1. Proposed changes to the…

1. Proposed changes to the Standards and Guidelines for Consultant Archaeologists
These proposed changes to the Standards and Guidelines are for the most part poorly planned and will not achieve the stated goal of streamlining assessments. Most of the changes introduce further uncertainty to the archaeological process that will lead to additional delays and additional expense to developers and municipalities undertaking the assessments.

Selected specific comments on the Draft 2026 S&Gs:
Table 1.1. "Linear corridors must be less than 20 m wide."
A standard road allowance width in Ontario is 66 feet wide (20.1 m) which excludes all road improvement projects or new road development projects as being 'linear corridor' projects. This makes no sense.

Page 11: "When assessing the archaeological potential of a project area, the licensed archaeologist will not use checklists or other tools designed for nonspecialists for determining whether to trigger an assessment."
Why not - what is the justification for this limitation? If the checklists or other tools are sufficient for non-specialists to determine the archaeological potential of an area, why should they not also be used by LCA when determining the archaeological potential of an area?

Page 11: "previously identified archaeological sites within or in close proximity to the project area". The existing S&Gs indicate that archaeological sites have a buffer of 300 m, within which all lands have general archaeological potential. By removing the stated distance and changing it to 'close proximity' uncertainty is introduced to the process that will lead to project delays for developers.

Page 31: "2. Any artifacts that are located less that 20 metres apart must be considered part of one archaeological site."
Why? This is not standard archaeological practice and it is bad archaeological practice to insist on this artificial lumping of what might be culturally or temporarily distinct sites. If this change will be made it must be justified to professional archaeologists by providing the underlying archaeological theory that is the basis for this change.

Page 102: Stage 1 reports are supposed to: "Provide images to document features indicating archaeological potential, to support the analysis, conclusions, and recommendations, and to assist in understanding the maps." How is this possible when the new S&Gs do not allow Property Inspection in Stage 1?

There is no longer a defined 'monitoring buffer' in the draft S&Gs. A defined monitoring buffer is necessary to provide clients and CLAs with certainty as to when licensed archaeologists must be on site to confirm avoidance and protection strategies are successfully implemented.

2. Proposed Criteria for Evaluating LCA Compliance
The major problem with the proposed criteria for evaluating LCA compliance is that is dependent on the assessment of archaeological reports by AROs who misinterpret the Standards and Guidelines they are meant to be reviewing against and lack archaeological knowledge and expertise. It is simple for an ARO to reject a report for a typographical error which puts a LCA out of compliance with the S&Gs but this does not indicate that the LCA is not a competent archaeologist. The APU currently does not answer telephone calls from LCAs and does not offer timely advice when requested, meaning that they do not provide necessary guidance for LCAs when conducting fieldwork. This leads to LCAs unwittingly working under an interpretation of the S&Gs that an individual ARO might not share and will subsequently reject during the report review process. This lack of service from the APU is the most significant delaying factor in the archaeological process in Ontario - it is not the compliance LCAs that needs improvement, rather it is the service that LCAs receive from the APU that needs improvement.