I echo the comments provided…

I echo the comments provided in the March 15 2024 letter from the Ontario Association of Heritage Professionals.

I understand the need to streamline and remove unnecessary barriers to provide needed infrastructure, but urge the Province to not ignore built heritage resources, cultural heritage landscapes, and archaeological resources in ensuring its path forward.

As it was stated in the letter, I have concerns in three areas:
1) Consideration of heritage and archaeological resources
The 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. So what duplicative system is the ERO statement referring to? Documented examples need to be provided.
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 MCEA system. 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. How would this be in any way more efficient.

Further consultation should be undertaken on this proposal to understand the implications for the cultural heritage resources and archaeological resources across the Province. An example of successful consultation that resulted in a streamlined process and considers cultural heritage resources would be the Municipal Engineers Association and the Ministry of Citizenship and Multiculturalism developing a new checklist, Municipal Bridges Criteria for Evaluating Potential for Cultural Heritage Resources (April 2023). This exemplifies how careful thought-out processes can be developed in consultation with professional experts can balance both the desire to streamline processes and consider cultural heritage resources.

There is a great willingness in the cultural heritage profession to provide expertise and further insight by participating in stakeholder consultation, working groups and/or advisory bodies. They can also assist with identifying potential barriers and issues with proposed legislation and regulations from a practical, solutions-based approach.

I again urge the Province of Ontario to listen to the experts in their field, they raise valid concerns and warrant serious consideration. Make sure that the implications and results of these changes are fully thought through and not just what short-term benefit might be gained.

Your's in heritage.