The proposal ERO# 019-7891 …

The proposal ERO# 019-7891 "New regulation to focus municipal environmental assessment requirements" dramatically FAILS in multiple instances to provide sufficient safeguards and protection to archaeological heritage and Ancestor burials.

This proposal comes into complete contradiction with the current regulations under Ontario Heritage Act and the Funeral, Burial and Cremation Services, as it is illegal for municipalities and private developers to disturb archaeological sites.

If this proposal is adopted (and by revoking the Municipal Class Environmental Assessment -MCEA, and Private Sector Developers Regulation) it would lead to a uneven landscape of municipal policies and procedures being adopted to fill the gap where the MCEA and private sector developers regulation is revoked.
This would contradict the provinces own language in "Project information about this class environmental assessment: proposal"

1) "Streamlin[ing]".
As mentioned above, it is illegal for municipalities and private developers to disturb archaeological sites (as dictated by the Ontario Heritage Act and the Funeral, Burial and Cremation Services).
The proposal adopting buzzwords such as streamlining inherently contradicts itself, as the Ontario Heritage Act and the Funeral, Burial and Cremation Services would still have to be followed, and would create policy disorder and counter the provinces own narrative of efficiency in environmental assessments.

2) "modernize its almost 50-year-old environmental assessment process that is too slow, unnecessarily burdensome and costly, to build Ontario while continuing to protect the environment" Sensible, practical changes that would provide environmental oversight while reducing delays to get shovels in the ground on projects that matter most to Ontario communities."
It is unclear what modernization is defined as, and there is a lack specificity or particularity regarding what unnecessarily burdensome or practical changes involve. Another contradiction of this proposal regarding practical changes is the utter disregard of adopting regulations to implement further consultation with Indigenous communities. This is noted below.

Finally, the proposal also fails to include tenets of the Truth and Reconciliation Commission Report (TRCC), as this new streamlined EA proposal would, in fact, lead to reduced consultation with Indigenous Communities, as mentioned above through failure to protect archaeological heritage and Ancestor burials.

ERO# 019-7891 should NOT be adopted, as it fails at multiple occasions to properly provide sufficient safeguards and protection to archaeological heritage and Ancestor burials.