As a professionally licensed…

As a professionally licensed consultant archaeologist working in Ontario for over 20 years, I am submitting the following feedback and concerns about the updated Standards and Guidelines that were posted on the Cultural Heritage industry on March 6th, 2026.
To begin, in the first part of the updated Standards and Guidelines for Consultant Archaeologists there is a bizarre exemption of assessments on partial parcels of land for projects that meet the criteria for “linear corridors” and “limited small-scale impact” projects. Many projects triggered by the EA Act will be affected by these definitions.
The criteria listed to define what a “linear corridor” is in Table 1.1 will not correctly apply to many projects triggered by the EA Act, especially new highway corridors. Consistency in continuous linear width, less than 20 metres wide, and at least 50 times as long as it is wide is very strange and restrictive criteria. Many linear corridors are not 50x longer than their proposed width. What is the rationale for including this random ratio as a descriptive criterion?
As stated above, new provincial highways won’t apply here. Maybe some LRT or subway transit corridors will, but the definition cannot capture all other linear corridors. Overall, these criteria are obstructive and can impact the efficiency of archaeological assessment on portions of parcels based on the limit of impacts. This exemption will likely result in a requirement to assess larger areas than necessary/impacted, which will in turn increase budget and project delivery schedules. These criteria seem to be solely aimed at projects under the Planning Act or a narrow selection of projects that are triggered under the EA Act.

For “limited, small-scale impacts”, it is worth noting that public sector proponents also undertake limited assessments and to have a criterion that only privately-owned lands can be subject to limited assessments creates inconsistency across the S&Gs and may create unnecessary confusion and dispute between proponents and their archaeological consultants.

Stage 1 Background Study (& optional Property Inspection) Update:
• The updated S&Gs have removed the Optional Property Inspection from Stage 1 Background Study assessments which is not a practical decision and in fact is a regressive action.
Stage 1 analysis describes the assessment of archaeological potential as requiring “a clear description of all features of archaeological potential noted for the project area” and “a detailed assessment of the project area’s archaeological potential.”
How exactly are these two components of Stage 1 supposed to be established without a property inspection initiated BEFORE Stage 2 is recommended or the additional need for several of the Guidelines for evidence to actually be Standards?
Either the threshold for Stage 1 analysis is high (requires a lot of evidence both archival/historical and physical) because you want to accurately screen out potential with a Stage 1 Background Study and a required Property Inspection, or the threshold is low because the Stage 1 Background Study simply comprises a desktop survey with a few basic details that can indicate potential but may not actually do such, thereby always triggering a Stage 2.
Several of the Guidelines listed for additional evidence in a Stage 1 should be required elements if you do not want to completely neuter the efficiency and accuracy of a Stage 1 study.
A robust Stage 1 study helps inform the consultant archaeologist and proponent about what potential may or may not exist. For the consultant, it also gives them the ability to more effectively later analyse field data (artifacts and cultural features), archival history and land-use history. These components are required in later Stages but they should also be completed as early as possible in Stage 1 to create a modicum of foundational site knowledge. Right now, few licensed consultant archaeologists are exhibiting a proficient ability to conduct effective research and combine it with artifact analysis and site formation processes. It is revisions like the ones implemented that are contributing to their inability to link information and think critically.

Removing the Property Inspection component also makes Stage 1 Background Studies an ineffective tool for land use planners in both the public and private sectors. As a result of shifting property inspection to Stage 2, these next-stage assessments will be triggered more easily, occur significantly more often, and increase the administrative burden for archaeologists and their proponent clients. Taking out separate PIFs for Stage 1 Background Studies and then a separate Stage 2 PIF to simply document property conditions (as opposed to undertaking a full Stage 2 property assessment which a Stage 1 could have screened out the necessity for) creates dysfunction in the flow of the staged archaeological process.
The proper update here is to make Stage 1 Property Inspections be required (not optional) where possible (i.e. there is Permission to Enter from proponents who own the project properties or have current property owner permissions). And if not possible, an explanation as to why it was not possible should be put into the report.
Combined Stage 1 & 2 assessments should still be permitted to occur as a single assignment/report deliverable under one PIF. This is what makes the most sense for efficiency. What the update proposes is an adverse impact to project timelines and may increase budgets and prolong schedules for archaeological clearance in both public and private sector development.

