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 committee gave Bylaw 260 third reading on 15 September 2026. It needs your approval before adoption. Please withhold approval until the points below have an answer. [Add where you live, own or rent, and why this plan matters to you.]
1. The twenty-year housing figures your ministry praised were deleted.
The draft plan included a need for 109 more homes over five years and 359 over twenty. Your 21 July 2026 letter welcomed the twenty-year numbers. It asked for the phrase housing targets on page 8 to change. It also asked for the statements and maps required by section 473(1)(a). The exact source words are below.
Exact source words
“great to see that Denman Island has incorporated the 20-year HNR numbers.”
“housing targets”
“ensure that the OCP includes the necessary statements and map designations for the approximate location, amount, type, and density of residential development needed for at least the next 20 years (LGA s.473(1)(a)).”
On 24 August 2026, resolution DE-2026-070(a) removed the figures. They were absent from the 15 September third-reading text. The planner’s recorded words are below. In the staff reply, housing target became future housing capacity. Staff also said the old land-use map still applied. The reply did not set out the amount needed over twenty years.
Exact source words
“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.”
“housing target”
“future housing capacity”
2. After this bylaw, the plan states no amount of housing at all.
The plan had three other ways to state housing amounts: a total density cap, about five percent extra for named uses, and a density bank. Their names were Housing Objective 3, Housing Policy 12 and Appendix D. Bylaw 260 removes them in items 27, 32 and 47–49. The text still names about 74 vacant residential lots and urges caution. Its content list still calls for an amount over at least twenty years. Section 473.1(3) asks town and city councils to provide for the report’s total of 359. That duty is different from section 473(1)(a), which still calls for an amount in this plan. The exact text is below.
Exact source words
“approximately 74 vacant residentially zoned lots”
“caution is needed when considering future housing capacity.”
“statements and map designations identifying the approximate location, amount, type, and density of residential development to meet anticipated housing needs over at least a 20-year period.”
3. The bylaw reduces housing capacity while deleting its needs evidence.
Staff estimate about 100 fewer units of maximum outright capacity under the two bylaws together. That means the most units allowed without a further land-use decision. It is not 100 demolished homes. Section 473(1)(a) calls for the place, amount, type and density of future homes over at least twenty years. Section 473.1 says to weigh the latest needs report when the relevant plan parts change. Show how the final text meets those duties. The exact source words are below.
Exact source words
“remove outright subdivision potential and reduce the number of units permitted outright on larger lots,”
“approximately 100 fewer units than under the current regulations.”
“the approximate location, amount, type and density of residential development required to meet anticipated housing needs over a period of at least 20 years,”
The local committee should choose and justify its figures. I ask for a public account of how the plan meets sections 473(1)(a) and 473.1. The record removes housing numbers while staff estimate lower outright capacity. Explain the result before approval.
What I ask.
Please withhold approval of Bylaw 260 until these points are answered. State a housing amount for at least twenty years. Or publish a clause-and-map account of how the plan meets sections 473(1)(a) and 473.1. The amount could use the report’s figures as future capacity. Another number needs sound reasons. Show the case in public before the plan takes effect.
Exact source words
“targets,”
Keep the gains in Bylaw 264. They remove the temporary-use-permit step for extra homes, allow homes in Industrial zones and add suite and secondary-home choices. This letter asks you to decide on the plan, not the zoning. Sections 56 and 27 of the Islands Trust Act set the route. The zoning here goes through the Executive Committee. The reason is that Denman already has a Minister-approved plan.
Yours respectfully,
[Your name]
[Your address, and your interest in Denman Island or the trust area]