Environmental Registry of…

Environmental Registry of Ontario,

After careful consideration and analysis, it is evident that the proposed revocation of the Municipal Class Environmental Assessment (MCEA) regulations poses significant risks and challenges that cannot be overlooked. While the government may perceive this as a streamlining effort, it is imperative to recognize the broader implications, particularly concerning the preservation of Indigenous history and the livelihood of archaeologists in Canada.

The proposed revocation jeopardizes the protection of archaeological heritage and ancestral burials, leaving these sites vulnerable to disturbance and destruction. Notably, the elimination of MCEA regulations would remove crucial triggers for archaeological assessment, undermining the proactive preservation measures currently in place. This erasure of history would be a continuation of Canada's colonial history, and work directly in opposition to decolonial and reconciliation efforts in Canada.

Furthermore, the reliance on consultant archaeologists for compiling reports on archaeological potential underscores the importance of maintaining robust regulatory frameworks. Without these regulations, municipalities would face considerable difficulty in fulfilling their obligations under the Ontario Heritage Act, exacerbating the risk to cultural heritage sites.

Additionally, the concerns raised by the Chippewas of the Thames First Nation regarding the lack of consultation and consideration of Indigenous knowledge cannot be ignored. The proposed changes disregard the principles of the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) and the Truth and Reconciliation Commission (TRC) Calls to Action 43 and 44, undermining the treaty rights of Indigenous communities and disregarding their invaluable contributions to environmental assessment processes.

Moreover, the proposal's alignment with the interests of the housing sector raises concerns about prioritizing economic gains over environmental and cultural preservation. This directly opposes Call to Action 74, 75, 92, which can be found in the attached URL. By catering to private developers' cost-cutting measures, the government risks irreparably damaging irreplaceable cultural and natural heritage, perpetuating historical injustices against Indigenous communities.

In light of these considerations, it is imperative to oppose the proposed revocation of MCEA regulations and advocate for the preservation of Indigenous history and the protection of archaeological sites. We urge the government to reconsider its approach and engage in meaningful consultation with Indigenous communities and stakeholders to develop inclusive and effective environmental assessment frameworks.

Sincerely,

Jessica Watson
Archaeological Technician III
AECOM