I support the revision and…

I support the revision and updating of Ontario's archaeological approving system; however, given the impacts of the changes, the proposed amendments require further consultation with those working in the discipline, such as consultant archaeologists, proponents, and Indigenous partners, all of whom have a strong understanding of the implementation and outcomes of the Standards and Guidelines. One example of a proposed change that requires further consideration is the proposal to eliminate the Stage 1 property inspection. While the purpose is to reduce unnecessary work, the outcome of removing the property inspection will result in the opposite. Stage 1 property inspection is essential to the archaeological process as it enables strategies to be developed for further work ahead of the initiation of Stage 2 survey. The result of this is the avoidance of unnecessary Stage 2 surveys and, where Stage 2 is required, a data-informed strategy that makes the process quicker and more efficient, thus avoiding development delays. Early verification of information about the property also enables meaningful participation by Indigenous organizations early in the process, opening lines of communication and creating a path to partnership. Modernization of the Standards and Guidelines is welcome as the discipline has developed considerably since 2011; however, it is a process that should carried out in collaboration with the various parties who have knowledge of the process and are impacted by it.