Salt Spring Island's duelling crises
Housing is at a breaking point. But to understand why there’s nowhere to live, first we need to understand why it’s getting harder to get water
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Housing is at a breaking point. But to understand why there’s nowhere to live, first we need to understand why it’s getting harder to get water
Housing is at a breaking point. But to understand why there’s nowhere to live, first we need to understand why it’s getting harder to get water
Housing is at a breaking point. But to understand why there’s nowhere to live, first we need to understand why it’s getting harder to get water
We are grateful for the generous support of the Society for Environmental Journalists’ Fund for Environmental Journalism.
Omrane Hassan and Sarah-Vanessa Daigle have planted a garden. It’s overflowing with bounty already in the early June heat, spilling out onto a lawn they don’t own, just out the basement door that will soon be locked to them.
It will be the eighth time Hassan has had to move in the six years he’s lived on Salt Spring Island, and Daigle is no different. The couple says they’ll bring the plants with them, but given that one of their possible next homes is a sailboat anchored in Ganges Harbour while another is a van parked on a side street somewhere, it’s unlikely the plants will thrive like they do here, in a sunny backyard on a gently sloping hill.
The plants wouldn’t be the only thing that would suffer from a move. Their cleaning business depends on a certain amount of space for staging and storage, and losing what little space they have now will throw it into chaos.
“Business is—” Daigle begins.
“Phenomenal,” Hassan gushes, and she nods. They haven’t advertised in months and still they hear from prospective clients every day. “But there’s just no labour.”
The couple can’t find anyone to work for them. There’s more than enough demand for young, energetic workers on an island with a median age more than 10 years older than the province as a whole. But few people can afford to live here.
“You can go to an art store and pick up a painting, but you can’t get your fridge fixed,” says Bryan Young, chair of Transition Salt Spring, a climate advocacy group. “We have a lot of the people who work in Country Grocer who come in on the friggin’ ferry from Crofton, because they can’t find a home.”
The shortage of housing cuts across industries.
“Teachers, RCMP officers, healthcare providers—we’re having a hard time recruiting doctors—we’re definitely seeing it in all sectors of our economy. People that would be working can’t afford to be here,” says Kisae Petersen, executive director of Islanders Working Against Violence, an organization that is building a small housing project on the eastern edge of Ganges.
Still under construction, the cost of building the development, Croftonbrook, had to account for a half-million dollar investment in a grey water system to make the most of the well water it was using—because despite being just steps from downtown Ganges, it can’t be connected to the local water service.
About 600 customers across five corners of Salt Spring have access to small Capital Regional District-operated water systems. Water for more than three times that many residents, including those who live in Ganges, is provided by North Salt Spring Waterworks. But the waterworks instituted a strict moratorium in 2014. It hasn’t connected a new water user to its system since.
As a result, new housing projects in or near the island’s commercial centre must be connected to their own well, leaving developers to face down a maze of questions anyone with piped-in water doesn’t need to think about: is there enough groundwater to meet everyone’s needs? Who will manage the well? Where will the wastewater go? How much will it cost?
Those questions have been enough to prevent almost any new affordable housing from being built on the island at a time when existing rental housing is increasingly being converted back to owner-occupied as the owners retire or sell their homes to eager buyers from the city. Their homes—the ones Hassan and Daigle clean, occupying thousands of square feet of living space—are free to use water as they see fit. They can have hot tubs and endless gardens, and pay a bit more for their increased consumption. Multiple vacation rentals and real estate listings boast poolside living.
Currently five affordable housing projects have been put on hold, some for more than a decade.
It’s common knowledge that on this island, with a well educated, independent-minded, stubborn population, if you get five people in a room together they’ll come out with six different opinions. Even the name of the place contains an internal contradiction, as though it can’t agree even with itself: Salt Spring, named for springs of water, just not the drinkable kind.
Accordingly, the place contains both abundance and scarcity of water, dispersed in time and space. Housing, too, wouldn’t be in short supply if it was measured in total square footage instead of the number of front doors. The inevitable result is a class-warfare mentality among those who are left out, and a sense of oblivious defensiveness among those raising the drawbridge.
Where water and housing meet, the distance between positions on how to allocate them is growing ever wider, but there are plenty of people who will agree with Rhonan Heitzmann: “Our island is in a slow-motion collapse,” he says.
