To the Honourable Christine Boyle, Minister of Housing and Municipal Affairs,
Re: Denman Island Official Community Plan Bylaw No. 185, 2008, Amendment No. 1, 2026 (proposed Denman LTC Bylaw No. 260) — approval requested under s. 27(2)(b) of the Islands Trust Act
The Denman Island Local Trust Committee gave this bylaw third reading on 15 September 2026 and it will be forwarded to you for approval. I ask you to withhold approval until the two matters below are addressed. [Say here whether you own, rent or live on Denman Island, or elsewhere in British Columbia, and why the plan matters to you.]
1. The twenty-year housing figures your ministry praised were deleted.
The draft amendment incorporated the figures from Denman Island’s housing needs report: 109 additional units over five years and 359 over twenty. Your ministry’s referral letter of 21 July 2026 said it was “great to see that Denman Island has incorporated the 20-year HNR numbers,” and recommended only that the phrase “housing targets” on page 8 be changed or removed, on the stated ground that the twenty-year numbers are not targets.
On 24 August 2026 the committee deleted the figures instead. The planner’s explanation, on the recorded meeting: “I guess it’ll be left to the ministry to decide how we’ve referred to it. So how about we just delete it and see what they say.” The concern your letter raised was wording. The response removed the substance — the only quantified statement in the plan of how much housing Denman needs.
2. The bylaw reduces housing capacity while deleting its needs evidence.
Staff’s second-reading report states the effect of the paired amendments plainly: they “remove outright subdivision potential and reduce the number of units permitted outright on larger lots,” for a maximum build-out “approximately 100 fewer units than under the current regulations.” Section 473(1)(a) of the Local Government Act requires an official community plan to include statements and map designations for “the approximate location, amount, type and density of residential development required to meet anticipated housing needs over a period of at least 20 years,” and s. 473.1 requires the local government to consider its most recent housing needs report when amending the plan in relation to those statements. The bylaw before you reduces outright capacity by the sponsor’s own estimate and now answers s. 473(1)(a) with no quantity at all.
I am not asking you to direct that specific figures be restored — that is the local committee’s job, and my request below asks only that the requirement be met, not that any particular number be chosen. But approval of an OCP amendment that deletes its quantified needs statement over a page-8 wording concern, while cutting outright capacity by about a hundred homes, deserves a published account of how ss. 473(1)(a) and 473.1 are addressed before the bylaw takes effect.
What I ask.
Withhold approval of Bylaw 260 until either (a) the twenty-year housing figures are restored as a statement of future housing capacity — not “targets,” which is the distinction your own referral letter drew — or (b) the Islands Trust publishes a clause-and-map account of how the final OCP addresses Local Government Act s. 473(1)(a) and considers the housing needs report under s. 473.1, so that your approval is given against that account rather than against silence.
For completeness: the paired zoning bylaw (No. 264) carries reforms worth keeping — it removes the temporary-use-permit requirement for secondary dwellings, permits dwellings in Industrial zones, and expands secondary-suite and detached-secondary-dwelling options. Nothing in this letter asks you to weigh in on zoning: under s. 56 of the Islands Trust Act, a zoning bylaw needs your approval only for land not covered by a minister-approved plan, and its approval here rests with the Executive Committee under s. 27. My request concerns only the plan, and only the requirement the statute places on it.
Yours respectfully,
[Your name]
[Your address, and your interest in Denman Island or the trust area]