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• What is an improvement district?
• Who has authority over improvement districts?
• GFPID Governance
• Options for resolving local government-related concerns

IMPROVEMENT DISTRICTS

What is an improvement district?

Province of BC, Improvement Districts

“Improvement districts are autonomous local government bodies responsible for providing one or more local services for the benefit of the residents in a community. … Improvement districts are usually located in rural areas of the province where there was no alternative form of local governance available, suitable, or desirable for the community. They are similar in structure to a municipality but are more informal and only provide direct services such as waterworks, fire protection or street lighting.” (IDMp9)

• Provincial government webpage on Improvement Districts. Includes links to policy and regulatory documents.
• Improvement District Governance
• BC Improvement Districts BC Improvement District Manual (IDM p3) “This Manual has been prepared by the Ministry of Community Services (the Ministry) as a guide for improvement district trustees, staff and others who have an interest in the administration and operation of improvement districts.”
• Improvement District Trustee Handbook (p1) “This Handbook is intended to introduce trustees to the fundamentals of improvement districts and explain the role of the trustees - including their financial responsibilities and powers. The Handbook may also be useful to anyone interested in becoming a trustee, or who wants a better understanding of how improvement districts are governed.”

Under the Local Government Act, “improvement districts have authority to directly levy and collect property taxes to support the services they provide to properties within their boundaries.” Gabriola’s tax levies are paid as part of our property taxes; these are collected by the RDN and the funds are distributed to the improvement district in July of each year. 

How is an improvement district governed?

“The improvement district’s Letters Patent, applicable sections of the Local Government Act, and other applicable provincial statutes outline the powers that can be exercised by the board of trustees. These powers include the ability to enact and enforce its regulations and charges, to assess and collect taxes, to acquire, hold and dispose of lands, to borrow money and to expropriate lands required to carry out its functions. The board of trustees exercise these powers through the passage of resolutions and bylaws.” (IDM p9)

• Improvement district governance

Letters Patent

This is the document approving the incorporation of an improvement district by the provincial government through Cabinet Order. “The Letters Patent contain: the name of the improvement district; its boundary; and, the services which it would provide to the residents within that boundary.” (IDM p3)

Bylaws

“Section 746 of the Local Government Act, states all improvement district matters are decided by passing a bylaw or a resolution. Both are similar insofar as they record a decision made by a majority of the trustees that govern the operation and administration of the improvement district; however, resolutions differ because they can be effective immediately upon passage whereas bylaws must be registered with the Inspector of Municipalities before becoming effective. … Bylaws are commonly passed for levying taxes, regulating the services operated by the improvement district and for borrowing money. (p15)

“…All bylaws passed by the board of trustees must be registered with the Inspector of Municipalities and the bylaws are not effective until that approval is granted. In addition, each year the improvement district’s audited financial statements and the minutes of its annual general meeting are reviewed and filed with the Ministry.” (p9) (IDM)

Bylaw requirements are set out on the provincial government’s website.

Trustees

“Improvement districts are administered by an elected board of trustees, one of whom has the additional duty of chair. Each trustee is elected for a three-year term by the eligible landowners of the improvement district.” (IDM)

Chair

“The chair presides at board meetings, decides on points of order, co-signs meeting minutes and adopted bylaws, and sets the tone for meetings through their leadership style. The chair may also be selected by the board to represent the improvement district in meetings or to the media. … [T]he chair has one vote.”

Officers

The provincial government sets out the administrative requirements for improvement districts. “Every improvement district must have two officer positions, established by bylaw, to perform key roles in administering the improvement district. … One position is responsible for corporate administration and the other is responsible for financial administration. A number of mandatory duties are assigned under the Local Government Act to each position, but the board may assign additional duties.

"... The same person can be appointed to both positions and assigned any title the board decides is appropriate such as manager, administrator, or corporate officer.”

The mandatory duties as described are:

Corporate Officer

• • Corporate administration includes, at a minimum:
  • Preparing accurate meeting minutes and ensuring the safekeeping of minutes, bylaws and other improvement district business records
  • Providing access to all improvement district business records as required by law or authorized by the board of trustees
  • Signing and certifying copies of bylaws and other documents as required or requested
  • Accepting, on behalf of the improvement district or the board of trustees, notices and documents given or provided to the improvement district or the board of trustees
  • Keeping the improvement district seal and having it affixed to documents as required

Financial Officer

• • Financial administration includes, at a minimum:
  • Receiving all money paid to the improvement district
  • Keeping all funds and securities of the improvement district
  • Expending and disbursing money in the manner authorized by the board of trustees
  • Investing funds in investments
  • Preparing, maintaining and keeping safe the accurate records and full accounts of the improvement district’s financial affairs
  • Compiling and supplying information on the financial affairs of the improvement district required by the Inspector of Municipalities.

