Letter sent to Victoria’s Mayor and Council and City Manager’s office, regarding the City’s potential withdrawal from the UDI development/real estate lobby.

Letter sent to Victoria’s Mayor and Council and City Manager’s office, regarding the City’s potential withdrawal from the UDI development/real estate lobby.

By Sasha Izard
Sept 6, 2025

2 days ago on Sept 4, 2025 – Victoria’s City Council deliberated on the following motion:

City Councillors Hammond and Gardiner put forward Motion to “Terminate Victoria’s membership in the Urban Development Institute” “effective immediately”. – CRD Watch Homepage

The Transcript of the council deliberations at the Sept 4, meeting can be read at the following link:

Transcript of City of Victoria Council Deliberation on Motion put forward by Councillors Hammond and Gardiner to “Terminate Victoria’s membership in the Urban Development Institute”. (Sept 4, 2025) – CRD Watch Homepage

The council member motion for immediately ending the city’s membership in the lobbying organization was voted by all but the two councillors that put it forward to be referred to another day, postponed approximately a week or several after those deliberations.

Much of the content of the deliberations were notably at a superficial level, but those involved cannot claim, nor feign ignorance of the serious issues involved.

—————————————————————————————————

Several days prior to the deliberations, I sent the following letter to Victoria’s mayor and councillors, as well as to Legislative Services, and the City Manager’s office, on Sept 1, 2025:

“Hello, I am submitting a letter to be included in the correspondence for the Thursday Sept 4, 2025 City of Victoria Committee of the Whole Meeting, agenda item H.4:

“Council Member Motion: Terminate Victoria’s membership in the Urban Development Institute”

Description: “A Council Member Motion regarding terminating Victoria’s membership in the Urban Development Institute, a lobbying organization for the development industry.” As mentioned in the Motion, over the last 2 and a half years, 4 municipalities have pulled their UDI memberships on Southern Vancouver Island, in addition to the regional government the Capital Regional District, which pulled its membership from the UDI after 23 years.

Why have these local government entities on the Southern Vancouver Island all decided to discontinue their organization’s paid memberships with the registered lobbying group for corporate development/real estate interests?

I think the answer is self-evident, because the ‘potential’ conflicts of interest of local governments (much of the function of which determines zoning policy), being paying members using public tax dollars, of a lobbying organization for corporate development and real estate interests is simply far too glaring in the light of day.

The District of Oak Bay and the CRD withdrew by staff decisions.

Of the 3 councils that voted to end their memberships in the organization (Saanich, View Royal and the District of Sooke); in each case, the votes by the elected officials were unanimous. Not one elected official in these municipalities voted for their branch of government to remain a paying member of the lobbying group. Separation of lobby and state is a most basic precursor of a democratic society, and when it comes to voting, as long as the issue is on the table and on the camera, elected officials have a tendency to recognize this.

As I learned through Freedom of Information and through communications with the City, the City of Victoria did not vote to join the UDI as a paying member by a vote from elected officials. The decision to join the UDI was made unilaterally by staff using public funds, without elected officials signing off on the decision.

Does this seem appropriate? Should unelected staff members be signing an entire branch of government up to be a paying member of a lobbying organization in the first place, and then in the second place, without direction to do so by the actual elected officials?

Freedom of Information requests to the various municipalities in the Greater Victoria Region that joined the UDI as paying members, revealed that of the 8 that joined the UDI over the last 2 decades (half of them have since left in the last 2 and a half years), only one municipality had elected officials that actually voted for their municipality to join the UDI as a member. That was the District of Saanich, approaching 7 years ago.

Of the 8 municipalities to become paying members of the UDI, 7 municipalities out of the 8 joined the UDI as paying members without votes from elected officials.

In the case of the Township of View Royal, it turned out the elected officials were not even informed of the decision by their staff for their District to become a paying member of the UDI.

When confronted on this issue, View Royal staff finally and belatedly reported on the membership join many months after to the elected officials. At that meeting, the View Royal September 12, 2023 Committee of the Whole – the UDI Capital Region’s Executive Director of many years, told View Royal Council during public input: “UDI is not a lobbying group.” However, that person just so happened to be simultaneously registered on the BC Lobbyists Registry entry for the UDI, as “In-House Lobbyist” for that organization.

2 years later, the UDI Capital Region no longer has an Executive Director listed as staff.

When the elected officials of Sooke learned that the district had joined the UDI as a paying member without their votes, they provided the UDI an entire year to explain to the elected officials about their lobbying activities. More than a year passed. The UDI did not show up. They cancelled twice, and finally they notified the District that they would not be meeting them, at any foreseen time in the future.