• An additional problem noted for the updated Stage 1 standard is that the reporting is still requiring images to support the analysis, conclusions, and recommendations of the research. Note: Images refers to photographs whereas Plates are maps.
What images are to be provided if a property inspection is not undertaken?
For example, Google Earth aerial images typically only extend back to the mid-1980s, and images from that era are so blurry that they cannot effectively be used as supporting material for literary or oral references. Twentieth century historic aerial images are also not consistently available in all places or for a range of decades to illustrate land use changes. Their resolutions (i.e. the flight altitude/height from which the pictures are taken) may also vary significantly, making them somewhat ineffective as evidence for land use changes over smaller project areas.

Overall, the proposed update for Stage 1 is disadvantageous and should not be put into effect.

Stage 3 Site-Specific Assessment:
• Regarding the continuation of temporary Avoidance and Protection strategies for archaeological sites in Stage 2, Standard 1:
Are all sites to be subject to a 20-metre protective buffer after Stage 1? How can this be done if property inspections aren’t permitted? Is it only for sites that are already recorded, retain CHVI, and must be further investigated before clearance?
Other sections of the document still suggest the currently used 10- and 20-metre buffers be applied depending on the type of site identified. This contradiction needs to be clarified.

Other Comments/Questions:
• Can a Preliminary Excavation Report (PER) be prepared for other Stages of the Archaeological Process? For example, after a particularly large Stage 3 site-specific assessment where post- field excavation activities like artifact analysis, interpretation, and cataloguing will take a particularly long period of time?
MCM should consider this and make a more consistent standard for the use of PERs.

• Clarification on whether PIFs taken out prior to the finalization of the 2026 Standards & Guidelines can still follow the 2011 S&Gs. If not, a significant amount of reworking field strategies, budgets, and schedules will have to be undertaken across the industry on multiple projects in the private and public sectors.

New Glossary entries:
Several new glossary entries were added to the updated S&Gs. Several of them are poorly written to the point that the definition is not clear and concise.
The following entries must be revised:
• Chisel plough: -- other ploughs should also be defined in the glossary. – particularly mould-board and disk ploughs.
• Construction monitoring: should specify that it involves observing machine excavation undertaken by constructors, not archaeologists.
• Inspection: - It should be “Property Inspection” as related to Stage 1 because it identifies archaeological potential.
• Linear corridor: A project area which is substantially longer than it is wide.
– see above comments for why the definition and its later expanded description do not correlate.
• Midden: - refer to an archaeology text book for a better description. I
• Post-contact period: Why is contact period which falls between the pre- and post-contact periods not included as a definitive time period?
• Pre-contact period:
• Stratigraphy:
• Survey transect: This should be related back to “archaeological survey” and describe that it is observations taken on a regular grid laid over a property. It is also not only used for test-pitting or pedestrian survey but also geophysical surveys, etc.

The application of these new Standards and Guidelines requires consultation with the Cultural Heritage industry which includes Ontario’s Archaeologists, Heritage Planners, and Indigenous Communities.
Releasing new updates that have never been discussed, edited, or agreed upon amongst the professionals who are required to use them, one month prior to the opening of the 2026 field season is incredibly irresponsible and has high chances of causing bureaucratic chaos on the successful advancement and completion of the season’s work schedules.
It is evident from the changes made that representatives from the government’s own consultant archaeologists, consultant archaeologists working in the private sector, and those working for Indigenous Communities were not at the table or part of the committee that created these updates. Assigning non-technical expert policy wonks to write new or updated Standards and Guidelines for an industry they are not educated in, are not employed in, nor truly understand, is laughable. Reading about archaeology is nowhere near equivalent to understanding the working conditions, business practices, and bureaucratic problems within the industry. The system is not perfect but many of these current changes help to further degrade it.