NOTE: Fire departments typically use "Officers" as a term to distinguishing between hierarchical classes of authority, but this can lead to confusion as the same designation is used to identify Corporate and Financial Officers. Although both employees and the Corporate/Financial Officers report to the Board, their responsibilities and duties are functionally very distinct:

• Corporate/Financial Officers are mandated by law, serving the functions of, and reporting to, the local government (i.e. the Board).
• GVFD Officers are internal designations applied to employees who carry out the work of the improvement district, with lower levels reporting to the Fire Chief, who reports to the Board.

Employees

“While trustees govern the improvement district and set priorities, employees are responsible for the implementation of the priorities and decisions, and for overseeing the day-to-day operations needed to provide services.” (Local Governments)

Financial management

• Improvement district finance
• Reporting requirements:
  • “An improvement district must produce financial statements for the preceding year for presentation at the annual general meeting. Those statements must be audited by a qualified accountant.”
  • “Local governments must annually submit to the Ministry of Housing and Municipal Affairs their forms by May 15. These forms are a standardized presentation of a local government's financial position and activities, such as assets, liabilities, revenue, expenditures, over the course of the previous fiscal year (based on the audited financial statements).”

Meetings

• Improvement district meetings

Privacy legislation

Personal information "means recorded information about an identifiable individual other than contact information." In the private sector, rules around privacy and the use of personal information are set by the Personal Information Protection Act (PIPA). The Freedom of Information and Protection of Privacy Act (FIPPA) regulates and limits the collection and disclosure of personal information in the public sector—how "government ministries and other public bodies must collect, use, disclose, store and dispose of personal information appropriately to protect personal privacy" while providing public access to information.

"Improvement districts are governed by the Freedom of Information and Protection of Privacy Act. Staff must be prepared to provide bylaws, meeting minutes, budgets and the audited financial statements, among other information, when requested by the public. ... However, the improvement district has a responsibility to protect the privacy of the landowners, staff, trustees and other individuals." (Improvement district accounting and reporting requirements)

Who has authority over improvement districts?

Oversight

The Ministry of Community Services is charged with formal oversight of improvement districts, exercising it through the Inspector of Municipalities, but their involvement is limited.

A 2006 document called “Improvement District Governance: Policy Statement,” goes into the history of improvement districts and identifies a number of issues associated with them. It explains that improvement districts are a historical legacy from the 1920s, and that their  framework is potentially problematic with regard to public accountability, administrative effectiveness, relations between improvement districts and regional districts, and growth management. Government policy overall has therefore been to convert them to regional district and municipal jurisdictions, but the province has chosen to encourage this through incremental and voluntary changes.

Legislation introduced in 2000 (Bill 14, Local Government Statutes Amendment Act) updated some requirements relating to Improvement District functions and procedures, and is part of these incremental changes. Consultations have been held with regard to further legislative changes but action on the issues discussed is currently deferred as it requires further research and policy development.

Inspector of Municipalities

“The Inspector of Municipalities, appointed by the Lieutenant Governor in Council, is responsible for oversight of local government financial matters and approval of certain local government decisions to ensure consistency with provincial legislation.” Among other things, the Inspector of Municipalities is responsible for:

• Approval of loan authorization an other bylaws
• Reviews of audited financial statements
• Approves local government decisions to ensure consistency with provincial legislation.
• Authority over: has some authority to conduct forensic audit. The Inspector can order the auditor to produce a suppementary report on integrity of  internal controls

SUMMARY: although the Ministry of Community Services has formal oversight of Improvement Districts, it has chosen a largely hands-off approach to dealing with them, and conversion to regional district jurisdictions only happens if a Board requests it.

Other authorities and jurisdictions

Although the Ministry of Community Services is charged with formal oversight of improvement districts, a number of other bodies and/or areas of legislation do have jurisdiction over components of their work or can investigate complaints.

Local Government Act (Part 17)

BC has a range of local government structures within an overall framework operating beneath the level of the provincial government. “The Local Government Act is the primary legislation for regional districts and improvement districts, setting out the framework for structure and operations, as well as the main powers and responsibilities.”

Part 17 of the Local Government Act is specific to Improvement Districts, and sets out legal requirements for the administration and function of the improvement district and its board.

