Thirteen Islands, Eight Definitions of "Affordable"

The Islands Trust Policy Statement uses the word "ecosystem" 48 times and "affordable" once — in a sentence about food. Trust Council directed itself to define affordability in 2015. In 2021 staff told a committee the working group could not do it. In the gap, six islands wrote eight different income tests and three incompatible rent rules.

The Islands Trust governs thirteen local trust areas under one Act, one Trust Council and one Policy Statement. Every official community plan and every land use bylaw in the Trust Area must conform to that Policy Statement, and the Executive Committee checks each bylaw against it before it can take effect.

Here is what the Policy Statement says about affordable housing.

Once. In a sentence about food.

The Policy Statement is Trust Council Bylaw No. 17, consolidated April 2003 and amended four times since.^[1] In its 74,000 characters:

The one appearance of "affordab-" is not a policy. It is a description of what makes a community healthy — "the availability of such necessities as educational and social services, transportation, affordable food and housing."^[1]

Of the two "housing" mentions, that sentence is one. The other is the only operative housing policy in the document, and it hands the question to somebody else:

> Directive Policies 5.8.6 — Local trust committees and island municipalities shall, in their official community plans and regulatory bylaws, address their community's current and projected housing requirements…^[1]

To be fair to the Trust: 5.8.6 is a real, mandatory policy. It is not nothing. But it does not say what affordable means, what a rent should be measured against, who should qualify, or for how long. The Trust delegated the definition without supplying one.

The Trust knew. It said so in 2015.

This is not an outsider's complaint. It is the Trust's own finding about itself.

On 1 June 2015 the Islands Trust Programs Committee recommended:

> "THAT Trust Council review the Islands Trust Policy statement to ensure that it: includes clear and well-thought out definition of affordability; includes clearly articulated vision, goal and objectives for affordable housing; gives affordable housing a greater profile for its role in sustainable communities…"^[2]

The Executive Committee endorsed it in October 2016. It was on Trust Council's agenda that December. Dillon Consulting put it to Trust Council again in June 2018, as recommendation 1(a) of its *Housing in the Trust Area* report.

Six years later: "the working group was unable to come up with a definition"

Islands Trust Programs Committee, 3 May 2021. Trustee Colbourne asks where the definition went:

> "item 16 in the… plan says review the Islands Trust policy statement to ensure that it includes a clear and well thought out definition of affordability… I'm having trouble finding some of the clearly articulated definitions, especially when it's right there in the strategic plan that was voted on by the majority of Trust Council."^[3]

A trustee puts it to staff:

> "I'm going to ask for the first one first. Is there a definition of affordable housing?"^[3]

The answer:

> "There's not. And that is because the working group was… unable to come up with a definition, a working definition for affordability. I think we determined that it's a very difficult concept to define."^[3]

And then a trustee draws the conclusion out loud:

> "the direction was to include a definition but we don't have a definition because we couldn't come up with a definition and so we're not quite meeting our obligation as per our strategic policy… So it is a chicken and egg problem. Okay, so I'm not sure how to go forward with that."^[3]

Ten years after that direction, the draft Policy Statement given first reading on 30 July 2025 mentions housing nineteen times — real movement — and still defines nothing. Its strongest affordable-housing clause tells staff to process the applications faster.^[4]

What thirteen islands did with a blank space

They filled it in themselves. Six of the thirteen have adopted housing agreement bylaws, and between them those bylaws use eight different tests for who counts as low income.

On Denman, two of them are in force at the same time, adopted five months apart by the same committee.

Bylaw 239, adopted 27 September 2022, for the Pepper Lane housing at 3730 Denman Road:

> "the Affordable Dwelling Units will only be occupied by Qualified Occupants whose Annual Household Income has not, in any of the previous three years, exceeded 160% of the most recently published before tax Low Income Cut-offs, for rural areas"^[5]

— plus a rule that the household may hold no more than $60,000 in assets.^[5]

Bylaw 243, adopted 7 February 2023, for the Denman Housing Association at 1151 Northwest Road:

> "the Household's Annual Household Income must be less than or equal to BC Housing's Housing Income Limits for the Comox Valley Planning Area"^[6]

— and no asset test at all.^[6]

Two different definitions of a low-income household, on one island, in the same year. Which one applies to you depends only on which lot the building stands on.

