Hello, I'm a professional…

Hello, I'm a professional archaeologist currently working in CRM in Ontario. I am going to address a few key points of the proposal that worry me and offer some alternatives to MCM that might be able to achieve the objectives of this proposal without jeopardizing Indigenous relations, Ontario's heritage, and the jobs of thousands of skilled workers.

Exemption of Property: The ability to exempt properties by the Lieutenant Governor according to unspecified criteria for eligibility will effectively render all properties subject to exemption from OHA legislation. The wording for provincial priorities that may warrant exemption, in particular, "other infrastructure or such other priorities as may be prescribed," is also deliberately vague in order to make the decision entirely up to the discretion of the Lieutenant Governor.
The proposal also states that among the few things that may prevent exemption are, "Indian Residential School sites, burials and significant archaeological sites." I would like to know how the precise location and significance of an archaeological site or residential school can be determined without an assessment occurring in the first place, also what criteria determine the "significance" of a site?
This amendment is overwhelmingly bad for archaeological and heritage consultation, featuring vague language intended to circumvent proper consultation at the provincial government's discretion to the province's detriment as a whole.

The other amendments ostensibly can expand provincial authority to ensure compliance with the OHA on part of licensees, property owners, and developers. While no explanation is given as to exactly how they may be implemented, they could help ensure compliance. Namely, the ability and a willingness to fine licensees, property owners, and developers goes a long way towards meaningfully protecting Ontario's heritage by holding perpetrators accountable. The revenue from this can be used to offset the costs of consultation as well.

If the objective behind this legislation is to streamline the archaeological consultation process, I know plenty of licensed archaeologists here with long lists concerning how to achieve that, try asking them first.
The greatest time and money wastage happens within the MCM. The process of renewing licenses is bloated and dysfunctional. I know many licensees who have waited over a year to have their licenses renewed, longer for approval in the first place. Instead of having MCM's limited staff wasting time with renewals, they can use it to review and approve reports faster. Furthermore, I would suggest ensuring licensee compliance in the same way as BC's archaeological regulator does: regular field audits and the willingness to revoke licenses for infractions. In fact as it stands there is little in the report review process to ensure licensees are compliant whatsoever; there is nothing to guarantee any information in the report reflects the actual archaeology if you do not confirm the completion and quality of fieldwork in person. Should the quality of archaeology not meet the OHA's standards, then it is justified to either give a warning to the licensees in charge, or revoke their licenses.

Is risking thousands of skilled jobs in heritage and environmental consultation really how the MCM plans on "unleashing the economy?" With the financial stresses already being put on Ontarians, I expect a lot of unemployment and the exacerbation of economic downturn to follow.