There are many issues that…

There are many issues that are to be highlighted with this new draft of these standards for LCA’s to follow. Here are some concerns:

Stage 1 Assessments
How is it possible to assess in detail the project area's archaeological potential without having to visit the property? That is the point of the initial assessment. How can archaeological potential can both be confirmed and eliminated based on the use of air photos, but when it is possible, no field work (i.e. property inspection) is allowable to be able to confirm first hand the condition of the property, even though one of the requirements through the Stage 1 work is to describe in detail the conditions of the property and to identify areas of archaeological potential. This amounts to the easy erasure of archaeological potential in northern Ontario.

Stage 2 Assessments
The audacity that it states in these standards that, “The licensed consultant archaeologist may engage with relevant Indigenous communities to determine their interest (general or site-specific) in the Indigenous archaeological sites found during Stage 2 and to ensure there are no unaddressed Indigenous archaeological interests connected with the land surveyed or sites identified. When will it say you MUST consult with First Nations when there is an assessment that it taken out on there lands? When will it say you must competently engage with Indigenous groups in a meaningful way when lands are proposed to be developed before Stage 1 assessments are taken out? There is an inherent problem with what the MCM, LCA’s and Indigenous people might consider as relevant material. To the MCM, and with these standards, some of the parameters are similar in their structure to the previous S&G's, but are truly defeating when we think of reconciliation and the Duty to Consult with First Nations. Such are selfish and colonial. It is crime and bending of the inherent rights of First Nations to try and state that only after we have done work in Stage 2 will we consult you.

Stage 2 assessments and Stage 3 assessments should be conducted in their own separate reports and not together. By doing so, you are reducing the ability for the involvement of First Nations. As previously mentioned, “Stage 3 controlled surface pick-up (CSP) may be completed during Stage 2, following Section 3.2.1”. What is the point of having separate stages when you are trying to combine them?

There is nothing TRANSFORMATIVE about this framework, except the ability for the MCM to figure out how to change the font from the new draft of these guidelines. If we imagine a transformative process, we could look to a process to that of the caterpillar, to a chrysalis, to a butterfly. By comparison these recommendations would be comparable to a healthy caterpillar to a sickly one, starving of sustenance due to the poisoning of the locale environment.

There are no mentions of penalization for not following the rules to these standards by bad faith actors of proponents, or LCA’s. There are no mentions about the Duty to Consult, reconciliation or UNDRIP.