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A 2017 letter from the Urban Development Institute (UDI) to the Federal government offered a series of recommendations, including density targets around transit stations/corridors and for the adoption of TODs (Transit Oriented Developments).

This and other letters from the UDI to the Feds, begs the question of why the UDI, which is registered on the BC Lobbyists Registry, is not registered on the Federal level of government, and whether or not the Feds have intentionally designed legislation that allows lobbying at the Federal level to not be registered by not meeting a dubious threshold set by the Feds.



By Sasha Izard Dec 10, 2024

The 2017 letter from the UDI to the federal government can be read in full at this link: [October 20, 2017 UDI letter to the Federal Goverment] from the House of Commons website ourcommons.ca

At present, I have been unable to locate Urban Development Institute (UDI) registrations of lobbying activity to the federal government within the last 15 years.

On April 5, 2024, In regard to a different UDI letter to a Federal Minister, I sent the following email to the Federal Government:

Hello Office of the Commissioner of Lobbying of Canada,

I have a question:

If an organization has contacted Federal Ministers by email asking for/recommending the implementation of the organization’s preferred policies.  Is that considered lobbying and is it required for such actions to be registered on the Federal Registration of Lobbyists?

Thank you,
Sasha Izard

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The Federal lobbyist Commissioner’s Office responded:

Hello Sasha Izard,

Thank you for your email.

For organizations, lobbying is communicating, with federal public office holders, on behalf of the employer, regarding:

•              the making, developing or amending of federal legislative proposals, bills or resolutions, regulations, policies or programs;

•              the awarding of federal grants, contributions or other financial benefits;

If an organization’s lobbying activities by all paid employees represent A significant part of duties (“The 20% rule”), the most senior employee (the registrant) would be required to register the organization within 2 months of meeting this threshold. In the registration, the registrant would be required to name all employees who undertake lobbying activities on behalf of the organization.

Contacting Federal Ministers by email asking for/recommending the implementation of the organization’s preferred policies, is considered lobbying. As such, this organization may be required to register if they meet registration requirements under the Lobbying Act.

Please do not hesitate to contact us with any questions or if you require further clarification.

Sincerely,”

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The following from the email, I think requires some serious scrutiny:

“If an organization’s lobbying activities by all paid employees represent A significant part of duties (“The 20% rule”), the most senior employee (the registrant) would be required to register the organization within 2 months of meeting this threshold. In the registration, the registrant would be required to name all employees who undertake lobbying activities on behalf of the organization.

Has this seemingly arbitrary threshold been setup so that other lobbying activity that does not meet that bar, go under the radar by not being required to be registered on the federal level?

In this case, is lobbying activity aimed at the Federal government from the organization that calls itself the premier voice of the real estate and development industry in B.C., which makes such bold claims about its economic impact, actually below the threshold of needing to be registered on the Federal Lobbyist Registry?

If that is below the threshold, what is actually above the threshold of requiring registration of lobbying activity to the Feds?

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I responded: “Hello Office of the Commissioner of Lobbying of Canada.

Thank you.

I turn over this FOI to you for review.

You will note that on pages 33-39, the Urban Development institute is “Contacting Federal Ministers by email asking for/recommending the implementation of the organization’s preferred policies, is considered lobbying.”

These [potential] lobbying activities have not been registered on the Federal Lobbyist Registry.”

This was in regard to the following letter:

The letter concluded:

The letter was carbon copied to the following:

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The following is excerpted from the Oct 20, 2017 letter from the UDI to the Federal Government, in which the UDI recommended that Transit Oriented Developments (TODs), as well as density targets around transit be adopted:

Excerpted section:

Note: A couple days after this article was published, the following article was published in the National Post: Paul Deegan: Our once leading lobbying regime is lagging | National Post Dec 12, 2024

The article discusses the same 20% rule and other massive loopholes that are allowing vast amounts of lobbying to go unregistered on the federal level.