He can’t find employees for his business—an increasingly essential water delivery service—and he’s barely squeezed his way into the scorched and desiccated housing market. But on the piece of hillside land where he fills his truck, water surges forth in a never-ending stream, burbling merrily into the open from deep below ground.
Hear the story behind the story on the Capital Daily podcast.
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The staircase in Fernando dos Santos’s newly built home is a point of pride for the retired lawyer. It curves to mimic the whorls of a snail shell, a Fibonacci sequence built in as the centrepiece of the big house that overlooks Ganges Harbour.
But the real treasure is below our feet: a swimming pool-sized rain catchment cistern that has meant he barely touches his well even in the depths of summer. Peering into a hatch just off the kitchen, he estimates he’s got about 10,000 gallons of water left in the tank.
“Last year once May rolled around it barely rained right through the summer,” he says. “By the end of the summer, we still had almost 5,000 gallons left.”
Winter largely skips Salt Spring Island, one factor that has made it so popular among retirees. While it may occasionally snow here—about six days a year on average—the winter is really defined by rain. Rain starts falling in earnest in October and stops abruptly in May. Midsummer, islanders can expect just a few days of rain each month. Previously this seasonal aridity was almost an amenity, like having a great transit system or a Michelin-starred restaurant. But in the era of climate change it is quickly becoming a liability.
The water that will be consumed throughout the dry summer has to be collected in the rainy season, one way or another. For Dos Santos, the rainwater is collected from the roof, through a few filters, and stored under the floor. For everyone using piped water from North Salt Spring Waterworks, the water is collected in one of two lakes: St. Mary Lake and Maxwell Lake.
The water utility therefore has the perennial challenge of watching the water level drop, slowly and steadily, throughout the busiest time of year, while keeping faith that the water will rebound again come winter as it always has. Throughout that whole time, they have to provide water to everyone connected to its system, while not fully knowing all the factors that play into where the water is coming from or going.
“All of the islands are struggling to do some type of water balance analysis,” says Diana Allen, a hydrogeologist at Simon Fraser University who has studied the Gulf Islands’ groundwater supply. “But to be honest, the science is…” she sighs. “Even using the best available information right now, I’m not sure we could confidently quantify that balance.”
The balance, whatever it is, is changing. The winters are getting wetter, with more rain expected to fall on Salt Spring over a shorter period each year as the climate changes. “Instead of it drizzling all day, you’ll get these big whopping storms,” Allen predicts—and the soil might not be able to absorb the dumping rain as well as the gentle mist the island is used to, spilling instead out into the sea. But the dry season, too, is becoming drier. Since mid-June, there have been more days over 35 degrees (three) than there have been rainy days (zero).
It’s months like these that give credence to claims that the island can’t support any more people; that it’s reached its carrying capacity. The island has grown at a snail’s pace, adding just 320 people between the 2011 and 2016 census, but without knowing how many people’s needs the island could meet at its best, it’s even harder to know how many it could accommodate in the range of future scenarios.
This summer’s incessant heat has provided a glimpse at a likely future. The water level on St. Mary Lake is lower than any year except 2015, and there’s even less water in Maxwell Lake than there was this time that year. Visitors to the island are being asked to bring their own water. If things persist, water use could be restricted to some parts of the day, and sports fields and lawns would be left to wither, as they were six years ago. Hassan and Daigle’s sprawling backyard garden will have to be watered by hand in the cooler gloaming hours of the day.
It’s not just drinking water that’s in short supply. In the cool darkness of the morning at the beginning of June, a fire broke out at Windsor Plywood, an almost perfectly combustible building. For 15 hours, 26 exhausted firefighters worked to put out the fire. They used more than 100,000 gallons of water in all.
The following day, waterworks chair Michael McAllister called Vaughn Figueira. As the operations manager for North Salt Spring Waterworks, Figueira had been awake that night, watching the water level drop steadily as the firefighters pumped and pumped to combat the inferno and stop it from spreading into Ganges. A fire in downtown Ganges, with its aging water infrastructure and dry wooden buildings, would have been a disaster beyond reckoning for the small fire department.
The creaky infrastructure between the water tanks that hold emergency water and the fire raging just outside of downtown was straining to keep up, and the water supply itself was being pushed far beyond what it would normally need to bear.
The first thing McAllister asked: “Did we run out of water?”
