Housing Review

A written submission you can send.

Copy this, change the parts you disagree with, put your own name on it, and email it. Written submissions are part of the hearing record. Include only statements that are true for you.

Where this stands, 15 September 2026. The public hearing has closed and the committee has given third reading to Bylaws 260 and 264. Bylaw 260 now goes to the Minister of Housing and Municipal Affairs for approval, and both bylaws go to the Islands Trust Executive Committee, with final consideration and adoption to follow. The deadline below has passed; this page stands as the record of the submission that was asked for. Ready drafts now exist for the Executive Committee and the Minister of Housing and Municipal Affairs. The chronology records the hearing and third reading.

Before you copy it: make it yours

A hearing works better when the committee hears what people actually think. The most useful thing you can add is the part only you know: what you own or rent, what these rules would do to it, and what you want changed. Three sentences in your own words are worth more than all five points below.

You are also free to disagree with us. If you think the bylaws are right, say that — the record is better for it.

The letter

To the Denman Island Local Trust Committee,

I am writing about proposed Bylaw Nos. 260 and 264, ahead of the public hearing on 15 September 2026. [Say here whether you own or rent on Denman, and where.]

I oppose adoption in their present form and ask for the revisions below. I ask that the useful housing reforms these bylaws carry be retained: the removal of the temporary-use-permit requirement for secondary dwellings, dwellings permitted in Industrial zones, the expanded secondary-suite and detached-secondary-dwelling opportunities, and the support for Agricultural Land Commission exclusion applications for affordable housing. [Optional: name the documents you have actually read and explain how the proposals affect you.]

1. Explain and reconsider the general subdivision restriction.

Bylaw 264 sets a minimum lot area of 64.0 hectares in every zone — Residential, Rural Residential, Land-Share, Agriculture, Forestry, Commercial, Light Industrial, Institutional, Conservation and Park alike (ss. 5.1(12), 5.2(13), 5.3(11), 5.5(19), 5.6(18), 5.7(5), 5.8(6), 5.9(5), 5.10(3), 5.11(4)). For an ordinary split to pass that general area test, the parent parcel must have 128 hectares. Family-lot and specified-purpose provisions and rezoning routes remain.

The campaign’s model includes 894 mapped parcels after stated exclusions; it does not verify ownership. Of those, 2 pass the proposed general area screen. Both are Agriculture-zoned and ALR-flagged. This is not subdivision approval: water, title, geometry, frontage and ALC conditions remain untested.

Please publish a plain-language account of the general rule, the retained family-lot route in section 8.4, each specified-purpose exception and the rezoning criteria. Reconcile the campaign’s single-zone area approximation with the Trust’s build-out analysis before relying on either as a count of feasible housing.

2. Protect practical farm-family and worker accommodation.

Land Use Bylaw 186 Table 3 sets the minimum lot area per principal dwelling in the Agriculture zone at 15.0 hectares outside the Agricultural Land Reserve, with no maximum. Bylaw 264 s. 5.5(4) replaces that with one principal dwelling per lot, inside the ALR or out, at any acreage. Outside the ALR a 100-acre farm goes from two permitted principal dwellings to one, and the reduction grows with the size of the holding.

A suite or detached secondary dwelling can still house another household. My concern is the reduction in independent principal-dwelling options on larger non-ALR holdings. Retain a justified per-area allowance there, and explain and reconsider the suite-OR-cottage rule in s. 5.5(7), subject to ALR conditions, servicing and protection of productive farmland.

On ALR land the Province already allows a principal residence, a secondary suite within it and a detached additional residence of up to 90 m² (186 m² on parcels over 40 hectares) without a Commission application (ALR Use Regulation ss. 31 and 34.3). Please do not make local rules narrower than that without evidence, and support applications to the Agricultural Land Commission for farm-worker and multi-unit farm housing.

3. The rural cap of four falls only on the largest properties.

Section 5.2(3) allows one principal dwelling per 4.0 hectares up to a maximum of four. Bylaw 186 has no maximum for this zone. The cap changes nothing on 10 or 40 acres; on 100 acres it cuts the permitted count from ten to four. Please publish the evidence supporting four, and compare alternatives addressing cumulative aquifer impacts, habitat, access and fire response, as well as individual water and sewage capacity.

4. A missing number that should be fixed before third reading.

Section 5.2(2)(c) makes secondary dwelling units a permitted accessory use in the Rural Residential zone. Section 5.2(4) gives the number for a lot under 4.0 hectares, and s. 5.2(5) gives the number of secondary suites. Please identify the provision that fixes the detached-secondary-unit count on lots of 4.0 hectares or more, or add an explicit number before third reading. Count principal dwellings, suites and detached secondary dwellings separately so the total is unambiguous.

