The Challenges of Developing Affordable Housing

Jan 17, 2023

By Stephanie Slater, Co-Chair, Denman Community Land Trust Association

I’ve been known to say that developing affordable housing is not an undertaking for the faint of heart. In fact, it’s a pursuit that requires, patience, persistence, and a passion for the cause.

It shouldn’t be this difficult, however. Here are some observations of the key challenges, based on the experience of the Denman Community Land Trust Association (DCLTA) in trying to develop the Pepper Lane Seniors Affordable Housing Project.

Multiple jurisdictions

Regulatory bodies include:
• the Agricultural Land Commission
• Islands Trust
• BC Hydro
• Ministry of Transportation and Infrastructure
• Ministry of FLNRO (Forests, Lands, Natural Resource Operations)
• Ministry of Municipal Affairs

Maneuvering through the requirements of each of these agencies is a complex and demanding process. And they don’t always play nice with each other – for example, the Islands Trust and FLNRO wrangled for about a year about how to share authority over water issues.

Unrealistic/unreasonable demands:

If Pepper Lane had gone through, it would have had six “encumbrances” on the title. Some of these are reasonable (e.g., Hydro right-of-way) but some are unnecessarily onerous. One example is the Trust’s insistence on a water monitoring covenant – developed at the DCLTA’s expense – despite the fact that wells installed on the property by the DCLTA were monitored weekly and we offered to freely share this data with the Trust.

Another example is a suggestion from the Ministry of Agriculture that there be 200-meter setbacks on the property. This Ministry isn’t officially involved in approving such developments but they were consulted and apparently pulled something out of a plan for a massive condo development. Such a setback on the two-acre property for Pepper Lane wouldn’t have left any room for development! Unfortunately, there are more examples, but let’s move on to…


The Agricultural Land Commission made mistakes about the request to exempt the project property from the Agricultural Land Reserve: first, they applied the exemption to the full four-acre property and not just the two-acre project site that was to be subdivided. Then they failed to exempt the laneway access to the property. It took three years to correct these mistakes.

The DCLTA began working on the Pepper Lane project in 2014. Our re-zoning application to the Islands Trust is dated September 2017. Re-zoning was only approved five years later in September 2022. When they did give third reading to the bylaws, it then took more than a year for the Ministry of Municipal Affairs to approve them (a step required before the Trust can adopt them). Re-zoning can be a complex process that needs to handled carefully and transparently but governments need to expedite this process so it doesn’t drag on for years.

Limited funding sources

Early DCLTA boards did not intend to seek external financing for this project. They planned to rely on community financing options and a small mortgage that would be funded from rental revenue. However, construction costs have risen incrementally since the project was first conceived in 2014 and the current board determined that external financing from sources such as BC Housing and the Canada Mortgage and Housing Corporation (CMHC) is necessary to ensure a viable project.

There is a lot of competition for these funds – and new funding from BC Housing has been delayed by the major internal review of that organization (frustrating, because if our intended land had been ready for affordable housing use a few years ago, we were assured that BCH would likely be able to fund the $2.5 million construction cost quickly).

The Comox Valley Regional District has been supportive with small grants, however we were surprised to learn it made a $100,000 funding commitment for the Beulah Creek housing project on Hornby. There was no call for funding proposals and we haven’t been able to determine what criteria was applied in the decision to support a second affordable housing project on Hornby when Denman Island, with a larger population, has none.


This is just a brief summary of the kinds of challenges faced by groups such as ours. We hope the new premier’s stated priority of creating more affordable housing signals a willingness to eliminate these barriers, as many are certainly within provincial jurisdiction.
Meanwhile, the DCLTA remains dedicated to finding land for affordable housing on Denman Island. While our primary focus since 2014 has been the project to build seniors affordable housing, our mandate is broader. We want to support affordable housing for all low-income residents and our constitution also allows us to make land available to other non-profit and/or charitable organizations for development as affordable housing.

Our board is committed to exploring all possible options to make affordable housing a reality on Denman Island.

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