I wish to comment on two…

I wish to comment on two aspects of the proposed regulation that would allow for a wide scope of exemptions from the Municipal Class EA process. These are:

1) all municipal roads or new parking lots in any location, reconstruction of any bridges with or without cultural heritage value, all water crossings; and
2) all private sector infrastructure projects for residents of a municipality regardless of size, including a new sewage treatment plant of any size.

My perspective is that of an archaeologist who has worked for 35 years in the planning sector, conducting archaeological assessments of development projects as they work through the planning process.

These proposed exemptions are too broad, they would allow archaeology to be disregarded for many projects in Ontario. This would result in the destruction of numerous archaeological sites, disturbance of unmarked burials, infringement of the rights of Indigenous peoples, and unnecessary delay of exempted projects as they would inevitably become contested in the political and legal spheres.

The current scope of exemptions works fine, it is wide enough to capture cases, where archaeology is necessary with the result that sites are preserved through documentation, unmarked burials are treated with respect, and Indigenous people are able to exercise their rights and participate in the development process. The existing process is well established, well understood, and when implemented properly does not cause undue delay or expense.