Ombudsperson

The Office of the Ombudsperson has a general responsibility for ensuring fair governance, working “to make sure public sector organizations are treating people fairly and following the rules. We listen to and investigate complaints about local and provincial public sector organizations as well as investigate reports of serious wrongdoing in the provincial government. … We receive a wide-range of complaints about how local and provincial public sector organizations deliver services, make decisions, and communicate with the public. People may have complaints about how or why a specific decision was made, why they are not getting benefits they believe they are entitled to, or may be experiencing lengthy delays in receiving service. These are all examples of complaints we can investigate. If we cannot handle a complaint, we will do our best to refer you to an organization that can.” The Ombudsperson deals with complaints when interactions with the improvement district and Inspector of Municipalities do not provide satisfaction.

Lieutenant Governor and Cabinet

The provincial Cabinet has specific powers relating to the function of improvement districts, including

• approving their Letters Patent
• revoking their Letters Patent (in the event of dissolution)
• setting regulations for meetings

Islands Trust

The Islands Trust has no jurisdiction.

GFPID GOVERNANCE

NOTE: this section includes many links. Where possible we have linked to documents on the GVFD Trustee pages, but many referenced are not available there, so in some cases we have linked to material hosted elsewhere. We look forward to adding more links as they become available.

What are the GFPID’s governing documents?

Letters Patent

• GFPID letters patent

Bylaws

Bylaws linked from gabriolafire.ca, the Gabriola Volunteer Fire Department website.

• Bylaw 66 - deals with Officer positions ; powers, duties and responsibilities
• Bylaw 88 - deals with levying taxes on the land and improvements within  the Gabriola Fire Protection District  hereinafter referred to as the "Improvement District" for fire protection purposes in each of the years 2014 to 2028 inclusive.
• Bylaw 97 - deals with the calling of Meetings
• Bylaw 98 - deals with the establishment of a Fire Department
• Bylaw 100 - deals with Assistance Agreements with other Fire organizations
• Bylaw 102 - deals with Fire Regulations
• Bylaw 103 - deals with the levying of taxes
• Bylaw 104, 105, and 106 - deal with the granting of power to exercise entering a contract about land or works
• Bylaw 107 - deals with the levying of taxes
• Bylaw 108 - deals with establishing multiple capital reserves

Because they are used for levying taxes, a new bylaw must be passed every year for that purpose, and the levy bylaws from the previous year become inactive. A zipfile of inactive bylaws is archived on the Trustees section of the GVFD website (under Bylaws).

GFPID structure

Communications

As per the Trustees page of the GVFD website, all communications filter through one email address, that of the corporate officer. Unless policy has been updated from previous versions, GVFD policy is that "General information regarding non-emergency related fire department operations or activities shall be coordinated and released by the Office of the Fire Chief." See gabriolafire Contact Us page.

Office Hours

May 6/25: The board has hired an interim corporate officer and administrative assistant, Marjorie Colebrook. The position is part-time. Office hours for the immediate future will be Monday and Tuesday, 9-2 and Thursday, nine to four.

Trustees and Chair

There are seven seats on the Board. Trustees are elected for a three year term at the GFPID annual general meeting, which takes place each April; typically 2 seats are up for election each year.

Current chair (effective November 2025): Erik Johnson

Corporate Officer and Financial Officer

The GFPID has combined the role of Corporate and Financial Officers into one position. The position is currently held by Marjorie Colebrook on a temporary contract, pending the hiring of a permanent employee.

Employees

The employees of the GFPID are the officers and firefighters who are paid to perform their firefighting and other emergency services-related duties.

Note that the term "volunteer" is generally used to apply to on-call firefighters who are not salaried, whether they receive some form of remuneration or not. Gabriola firefighters are paid for time spent for on-call responses and other job-related activities.

Fire Department operations are managed by the Fire Chief and Officers. Current positions (as per Sept/24 meeting minutes):

• Fire Chief - salaried position (Will Sprogis)
• Deputy Fire Chief - salaried position (Jamie Ovens)
• 2 Captains (North and South Fire Halls)
• 7 Lieutenants

In April 2025 the GVFD unionized, joining CUPE Local 606.

Meetings

Procedures relating to meetings and minutes of the GFPID are laid out in Bylaw 97.

Regular public meetings

Trustees generally meet on the first Wednesday of the month, at the Albert Reed Memorial Fire Hall, at 730 Church Street. A quorum is set at 4 Trustees.

All Board meetings are open to the public except where the Board passes a Resolution to close all or a portion of a meeting.

