To Whom it May Concern, I,…

To Whom it May Concern,

I, an Archaeological Field Technician in Ontario, am writing this letter to comment on the new Proposal to ‘Modernize’ Environmental Assessments for infrastructure. The proposal is meant to modernize infrastructure, to help Canada grow? How can you claim to be on the side of Canadians when Indigenous Canadians go without a voice in the matter. You can not claim to be doing this for the good of Canadians when you propose a decision that flies in the face of the UNDRIP and the TRC. This is not ‘modernizing for infrastructure’ , this is demodernizing. The proposal completely disregards Indigenous voices. This is not meaningful engagement. This is not even the bare minimum. “Increased Efficiency” should not be the priority when building Canada's infrastructure, ALL Canadians should be the priority, you can’t claim to be building a stronger infrastructure for Canada when this proposal completely takes Indigenous Canadians out of the conversation.
Not only that, but you are excluding them from something that directly affects their lives, their culture and their history. In the past the Government of Canada has tried to silence Indigenous voices in a multitude of ways, because of this it is so important that Indigenous Canadians are heard and involved in the conversation. This does not mean just ‘consulting with’ First Nations. Meaningful engagement means they get a say in the matter and there is enough time given to address their concerns properly and to the best of our ability. Six months is not enough.
From an archaeological perspective the main problem with this proposal is it allows certain building projects to completely skip the EA process. The Environmental Assessment stage is when Archaeologists find potential sites, this assessment allows us to investigate the area of interest in order to determine if there is any possibility of finding anything of cultural significance. If this assessment is streamlined it could mean the destruction and loss of multiple archaeological sites, not to mention the artifacts and the cultural significance they hold. First Nations history in Canada goes back thousands of years. The regulations put in place now allows for archaeologists to effectively find sites that were covered up or demolished before regulations and standardizations were put in place in the field of archaeology and construction. With the new streamlined proposal it will not allow for the discovery and protection of previously covered or damaged sites. This is particularly worrying when it comes to ancestor burials, none of these are recorded and a large amount of the information pertaining to ancestor burials is only known through living relatives and descendants. If this step of the process is removed there will be no way for those involved to be sure the ground is sterile and free of artifacts.
Moreover, we should not be decreasing the amount of engagement with Indigenous Canadians, we should be improving the way we engage in a way that proves meaningful. The proposal of this act demonstrates the lack of consideration for the First Nations of Canada. It is my opinion that you strongly reconsider the amendments to this Act.