I have concerns regarding…

I have concerns regarding the lack of duty to consult on the part of MTCS in archaeology when it comes to Indigenous issues. There is a huge difference between engagement and consultation.

The main concern that ministries have been and will continue to, determine how best to address their duty to consult responsibilities within their mandates and legislative and regulatory frameworks.” From what I have observed over the years is that each ministry has their own interpretation of what this process is. There is no consistency across the board for example MTCS and MNDM. The problem is - is that the MNDM does not feel that they have to do any assessments (archaeological or environmental) before an Advanced Exploration – which is basically when the mine goes in. The problem is that at the very early stage of “Prospecting and Staking” and “Grassroots Explorations” that prospectors usually are doing: drilling, mechanical stripping, trenching and stripping. Although these activities seem minimal in terms of an open mining operation they are HUGE risks for archaeological concerns as well as environmental concerns. MTCS – There are various triggers that are set off at the MTCS Archaeology Unit that would require an archaeological assessment (i.e. proximity to water, proximity of known archaeological sites, terrain features, etc…). If you send a map of the area of the mining claim to the MTCS (but don’t tell them it is a mining claim) and ask if an assessment needs to be done in that area because of concern for cultural resources. Then they look up in their database and advise whether it is needed or not. Even if the MTCS recommends that an archaeological assessment needs to be completed, the MNDM claims they do not need to do assessments until “Advanced Exploration.” This is just one example which is problematic for First Nation Consultation. It seems that guidelines for them to incorporate into existing consultation protocols that each ministry, are being ignored or overlooked if they are not copacetic with their existing policies. This is a major concern that the ministries are not on the same page when it comes to interpretation and policies of consultation/accommodations. Maybe the Ministries should be in the engagement process because some do not understand the consultation and accommodation process

[Original Comment ID: 211299]