Why given an entire year, would the UDI not explain their lobbying activities to the elected officials, who had not voted for their municipality to join the UDI in the first place?

The way it appears to me, the UDI cannot explain their lobbying activities to local governments publicly. To do so is far too incriminating for the organization. The day is over for local governments to be paying lobbying organizations to lobby them and other levels of government, especially when the lobbying organization has among its membership hundreds of paying corporate members that it offers political influence to, that represent billions of dollars in outside private interests that stand to profit from favourable decisions to them by the City.

The cat is out of the bag, and it is not going back in.
.
The UDI targets all levels of government with their “advocacy”, as is clear in their annual reports and newsletter, but in terms of registering lobbying activity, they are only registered at the Provincial level.

Urban Development Institute / Anne McMullin, President & CEO – 12-Month Lobbying Summary – Lobbyists Registry – Office of the Registrar or Lobbying of BC

The UDI currently does not need to register lobbying activity to the City of Victoria, because unlike the Province, the City does not have a Lobbyist Registry. This clearly demonstrates why it is crucial for local governments to have a lobbyist registry, so that staffers and elected officials are informed and are conscious of, as to who and what organizations are they are dealing with, and as a result they are able to avoid running into potential conflict of interest issues, like for example using public funds to pay lobbying organizations representing private interests, for memberships, or for attending their events using tax dollars, or relying on them too much in the operating of government institutions, including in land-use planning and policy generation/implementation, which the UDI has a particularly keen focus on.

The UDI has for years played a double game, where they legally register lobbying activity commonly under the euphemism of “advocating”, and then they turn around to local governments including elected officials and act as if they are just there to benevolently educate them and expect to get paid for it using taxpayer funds. At the same time they meet behind the scenes with City staffers in the form of so called “liaison meetings” between the City of Victoria and the lobbying organization, and they compare notes and discuss policy, as revealed by Freedom of Information and from the UDI’s own material.

While the UDI register their lobbying activity commonly as “advocating” they also advertised in their Policy and Advocacy Updates newsletter in March 2023 below a subheading “City of Victoria” nonetheless: “ If you are working in a municipality listed here and would like to be involved in our advocacy work, please contact [the UDI Capital Region’s Executive Director]”. Yes, the same one that denied that the UDI is a lobbying group, despite being registered as the UDI’s in-house lobbyist on the Province’s registry.

The following is a screenshot of two subsequent pages from the UDI’s Policy and Advocacy Updates News letter from March 2023, as revealed by Freedom of Information:

Note the text below: “If you are working in a municipality listed here and would like to be involved in our advocacy work, please contact” [The UDI Capital Region’s Executive Director/registered UDI in-house lobbyist with the Province].

That this text was below several municipalities including The City of Victoria, shows that the UDI was seeking municipal employees including the City of Victoria’s to be involved with their advocacy work. When the UDI legally files lobbying registrations, they typically file those lobbying activities as “advocating”, which shows that the UDI uses the terms lobbying and advocating synonymously.

The following are excerpts from Freedom of Information of minutes of a meeting between City of Victoria staff, and the UDI:

Were City of Victoria staff in the meeting with the lobbying organization, asking for the UDI to write a letter asking for them be delegated more authority? Presumably this would be delegated authority taken from the authority of the elected officials?

The following is from an email sent to CALUCs from a City of Victoria staffer:

“Subject: Delegating Minor Variances

Date: May 9, 2023 at 3:27:10 PM PDT”

“Hello CALUCs,

Council passed a motion at the February 9, 2023 daytime Council Meeting directing staff to seek input from the UDI and the CALUCs and bring forward recommendations to delegate minor variances to staff for Council’s consideration (see the January 19, 2023 Committee of the Whole staff report for more information here). A potential benefit of expanding delegated authority is that applications could advance through the system more quickly if only minor variances are required and if it complies with Council-adopted guidelines.

We are reaching out for your input on this proposed change to help staff determine potential variances and define appropriate parameters and guidelines. The following list reflects recent variance applications and offers some examples of the types of variances that could be delegated:

setbacks and site coverage to accommodate accessibility features
setback for the location of rooftop mechanical screening from the outer edge of a roof
setbacks to heat pumps and landscaping structures such as pergolas
projections into setbacks for stairs, ramps, porches, and eaves
siting and height variances where it can be demonstrated that there is a negligible impact on neighbours or the public realm
distance from a parking stall to a street
height clearance for underground parking stalls.

