I find it very disappointing…

I find it very disappointing that the current proposal was not shared more widely with the archaeological and Indigenous communities prior to the posting of this ERO, to engage in that space for meaningful consultation and feedback. There were only a few in-person meetings with Indigenous communities and even less in-person meetings with professional archaeologists.

While the existing 2011 S&Gs have serious flaws and require revisions and updates, the current proposal fails to make the necessary targeted changes that would streamline and modernize the archaeological assessment process. Instead, the planned changes create unnecessary confusion and chaos, conflict with other legislative and planning processes, risk impeding development and infrastructure projects, and threaten Ontario’s valuable archaeological resources.

The updates do not address the lack of Indigenous consultation early in the archaeological process which is contradicting to the Provincial Planning Statement (2024):

Policy 6.2.2 instructs planning authorities to coordinate planning matters with First Nations and requires that: “Planning authorities shall undertake early engagement with Indigenous communities and coordinate on land use planning matters to facilitate knowledge-sharing, support consideration of Indigenous interests inland use decision-making and support the identification of potential impacts of decisions on the exercise of Aboriginal or treaty rights.”

Policy 4.6.5 holds that: “Planning authorities shall engage early with Indigenous communities and ensure their interests are considered when identifying, protecting and managing archaeological resources, built heritage resources and cultural heritage landscapes.”

This short ERO period does not provide space for meaningful consultation on the proposed changes with the people it will affect the most. For example, the proposed changes to the Stage 1 process and removal of the site visit puts the new standards in direct conflict with existing processes and legislation outside of the APU (Municipal and Provincial Environmental Assessments, planning and feasibility studies). We are deeply concerned about the confusion that the implementation of this document will have on the 2026 field season, and we urge the HFT team to reconsider this deployment.

As an Ontario resident I request that these proposed changes to the Standards and Guidelines for Consultant Archaeologists are not implemented until they have been sufficiently workshopped with archaeology industry professionals and Indigenous communities and First Nations.