"30% of income" means three different things

Almost every one of these bylaws caps rent at 30%. Of three different quantities.

Your income. On Denman and Gabriola the rent is geared to what the tenant actually earns: "must not exceed 30% of the gross monthly Household income of the Qualified Renter."^{[6] [12]}

Somebody else's income. On Salt Spring's Meadowlane, the ceiling is 30% of the *island's median* household income — a flat figure that does not move when the tenant is poor. The bylaw shows its own arithmetic: median $59,077, 30% of that, $1,476.92 a month.^[7] A tenant earning $24,000 faces the same ceiling as one earning $59,000.

The province's median, averaged over a year. On Galiano, rent for a one-bedroom "in a calendar year will on average be at or below 30% of the average of… Income of One-Person Households; and Income of Couples without Children."^[9] Not the tenant's rent — the average rent, over a year.

How many people may live in an affordable home?

We read all of them for a rule on this. Two have one, and they contradict each other.

Salt Spring says no more than two.

> "The Affordable Housing Unit will be occupied only by Qualified Renters, and by no more than two Qualified Renters."^[7]

Hornby says at least two, and one must be a child.

> "'Household' means an applicant, spouse (if applicable) and dependent children (if applicable), and for Affordable Housing Units with two (2) or more bedrooms has a minimum of two (2) persons that must include at least one dependent child."^[8]

On Hornby, read plainly, a couple without children cannot occupy a two-bedroom affordable unit. On Salt Spring, a family of three cannot occupy that one. Both bylaws were checked by the same Trust for conformity with the same Policy Statement.

Where the numbers come from

Nobody could say.

Denman's 160% arrived in the bylaw through a staff report of 19 January 2021 which explains it in a single sentence:

> "A trustee has requested a minor amendment… to increase the maximum percentage of annual household income for Low Income Cut-offs, from 120% to 160%."^[10]

It names no trustee and gives no reason.

At the meeting, four minutes before the vote, a trustee asked whether the agreed figure had been 150. Someone answered "Correct." Seconds later the planner said the opposite: "that might have been our error — was it intended to be 150, I don't remember." One trustee said "I don't remember but I'm okay with 160." The other said the same. It passed unanimously, and stayed in the bylaw through a public hearing, four rounds of amendment and adoption twenty months later.^[11]

That number decides who is allowed to live there.

The point

None of this says any island chose badly. Every one of these committees was trying to house people, and several were plainly trying to widen eligibility rather than narrow it.

The point is that the Islands Trust identified the definition of affordability as its own priority in 2015, told itself in 2021 that it could not produce one, and had not produced one by 2025 — while thirteen local trust areas were each obliged, by the Trust's own Directive Policy 5.8.6, to work it out alone. What came back is eight income tests, three rent structures, and two occupancy rules that point in opposite directions.

A body that cannot define the word after ten years is not, on this evidence, the body that should be deciding who may live in these houses.

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How to check this. Every document above is a published Islands Trust PDF, linked in the sources. The word counts are of the published Policy Statement's own text and can be reproduced by anyone with a copy and a search box.

The meeting quotations were transcribed from the Trust's own recordings, and then checked a second time — each passage was re-transcribed from the Trust's stream using a different, more accurate method, and every quoted line came back the same. That second pass found one thing the first had missed: the word "Correct.", above. The recording ids and start times are in the sources, so you can play any passage yourself. The punctuation is ours; where a speaker breaks off we mark it with … rather than tidying it up — that is why the staff answer reads "the working group was… unable". Members of the public who spoke at these meetings are not named.