If you have thoughts on this, please email me directly by June 5, 2023 for consideration in our analysis and recommendations to Council. Please give me a call at the number below if you have any questions.”

The following is quoted from the Archive.org Waybackmachine snapshot of the UDI Capital Region’s Policy and Advocacy Updates page prior to that website being taken down by the UDI.

Policy and Advocacy Updates – UDI Capital Region

“Oct 26, 2021 – Development Approvals Process Review (DAPR)

Development Approvals Process Review

UDI participated in the Ministry’s Development Approvals Process Review (DAPR). On October 26, the Hon. Josie Osborne, Minister of Municipal Affairs, introduced Bill 26, the Municipal Affairs Statutes Amendment Act (No. 2), 2021. It includes several DAPR recommended improvements that would “…give local governments more powers to simplify and speed up their development approvals processes…”. If the legislation is passed:

It would remove “…the default requirement for local governments to hold public hearings for zoning bylaw amendments that are consistent with the official community plan;”
Councils would be able to delegate decision-making powers for minor development variance permit decisions to their municipal staff”

We’ve seen how the UDI’s “advocacy” reaches and influences varying levels of government.

As the UDI Capital Region’s former Executive Director put it to View Royal Council on Sept 12, 2023:

“We do extensive policy work, um, and this is where we look at informed changes across all levels of government. So we try to align the uh, policies, that are being, um brought forward by the federal government, the provincial government, and the municipal government, and to kind of help them align, so that they don’t, uh, collide with each other.”

This is all very apparent from material received from all levels of government through Freedom of Information and collisions are not rare events.

As a recent FOI freedom the City of Victoria revealed the UDI and staff had a scheduling problem, when they were scheduled to meet, but the Province was going to announce recent legislative changes to local governments at that time. The Housing Legislation put forward in 2023, overrode municipal powers and the content in the legislation was based on much on what the UDI had been lobbying them to implement.

To ensure that many strings moving simultaneously, operate to the same tune, and that they do not collide in the process, takes considerable talent, dexterity, energy, networking, money, and a great deal of multitasking, and multi-level information. It takes a certain mastery of the process to pull off such a feat.

Intergovernmental relations, is a key focus of the UDI as evinced by their Constitution, which includes the following aim:

Collision is always a possibility in such a scenario, but what about potential conflicts with such myriad interests at work, working together closely in co-operation and well aligned?

Please also note the text in the first of the 2 sections of the UDI’s Policy and Advocacy Updates newsletter posted previously: “If you are interested in connecting with the University of Victoria Real Estate Club for your next public hearing, please contact” [student’s contact info]. Yes, the UDI was advertising that in their newsletter to their members including governmental members.

The last posted UDI-Capital Region’s Executive Director was also on the UVIC Real Estate Club board of directors last year. Of that 8-person board, 2 were actual students, while 4 Directors, were also current UDI directors, and 2 former UDI directors were also on that board.

Since I exposed this issue to the administration of the University Victoria’s Gustavson School of Business, the club was compelled to rename its Board of Directors the “Advisory Board” containing all the same people as the previous UVICREC Board of Directors. People — UVic Real Estate

The members of the club have spoken under its banner at various public hearings in the City of Victoria, in favour of the developments of UDI member companies. The UDI followed by its member companies are the chief financiers of the club, and the club offers advocacy regarding development, much like the UDI and its directors that mentor it.

This was the page above the 2 sections already posted previously in the UDI’s newsletter:

The UDI’s advocacy towards the City of Victoria was mentioned in the UDI newsletter. It is also included under a list of the UDI’s “Advocacy Initiatives” in their 2022-2023 Annual Report. See below:

While the City of Victoria does not have a Lobbyist Registry, nor do any municipalities in the CRD, nor does the CRD itself have a Lobbyist Registry – there is evidence from the CRD’s own minutes that lobbying takes place from the UDI at the local government level. As you know regional governments are formations of local governments, and thus are at the local level of government.

The UDI up until recently, had a permanent seat on the CRD’s Regional Housing Advisory Committee (RHAC) since 2019, although that committee’s activities were suspended by the CRD pending review, after the practically closed to the public nature of the committee meetings, last year received legal scrutiny. The CRD had ended its UDI membership after 23 years, only months earlier.

The vast majority of the seats that were on the RHAC have at one time, and in one form or another, been paying members of the UDI.

The following is a quote from the minutes of the June 29, 2022 Regional Housing Advisory Committee meeting at the CRD:

“What can we do as a committee?” [The former UDI-Capital Region Executive Director] suggested RHAC members be more active in finding out what policies municipalities are working on and helping to push these policies forward via advocating and lobbying (e.g., Victoria’s missing middle).”