Meeting notices, agendas, and video recordings of past meetings are posted to the Meetings and Agendas webpage. The Bylaw requires 7 days notice for providing the Agenda to Trustees, but includes a provision for unanimously waiving this requirement.

Delegations to the Board may be allowed with 7 days notice. Questions from the floor are permitted at the end of meetings.

AGMs

• The AGM is open to all members of the public.
• Date of AGM: the GFPID Letters Patent require that AGMs be held between January 1 and May 1. Ministerial Order M10 (PDF, 736KB) (Order M10) removes the requirement that improvement districts in the schedule hold an annual general meeting during the time frame set out in its Letters Patent (e.g. January 1 to May 1). Improvement districts must hold an annual general meeting at least once every 12 months.
• Notice of AGM must be given 14 days in advance and published in the local newspaper.
• The first meeting of a new Board must be held within 30 days of the preceding AGM; normally the GFPID holds this meeting immediately after the election (i.e. on the same day).

Audited financial statements

The Financial Officer of an improvement district must produce financial statements for the preceding year for presentation at the annual general meeting. Those statements must be audited by a qualified accountant. Additionally, forms based on the audited financial statements must be submitted to the Ministry of Housing and Municipal Affairs by May 15th.

Minutes

Minutes of regular meetings must be uploaded to the Past Meeting Minutes subsection of the Trustees page by the Corporate Officer.

As of the time of writing, minutes of AGMs have not been published online. (Note that minutes of AGMs are not published until they are approved, which happens at the following AGM, so there is always a delay of a year between the meeting and posting the minutes of it; this is normal organizational practice.)

Financial management

Financial management duties are by law assigned to the Financial Officer, as described above.

• Annual audited financial statements can be found on the Financial Statements page of gabriolafire.ca
• First, second, and third quarterly financial statements were appended to general meeting minutes in 2023 but have not since been included in minutes.
• Long Range Plan 2025 and 2025 Annual Levy proposal documents

Relevant bylaws:

• Bylaw 88 - deals with levying taxes on the land and improvements within  the Gabriola Fire Protection District  hereinafter referred to as the "Improvement District" for fire protection purposes in each of the years 2014 to 2028 inclusive.
• Bylaw 103 - deals with the levying of taxes
• Bylaw 107 - deals with the levying of taxes
• Bylaw 108 deals with establishing multiple capital reserves

Annual budgets

Budgets are not available as standalone documents on the gabriolafire.ca site. Budgets for 2022, 2023, and 2024, together with other documents relating to them, are collected on an external website. At the time of writing (May 2/25) the 2025 budget has not been submitted.

Capital reserve funds

(2024, Bylaw 108): “The monies set aside will be deposited in separate accounts and until required to be used, may be invested in the manner set out in the Local Government Act, and will be disbursed only by bylaw passed by the Trustees of the improvement district. Monies in these reserve accounts will only be used for expenditures for any upgrading, replacement or renewal of existing works.”

• "Capital Replacement Trucks" —for the purposes of insurance deductibles, repairing, replacing, and any unforeseen emergency expenses related to fire trucks and fire truck related equipment necessary for fire protection services.
• "Capital Replacement Equipment"—for the purpose of insurance deductibles, repairing, replacing, and any unforeseen emergency expenses related to firefighting and emergency response equipment needed for fire protection services.
• "Fire Hall Repair and Replacement" — for the purpose of insurance deductibles, repairing, replacing, and any unforeseen emergency expenses related to Gabriola Volunteer Fire Department's three Fire Halls.
• "Contingency Fund" —for the purpose of insurance deductibles, repairing, replacing, and any unforeseen emergency expenses related to fire protection and services.

Committees

The Trustee page of the website does not list committees or provide information as to who is on them. By practice, Standing and Select committees are constituted at the first general meeting after the AGM, and further Select committees may be set up at other times as needed.

Based on the minutes of the April 2024 meeting, which lists committee membership at the time, the existing Standing and Select committees are:

Standing Committees

• Communications Committee
• Finance Committee
• Safety Committee

Select committees

• Long Range Plan Committee (created to develop new long-range plan)
• Hiring Committee (contextual, when needed)
• Website Committee

Committees referenced in other minutes

• Election Committee (presumably constituted annually to run AGM)
• Business Email Committee (presumably created to draft email policy)

GFPID policy documents

Long Range Plans

LRP 2025-2034: "The purpose of this 10 year Long Range Plan is to provide a framework in which to plan for the future of the Gabriola Fire Protection Improvement District ( GFPID) and the Gabriola Volunteer Fire Department (GVFD). This is a Living Document and as such it will be reviewed and amended throughout the 10-year period."