5. The housing need was removed after the Province asked for something else.

The draft plan carried the figures from Denman’s housing needs report: 109 additional units over five years, 359 over twenty. On 24 August 2026 the Committee resolved to remove them. The Ministry of Housing and Municipal Affairs, reviewing the same plan on 21 July 2026, did not ask for that. It wrote that it was “great to see that Denman Island has incorporated the 20-year HNR numbers”, and recommended that the reference to “housing targets” on page 8 be changed or removed, because the twenty-year numbers are not targets. Its other referral points addressed OCP content, map designations and documenting referral non-responses.

Local Government Act s. 473(1)(a) requires an official community plan to state the approximate location, amount, type and density of housing required to meet anticipated needs over at least the next twenty years. Removing two sentences alone does not establish non-compliance. Please publish a clause-and-map account of how the final OCP addresses that requirement and considers the housing needs report under s. 473.1. I ask that the figures be restored, consistent with the Ministry’s favourable comments; that is my requested remedy, not a restoration direction issued by the Ministry.

6. Count homes, not house types, and allow small multi-unit buildings.

Bylaw 186 permits buildings containing two or more dwelling units only in the Affordable Rental Housing zone (Table 2). Bylaws 260 and 264 keep separate counts and conditions for principal dwellings, suites and detached secondary dwellings. Outside the ALR, I ask the Committee to replace those categories with one number of dwelling units per lot, at least equal to each lot’s present combined permission and at least two on every residential lot, and to let owners build them as a house and suite, separate cottages, or a duplex, triplex or fourplex. Please allow additional units where homes share one building or a clustered site with shared servicing, allow units in such buildings to be held as strata lots subject to the proposed restrictions on whole-home short-term rental, and tie each unit to demonstrated water supply and approved sewage disposal rather than to a flat cap.

7. Keep a way back into conformity for lawfully built homes.

The plan’s “Zoning for Non Conforming Dwellings” policy tells the Committee to consider rezoning homes that existed when the plan was adopted on 15 May 2009 and were built in accordance with the land use bylaw in effect at the time. Bylaw 260 ss. 36–37 delete it, and nothing in Bylaw 260 replaces it. Owners of lawfully built homes that no longer fit the rules would be left in non-conforming status, unable to enlarge them. I ask the Committee to keep that policy or an equivalent, and to begin the inventory and compliance process for existing non-compliant homes that staff have described as a possible next step.

What I am asking for

  1. Reconsider the general subdivision minimum and state the retained exceptions and approval constraints plainly. An area screen is not a housing-delivery count.
  2. Retain a justified per-area principal-dwelling allowance outside the ALR and reconsider suite/cottage exclusivity.
  3. On ALR land, match provincial residential permissions and support Commission applications for farm-worker and multi-unit farm housing.
  4. Outside the ALR, count dwelling units rather than house types; permit duplexes to fourplexes and clustered homes, with strata ownership available, conditioned on water and sewage capacity.
  5. Publish the rationale and alternatives for the rural cap, including environmental and servicing constraints.
  6. Make principal, suite and detached-secondary-unit counts explicit before third reading.
  7. Restore the housing-need figures as requested here; correct the targets wording and demonstrate final OCP compliance.
  8. Retain small and alternative dwelling recognition, practical legalization with displacement assessment, year-round housing protection, and a financeable non-market option. Publish transition and delivery milestones.
  9. Keep the “Zoning for Non Conforming Dwellings” policy or an equivalent, and begin the inventory and compliance process staff called a possible next step.
  10. Given the scale of these revisions, and that this is the final regular meeting of the current committee before the election, defer third reading of Bylaws 260 and 264 to the incoming Local Trust Committee, so the committee that must administer these bylaws is the one that decides them.

I would be glad to have any of the parcel figures above checked, and will correct anything I have got wrong.

[Your name]
[Your address or connection to Denman, as appropriate]

Where every number came from

  • Public Hearing Notice, Bylaw Nos. 260 and 264, Denman Island Local Trust Committee (dates, times, address and the rule on late submissions).
  • Denman LTC regular meeting agenda, 24 August 2026, second-reading text of Bylaws 260 and 264 and the staff report from page 141.
  • Denman Island Land Use Bylaw No. 186, 2008, consolidated to 24 July 2024, Tables 3 and 7.
  • Letter from the Ministry of Housing and Municipal Affairs, 21 July 2026, in the same agenda package.
  • Public hearing binder (Islands Trust, file dated 26 August 2026): the OCP’s “Zoning for Non Conforming Dwellings” policy, PDF pp. 228 and 561; Bylaw 260 ss. 36–37, p. 31; staff comments, pp. 277, 502 and 756–757; Denman Conservancy Association letter of 3 August 2026, p. 993.
  • Parcel counts: Denman’s parcel boundaries and areas, 894 mapped parcels (ownership unverified) with water tenures, park and conservation zones excluded, and with rights-of-way and leases registered over other lots not counted as lots, measured 9 September 2026. The maps are on the main page.

If any figure here is wrong we want to know, and we will correct it on this page and say that we did. Bylaw figures refer to the second-reading draft; parcel figures are a separate campaign model; if the bylaws change at the hearing, this page changes with them.