British Columbia told local governments to zone for small-scale multi-unit housing. A local trust committee is not a local government.

In plain language: what the islands have to do about housing

More than commission a study, but they do not have to change their zoning rules to allow more homes.

Each island has two rulebooks:

• The zoning rules (the land use bylaw) say what you can build on your lot.
• The plan (the official community plan) is the big-picture guide the zoning rules must follow.

1. The study (the housing needs report)

• Have one ready by January 1, 2025. The Trust-wide report is dated April 2025, so it was late.
• Officially receive it.
• Put it online. It has been on the Trust's website since May 2025.
• Do a new one every five years. The next is due by December 31, 2028.

2. The plan has to say certain things

• How much housing is needed over the next 20 years, and roughly where, what kind and how dense. It does not have to be the study's number, but it has to be an amount.
• Policies on affordable, rental and special-needs housing.
• A policy for each kind of need the study must cover: affordable, rental, special needs, seniors, families, homelessness, and housing near walking, cycling or transit.

3. When they change the plan

• They have to consider the study: actually look at it and weigh it. They are allowed to disagree with it.
• An Islands Trust plan change needs ministerial approval before adoption. The Ministry says that approval is not a legal compliance check or a validation of the bylaw.

What they do not have to do

• Change the zoning rules to allow more homes. No duplexes, fourplexes or extra suites are required. Municipalities must do that; local trust committees are excluded.
• Plan for the study's exact number. Only municipal councils must.
• Update the plan by a deadline. Only municipal councils have one.

So is a study, or talking about the numbers, good enough?

• Commissioning the study is not enough on its own: it also had to be on time, officially received and posted.
• Talking about the numbers is not enough for the plan: the plan itself has to state a 20-year amount and carry those policies.
• For the zoning rules, nothing more is required. They do not have to add any housing.

Example: Denman Island's draft Bylaw 260 went into third reading without the plan's housing-need figures. The text passed at third reading has not been published. On October 2 the Ministry said the bylaw had not yet been referred to the Minister. The letter asking the Minister to require a 20-year amount.

Local Government Act ss. 473(1)(a), 473(2), 473.1(2)–(5), 481.3, 481.7, 585.31, 585.4 and 790; Housing Needs Report Regulation ss. 8(1)(b) and 23; Islands Trust Act ss. 27(2)(b) and 29(1)(b). A reading of the statutes, not legal advice.

What the record shows, island by island

Checked as of September 17, 2026. What we looked at:

• Every published meeting minute of each island committee from 2023 to September 2026.
• Each island's current plan and zoning rules.
• Our own computer transcripts of the Trust's meeting videos from June 2024 on.

On every island

• The law set January 1, 2025 as the date for a first (interim) housing report. The Trust's study is dated April 2025. We are asking the Trust if any island committee had an earlier report.
• We found no record in any island committee's minutes of the committee formally accepting the study. If there is one, we are asking the Trust to show us.
• Only one island, Mayne, has a plan that states how much housing is needed over 20 years.
• No island plan has a housing policy that names homelessness. Hornby's plan allows emergency and temporary housing. Denman's current plan mentions homelessness only in a definition that its draft change deletes. The study counts some homelessness need on every island except Ballenas-Winchelsea.

The last column lists changes adopted from January 2023 to September 16, 2026. Each one lets at least one more home be built. Some were asked for by owners. Some were started by the committee. Some add just one home.

What was said in meetings

• These are from the Trust's own meeting videos. We name a person only when we confirmed the voice by listening.
• Our transcripts are made by computer. Their speaker names and meeting titles can be wrong. The video is the true record.
• Staff give advice. The elected committee makes the decision.

• May 9, 2025, The Trust's regional planning committee. Stefan Cermak, Director of Planning Services.

  • About the province's way of counting housing need: "you have to follow legislation's uh process to calculate the numbers you're not allowed to deviate from that".
  • About 12 minutes later, asked if the committee could reject the report: "you can reject the findings and disagree with them for sure". He added: "i don't think you can reject the fact that submitted based on the model and it produced the results that it did". (listen)

  The committee voted to ask staff to send the reports on to the executive committee, and added that it had no confidence in the data and feared it could cause harm (RPC 2025-015: "lack of confidence in the data, its usefulness, and belief that it could cause harm").