The answer: almost.
—
Dos Santos buzzes about his home, showing off features great and small that he custom designed or sourced from small US suppliers. He points to his clever kayak hook; the otter-resistant material atop his dock; the siding he hauled across the border, only to realize he’d failed to fully account for the imperial/metric difference in dimensions. No problem, he says, he just had to innovate a solution to that.
Energy flows off him in jittery pulses as he leads me along his fence (factory panels he adapted for greater privacy) to show the half of his roof from which he collects all of his drinking water.
If there’s a problem in his way, Dos Santos will find a solution, or he will break himself trying.
Accordingly, he dismisses the idea of an intractable water shortage. He drilled a well on a piece of property he owns and water gushed forth like a geyser.
“This thing was just shooting up in the air,” he says. Though it’s more luck than anything, having a high-producing well is a godsend on the island.
The water, and the land, are for a proposed tiny home village called Dragonfly Commons, homes he hoped to sell for rates working people could afford on Salt Spring. But if they were all drinking from the same well, someone would have to own the well—and become, in essence, a water utility unto themselves, including ponying up as much as a million-dollar deposit against losses that could sink the project. As for when the deposit will be up, the province says it may return them, somewhat ambiguously, “when they are no longer required.”
An alternative, which wouldn’t beget the water utility problem, is to rent the homes; not ideal, he says, but at least workable. But the economics there are daunting, requiring him to carry hundreds of thousands of dollars in debt for years while the loan is paid down by rents. BC Housing would pitch in some money—not nearly enough to substantially cover the cost—provided he built the buildings to a standard that would add more to the cost than the agency would put up. That path was abandoned.
Another option is money available under the $300 million CMHC Housing Supply Challenge—Dos Santos is applying for money that could help the project move ahead, but the long and uncertain process is setting the project farther back. He’s optimistic, but if that doesn’t work, he’ll surely find something else.
While these high-level approaches from governments are intended to ease the restrictions on housing supply, an even more pressing problem, Dos Santos says, is a much more local one: the province is simply not interested in dealing with the kind of organization that delivers water on north Salt Spring.
“Right now they [waterworks] have no funds, so basically their water system is slowly degrading; they don’t have the money to repair leaks and things like that that they need to do, or make any infrastructure improvements, so eventually they’ll be forced to join the CRD,” he says.
“That's how they do it, right—they just starve them to death until they have no choice.”
The North Salt Spring water system is staring down the barrel of $25 million worth of upgrades over the next five years, including a new treatment plant for the water coming out of Maxwell Lake. But while the province is insisting that the waterworks build those expensive upgrades, it’s not pitching in to help make them happen. The province decided it will not provide grants to improvement districts (like North Salt Spring) because it prefers to deal with municipalities and regional governments like the CRD. The five smaller CRD systems, one of which serves just 16 customers, are eligible for grants.
“There’s been no flexibility offered in this,” laments Adam Olsen, the MLA for the area. He says he’s gone to the government multiple times to ask for some help for his constituents, but, “each time the response has been, ‘This is the model that we’re supporting, and you can continue to be an improvement district as you’ve always been, and the policy is not changing.’”
That leaves the waterworks in the unenviable position of having to go to its ratepayers to raise millions more dollars—spread only among 1,800 or so accounts.
Those people are not likely going to be in a mood to approve another expensive solution that could help ease the seasonal shortage: raising the weir on St. Mary Lake. A higher dam would capture more water in the wet season, meaning the reserve could last longer through the summer.
To raise the weir, however, would also flood parts of properties around the lake, adding cost and controversy. But regardless, the money isn’t there. With $13 million in debt-financed investments in the last three years, there’s no appetite to go further into the red for the benefit of people who don’t even live there—likewise, there’s no interest in bending the rules on the water moratorium for some kinds of housing and not others.
A CRD-owned proposal on Drake Road, just up the hill from Ganges, has been languishing for years. Kisae Petersen remembers when it was first announced.
“My kids were teeny tiny,” she recalls, “and I was single parenting and I was like, ‘Oh, great! I'll move there!’ They've since grown, left home, and I'm empty nesting. And I'm thinking of … all the families that have left the community, because there hasn't been housing.”
The development hasn’t so much as broken ground—and the only missing piece is water.
