I would like to make a few…

I would like to make a few comments concerning the MMHA proposal in regards to Indigenous engagement, the importance of archaeological sites, and the possibilities of protective mandates when dealing with First Nations heritage.

You've identified that there be proactive strategies for identifying archaeological sites as part of your steps moving forward. However, you have no mention of the proactive protection of set archaeological sites if (mis)identified or discovered where there was thought to be not potential.

It is one thing to acknowledge First Nations heritage sites that are important to Indigenous communities. It is another to make appropriate protocols for ensuring that the future generations have a place that is meaningful to return to. It is unfair that even the awareness of what was once there, such as a village, is now a highways or housing subdivision. Hidden away from public eyes and never to be celebrated or remembered.

The Ministy of Citizenship and Multiculturalism released statements to registered Archaeologists that 3500 projects were opened with the Ministry in 2022, and 3200 reports were filed for the entirety of the province. Nothing released in these bulletins describes how many sites were protected or completely removed through excavation. It is likely that the majority of the site has been removed. I am for this new planning initiative, then what are we doing in terms of heritage? Who's heritage? Indigenous sites are contiuiously and completely removed. What is to be remembered and celebrated?

I ask that more stringent engagement protocols for lands and projects that have Indigenous interest. Particularly when sites are triggered for an archaeological assessment, the duty to consult. I will provide an example of the type of lack luster protocols and engagement that happen and what the MMHA and the updated plan may be able to assist with.

An archaeological (CRM) company that is tasked with performing the assessment is bending the law and formality of the duty to consult. They have stated that they wish to protect the client into entering an agreement with the First Nations. Communication between the client and First Nations communities can not be established as they with to be named anonymous and refuse to engage,

"[The] Proponent has not agreed to provide contact information....at this time the CRM company reminded the Proponent of the expectation among local Indigenous communities that representatives be retained as paid on-site monitors during a Stage 3 field survey".

They continue and state that the current legislation does require the private/independent corp. are not required to engage but is a suggested that they do. However, they do state that Indigenous representatives can come out for free and watch the destruction and removal of our heritage. I wish to move forward and ask that it not be suggested but required for First Nation involvement at all stages of archaeological assessments and not merely 'suggested '.

As a First Nations person and archaeologist, I find it very difficult within my profession to deal with this behaviour. The cilent and archaeology company are asking for free consultation and behalf of the community. The CRM company has, however, "recommended that all applicable Indigenous communities be granted access to the property throughout the investigation. " This tells me that they want free consultation on treaty lands and on sites that have Indigenous materials, and it be out of the goodness of our hearts that we participate.

My final point that I would like to address is when an archaeological assessment is triggered and when. I have been part of multiple site discussions that involve compromised protected sites or sites that have yet to be assessed properly.

Every municipality around the GTA seems to have a different idea of what engagement means and what is required of them for archaeological assessments. I ask that not only does this new planning ask for site assessments that have potential, but better protocols for site protection and enchment of the Ontario Heritage Act. Not every site should be excavated. Not every site has a stone foundation. Time and time again are Indigenous villages, burial sites, and early settlements completely removed. They are being removed because the money is there and and the province does seem to care about the CHVI value of First Nations' site or history. it stands in the way of housing developments, highways, and even walking paths in conservation areas. It is unfair that private housing developers hold the land title, the money, and the blessing of the province to remove the cultural heritage of another group they have no concerns about.

I hope that some of these points resonate with the current plan in development.