  Read and listen. Source: Trust meeting video, May 9, 2025 (our file 250509A); committee minutes.

• June 4, 2025, The Trust's executive committee. A Trust staff member (voice not confirmed).

  • "We haven't finished all the requirements of the legislation, though, and forwarding it to all the local trust committees. I was waiting for the results of today's conversation before I did that."
  • About 16 minutes later, after the committee voted to write to the Ministry and the chair asked for the long report to be split up by island: "it might be wise for me to delay sending that memo to all the ltcs till this letter's crafted and maybe they'll form part of the package". (listen)

  The committee voted to tell the Ministry of Housing and Municipal Affairs that the province's formula "was inadequate to capture the true housing need in rural island communities", and to ask it to change the method (EC-2025-073).

  Read and listen. Source: Trust meeting video, June 4, 2025 (our file 250604A; our transcript list wrongly titles it as a Salt Spring meeting); executive committee minutes.

• July 28, 2025, Mayne's island committee. Narissa Chadwick, Island Planner.

  • About the study: "looking at what we received from the consultant and also putting some language around it ... There's a provincial requirement for a specific number um but we're building some language around that and it's going to be consistent across the trust area".

  Mayne's plan change (Bylaw 196) later added the study's 110 and 330, with the words "Given challenges with this data".

  Read and listen. Source: Trust meeting video, July 28, 2025 (our file 250728E).

• July 16, 2026, Gabriola's island committee, talking about its draft plan. Speakers not confirmed (our transcript's speaker names for this part are not reliable).

  • Someone asked: "Can we just say it was useless?" The answer: "Yes."
  • Then: "There is a provincial requirement, I know, to basically quote what that needs assessment says."
  • Later: "So acknowledge it and then say, and it was useless."

  The draft plan (Bylaw 325) quotes the study's 367 and 1,196 and says the study has "limited value".

  Read and listen. Source: Trust meeting video, July 16, 2026 (our file 260716B).

• August 24, 2026, Denman's island committee. Trustee David Graham and Narissa Chadwick, Island Planner.

  • Trustee Graham asked to remove the sentence with the study's numbers. He said it would suggest the plan means to grow Denman's population.
  • Ms. Chadwick: "So this is very awkward. Staff, absolutely agree with you." She said there is "a legislative requirement to reference the housing needs report", and that the report "did not consider local conditions".
  • She first suggested keeping a reference and maybe making the plan's caution about groundwater stronger.
  • Someone asked: "Can we just delete it or no, Narissa?" Ms. Chadwick: "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]".
  • Ms. Chadwick: "We're removing those two sentences that refer to the report. ... We'll see what the ministry has to say."

  The committee voted to delete both sentences, including the study's 109 and 359 (DE-2026-070, draft minutes). About five weeks earlier the Ministry of Housing and Municipal Affairs had written to Trust staff: "It's great to see that Denman Island has incorporated the 20-year HNR numbers." It also said the numbers "are not targets and do not set a requirement to build", asked for the words "housing targets" to be changed, and said the plan should show the housing needed over at least 20 years. The committee gave the plan change third reading on September 15, 2026, with changes (reported by an observer; the minutes are not yet posted). On October 2 the Ministry said the bylaw had not yet been referred to the Minister and that its July comments were preliminary and advisory.

  Read and listen. Source: Trust meeting video, August 24, 2026 (our file 260824D); draft minutes, August 24, 2026; Ministry email of July 21, 2026 (meeting package, pp. 375-376).

What this does and does not show

It shows:

• The Trust knew the study was required and had to be referred to in its plans. Its own staff said so at public meetings.
• One Trust committee voted that it lacked confidence in the study's data. The executive committee told the Ministry the province's formula was inadequate. One island committee (Denman) voted to take the study's numbers out of its draft plan change.
• We could not find a vote receiving the study, a 20-year amount in any plan except Mayne's, or a housing policy that names homelessness.