Note: This was prior to the local government election of 2022, where Missing Middle was a key election issue in the City of Victoria. The Missing Middle Housing Initiative had not been approved yet in the City of Victoria, nor in any municipality in the CRD, yet the UDI had been pushing for missing middle housing for years, and it is one of the “Advocacy Initiatives” listed under the City of Victoria that the UDI mentioned in its Annual Report of 2022-2023, in the section I showed previously.

The following are two excerpts are from minutes obtained from Freedom of Information of a UDI/City of Victoria staff municipal liaison committee meeting held just before the election. The meeting took place on Sept 27, 2022:

As you can see advocating and lobbying are used side by side. What is the difference? Can anyone tell? Is it simply a euphemism for lobbying? Even advocating and lobbying are terms used frequently in lobbying registration forms and often it seems can be used interchangeably.

The following is a screenshot of the UDI’s lobbying registrations on the BC Lobbyists Registry showing that the UDI files lobbying activities as “advocating”.

Do any of the items they advocate/lobby for look familiar? Notice how they target municipal zoning in their lobbying activities? The reason for that is clear, the UDI seeks favourable zoning e.g. upzoning, which makes their members involved in development and real estate huge potential profits, and they attempt to take the public out of the democratic process e.g. through pre-zoning/waiving public hearings based on staff alleged OCP compliance of projects.

The UDI lobbied the Province for example for the very conditions that came to fruition in Bills 44 and 47 that have provisions that override municipal zoning through vast amounts of blanket upzoning, which removes vast swathes of public hearings in the process.

As for the RHAC, it is currently suspended during ongoing reviews of its operations, and it has recently been opened to all members of the public for attendance should it ever continue again in some reformed version (I was informed if it does, the UDI will not have a permanent seat on it anymore). This shift in regard to the RHAC took place after the CRD undertook a look at the legal basis for its Terms of Referencing requiring that for members of the public to attend the committee meetings, they would need both the approval of a committee member and of the committee Chair for attending those meetings. The CRD as mentioned has also withdrawn from the UDI after 23 years of being a member. The City of Victoria also like the UDI had a seat on that Committee.

Are the UDI lobbying for municipal interests as one councillor, posed a question in Sooke? No, I think the evidence is quite clear, that the UDI is lobbying against local government powers over zoning and against public input during local government council meetings, something that arguably violates Charter Rights in the Canadian Constitution in regard to freedom of expression and public participation in the democratic process.

The UDI has lobbied the province successfully to eliminate vast swathes of public hearings from local governments. They have successfully lobbied the province to adopt enforceable housing targets, and they have lobbied the province to adopt a carrot and stick approach in dealing with municipalities that do not conform to their agenda, which includes potentially cutting infrastructure funding to them, if they aren’t growing fast enough, in key areas well-served by transit, and by raising taxes on residents living in those areas:

These following excerpts regarding “enforceable housing targets” are from a UDI advocacy/lobbying letter to the Province of BC dated to March 10, 2022 titled: “Establishing and Implementing Housing Targets”.

So, the UDI lobbies the Provincial government to take actions, including meting out punitive measures where perceived necessary, to municipalities that are not conforming with the UDI’s construction agenda, and such actions will they hope “compel municipalities to prioritize the delivery of housing.” What is downgraded in such a forced priority list, local ecology perhaps?

And who benefits from the UDI lobbying the Province to take power over zoning from the municipalities and reduce public input in local government? Well you guessed it, the development industry that the UDI offers paid representation for, through their memberships, which are far more expensive for companies than for local government entities, which the UDI is very happy to have as their members, because then they can show how much influence and access they have with government to their corporate members and prospective corporate members.

So as you can see, the UDI is lobbying against local government power and against democratic public input opportunities at the local level, through pre-zoning, the waiving of public hearings through OCP compliance and compliance to provincial legislation the content of which that they have advocated/lobbied for etc.

Or as it was put in a Feb 7, 2024 UDI-Victoria municipal liaison meeting as revealed by Freedom of Information:

For more information on the UDI’s lobbying that found manifestation in the Province’s housing bills, I offer reading my recent in-depth article on this subject:

https://crdwatch.ca/2024/11/22/freedom-of-information-reveals-that-the-province-of-b-c-was-working-to-implement-what-the-registered-lobbying-organization-the-urban-development-institute-had-been-pushing-for-this-culminated-in/

Now that I have shown you what their target of lobbying is (the government in general), the reason why they only register lobbying activity at the Provincial level of government, is due to the BC Lobbyists Transparency Act (LTA), which requires lobbying organizations to comply with it. Both “lobbying” and “organization” are defined in the act, and lobbying organizations are required to register their lobbying activity on the BC Lobbyists Registry.

