As a Professional…

As a Professional Archaeologist in Ontario, I find this incredibly disturbing for a number of reasons. Primarily, it is not the actual physical archaeological work that is holding up projects, it is 1) the insistence of the government to not to follow established, appropriate and required Indigenous Engagement protocols, which delays project start-up/execution, and 2) the mess the government has made in the report review process internally at the Ministry of Citizenship and Multiculturalism (MCM).

How will this take into account the Indigenous Nations? This government has continuously tried to avoid their Duty to Consult with Indigenous Nations to advance projects and exclude them from any land-use planning processes, which in turn eventually results in numerous unnecessary delays. Has this act been evaluated taking into account Article 11 of UNDRIP and Section 35 of the Constitutional Treaty Rights of Indigenous Peoples?

The system for reviewing archaeological reports in this province is broken. The Archaeology Division’s current approach is obstructing the very purpose of its existence by prioritizing internal bureaucratic processes over meaningful heritage outcomes. The review officers are working through a backlog of reports that have been in the queue for 5+ years and are either not reading them, making errors, or are retroactively applying current understandings/practices of what is acceptable by the MCM under the S&Gs onto these reports that have sat unreviewed for years, resulting in many reports unnecessarily sent back in error, causing risk to license, additional delays in process, and further uncertainty/inconsistency in the MCM review process. The result is a crisis that is undermining the integrity of the licensing process, delaying critical infrastructure and housing projects, and eroding public trust in heritage conservation in Ontario.

Some questions:
How and by what criteria will project exemptions be established?
Who will ensure that the exemptions are not provided to friends or supporters of the government?

This violates the principle of procedural fairness, and virtually every proponent in the industries mentioned in this Bill will be seeking an exemption. Instead of removing the work entirely (which is a completely ridiculous proposal) can the government not look to make the process more efficient at MCM? Consultant Archaeologists in Ontario have been demanding better of the MCM for years, voicing concerns and providing suggestions to make the system more efficient/effective that have consistently been ignored or dismissed.