Yes, this would be considered a "minor kennel" so long as:
- All dogs are on the same lots
- At least five of them are six months of age and older
- They are maintained out-of-doors or in unheated buildings
To see where minor kennels are allowed, visit "Where can I open a new dog (or cat) kennel?" The full definition of "kennels, minor" is included from FNSBC 18.04.010.B:
Kennels, minor" means "a lot on which no fewer than five and no more than 24 dogs or cats, six months of age and older, are maintained out-of-doors or in unheated buildings.