“DCC Now knowledge-base card: What is a delegation request? A resident guide to speaking before Council in Delta.”

What Is a Delegation Request in Local Government, and What Is Its Purpose?

A “delegation request” is a formal request by a resident, organization or community group seeking permission to speak directly to the Mayor and Council at a public Council meeting.

The term is easily confused with “delegation of authority,” but they have completely different meanings.

1. What is a public delegation request?

A public delegation request provides a structured way for members of the public to:

  • present information or evidence directly to Council;
  • explain a community concern;
  • ask Council to take a particular action;
  • propose a policy or bylaw change;
  • seek accountability from elected officials;
  • place an issue before the elected Council rather than dealing exclusively with municipal staff; and
  • answer clarification questions from Council members.

A delegation does not make a decision. After hearing the presentation, Council may:

  • receive it for information;
  • ask questions;
  • request a staff report;
  • refer the matter to staff or a committee;
  • pass a resolution; or
  • take no further action.

The central purpose is to provide residents with an orderly and transparent way to bring municipal concerns directly before their elected representatives.

2. Is appearing as a delegation a right under the Local Government Act?

Not exactly.

Neither the Local Government Act nor the Community Charter gives every person an unrestricted right to appear as a delegation whenever requested.

Instead, section 124 of the Community Charter requires every municipal council to adopt a procedure bylaw establishing how Council and its committees conduct their business.

A municipality’s procedure bylaw may establish:

  • how a delegation request must be submitted;
  • who may apply;
  • submission deadlines;
  • approval requirements;
  • presentation time limits;
  • permitted and excluded subjects; and
  • meeting conduct requirements.

In Delta, ordinary delegation requests are governed principally by Council Procedure Bylaw No. 8330, rather than by a general delegation-request provision in the Local Government Act.

Source: Community Charter, section 124

3. What does Delta’s Council Procedure Bylaw say?

Under Delta’s current Council Procedure Bylaw:

  • Section 13.1 says the Committee of the Whole provides organizations and other members of the public with an opportunity to make representations to Council.
  • Section 13.3 says topics may be identified by Council or staff, or requested by an external organization and approved by the Mayor.
  • Section 13.4 says an external organization wishing to discuss a specific topic must submit a written request to the City Clerk. The request is subject to the Mayor’s prior approval. The bylaw defines “Delegation Request” by reference to this section.
  • Section 13.5 says Committee of the Whole appearances may be rescheduled because of agenda size or priorities. Delegates are permitted up to 10 minutes. Additional time is provided for questions from Council. The Clerk communicates the tentative and confirmed dates.
  • Section 13.10 is broader than section 13.4. It applies to “Delegations wishing to address Council,” not only external organizations. It permits an appearance at a Regular Council meeting or Committee of the Whole when the delegation has been scheduled and approved by the Mayor under subsections 13.10(1) and 13.10(2). Subsection 13.10(3) separately permits a presentation at a Public Hearing concerning a matter referred to that hearing and does not state the same mayoral approval requirement. The City Clerk chooses and advises the appearance date. The bylaw defines “Delegation” by reference to this section.
  • Section 13.11 requires presentation materials and any written materials for Council to be submitted to the City Clerk at least seven business days before the meeting, not including holidays.
  • Section 13.13 requires a delegation that makes submissions to Council to:
    • state their name(s) and address(es) for the record;
    • not speak for more than 10 minutes;
    • not speak about any of the matters listed under section 19.4 (in-camera / closed-meeting subject matter under Community Charter section 90); and
    • comply with the General Rules of Conduct in section 6.1.
  • Section 13.14 allows each Council member up to 3 minutes to ask clarification questions of a delegation and to hear the responses.

Two clauses must be read together. Section 13.4 specifically addresses a written “Delegation Request” from an external organization. Section 13.10 uses the broader term “Delegations wishing to address Council.” For ordinary appearances at a Regular Council meeting or Committee of the Whole, sections 13.10(1) and 13.10(2) identify the Mayor as the approving authority.

Section 13.10(3) separately addresses presentations at a Public Hearing. It should not be confused with the approval process governing an ordinary delegation appearance.

Under the wording of Bylaw No. 8330, the City Clerk/Corporate Officer may receive and administer a delegation request, and Legislative Services may schedule an approved appearance. For ordinary delegations under sections 13.4 and 13.10(1)–(2), however, the Mayor is identified as the approving authority. If another official makes the final approval or refusal decision, the City should be able to identify the bylaw, resolution or other legal authority supporting that arrangement.

Receiving a request is different from approving it. The City’s “How We Work” page directs members of the public to submit written delegation requests to the Corporate Officer and says Legislative Services will schedule an approved delegation. This is not necessarily inconsistent with Bylaw No. 8330 because section 2.2(6) defines the “City Clerk” as the officer assigned the responsibility of Corporate Officer, including an authorized deputy.

The important question is not who receives and schedules the request. Under sections 13.4 and 13.10(1)–(2), the Mayor is identified as the approving authority for an ordinary delegation appearance.

Source: City of Delta Council Procedure Bylaw No. 8330 · City of Delta, How We Work

4. What is the democratic purpose?

The deeper purpose of a delegation process is to create a structured channel between residents and their elected Council.

Section 89 of the Community Charter generally requires Council meetings to be open to the public. However, the right to attend and observe a public meeting is not automatically the same as a right to speak during that meeting.

Public attendance provides transparency; a delegation provides direct participation.

Because Delta’s bylaw makes delegation appearances subject to prior approval, submitting a request does not guarantee that the applicant will be permitted to speak.

Nevertheless, an approval power should be exercised:

  • consistently;
  • in good faith;
  • for relevant purposes;
  • according to the applicable bylaw; and
  • without arbitrary or improper considerations.

A clear process should also allow residents to understand who made the decision and why a request was approved, refused or redirected.

Source: Community Charter, section 89

5. What is “delegation of authority”?

“Delegation of authority” is different from a public delegation request.

It generally means that Council transfers a municipal decision-making power, duty or function to an officer, employee or another authorized body.

For example, Council may authorize municipal staff to approve certain permits, agreements or administrative matters without requiring every decision to return to Council.

The Community Charter places limits on these transfers. Certain powers cannot be delegated, including the power to adopt a bylaw.

Term Meaning
Delegation request A person or organization asks for permission to speak before Council.
Delegation of authority Council transfers a legal power, duty or decision-making function to an authorized person or body.

A public delegation request concerns access to address Council. Delegation of authority concerns who may exercise municipal power.

Source: Community Charter, sections 154–156

Why does this distinction matter?

Residents should know whether they are:

  1. asking to speak directly to their elected representatives; or
  2. challenging a decision that Council has authorized municipal staff to make.

Those situations involve different bylaws, legal rules, and accountability mechanisms.

Understanding the difference also helps residents ask the correct questions:

  • Who received the delegation request?
  • Who possessed the authority to approve or refuse it?
  • What criteria were applied?
  • What bylaw provision supported the decision?
  • Was the applicant given a clear reason?
  • Is any reconsideration or review process available?

A delegation process is not merely a speaking slot on a Council agenda. It is part of the relationship between residents, municipal administration and elected representatives.

Related DCC Now records

Sarbjot Singh Locham

Resident & Editor, DCC Now – Delta Community Concerns

info@dccnow.com • dccnow.com • Independent Community Reporting • Public Records • Transparency • Accountability

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