Proposed changes to the PPS …

Proposed changes to the PPS (2014) will have varied effects depending on the proposed change and implementation practices arising as a result of the changes. We make the following comments with the understanding that the changes must be directed towards some specific or general desired effect.

PPS section 1.2.2: The proposed changes strengthened the requirement for planning authorities to engage Indigenous communities and coordinate on land use planning matters.

We view this change as positive. Indigenous communities should be engaged, and the Crown should also be able to become present when concerns beyond the scope of the planning or development matter that forms the basis for the engagement. It would be beneficial for the province to develop guidance on engagement for planning authorities during implementation of the revised PPS to encourage swift and meaningful uptake.

PPS Section 2.6: The proposed changes to Section 2.6.5, which states that planning authorities shall engage Indigenous communities and consider their interests when identifying, protecting and managing cultural heritage and archaeological resources is a welcome change. We trust that the province will again provide training and direction on how planning authorities can engage meaningfully and meet the spirit of the proposed wording.

PPS Definitions: The change in the definition of Areas of Archaeological Potential are generally positive, however, we are not clear on the reasons why reference to “municipal approaches’, which we understand to mean Archaeological Master Plans, has been replaced. Typically, Archaeological Master Plans are more detailed than the provincial criteria, and integrate more local information. Overall, we view this change positively.

In terms of the overall direction indicated by the proposed changes, we are concerned that the ministry has signalled a significant change by placing cultural heritage and archaeology in a category of concerns headed ‘Reducing barriers and costs’, and removing it from the category of ‘Protecting the environment’, a desirable objective.

Cultural heritage and archaeology is of the environment, clearly stated in the Environmental assessment act (“any building, structure, machine or other device or thing made by humans”). It is, therefore, no more a cost or barrier than fresh air or clean water. We would also refer you to the definition before the one quoted, which includes “the social, economic and cultural conditions that influence the life of humans or a community”. Communities seek out heritage values as touchstones, buildings that make neighbourhoods unique, or sites with remains representing the lives of ancestors are important to many of us.

By casting cultural heritage and archaeology as a cost and barrier, an agenda is suggested, and I hope that this is not the intent.