“We’re very very concerned that needed social housing, government-funded social housing, is being impacted because of the moratorium,” Waterworks’s McAllister says. But in the end, rules are rules. “To me it would have been inappropriate for us to say we will ignore our moratorium for Drake Road because it’s social housing.”
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Many of Gerda Lattey and Mike Lachelt’s employees are young, barely old enough to buy liquor by the looks of them, yet here they are, slinging cider on Salt Spring Wild cidery’s sloping property. They have one secret weapon that even the most experienced bartenders lack, however: a place to sleep on Salt Spring Island, at their parents’ houses.
The staffing problem is especially keen for businesses that need specialized skills or training, like chefs.
“It's virtually impossible to fill those positions without providing a housing solution oneself,” Lachelt says.
Even essential government jobs are no exception; Figueira, hired by the waterworks that some blame for exacerbating the housing shortage with its moratorium, struggled to find himself a place to live after landing the job.
With skilled staff worth their weight in gold, business owners on the island have taken to buying up properties to use as staff accommodations. But that in turn has had the effect of contributing in some small way to deepening the housing crisis for everyone not able or willing to invest their business earnings in property.
For workers, it often means scraping by, accepting whatever housing is available. At any given time there may be as many as 100 people with active requests for housing on the popular Salt Spring Exchange housing board. A group of 20-somethings live on the water, in a shanty of sorts, well within the view of multi-million-dollar mansions occupied by one or two people. They get to live close to town, but among the drawbacks is a lack of electricity and running water. They charge their phones and iPads at an outdoor outlet in Centennial Park. There are more squatters in the woods, some with tacit permission to camp on other peoples’ land, and some without.
“I know some people who have lived in the park,” Hassan says. “Very functional people, who go to work nine to five every day, like skilled, skilled carpenters and masons.”
Lattey recalls a conversation with another business owner who runs a company with about 50 employees locally.
“They couldn't even afford to buy a bicycle at this point, because they've taken everything they owned and invested it into property,” Lattey says. “They were putting all of their effort into finding and keeping and housing staff, as opposed to putting effort into keeping the business going.”
Dale Schweighardt is one of those business owners who has become a landlord on top of his day job. About four years ago he found his pub, Moby’s, chronically short-staffed. So he bought a four-bedroom house to accommodate his cooks. Then, borrowing against that house and his own, he bought another for his managers and more senior employees.
“I never signed up to be a landlord; I didn't want to do that,” he says. “But if I wasn't a landlord right now, I wouldn't be a restaurateur.”
It’s about as band-aid a solution as they come. But without new housing on the island, it’s the only option for business owners in need of employees.
In a survey of Southern Gulf Island tourism-related businesses for a 2020 workforce report, half of the businesses said they struggled to keep workers. The report specifically cited a lack of housing, calling it a “critical barrier” to finding and keeping employees. Three quarters of business owners said employees had had trouble finding housing.
Grocery stores are in the same position, as are other service industry businesses like Hassan and Daigle’s cleaning business.
When I text Hassan in July to get an update on his housing situation, he replies that he and Daigle have found a tiny home to buy—all they need is a place to put it, for an additional $500-750 a month. That in itself will be no small feat, but at least it’s progress, and roomier than a van. He doesn’t seem as concerned as I would be about not having a place to live, though, or where the plants will go. He just wants me to make sure I include the name of his cleaning business in the story. (It’s called Salt Spring Cleaning.)
“I figure that your story is my best bet on getting me employees,” he texts, with a smiling/sweating emoji.
—
Rhonan Heitzman’s truck is overflowing with water; you can see it sloshing around in the translucent plastic tank as he fills it. When he pulls the hose out, he takes the opportunity to fill his water bottle with the excess streaming from the valve.
It’s the kind of clean, clear spring water—and bottling location—that fancy water companies aspirationally name themselves after: mountain spring, island mist, rainforest whatever.
He starts the truck and we rumble off for a delivery, something he does all over the island for people whose wells don’t produce the kind of prodigious gushing pressure his own does. A metre of rain falls on the island annually, but his business partner's well gets the slow-release result of that rain, filtered through soil and gravel and into cracks in the bedrock over years, until it’s running down through cracks in the granite a hundred feet down, and pumped up into his truck.
“We get really busy in the summer, and then hardly anything all winter,” he says. That pattern appears all over the island, flowing from the rainfall into everything that depends on presence or lack of water—that is to say, everything. Business, tourism, housing, water—it’s part of the same system and it is all caught up in a moment of change.
