It's unclear why a property inspection (formerly an option during Stage 1 assessment) to confirm current conditions within a project area, which assists in evaluating and determining archaeological potential, has been move to a Stage 2 activity.
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The current requirements for receiving an archaeological license are exclusionary of academics whose field experience and expertise different from CRM; the language of the bulletin does not even account for or include them, presenting archaeology as a static resource rather than the cultural belongi
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The need to overhaul and update the archaeology act is needed :
Unfortunately this Act totally fails to address right of private property ownership - especially lands owned fee simple - and the alternative land ownership, which are Crown Lands.
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Is private property Ceded Land? If so then how can a Native Land claim for a archaeological dig be valid. More over who ever is claiming interest should also pay for what ever kind of assessment that is being done.
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Unbelievable... So you didn't listen to a single thing from First Nations or the folks who actually work in this industry. You are creating more bureaucracy and red tape! This will slow everything down. Just wait and see. Good luck on Treaty lands! Absolutely asinine this is.
Page 52, Continuing temporary avoidance + protection of sites: states protected are must consist of the site limits plus a 20m protective buffer where Stage 3 AA has been completed.
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Moving property inspections to Stage 2 doesn't make any sense; especially for northern Ontario. Recommendations can't be made without verification, so Stage 2 is basically always going to be recommended in order for a client to be able to do anything with their property/development.
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In regards to an Archaeological assessment, there needs to progressive controls implemented to allow Municipalities and developers to advance a project , while still maintaining impact controls for a development.
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This proposal should include changes to the application process for new licenses in Ontario Archaeology.
Currently the requirement for an applied research license is a degree in archaeology or area of archaeology, with proof of degree saying archaeology.
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A review of the draft 2026 Standards and Guidelines for Consultant Archaeologists highlights several deficiencies and practical gaps when applied to Municipal Class Environmental Assessments (Class EAs), particularly for long, linear corridor projects that frequently exceed 20 m in width.
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I have the following questions and comments:
• Will the 50 m protective buffer after Stage 2 be applied retroactively to current sites?
• Will the 20 m protective buffer after Stage 3 for partial clearance be applied retroactive to current sites?
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Fundamental misfit between Class EA corridors and “project area” logic
The 2026 draft replaces the long standing concept of “property” with “project area”, requiring archaeologists to precisely define and justify the spatial limits of assessment at the PIF stage.
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The 2026 draft introduces formal “limited assessment” standards for Stage 1 and Stage 2 work, intended to streamline smaller or discrete projects.
Deficiency for Class EAs
While helpful for small footprints, these standards:
• Are designed for contained areas, not linear systems
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Once corridors exceed ~20 m, which is typical of many Class EAs they begin to resemble developable parcels, triggering more work/recommendations:
The 2026 standards:
• Provide no scaling logic for width vs function
• Provide contradictory definitions of corridors in Table 1.1. and glossary
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It's unclear why a property…
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Heritage Framework Transformation: Proposals related to Ontario’s Archaeology Program, including targeted changes to the Standards and Guidelines for Consultant Archaeologists
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183047
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The current requirements for…
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Heritage Framework Transformation: Proposals related to Ontario’s Archaeology Program, including targeted changes to the Standards and Guidelines for Consultant Archaeologists
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The need to overhaul and…
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Is private property Ceded…
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Heritage Framework Transformation: Proposals related to Ontario’s Archaeology Program, including targeted changes to the Standards and Guidelines for Consultant Archaeologists
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183121
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Unbelievable... So you didn…
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Heritage Framework Transformation: Proposals related to Ontario’s Archaeology Program, including targeted changes to the Standards and Guidelines for Consultant Archaeologists
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Page 52, Continuing…
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Moving property inspections…
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Thank you for the…
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In regards to an…
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This proposal should include…
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Modernizing Ontario’s…
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Any changes should be done…
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Implications for Municipal…
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A review of the draft 2026…
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I have the following…
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Fundamental misfit between…
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The 2026 draft introduces…
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Once corridors exceed ~20 m,…
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Changes that will result in…
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