This short ERO period does…

This short ERO period does not provide space for meaningful consultation on the proposed changes with the people it will affect the most - the consultant archaeologists, proponents and Indigenous communities.

While the intent of the proposed 2026 updates appears to be streamlining and modernization, several changes raise significant concerns.

The removal of the Stage 1 property inspection is a substantial concern, as this early field-based review has long played a critical role in accurately characterizing archaeological potential at the outset of a project. Although inspection-related requirements have been shifted to Stage 2, the absence of an early site visit limits the consultant’s ability to validate background research findings and identify obvious disturbances or sensitivities before formal recommendations are made.

Without an initial site visit, Stage 2 assessments are more likely to be recommended by default as a precautionary measure, even in situations where on-the-ground conditions may not warrant them.

The Stage 1 site visit has historically functioned as a cost‑effective risk management tool, allowing for early refinement of recommendations and, in some cases, reducing the scope or need for more invasive investigations. Its removal undermines this efficiency and shifts unnecessary burden later into the project lifecycle.

Limited and small‑scale assessments raises significant concern, particularly from a municipal environmental assessment perspective. As currently framed in the proposed 2026 updates, these assessments do not appear to be well tailored to the requirements, processes, or objectives of municipal Class Environmental Assessments.

Municipal EAs are designed to evaluate alternatives, assess environmental effects at a corridor or area-wide scale, and consider long-term and cumulative impacts on cultural heritage, land use planning, and the natural environment. In contrast, limited and small‑scale archaeological assessments are narrowly scoped to discreet development footprints and short-term impacts. This disconnect creates challenges for municipalities attempting to integrate archaeological findings into EA decision-making, particularly where projects are phased or linear, only impacted small portions of a property.

To better support municipal environmental assessments, limited small‑scale assessments should be revised to more clearly acknowledge municipal EA frameworks.

I respectfully request that the proposed changes to the Standards and Guidelines for Consultant Archaeologists not be implemented until they have been meaningfully workshopped with archaeology industry professionals and Indigenous communities and First Nations. Proceeding with a full rollout of the updated standards without any form of pilot program, trial period, or phased implementation is problematic and risks unintended consequences for project delivery, cultural resource protection, and regulatory consistency. Adequate consultation and practical testing are essential to ensure the revised standards are workable in real‑world conditions, responsive to diverse project contexts, and aligned with both professional practice and Indigenous interests.