Page 2 This proposed change…

Page 2

This
proposed change to the EA process does not provide sufficient protection for cultural
heritage and archaeological resources as well as ancestor burials. Removal of the
current regulations that trigger heritage and archaeological assessments in advance of
impactful infrastructure projects could leave known and potential cultural heritage
resources and archaeological resources, as well as
ancestor burials vulnerable to disturbance and destruction.
2) Lack of municipal trigger/processes in place:
The ERO listing notes: “Depending on the project and location, there may be other
legislative, regulatory and/or municipal requirements outside of the EA Act.” This
essentially states that the responsibility and onus for requiring any studies for most
infrastructure projects will be on the municipalities. The ERO statement notes that the
proposed process will “reduce duplicative requirements,” even though there is no
duplicate system for cultural heritage resources. Most municipal legislative frameworks
do not currently have any trigger for heritage or archaeological assessments in
infrastructure projects as this has always been part of the MCEAsystem. Municipal
heritage planners would not have the authority, capacity or ability to identify and address
impacts to cultural heritage resources as a result of the gaps left by the proposed
legislation.
3) Creates inconsistency and risk:
By downloading the triggers for cultural heritage and archaeological assessments to
individual municipalities, there will be inconsistency across the Province. This
inconsistency will create significant uncertainty. Further, without the consideration of
cultural heritage resources early in the process, there is a risk that key information
regarding cultural heritage resources will not be obtained by the project team until late in
the process, which will cause project delays and increased costs.