I am writing in to provide…

I am writing in to provide comment on the ERO posting regarding changes to the MCM Standards and Guidelines for Consultant Archaeologists (S&Gs).

To begin with I would like to speak to the proposed “targeted changes” to the 2011 S&Gs that would “support streamlining assessments” and “make administrative changes”. While it is laudable and long overdue to open up the document and initiate proposed changes with the S&Gs, these changes feel hastily prepared. As an individual on the Ontario Archaeological Society (OAS) Board who participated in the consultation with the consulting team hired by MCM late 2024 for the Heritage Framework Transformation project, it feels that there has not been sufficient reporting back on the consultants’ results as well as there has been no workshopping of translating these results into well thought through potential changes.

I am aware that the OAS Executive Director received an email in January 2026 indicating there was to be a technical sector table established with municipalities, proponents from the development industry as well as archeologists starting up in February. And the OAS Executive Director was told that the OAS would be contacted about the table. Additionally, MCM Minister McGregor in his letter of February 27, 2026, indicated the Ministry was to continue engaging with sector partners. However, the OAS has not heard anything about a technical sector table, and I have reached out to several others – an archaeological heritage planner at the City of Toronto and a number of archaeologists and it appears that no one has been contacted. Has such a table been formed? If yes, were some of these proposed changes to the S&Gs workshopped with them and was a report back on the HFT consulting team’s results? If not, this is deeply unfortunate as this table could/should provide input on any S&Gs changes in general, and in particular, changes to the way Stage 1 project areas are scoped. Activities of municipalities and development proponents are what trigger Stage 1 archaeological assessments and consultant archaeologists do the work and these individuals have real life/on the ground current and relevant experience with archaeological assessments rather than MCM staff interpreting comments from stakeholders such as municipalities and development proponents, Indigenous communities and archaeologists, and attempting to translate them into effective changes.

There is one area where I have direct experience with, linear corridors, as I worked at the Ministry of Transportation for eight years on various MTO Class EA projects and intersected with property management activities such as removal of heritage building from provincial ownership. These projects involved routinely involved linear corridors of varying widths and lengths. As such, I not sure that I understand the purpose of one of the three Stage 1 exemptions, Standard 1, linear corridors as defined in Table 1.1 Standards for Determining Exceptions to Section 1.1, Standard 3. In this exemption a linear corridor must be less than 20 m wide and at least 50 times as long as it is wide. My first question is: do these prescribed width and length requirements apply to specific types of linear corridors? Are they related to hydro or pipeline transmission corridors, or highway widenings or new highway construction? If these dimensions refer to particular types of corridors, it would be preferable to reference them. Also, I am unsure what one is to do for shorter and/or wider linear corridors? My suggestion would be to use the first 2 criteria – 1. a. and 1. b. and remove the width and length restrictions requirements – 1. c. and 1. d. Otherwise you may run into the problem of conflicts between proponent’s types of linear corridors and linear corridors as defined in the S&Gs. It would be deeply problematic for a LCA to be unable to use a proponent’s project area terminology.

As our comments are due right now, early April, and the ERO material and earlier letters from the Minister and an ADM indicate that these proposed changes to the Standards and Guidelines are to be implemented by this spring field season, there does not seem to be sufficient time for the Ministry to review people’s comments and incorporate suggestions/recommended changes. The ERO proposed changes then appear to be already decided and this undermines the ERO process of asking for comments. This ERO posting therefore feels quite performative as opposed to meaningful consultation.