I highly recommend reading the Act and familiarizing yourselves with the contents, if you haven’t already:

https://www.bclaws.gov.bc.ca/civix/document/id/complete/statreg/01042_01

That is why the UDI has to by Law, inform the Provincial Government of B.C. of their lobbying activity to it and hence why they have the registration and label of lobbying, as they both have in the past and continue to do so.

I suggest that the City of Victoria draft Bylaws that are similar, for the creation of its own Lobbyist Registry, so that its staff and elected officials can identify lobbying organizations and lobbying of the District in the future. I think it is a crucial component of good governance for government officials to be well informed of who and what are lobbying them and their branch/level of government, and who and what organizations are doing so, as well as the purposes and functions of such organizations that government funds are being sent to.

In regard to their mandate, here is the direct proof that the UDI’s mandate is to approach local governments and convince them of things for developers:

The following was from the front page of the UDI Capital Region website before it was taken down at the end of 2023:

“PRIMARY AREAS OF FOCUS

Government Relations

We are the public voice for Capital Region’s development industry, liaising with local governments and the media to promote balanced, well-planned and sustainable communities.”

“Your voice in the Capital Region’s development industry

Join the team of industry leaders and professionals who are influencing the issues that affect your bottom line.”

—————————————————————————————————

So, there you have it, you have seen in this letter the direct evidence that the UDI is a lobbying group, including from its own registrations on the BC Lobbyists Registry, and as shown previously, that it has been lobbying the Provincial Government to take away local powers over zoning, and reduce public input through pre-zoning etc. All of that is in their registrations on the BC Lobbyists Registry.

The UDI Edmonton Metro has been even more explicit at their targeting of municipalities and their planning departments on their website. The following was a screenshot of http://www.udiedmontonmetro.com/influence taken within the last 2 years. That webpage was later taken down and replaced. I guess they realized that the reference to influence was too explicit. They later redirected to a new page called “Our Impact” Our Impact – Urban Development Institute Edmonton Metro. The Link to “Our Impact” on their front page at present can be seen in the 2nd screenshot below:

Note: The target of their influence and “advocacy” (The UDI files its lobbying activities with the BC Lobbyists Registry frequently as “advocating”): District Planning, including municipal and elected officials.

As elected officials, there should be no confusion when you finally do make the decision as other municipalities and the regional government have recently – whether or not to discontinue the City’s paid membership from the lobbying organization representing the interests of hundreds of companies that profit from development and real estate, and seek (successfully) to influence all levels of governments to influence the issues that affect their bottom line.

The following is a quote from the former UDI Capital Region’s Executive Director at the Sept 12, 2023 View Royal Committee of the Whole:

“UDI representatives get together with the directors of the develop or the departments that work directly with development, and we exchange information and we help the municipalities out by creating working groups that can inform and, and help make decisions, uh for your policies.”

As such, it becomes major cause for concern in a democracy, when unelected staffers are signing up without votes by elected officials, and with taxpayer dollars, entire municipalities to be paying members of such a lobbying group.

The fact that the UDI refused to engage with the elected officials of the District of Sooke publicly after over a year that was provided to them to explain their organization and its lobbying activities, when asked to by Motion, should be all the information you need to protect the public interest from ‘potential’ undue influence from an outside lobbying group.

If you have any more questions, feel welcome to reach out to me.

You are now very well informed about this shadowy lobbying organization that is now hiding from the public its members directory and list of committees that work behind the scenes with numerous branches of government.

Please do the right thing and separate lobby and state in the City of Victoria.

The following is the screenshot of the full page from which the excerpt was taken from:

The following is quoted from the Province of BC’s Press Release this year, in regard to allowing developers to defer full payment of DCCs for several years:

“Anne McMullin, president and CEO, Urban Development Institute –

“The requirement to pay development fees up front has become increasingly onerous for builders, especially as fees rise and access to capital tightens. By shifting payment to occupancy, the provincial government is enabling more projects to move forward. This policy lowers early-stage financing costs, frees up capital for construction and helps builders reinvest in new housing.” “

BC Gov News

Archived copy:

BC Gov News

In essence a year after what looks like the UDI having asked City of Victoria staff to lobby the Province to adopt their preferred policy, the Province implemented that policy, quoting the head of the UDI in the press release

Recapping the section from the UDI-City of Victoria liaison committee meeting minutes:.