I find this Bill very…

I find this Bill very concerning. What happens when the appropriate archaeological or burial investigations are not conducted for a specific project and then during construction they disturb or completely destroy either an archaeological site or a unknown burial? Who then is to blame? How will the government account for the destruction of these sites that would have potentially been identified, excavated, or protected and avoided? A streamlined approach or "fast track" to conducting archaeological investigations may well be necessary for certain projects, but this can be accomplished by working with the Ministry of Citizenship and Multiculturalism and developing an updated set of Standards and Guidelines for special circumstances that does not eliminate Stage 1 and 2 archaeological assessments, but offers more opportunity to forgo Stage 3 and 4 assessments if the project is critical in nature and the site discovered does not meet the new special criteria. A recommendation of construction monitoring by an archaeologist and interested Indigenous Communities for all site areas should be mandatory after a site has been identified, but not given enough importance to qualify for a stage 3 assessment under those new rules. In this way, the government can fast track less important sites, but do its best to guarantee that sites and potential burials are not missed. If something of importance is unfortunately discovered, then the the default would be to revert back to the original S&G's and the archaeological process would take its normal route.

I think this route would require the least amount of change and upheaval, and the standards and Guidelines are outdated (2010) and in desperate need of a revamp anyway. Leave it in the hands of the MCM and interested stakeholders to work out, with an emphasis on special conditions for fast tracking projects that the Lieutenant Governor deems "important", but with a very tight descriptions of what qualifies as important or critical, so that this legislation does not get abused. A lot of work has been done over the last 10 years with regard to improving Indigenous relations and building up trust in the archaeological process and with the government. Introducing this Bill as it currently stands would undo all of that and would be met with serious litigation and protest from the FN groups as well.

Sincerely,

- an archaeologist who values compromise, lives in the real world, and who can see both sides of an issue.