Changes that will result in…

Changes that will result in cost and time savings for applicants are welcome by the Township of Alnwick/Haldimand. We have heard from applicants that they are frustrated with the length of time it takes for an archaeological assessment to be reviewed by MCM, and ultimately entered into the Ontario Public Register of Archaeological Reports. Receiving confirmation that an assessment is entered into the Register is key for the Planning Department to have confidence that the report was completed in accordance with the Standards and Guidelines for Consultant Archaeologists.

An update to the "Criteria for Evaluating Archaeological Potential: A checklist for the Non-Specialist" would be welcome. In reviewing the checklist with potential applicants, it is apparent that there are varying interpretations when answering Question 8. A better description on what 'extensive and intensive disturbance' means would be helpful in providing clarity and to avoid misinterpretation.

It would be helpful if training sessions were provided for Planners to ensure consistent implementation of Section 4.6, 3 of the Provincial Planning Statement and the "Criteria for Evaluating Archaeological Potential: A checklist for the Non-Specialist" . Training could provide direction on proper implementation of the policies and a better understanding of how to identify archaeological potential.

Providing discussion in the introduction under the heading "Archaeology in the Context of Land Use Planning and Development" to clarify that development requires an application under the Planning Act may help manage expectations. We have been questioned as to why an archaeological assessment was not completed when construction on a property with archaeological potential did not require an archaeological assessment. Applicable law relating to Building Permits does not provide a mechanism to require an archaeological assessment. Adding a definition of 'development' to the glossary may also be helpful.

We have heard from applicants, particularly residents with small scale developments (minor variances, consents), that the cost of assessments are beyond what they can afford. These situations involve the discovery of artifacts which triggered the requirement for a Stage 3 and 4 archaeological assessment to be completed.

There is one situation where artifacts were unknowingly uncovered and the property owner is now in a position of not having the financial resources to continue. This will result in them not being able to move forward with improvements to their property (cottage addition and new septic system). The property is quite small making it impossible to meet the Stage 4: Mitigation of Development standards of protected 10 m or 20 m protected buffer zones to be applied to an archaeological site. The province should consider providing funding opportunities for property owners so they have the ability to address the proper protection of archaeological resources

Part VI of the Ontario Heritage Act protects archaeological sites, making it illegal to knowingly disturb them unless one is a licensed archaeologist. Through planning application reviews and fielding inquiries, it appears that the general public is not fully aware of this requirement. Providing education materials in a plain language format to educate the public on their legal obligations would be helpful.

Section 4.6, 4 of the Provincial Planning Statement encourages planning authorities to develop and implement archaeological management plans for conserving archaeological resources. An archeological management plan outlines when archaeological assessments are required for public and private projects and provides data to help determine when a property or area has archaeological potential. It would identify policy and regulatory changes and implementation tools the municipality could implement to better address provincial policy direction for protecting archaeological resources. Financial resources would be necessary to engage an archaeologist to create an archaeological management plan. It is expected that the development of the plan would include engagement with First Nations, the development community and the public. The province should consider providing funding opportunities for municipalities for the creation of archaeological management plans.