I don't believe these…

I don't believe these proposed amendments are a good idea. Especially the "Exemption for Property" change. Making changes for the sake of efficiency almost always compromises integrity. Allowing the Lieutenant Governor in Council to make decisions on what projects should have assessment opens the door to potential cronyism. It also leads to the impression that those in charge already have made decisions on projects without analysing the data. Allowing projects to fast track the archaeology process is an attempt to avoid collecting data in the first place that could be used to argue against the fast track. I believe that the Ministry recognizes there is a backlog of projects in the archaeology clearance pipeline and they think this is the way to clear this backlog. I disagree. Deciding not to do archaeology on a project doesn't mean the cultural or heritage concerns for a project disappear. Proponents may think this is the case, and the Ministry may hope that this is the case, but it doesn't make it true. I believe that the Ministry created this backlog situation themselves by not properly supporting the regulatory aspects of heritage management. Mandating less archaeology is not a way to fix that problem.

This proposal also seems poorly planned out from a First Nations consultation perspective. Have you consulted with First Nations on these amendments? I assume not. The fact that right out the gate you are avoiding consultation on this matter tells me the amendments can be used to avoid consultation on the projects themselves.

The proposed amendments also address inspections and artifact collections. I do believe the Ministry needs to deal with the situations and changes need to be made. However this needs to be done with true consultation of FN and archaeology community, not just using a 30 day comment window.