The Ontario Archaeological…

The Ontario Archaeological Society would like to express its disappointment regarding the updated Standards and Guidelines as outlined in the ERO Posting 026-0216.
The OAS Board of Directors is strongly opposed to the implementation of this document. We also oppose the application of the proposed licensing requirements.
As many of our members and colleagues will be commenting on the specifics of the changes, we will not be addressing those directly here. Our membership includes not just consulting archaeologists in Ontario, but academic researchers, avocational archaeologists, members of Indigenous Nations and heritage practitioners in Canada and the United States, therefore, we are focusing our comments on the lack of consideration and consultation that are evident in these updated guidelines.
One of the main reasons we, and other heritage organizations, have been calling for changes to the Standards and Guidelines is that they have become outdated, and do not address the current challenges of development and heritage considerations since the original document was introduced in 2011. The proposed document outlines how these Standards and Guidelines were originally created and the proposed updates. From the document:
“• input from a technical advisory group representing a cross-section of archaeologists with specific technical expertise and understanding of a range of contexts within which archaeological consulting is carried out. The group met for a number of intensive day-long workshops during 2004 and 2005.
• input on draft sections from regional stakeholder information and feedback workshops held from 2004 to 2006
• feedback on 2006 and 2009 drafts from archaeologists, archaeological organizations, and other stakeholders, and Indigenous communities, organizations and representatives
• In 2026, the ministry proposed targeted changes to the 2011 Standards and Guidelines for Consultant Archaeologists that would support streamlining assessments and make administrative updates to the document.”
Why is there is no mention of any of the proposed changes reflecting any discussions after 2009, given the changes proposed are more than just administrative and as many will be pointing out in other submissions, will not streamline the process. I can assure you that our organization, along with many others, has spent countless hours-on our own, non-paid time-providing reasonable, professionally considered direct advice to the Ministry regarding areas of improvement for the Standards and Guidelines since 2009.
Why is there a gap of over 25 years regarding where you have gotten your information from? Because it is obvious that whoever put this document together didn’t bother, and it’s insulting.
Our society, along with others in the province, such as the Association for Professional Archaeologists and the Ontario Maritime Heritage Committee have been actively engaged in the process for calling for improvements to the 2011 Standards and Guidelines for over a decade. We have met regularly with not just with the members of these various organizations, but also our colleagues in the Archaeology Review Office of the Ministry of Citizenship and Multiculturalism, Indigenous Nations and organizations, other heritage organizations throughout the country. We have provided numerous constructive and what we feel are reasonable suggestions for improvement over many years, often in conjunction with these groups. More recently, we have been having regular communication with Minister McGregor’s office and have also been actively engaged with the Heritage Transformation process. It is beyond disappointing that this attempt to update the Standards and Guidelines has used little of the enormous amount of time and thought we have put into suggestions that are based on the collective experience of hundreds of archaeologists, Indigenous partners and other heritage practitioners. Many of us have devoted countless unpaid hours to crafting recommendations that we feel will strike a balance between ensuring that development can move forward while also ensuring that Indigenous concerns are addressed and Ontario’s heritage is preserved for current and future generations. Quite frankly, this attempt at updating the Standards and Guidelines seemingly by a group of people with little understanding or knowledge of archaeology is a slap in the face to the many professional, academic and avocational archaeologists in this province.
As a result, the OAS Board of Directors asks for consultation on the requirements for licensing including, “Being a member in good standing of an archaeological organization with a code of ethics or code of conduct.”. The OAS Board of Directors have spoken to both the Archaeology Review Office and the Ministry about this topic and have not been consulted on this further.
Despite this obvious lack of faith in our membership of over 700 consulting, academic, Indigenous and avocational archaeologists, along with those of us who work in heritage related activities in the province and elsewhere, we will continue to advocate for the preservation of heritage in Ontario and will continue to provide recommendations for sensible, reasonable and data-driven changes to the current heritage framework in Ontario that will not only benefit our members, but will also ensure that the priorities of the Ontario government will actually be met.
We would welcome outreach from the Ministry, Archaeology Review and Heritage Transformation teams to provide information on who contributed to the completion of this update. We would be happy to discuss alternative solutions to contribute to more positive outcomes for everyone. The OAS is pleased to stand with Indigenous communities to protect heritage and advance economic reconciliation while supporting the province’s goal of strengthening economic resilience. These goals do not need to be mutually exclusive. The OAS would welcome the opportunity to work with you and Indigenous partners to create a successful archaeological heritage framework that serves all these objectives.