The consolidation of a…

The consolidation of a number of policies into consistent direction with respect to licensing and applications under the Aggregate Resources Act is, generally, a worthwhile proposal. Specific to the proposed Cultural Heritage Policy, the language mostly aligns with other provincial mandated processes such as the Environmental Assessment Act and the Planning Act. One specific area the proposed Cultural Heritage Policy does not align with is in regards to Indigenous engagement in archaeological and cultural heritage activities. Both the Planning Act (through the Provincial Planning Statement) and the Environmental Assessment Act (through specific EA policies) have amplified the requirements to engage with Indigenous Nations beyond the minimums represented in the individual Ministry of Citizenship and Multiculturalism (MCM) screening checklists referenced in the Cultural Heritage Policy and the MCM Standards & Guidelines for Consultant Archaeologists. To remain consistent with overarching provincial policy direction, the Cultural Heritage Policy should include language requiring Indigenous engagement in completing the individual checklists and any resulting archaeological assessments and/or heritage studies. This direction should specify that this engagement be conducted early in the process and may be included as part of overarching consultation programs conducted by the applicant and/or conducted by Consultant Archaeologists or Qualified Persons (QP) retained by applicants.