I am employed in the…

I am employed in the archaeological industry, and I have serious misgivings about this Bill.

Of particular concern is the amendment that would exempt certain projects from the requirement for archaeological survey. The bill is far too broad in its scope for exemptions. In addition to transit, housing, and health, the inclusion of ‘other infrastructure’ would effectively cancel the need for archaeological work to be done in this province. If implemented, this would have serious impacts. It would infringe on the rights of Indigenous peoples for prior and informed consultation. It would do damage to the preservation of Indigenous culture. It would ruin a decade-plus of work that some archaeology firms have done to improve relations and conduct surveys in the spirit of reconciliation.

The bill states that properties containing sites would not be eligible for exemption – this appears based on a fallacious assumption that we have a complete knowledge of where every archaeological site is located. We do not. There are thousands of undocumented sites in the province. The majority of these are indigenous sites, including burial grounds. Archaeological work must be conducted to ensure that the destruction of cultural heritage and the desecration of ancestral remains does not occur.

We do need updated regulations. The current Standards and Guidelines for Consultant Archaeologist has not been updated in over a decade. The Ministry of Citizenship and Multiculturalism currently uses a review process for archaeological reporting that is adversarial and broken. If the province was serious about making changes to red tape, it would take a look at how its own ministries contribute to delays in the development process. The process could become more collaborative between professional archaeologists and the regulator. There is also currently a year-long bottleneck in approving new archaeological licenses to qualified candidates. If we had more people licensed, we can do more work. More licensees means faster turnarounds for approval and an increase in the amount of land we can survey in a given season.

In addition to the archaeological concerns, the cancellation of such work would have knock-on economic impacts. I have been across this entire province doing archaeological work. We spend money many places: hotels, car rental companies, restaurants, hardware stores, lumber yards, and many other businesses both big and small. If hundreds of workers stop travelling, stop spending money – this will have a negative impact on the businesses we frequent. Given all the economic uncertainty we are currently experiencing, this province cannot afford to eliminate these jobs.

We should examine how the system can be made more efficient, but as currently written, Schedule 7 is an odious piece of legislation. As written, these proposed amendments trample Indigenous rights and eliminates jobs for hard-working Ontario residents. I would urge the provincial government to take these comments seriously and come up with something better.