Another major change is underway that will affect all of the above: the Islands Trust is revising its policy statement to look forward to 2050.
The trust is the governing body of the Gulf Islands, with a mandate to “preserve and protect” the islands and their surrounding waters. Its policy statement, which hasn’t been updated since the 1990s, determines how it will carry out that duty.
Housing—which has reached crisis levels on islands across the Salish Sea—has been proposed to be identified as a priority alongside reconciliation and climate change.
“Many islands in the Trust Area are also facing a lack of safe, secure, and affordable housing that is threatening the long-term sustainability and resilience of Trust Area communities,” a draft statement reads. “The gap between those who can, and those who cannot, afford a home is growing rapidly.”
The proposed statement, however, set off alarm bells. Amid concerns over the content and, especially, the lack of consultation in drafting it, the Islands Trust back-pedalled and delayed a vote to move forward with it.
Heitzman is part of a group, Salt Spring Solutions, advocating for “bold action” on housing, urging the Islands Trust to help housing projects overcome the regulatory hurdles that have kept projects like Drake Road and Dragonfly Commons from moving ahead. In all, five projects making up more than 200 units of housing have been proposed but are stuck in suspended animation, mostly awaiting water.
They have answers for water. Rainwater collection for drinking water, like the system Dos Santos uses for his home, is currently only allowed for multi-family housing with special permission from the health ministry—and no one, to date, has received that permission. They want that barrier lifted so that a development like Dragonfly Commons could catch and hold water. But Heitzman says they’re met with opposition from people who are fearful of density.
“Where we get pushback is there's a crowd that, just, they're afraid of carrying capacity, they’re afraid of too much density. It’s a whole sort of old ethic with the Islands Trust that says the only way to preserve and protect the environment is to limit the population. And the way we limit the population is by limiting the densities.”
Maxine Leichter is among those concerned about the declining water supply—and who worries that pushing the population beyond its limits will end in disaster. But she insists it’s not about any opposition to housing per se.
“I think it’s very unfair what some people are doing—to imply that people that want to recognize our limits are against affordable housing,” she says. “I’m not against affordable housing; I want it to go where there’s adequate water.”
Leichter, as the head of another local group, the Salt Spring Island Water Preservation Society, says she’d like to see housing that’s allocated specifically to island workers, and she’s far from alone in that sentiment. Having spent her career as a city planner in Los Angeles, she moved to the island in 2003 from California, seeing a place that was “a real community, not just a seniors’ community.”
But thanks in part to the housing shortage, that is exactly what it has become—a demographic chart of the island compared to the province as a whole looks like a tree without roots, unbalanced and ready to topple over.
Shopping in the grocery store one day, Leichter noticed that the woman ringing her through didn’t seem particularly accustomed to the job. The flustered employee, Leichter recalls, apologized—she normally does a completely different job but they had no staff to cover the tills.
“That’s when I got concerned,” she says. She sees the problem, and where this is all leading. But she still won’t budge on water as the ultimate underlying limit to growth.
Now she’s seeing people leave because they are at an age where they need medical care, but there are not enough workers to support them to age in place.
The demographic concentration hasn’t been lost on other residents.
“I’ve lived here for over 20 years,” Lattey says. “I don't want to see this place just be a place for seventy-year-olds to come and spend the weekend here. And that's really what it's become.”
—
There’s a place that has become a cautionary tale, just north of a town named for another one: Vesuvius.
In the mid-1980s, the Channel Ridge development was set to become a new gravitational centre for the island, adding 577 high-end homes. It was first proposed with an Alps theme, to give a sense of its aesthetic match with the island’s misty winters and Mediterranean summers.
When I set foot on the property, there are actual vultures circling—a bit on the nose, frankly—and dog walkers have taken a liking to the place. “The world’s fanciest dog park,” one calls it, though they’re not walking along cobbled streets between gabled roofs as originally intended, but rather along dusty half-constructed dirt tracks with the bones of a neighbourhood sitting exposed and abandoned along their edges. Sewer tops stand head and shoulders above the ground like nails waiting to be pounded into the ground, overgrown with invasive broom and bedecked with graffiti.
As I head back out of the punishing heat toward the cooling shade of the woods, tiny divots appear in the dust. It’s starting to rain, the last drops of the season.
