There is no indication that…

There is no indication that First Nation engagement has been sought or achieved with these amendments.

New section 66.1 to exempt properties from assessment, has the potential to reduce assessments to a point that very few, if any, previously undocumented sites would be identified and many sites would be lost. The proposed authority of the Minister to make an “assessment order” or an “inspection” order for the “purpose of assessing”, is useless if it is dependent on a report provided by an unknown person (eg a passer-by) and would not be fast enough to stop an exposed site from being destroyed. Who do they propose would be the watchdog for undocumented sites? Or if no assessment is to be conducted, who will advise whether a previously registered site is within the study area?

Concern re housing development or infrastructure exemption – what would be the criteria? Would only large projects be exempted, with greater potential for site loss? Would a one or two house plan or severance still need an assessment leaving that burden of cost on an individual?

Section 66 re collections: is there any compensation provided to the museum/public institution or Indigenous community to prepare & maintain suitable artifact collection facilities, as financing the long-term housing of collections is the major stumbling block in their being transferred to such facilities, including the costs for a licensee to effect the transfer and the costs for the facility to maintain the collection. There is little point in saying the Minister shall have power to direct if there is no appropriate facility to accept the collection or funds to complete the transfer (eg the archaeologist is required to pay to place artifacts in the Sustainable Archaeology McMaster or Sustainable Archaeology at the Museum of Ontario Archaeology and this cost burden cannot always be transferred to the development project costs but is carried by the individual licensee)

New Part VI.1 “mandatory production orders for documents or data that may provide evidence of an offence” – the phrasing “may provide evidence” sounds like just fishing for offences and a potential cause of undue stress and hardship with no chance of compensation.

The government could greatly speed up the archaeological assessment process and reduce the red tape if the Ministry were allowed and encouraged to spend less time in detailed report reviews from their licensed professional body and more time being accessible for advice and for site visits when appropriate. If the government has a fund by which an individual (ie not a company, governing body or organization) could receive compensation for mandatory archaeological assessment costs on their own private property then that would also be a benefit to include in the OHA.