It does not show:

• It does not show a law was broken. The Ministry says ministerial approval does not validate a bylaw or preclude a legal challenge.
• The rules let a committee disagree with the study. They do not make it plan for the study's exact number.
• Some committees did add the numbers (Mayne) or plan to (North Pender).
• Trustees disagreed about the study. Some said it counts too few homes. Others said it points to more growth than the islands can take.
• A missing record may exist somewhere we have not seen. We are asking the Trust.

This is our reading of the law, not legal advice. If we are wrong, we will say so here.

Sources: Each island's committee minutes and meeting packages (Islands Trust document library); each island's current plan and zoning bylaw; Islands Trust Housing Needs Assessment 2025. Our working notes cite a document and page for every line.

The five provisions, quoted

• Local Government Act, Schedule — Definitions

  “local government” means (a) the council of a municipality, and (b) the board of a regional district

  Two bodies, and a local trust committee is neither. The same Schedule separately defines “local trust committee” as “a local trust committee within the meaning of the Islands Trust Act”, so the Act plainly knows what one is.

• Local Government Act s.481.3(4) — small-scale multi-unit housing

  A local government must exercise the powers under section 479 to permit…

  This is the 2023 duty to zone for townhouses, triplexes and secondary suites — the medium density the islands are short of. The obligation is placed on a local government.

• Local Government Act s.585.1 — housing needs reports

  “local government” includes a local trust committee

  ★ The hinge. For the duty to MEASURE housing need, the Legislature expressly extended the term to cover local trust committees. It would not have needed to say so if they were already included — and it did not say so for the duty to zone.

• Islands Trust Act s.29(1)(b)(i) — added by Bill 44 (2023), s.47

  Part 14 [Planning and Land Use Management] of the Local Government Act, other than the following: (i) section 481.3 [zoning bylaws and small-scale multi-family housing]

  ★ The carve-out we first said did not exist. A local trust committee gets a regional district board's Part 14 powers except the ones listed, and the very first exception is the small-scale multi-unit duty. Bill 44 added this subparagraph in the same Act that created the duty, so the omission was decided by the Legislature, not left to interpretation. Also excluded: the inclusionary-zoning power in s.482.7 and Division 23 (transit-oriented areas). Ordinary zoning, density bonuses under s.482 and housing agreements under s.483 remain available.

• Islands Trust Act s.29(1)

  Each local trust committee has, in respect of its local trust area, all the power and authority of a regional district board under the following enactments…

  Read with s.29(2): the referenced enactments apply to local trust committees as they apply to regional district boards. This is not a general exclusion from planning obligations. The small-scale multi-unit duty is excluded expressly by s.29(1)(b)(i).

• Islands Trust Act s.29(2); Local Government Act ss.473–473.1

  For the purposes of subsection (1), the enactments referred to in that subsection, as they apply to a regional district board, apply to the local trust committees.

  The OCP provisions still require housing policies, a twenty-year planning horizon and consideration of the most recent housing needs report when developing or amending relevant plan provisions. The numeric HNR-alignment duty in s.473.1(3) is specifically for municipal councils.

• Islands Trust Act s.3 — the object of the trust

  The object of the trust is to preserve and protect the trust area and its unique amenities and environment for the benefit of the residents of the trust area and of British Columbia generally…

  Housing is not in the object clause. It is not there in 1974 and it is not there now. Housing is not expressly named in that purpose. Housing obligations also arise through the reporting and OCP provisions; the omission from s.3 does not erase them.

Check them: Local Government Act, Part 14 · the Act’s Schedule of definitions · Islands Trust Act

This is not a claim that the Trust has broken a law. Non-application is not non-compliance, and a local trust committee that chooses to allow medium density is free to. We asked the Ministry whether leaving local trust committees out of s.481.3 was deliberate; the statute has since answered that itself (see the correction below). The policy question is whether that specific exclusion remains justified given the housing need measured on the islands.

⚠️ This is a reading of the statutory text, not legal advice. Every provision is quoted above and linked so it can be checked. If a lawyer or the Ministry shows that s.481.3 does reach a local trust committee, this section is wrong and we will say so here.