• Long Range Plan 2025 - 2034
• 2025 Levy Proposal

• Gabriola Fire Protection District: A Long Range Plan (Albert Reed, 1999) This was the GVFD's first long range plan. It is no longer hosted on the GVFD website, but is archived on the external gfpidiculous site.

Policies and Guidelines

Published documents

Published on gabriolafire.ca:

• Meetings and agendas
• Letters patent
• Bylaws
• Past meeting minutes
• Financial statements
• Long range plan and 2025 levy proposal

In addition to these documents, there is a GFPID Handbook of Governing Policies. All policies are currently under review because the unionization of the firefighters will result in the need for changes in some areas.

Reports

(NOTE: these documents are no longer available on the Trustees page. The Special Review Committee links to the gfpidiculous external website, the Brownlee Report is hosted here.)

• Report of Special Review Committee: Board of Trustees Governance Review.
• Fire Services Review Project (Jay W Brownlee & Associates, February 2023)

Additional documents

In general, GFPID policies are not published on the GVFD website, though some may be available on request. This collection (archived on the gfpidiculous external website) includes some of those policies, which were obtained through various channels, including FOI requests.

• BCEHS Agreement (obtained through FOI request to Ministry of Health)
• Chain of Command Policy (all communications between Chief, Trustees, and Corporate Officer are through the Chair)
• GFPID Code of Conduct (obtained through FOI request)
• FIPPA Policy
• Albert Reed’s Plan (obtained through FOI request)
• GFPID Investment Policy
• GFPID Complaint Policy

Referenced in minutes

The policies listed below are mentioned in GFPID minutes from Jan 2022 to the date of this page’s publication. Policy numbers are included when provided in the minutes. In most cases the text of the policies is not appended to the minutes, and they are not published on the GVFD website. Likely there are more, as these were pulled from a very limited number of years.

The status of some of these policies is unclear, and it is not known if all referenced policies were developed and formally accepted.

• Audio and Video Recording of Board of Trustees Meetings Policy (transcribed from statement at the beginning of official GFPID recordings of meetings)
• Business by email policy
• Chain of Command policy (accepted June/23, see “additional documents” collection for link)
• Charitable Receipts policy (accepted 2022-08)
• Code of Conduct
• Communications policies (Oct/24 minutes mention 4 draft communications policies)
• Complaints policy (accepted, also amended policy #24-G58; see “additional documents” collection for link)
• Elections policy (draft accepted with amendments, Feb/24, further amendment Mar/24)
• Error of facts policy
• In camera policy
• Investment policy (accepted June/23)
• Land use policy (relates to use/leasing of land; policy approved Sep/23)
• Minute-taking policy (carried: "To amend recording of minutes as described in Robert's Rules")
• Orientation policy (for new Trustees; accepted Oct/22)
• Payment policy
• Privacy/FOI policy (May/24: motion to repeal FOI Policy #23-03 and replace with FOI Policy 24-11 carried)
• Record Retention and Handling policies (accepted Sep/24, Policy 24-11, referenced motion 24-G59) Draft policy was published in the Sounder News, May 8th/24.
• Role of the Chair policy (accepted Aug/23)
• Trustee access to Fire Hall policy (accepted June/23)
• Trustee roles and operations policy

GVFD

• GVFD Operating Policies (including GVFD Human Resources policies)
• Service level policy (referenced Mar/24)

Options for resolving local government-related concerns

From the webpage of the Inspector of Municipalities: 

Members of the public have several options if they have concerns about local government conduct, including

• Contacting staff and elected officials of the relevant local government to bring concerns directly to their attention.
• Contacting staff in the Ministry of Municipal Affairs who can often answer questions about local government legislation and authority.
• Contacting the Office of the Ombudsperson if a person feels they have been treated unfairly by a local government body on a particular decision or other matter directly affecting that person.
• Contacting the Office of the Information & Privacy Commissioner if a person feels that their privacy rights have been compromised or that they are not being given access to records to which they are legally entitled and for which their request for access has been denied.
• Contacting the auditor for the relevant local government if a person considers that a specific financial matter is not authorized under legislation, or there has been a misuse or other irregularity in the financial holdings of the local government.
• Initiating a judicial review in the British Columbia Supreme Court if an elector has evidence that its local government acted beyond its legislative authority in passing a bylaw or making another decision, or acted contrary to the legal rules of administrative fairness. Please be advised that independent legal advice is essential before considering a legal challenge.