In regards to the proposed…

In regards to the proposed details provided there are many stand out point to be weary of and very critical of.

Here are a summary of those notes:

1. The "changes to the previous proposed project list designating projects proposed to be subject to the streamlined EA process, including adding certain projects by private sector developers, and adjusting certain thresholds that are the basis for a project being subject"

What are these changes, and what are the parameters of the threshold to these changes that are exempt? Who is subject to these exemptions? What sectors, Water roads, housing, resources development or is this a catch all statement for safeguarding that are in collusion with the current Provincial government and there political lobbyists?

I think it is very dangerous that the MCM be the ones to determine if an area has potential. As a first reading into a project this is adequate, however the MCM has yet to assist with processes for Archaeologists and First Nations to protect and avoid important Ancestral sites. The MCM hardly have the staff to review reports without fabricating percentages of up to date report review processes.

They don't have field staff that come out to sites. In addition they are very good at complicating site logistics when it comes to Burial sites. To give them the power of personal opinion of a Minister that isn't swayed by development dollars than the current ethos of archaeology, TRC, and UNDRIP.

2. To "provide notice of the draft summary report to Indigenous communities, the Director of the Environmental Assessment Branch, Ministry of the Environment, Conservation and Parks (MECP) and MCM and post the notice on the website.

What is the notice of First Nations say "NO" to development? What happens after 30 days if a First Nation does not respond? Does that really count as consultation? What about developers that are too forward and destroy, strip and alter the landscape before consultation, EA's and archaeological assessments are done? I don't see any language to enhance the CONSEQUENCES of PENATILES AND JAIL TIME for those that act in bad faith.

3. "A licensed archaeologist who will undertake a Stage 1 and, where necessary, a Stage 2 archaeological assessment in accordance with the Standards and Guidelines for Consultant Archaeologists 2011, issued by MCM and have the report entered in the Register mentioned in section 65.1 of the Ontario Heritage Act"

I've seen may Stage 1 and 2 reports that re produces without First Nations involvement. The MCM and Archaeological group have often favour keeping Indigenous groups in the dark until the ABSOLUTELY need to engage at the Stage 3. I've also seen many poorly written Stage 1+2 by bad actors in the pursuit of budget dollars and client agendas. Here is a statement from a CTV new article:

"A 60-year-old man from Aurora has been charged with fraud over $5,000 as well as unsafe storage and unauthorized possession of a firearm. Ontario Provincial Police say they received information of a suspected fraud in association with archeological surveys submitted to the Ministry of Citizenship and Multiculturalism. Police say they did an extensive investigation into suspected irregularities in archeological reports."

This misguide archaeologist will hopefully face charges and jail time for fraud. I certain hope that this doesn't lead to the abuse of Ministers orders that walk a thin line of engagement protocols and fraudulent behaviours.

4. EA's are very important for the wellbeing close relatives in the natural world. If we de-house them, displace them, destroy them, with show the ugly site of a self serving government with no true compassion for Natural environment. If you really cared for First Nations involvement, you would be more considerate of the water, land and air. It is very unfortunate to see that by doing the archaeology this government is trying to weasel out of providing comprehensive assessments of the environment. A gross piggyback effort; a grossly incompetent's effort.