⚠️ Corrected 2 September 2026. We first wrote that there was “no carve-out” and that “nobody appears to have decided”. Half right. The duty never reaches a local trust committee — but not by accident. The carve-out is not in ss.481.3 or 481.4 of the Local Government Act, where we looked; it is in s.29(1)(b)(i) of the Islands Trust Act, which Bill 44 itself amended to list s.481.3 among the powers a local trust committee does not have. That is an exclusion the Legislature decided, and the Minister of Housing gave the reason in the House on 20 November 2023: the Trust’s “preserve-and-protect mandate”, and water. The Trust did not ask for it: the Salt Spring committee wrote to the Minister asking to be included as if it were a municipality, and an amendment to include it did not pass.

We have asked both bodies that could correct this

Written on 2026-08-31 to the Ministry of Housing and Municipal Affairs and the Islands Trust (Executive Office). Whether section 481.3 of the Local Government Act reaches a local trust committee; whether leaving local trust committees out of it was deliberate; and whether any local trust committee has adopted small-scale multi-unit provisions regardless.

Both replies will be published in full and unedited. If either body shows this reading is wrong, the page will be corrected and the correction will say so.

2 replies received, published in full below. No reply from the Ministry of Housing and Municipal Affairs by 2026-09-30, 30 days after the letter. The only response was an automatic reply. We have since written to the branch that reviewed the Denman bylaws. A follow-up went to the Islands Trust on 2026-09-17; if it has not answered by 2026-10-17, that will be recorded here too. The Ministry of Housing and Municipal Affairs answered the 2026-09-17 follow-up on 2026-10-02. The Ministry of Housing and Municipal Affairs answered the 2026-09-30 follow-up on 2026-10-02.

Follow-up to the Islands Trust, 2026-09-17; answer due 2026-10-17. Which local trust committees amended housing zoning since 2023, and when each committee received the 2025 housing needs assessment; whether the seven duties we read into the Act are right; where each plan states its twenty-year housing amount and its homelessness policy; and what was said at five recorded meetings. An annotated copy of the Trust Council Housing Strategic Action Plan went with it.

Follow-up to the Ministry of Housing and Municipal Affairs, 2026-09-17; answered 2026-10-02. Sent to the Land Use, Planning and Regional Impacts Branch, which reviewed the Denman bylaws (Ministry reference 192497). Whether the plan still meets sections 473(1)(a) and 473.1(2) with the twenty-year numbers taken out; whether ministerial approval checks those sections, and if not, what stage does; whether the Province gave the written approval of the late 2025 assessment that Trust staff describe; and whether a committee that has not voted to receive its report has met section 585.31.

Follow-up to the Ministry of Housing and Municipal Affairs, 2026-09-30; answered 2026-10-02. A short update to the same branch, quoting the Bylaw 260 housing wording from the 15 September agenda package, which gives no number of homes. It asked whether that wording meets sections 473(1)(a) and 473.1(2), whether the new land use map supplies the designations the Ministry said were missing, and whether the Islands Trust has sent Bylaw 260 to the Ministry for approval.

What they are required to do is count

The Trust commissioned the assessment the regulation demands, and it is a serious document. It found the islands short 2,028 homes within five years and 6,361 within twenty.

Method. The assessment’s own Key Findings table. Ballenas-Winchelsea is 0/0 because it is expressly exempt from the Housing Needs Report Regulation. Bowen is absent because it reports as a municipality. Source. Islands Trust Housing Needs Assessment 2025, prepared by Urbanics Consultants Ltd, April 2025 — study area total 2,028 homes in five years and 6,361 in twenty (2025-04).

Island by island, the assessment states the same implication in the same words: the dwelling stock must grow by roughly 15–20% in five years and 43–61% in twenty. Galiano 19% and 61%. Gambier 20% and 61%. Lasqueti 18% and 52%. Mayne 15% and 43%. North Pender 16% and 50%.

And what a 570,000-character housing assessment never mentions

Method. Case-insensitive occurrence counts over the full extracted text of the assessment, 570,713 characters. Counted mechanically, not read for sense — a term could in principle appear in a heading or a footnote. The four zeroes are what matter and a zero cannot be a false positive. Source. Islands Trust Housing Needs Assessment 2025, full text (2025-04).