In retrospect, the development seemed doomed from the start, with the original developer Louis Lindholm dying on his way to contest a court injunction against him in 1989—he had been found to have breached a contract with North Salt Spring Waterworks and the Salt Spring Water Preservation Society by clear-cutting part of the property, next to St. Mary Lake, for better views, according to historian J.I. Little.
His sons sold the land to an Alberta developer in 2000, and the plan moved ahead with the idea of marketing it to Baby Boomer retirees. As it dragged along through different investors, designs, redesigns and restarts over the next decade and a half, the water crisis worsened. The first hints of the housing crisis began to emerge as well. “Wealthy retirees and Americans looking for holiday retreats have driven up prices, with a modest two-bedroom home in the woods costing $200,000 and a small waterfront cottage going for $600,000,” journalist Mark Hume wrote in a 2004 Globe and Mail story about the development. Locals fretted that Channel Ridge was a sign that, in the years to come, the place would become an enclave exclusively for the very rich. A tent city of sorts crowded into Fulford Harbour to protest the rising housing prices that were forcing out the artists, the hippies, and the idealists who had given Salt Spring its quirky character.
The final blow for the development came in 2014, when North Salt Spring Waterworks imposed its water moratorium, cutting off the potential water supply for many of the houses. A lawsuit stemming from that decision is still being pursued by the development’s latest owner, Onni Group.
The place is frequently referred to by some islanders as an example of the anti-development attitude of the island or the NIMBY-ism of its residents, and by others as an example of how far developers will try to push things beyond what is suitable for a largely rural, quiet island.
A grey-brown scar on the landscape, it stands as a reminder most of all that on islands in the sea, water makes or breaks a place. Salt Spring’s decisions now—whether or not to house those who need housing; to protect its vital water supply; to maintain the systems, human and natural, that keep the water clean and plentiful—are going to shape how it comes into the era of unimaginable change.
We began reporting on this story as we searched for examples of the ways climate change was influencing tangible current events in the South Island region. Housing is in crisis everywhere—but what happens when water scarcity is factored in?
This story was primarily researched from Victoria, and its author, Jimmy Thomson, took a three-day trip in July 2021 with photographer James MacDonald to meet with sources on the ground and gather images. We had hoped to meet with North Salt Spring Waterworks but they were not available at the time of our visit. We interviewed more than 15 people, reviewed documents from water utilities, housing providers, governing bodies, academics, and environmental groups, and drew on reporting from other news outlets including Global News, CBC, and the Salt Spring Island Driftwood.
Islands Trust State of the Island Final Report, 2020
Islands Trust, Islands 2050 policy statement update process
BC Government Groundwater Level Data map
BC Government Water Utility Branch, Financial Guidelines for Certificate of Public Convenience and Necessity (CPCN) Applications, 2016.
CRD Drinking Water Quality Annual Reports
Southern Gulf Islands Tourism Partnership, Labour Market Gaps and Opportunities Final Report, April 27, 2020
Salt Spring Island Housing Council Society, Dragonfly Commons
Nolan, Elizabeth. Gulf Islands Driftwood, "Islands Trust Bylaw Enforcement Issue Aired" 2020
Nolan, Elizabeth. Gulf Islands Driftwood, "Trust Council Puts Hold On First Reading Of Policy Statement Bylaw" Jul 8, 2021
Little, J.I. "ARRESTED DEVELOPMENT: The Saga of a 'Sustainable' Planned Village on Salt Spring Island, 1985-2016," BC Studies; Vancouver Iss. 207, (Autumn 2020)
Attorp, Francis. Salt Spring Island Driftwood, "Death by a thousand cuts" 2021
Attorp, Francis. Salt Spring Island Driftwood, "Housing Groups Do Lobby" 2019
North Salt Spring Waterworks, St. Mary Lake water level report, July 2021.
Azpiri, Jon. Global News, "‘Come prepared, bring water’: B.C.’s Gulf Islands suffering drought-like conditions" July 14, 2021.
Correction on Aug. 3 at 11:30 am: Rhonan Heitzmann does not own the well from which he fills his truck; that belongs to his business partner, Fitz Lee. The article has been further updated to reflect that an August 2020 policy change means rainwater collection could be allowed for multi-family use, with a permit from the Ministry of Health.