+ RMA Rural Municipalities
of Alberta

Resolution 10-14S

Proposed Amendments to the Determination of Population Regulation to Provide Greater Flexibility for the Counting of Shadow Population

March 26, 2014
Expiry Date:
April 1, 2017
Active Status:
MD of Greenview
4 - Northern
Municipal Governance and Finances
Intent Not Met
Vote Results:

WHEREAS amendments were made to the Determination of Population Regulation to provide for the counting of the shadow population of a municipality (with the Minister’s approval); and

WHEREAS these amendments are a positive step towards considering the inclusion of this significant body of people which seasonally live within many Alberta municipalities; and

WHEREAS the Regulation currently allows for the counting of a shadow population using the same census date as for the remainder of that municipality’s census; and

WHEREAS only dates between April 1 and June 30 may be used by a municipality as a census date; and

WHEREAS many municipalities have shadow populations which exist outside the April 1 to  June 30 window; and

WHEREAS the Regulation also allows a municipality to only count those persons in the shadow population that both live and work within the same municipality to be counted; and

WHEREAS many people reside temporarily within one municipality and work in an adjacent municipality and neither municipality can, at this point, count those workers within their respective shadow population counts;

Operative Clause:

THEREFORE BE IT RESOLVED that the Alberta Association of Municipal Districts and Counties  requests that the Government of Alberta amend the Determination of Population Regulation to allow municipalities to use a shadow population count date outside of the current restriction of April 1 to June 30; and

FURTHER BE IT RESOLVED that the Alberta Association of Municipal Districts and Counties request that the Government of Alberta amend the Determination of Population Regulation to allow municipalities to count all shadow population residents living within their municipality that otherwise qualify, regardless of whether or not they work within that municipality.

Member Background:

In February 2013, changes were made to the Determination of Population Regulation to allow a municipality, with ministerial approval, to count the shadow population within the municipality.  Doing so potentially provides that municipality with access to additional, per capita-based grant funding.

In April 2013, the MD of Greenview (Greenview) requested the Minister’s approval to conduct a shadow population count.  In doing so, Greenview requested that the Minister consider allowing the MD to use a different date for the shadow population count than for the regular count as the shadow population is only prevalent during the winter months.  The Minister did not approve this request and Greenview was required to use the same date in May as was used for the regular census.  This resulted in a very low shadow population count as the vast majority of temporary residents were not counted.

As well, in the process of conducting a census on behalf of the town of Fox Creek, it was noted that a large number of temporary residents were residing within Fox Creek but could not be used for their shadow population count as the shadow population did not work in the same municipality in which it resided.  This, in effect, meant that those temporary residents could not be qualified as shadow population residents for either municipality.

Should the Honourable Minister agree to make the requested changes to the regulation, we believe there will be a much more accurate picture of the shadow populations encountered by Alberta municipalities.

RMA Background:

The AAMDC has no active resolutions directly related to this issue.

Government Response:

Alberta Municipal Affairs

In Alberta, municipalities may choose to conduct a municipal census to more accurately plan for their growth, and municipalities experiencing high population growth may qualify for more funding through provincial grants that are based on population counts. Any municipality that chooses to conduct a municipal census is required to conduct the census in accordance with the methodologies outlined in the Determination of Population Regulation (DPR) and the Municipal Census Manual.

Municipal census and shadow population counts are regulated under the DPR. The DPR defines shadow population as the temporary residents of a municipality that are employed by an industrial or commercial establishment in the municipality, for a minimum of 30 days within a municipal census year.

The DPR also provides for a municipality to undertake a census (and shadow population count if the municipality is conducting one) between April 1 and June 30 of the same year. The census date chosen must apply for both the normal count within the municipality and the count of the shadow population.  Having a common census date is an important requirement from the perspective of ensuring the integrity of the census counts. If a municipality wishes to establish a census date outside of the dates specified in the regulation it should obtain the permission of the Minister to do so in advance.

The DPR was last updated in 2013 following consultations with the AAMDC and other stakeholders. The 2013 update included the incorporation of provisions for a shadow population count.  The ministry expects to undertake a review of the DPR in 2017, including consultation with stakeholders, prior to considering renewal of the regulation in 2018.

The ministry is also undertaking a review of the Municipal Census Manual and will be following up with municipalities that undertook a municipal census in 2013 and 2014, as well as those municipal staff that attended the 2013 and 2014 municipal census training sessions to obtain feedback on the Municipal Census Manual.


The government response does not support expanding the municipal census window beyond the current April 1 to June 30 window except by special permission of the Minister. It also does not discuss the possibility of allowing for individuals that live in one municipality and work in another to be counted towards the shadow population of the municipality in which they reside. This restriction results in an inability for the municipality that provides this resident with services to conduct an accurate population measure, which may negatively impact their ability to access population-based grants.

As part of the MGA review, the Determination of Population Regulation is being reviewed and the AAMDC has had the opportunity to provide comment guided largely by this resolution; however, without the changes outlined in this resolution, this resolution has been assigned a status of Intent Not Met.

Provincial Ministries:
Municipal Affairs
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