“rezoning”, “approval”, “completions”, “multi-unit” — not once. The document measures how many homes are needed and never asks how one would be permitted. That is not a criticism of the consultants; it is what the regulation asked for. It is a criticism of a regime in which the housing duty stops at counting.

The amount of housing permitted in the past will shape population growth and shape this model’s projection of future household growth. Because this data is so dependent on past policy outcomes, it should not be used solely to inform housing needs.

The Trust’s own consultant, warning that the projection partly launders past restriction into lower future need. If an island has been hard to build on for fifty years, fewer people moved there, so the model forecasts fewer households, so the measured need comes out smaller. The number the Trust is required to report is depressed by the thing being measured.

How the Trust prices its own housing work

Method. Local trust committee project lines in the Trust’s own budget papers, quoted as printed. These are the years budgeted to REVIEW the rules, before any rule changes. Source. Islands Trust Council, 2026/27 budget — Local Trust Committee Projects (2026).

Four years to review the housing rules on Denman. Five to review Gabriola’s plan and bylaw. These are the years budgeted before anything changes, and they are the Trust’s own figures.

For these open files, we cannot tell from the records searched whether an application was ever decided.

In the archive searched as of 31 August 2026, thirty-one rezonings listed as open had no indexed appearance since before 2021, and fourteen since before 2017. This does not establish inactivity or a missing decision: records outside our archive or under other identifiers may resolve them. We did not find a consolidated decisions register against which to reconcile this cohort.

Method. Every rezoning in the Trust’s published applications register whose status is open, in progress, under review or ongoing, de-duplicated by file number, matched against the full text of all 7,167 documents we hold from the Trust’s own library. “Silent” means the file appears in the record and its most recent appearance predates the date given. Source. Islands Trust applications register and public document library, as held in this project’s archive (2026-08-31).

GB-RZ-2007.1 — 24 appearances in the Trust’s own meeting record, the last on 2014-07-17. A Gabriola rezoning with twenty-four appearances in the Trust’s own meeting record, the last of them in July 2014. It is still published as in progress. North Pender’s NP-RZ-2011.1 and .2 went quiet in September 2012; Hornby’s HO-RZ-2012.1 in May 2013.

This is a record-reconciliation question, not a processing-time estimate. Publishing each file’s disposition and relevant dates would let residents distinguish an active application, applicant delay, withdrawal and a completed decision. We have not established those outcomes for this cohort.

This belongs with the rest of the Trust’s record-keeping problems — the accessibility audit covers the documents that are unreadable, and the ones that have been removed outright.

We withdrew a claim to publish this page

2026-08-31

Withdrawn: “Open rezoning applications on the Islands Trust islands average 7.1 years, and that is how long the Trust takes.”

The average age is real, the interpretation was wrong. Checking every open rezoning against the Trust’s own meeting record showed that many of them stopped appearing in it years ago — so the age of an open file measures how long the register has gone un-updated, not how long the work takes. The processing-time claim is withdrawn. We could not measure processing time at all, because the published record does not contain decision dates.

Two data-quality problems in the register weakened the original counts as well: the same file appears under several islands (NP-RZ-2011.1 is filed under North Pender, South Pender and Saturna), and near-duplicate rows exist (GB-RZ-2024-0091, GB-RZ-2024.91 and GB-RZ-2024.091 are one application). The 139 figure above is de-duplicated by file number; the earlier one was not.

The island that took local control did not build medium density either

Method. New homes registered under the Homeowner Protection Act. A null is the Province’s privacy suppression, applied where fewer than five homes were registered in a year — so a null means “between zero and four”, not “unknown”. Bowen is the only island in this dataset because it is the only island that is a municipality; the twelve Trust islands are invisible inside regional district totals. Source. Province of British Columbia, New Homes Registry 2016–2024 (2024).

★ This one goes against us. Bowen Island has run its own planning department since 2000. It is the island that took local control, and in seven of nine years it registered fewer than five multi-unit homes — the Province suppressed the figure for privacy. Six in 2017, six in 2019. Single detached houses carried on at roughly twenty-five a year throughout. If the implied promise of incorporation is that local control delivers medium density, Bowen is not evidence for it, and anyone making that promise should have to answer this table.

What this page cannot tell you

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