When the City of Kamloops started accepting electronic signatures for Alternative Approval Process (AAP) response forms, it didn’t come with much attention. There wasn’t a big announcement or a lengthy debate. Instead, the change showed up in how submissions were handled.
At first glance, it looks like a small administrative change. In practice, it isn’t.
AAPs are used when the City wants approval to borrow money or move ahead with certain decisions. They are one of the few ways residents can formally register opposition without going to a vote. Because of that, how easy the process is depends heavily on how the rules are applied—especially something as basic as what counts as a signature.
By accepting electronic signatures, Kamloops has stepped away from a system built around paper.
A Small Step That Changes How People Participate
For some people, printing and signing a form is routine. For others, it isn’t.
Not everyone has a printer, and not everyone feels comfortable scanning a document or converting a photo into something that can be emailed. In some cases, people rely on others to help. In other cases, they decide it’s not worth the effort.
Electronic signatures don’t remove the need for verification. The City still needs to confirm who submitted the form and whether they’re eligible. However, they do reduce the number of steps required to take part.
As a result, that change can affect who participates.
Different Cities, Different Rules
Across British Columbia, municipalities are handling AAP submissions in different ways.
Some allow electronic submission of forms. Others still require printed and signed documents, even when those documents are submitted digitally.
The variation also shows up in how municipalities handle online submissions. For example, the City of Nanaimo allows response forms to be submitted through its website. At the same time, it requires that the form itself be signed by hand and uploaded as a scan or photo. Its policy also states that forms will not be accepted by email.
The variation isn’t limited to cities. The Regional District of Central Okanagan states in its AAP materials that:
“No faxed or email elector response forms will be accepted; original signatures are required.”
In that case, electronic submission is not just limited—it is excluded entirely.
The process is the same. The requirements are not.
The legislation behind AAPs, set out in the Community Charter, requires a signature. However, it does not say what that signature has to look like.
What the Province Says—and What It Doesn’t
Guidance from the Government of British Columbia does not settle the question.
The Province’s 2023 AAP Guide says response forms must include identifying information, and be signed. However, it does not define the format of that signature.
Instead, the focus is on whether the submission can be tied to a real person who is allowed to take part.
Electronic Signatures Are Already Recognized
There is also provincial law that deals directly with signatures.
Under the Electronic Transactions Act, a signature can be electronic.
"If there is a requirement under law for the signature of a person, that requirement is satisfied by an electronic signature."
That doesn’t mean municipalities have to accept electronic signatures in every case. However, it does mean that electronic signatures are not automatically invalid.
For AAPs, nothing in the legislation or provincial guidance rules them out.
Where It Gets Left
The same provincial guide includes a short line that ends up carrying a lot of weight:
“Any policies related to electronic submissions would best be set out by local governments in a formal policy document.”
In other words, the Province leaves the decision with municipalities.
The Issue Has Already Been Raised Provincially
The question of how AAP submissions should be handled has also come up through the Union of British Columbia Municipalities.
A UBCM resolution on strengthening AAP legislation raised concerns about how the process works in practice, including accessibility and clarity.
In its response, the Government of British Columbia acknowledged how practices are already changing:
“As most of the province now has access to reliable internet and most British Columbians use email and expect to have online options, many local governments are choosing to allow emailed elector response forms.”
At the same time, the Province did not move to standardize those practices.
As a result, municipalities continue to work within a framework that allows flexibility but does not define how it should be applied.
Kamloops Put It in Writing
The City of Kamloops didn’t leave it to interpretation.
Council adopted AAP Policy GGL-33 on July 29, 2025, after reviewing a staff report that outlined how the process would work.
The policy states:
“Elector Response Form must include the signature of the elector, and electronic signatures are acceptable.”
The staff report explains why:
“One difference between these policies and the proposed GGL-33… is that the City’s policy allows for electronic execution (signing) of elector response forms, pursuant to BC’s Electronic Transactions Act. This increases accessibility by expanding the opportunity for electors to participate in the alternative approval process.”
In other words, the decision was tied directly to accessibility.
A Different Approach in Prince George
The City of Prince George has taken a different approach.
Its AAP page sets out the requirements clearly:
“Elector response forms must be completed in their entirety including the elector's printed name, handwritten signature, and complete residential address.”
There is no reference to electronic signatures.
In addition, the instructions require that all pages of the form be submitted, even if the final page does not require any information. As a result, the process assumes access to printing and document handling.
After reaching out to the City of Prince George last week, staff confirmed that a digital submission approach would not be considered for the current AAPs. It may be considered in the future.
When asked whether electronically signed forms from a third-party platform would be accepted, the response matched the published instructions: a handwritten signature is required.
Same Rules, Different Outcomes
Both Kamloops and Prince George are working within the same provincial framework.
However, the difference comes down to how that framework is used.
- Provincial law recognizes electronic signatures
- Provincial guidance leaves the details to municipalities
- Kamloops has set its approach in policy
- Nanaimo allows online submission but requires handwritten signatures
- Prince George requires handwritten signatures
- The Regional District of Central Okanagan does not accept electronic submissions at all
From a resident’s point of view, the process can feel very different depending on where they live.
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Where Submission Tools Fit
As more municipalities allow electronic signatures, the process itself starts to shift.
Instead of figuring out how to print and scan a form, the focus becomes filling it out properly and submitting it on time.
Tools like Kamloops AAP Submission Service are built around that idea. They don’t change the rules. They work within them.
Where electronic signatures are accepted, they can make the process more straightforward. However, where handwritten signatures are still required, they don’t have much role to play.
Noticed in Local Coverage
The shift in Kamloops has started to show up in local reporting.
An article by Levi Landry, published by iNFOnews, looks at a third-party submission site and includes a comment from Maria Mazzotta confirming that the City of Kamloops is accepting forms submitted through it.
That indicates submissions are being reviewed based on whether they meet AAP requirements, rather than how they are created.
Appendix: AAP Signature Instructions (Selected BC Jurisdictions)
Prince George
“Elector response forms must be completed in their entirety including the elector's printed name, handwritten signature, and complete residential address.”
Source: City of Prince George – Alternate Approval Process page
Regional District of Central Okanagan
“No faxed or email elector response forms will be accepted; original signatures are required.”
Source: Regional District of Central Okanagan – AAP Elector Response Form
Nanaimo
“Elector response forms will be accepted… through electronic submission on the City of Nanaimo’s website.”
“Elector response forms must include the original signature of the elector.”
“Elector response forms being submitted electronically… must be submitted as either a scanned copy or a photo of an original signed form.”
“Elector response forms will not be accepted via email.”
Source: City of Nanaimo – Alternative Approval Process Policy
Disclosure
The author is a co-owner of Wilbur’s Web, which operates the Kamloops AAP Submission Service. The service provides a structured way for residents to complete and submit AAP response forms.
Municipalities or community groups interested in a similar service can contact office@wilbursweb.com for more information.
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