

Thank you for the opportunity to comment. I hope someone will read this and perhaps implement some ideas.

A 50 Year Licence Holder in Ontario Archaeology