Island Plan 2022-25: Approval (P.36/2021) – eleventh amendment (P.36/2021 Amd.(11)) - addendum [P.36-2021 Amd.(11)Add.]

STATES OF JERSEY

ISLAND PLAN 2022-2025: APPROVAL (P.36/2021) – ELEVENTH AMENDMENT(P.36/2021 AMD.(11)) – ADDENDUM

FIELD 630, ST. OUEN

Presented to the States on 18th March 2022 by the Connétable of St. Ouen

STATES GREFFE

2021  P.36 Amd.(11) Add.

ADDENDUM

1. I have made submissions through the Bridging Island Plan Review process to keep the opportunity to provide affordable homes on Field O630. The Minister for the Environment is proposing to designate this piece of land in the centre of St. Ouen 's Village as Protected Open Space. This means that it could not be built on and would have to be maintained. Currently it is kept as grass and used as occasional car-parking.
2. The need for housing in the island is well documented and evidenced. It is an issue that has been reviewed by the independent Planning Inspectors as part of the Examination in Public of the Draft Bridging Island Plan (DBIP).
3. The foundation for the DBIP is provided by the Island Plan Review Preferred Strategy (IPRPS), sponsored by the Minister for the Environment and endorsed by the Council of Ministers. In terms of housing policy, the IPRPS identifies the availability and cost of housing as a key issue that the DBIP is designed to address. Under the planning for the needs of the community strategic policy in the IPRPS, one of the principles is to ensure that all islanders have access to and can afford a decent home. Critical considerations for housing on the island are therefore the balance between demand and supply and the spatial distribution of additional housing provision.
4. The  evidence for  housing  need  is  based  on  the  Objective  Assessment  of Housing Need (OAHN) which was undertaken by consultants in 2018 with the Final Report published in January 2019. Drawing together the various elements of housing demand, the Minister considers that the DBIP should have an overall five-year housing target of 4,000 additional homes (SR23 and PCR6). This includes a requirement for 1,000 affordable homes during the five-year period (Policy H5, DBIP, page 189).
5. The Parish of St. Ouen has engaged fully with the Bridging Island Plan process. It has undertaken its own survey to get an understanding of housing need within the parish. The results of a survey undertaken in 2019 identified a demand for 54 homes for older people (55+) and 80 homes for first time buyers. This has risen to 106 homes for first time buyers and 124 homes for older people as at 1st February 2022.
6. Working with The Church of England I have identified Field O630 as an ideal site to provide five homes for older parishioners. A scheme has already been drawn up and favourable advice given by Planning Officers.
7. I am very concerned about the implications of the Minister's proposal and review of the site as the proposal would lose the opportunity to provide five new dwellings for older parishioners in the heart of the village, within walking distance  of  shops  and  services.  In  the  Minister's  Consultation  Report (September 2021) the assessment of the submitted response on behalf of the Connetable is dismissed on the following basis:
8. Both the landowner objection and proposed states member amendment no.11 incorrectly highlight the Infrastructure Capacity Study (ICS) and 2008 Outdoor

Open Space, Sport and Recreation Study (the 2008 study) as being the basis for the proposed designation of protected open space of field O630.

9. This is surprising because the Minister's own report Infrastructure Capacity Study, December 2020' commissioned to inform a baseline of the island's existing and planned infrastructure including Open Space (page 84 of the report) and Policy C17 – Protected Open Space states that the evidence base for the 2020 assessment includes:

• Outdoor Open Space, Sport and Recreation Study (2008)

• The Revised Island Plan (2014)

• St Helier Open Space Audit (2018, unpublished)

• The Government Plan 2020-2023 (2019)

• The Government Plan 2021-2024 (2020

10. At page 54 of the Minister's statement response SR18 – Policy CI7 – Field 630

– protected open space (September 2021), the Minister for the Environment says that:

Both the landowner objection and proposed states member amendment no.11 incorrectly highlight the Infrastructure Capacity Study (ICS) and 2008 Outdoor Open Space, Sport and Recreation Study (the 2008 study), as being the basis for the  proposed  designation of protected open space of field O630. The Minister for the Environment contends that neither of these reports form the basis for the proposed designation, but it is noted that they do have some thematic relevance:  

•the ICS considers the need for parks, amenity greenspace, play space and natural green spaces across the island broadly: it measures the potential  additional  requirement  for  open  space  based  upon anticipated population growth, and only ascribes this to settlement- type, not specific parts of the Island. This finding is therefore of no direct use in the determination of open space requirements in specific parts of the island.

•the standards alluded to in the 2008 study and mentioned in both the Parish of St. Ouen representation and proposed amendment no.11, have not been used as a basis to measure and justify the need to protect field 0630. These standards  have not been tested or  qualified for adoption in rural areas, but it is noted they have been tested and qualified for adoption in the Town area which is more dependent on the need for a balanced supply of a range of public spaces (see Policy CI6 –Provision and enhancement of open space and its preamble text, and also St. Helier Open Space Audit (2018)). The point raised in these representations highlighting that a prescribed standard for St. Ouen 's village wouldn't be appropriate due to the nature and proximity of rural and coastal areas is agreed and is the reason why standard has not been used for the assessment. The explanation of the basis of the proposed designation of field O630 is set out on page 45-46 of the Community facilities and open space: assessment of sites (2021)1. This assessment explains how the site was suggested for protection through

the Minister for the Environment's Call for Sites' process and explains the reasons why this request was agreed and the protection of the site as an important open space proposed. This report should be referred to for further information.

11. In  his  response  the  Minister  states that the  village  of   St. Ouen  compares unfavourably with other villages for open space and provides some plans for comparison. However,

1. The comparison does not include all the space in and around St. Ouen 's Village
2. There is no explanation about how open space is used or its quality.
3. There is no analysis of how the community uses the space and how the village functions from a sustainability perspective.

12. At the Examination in Public – Strategic Infrastructure Hearing the Minister advised that an assessment of open space in St. Ouen 's Village should be undertaken using the methodology provided in the St. Helier Open Space: Audit Summary. St. Helier is a town with approximately 35,000 inhabitants. There are no recent estimates of St. Ouen 's Village population, but we know it has approximately 600 dwellings (extrapolation approx. 1,200 population). The context is very different; villagers have much easier access to the surrounding countryside and north coast footpaths of the island and are well served by the amenity spaces already provided.
13. St Ouen's Village has:

1. a well-used and highly accessible Village Green with a band stand, petanque pitch, children's play area and open green space – there has been no feedback to suggest that it gets overcrowded.
2. An informal quiet woodland area along Hydrangea Avenue.
3. Recreation space to the north of the Village.
4. A space within La Ville ès Marettes
5. Football pitch to the south of the village.
6. The village is surrounded by countryside and there are beaches (St Ouen's Bay) within 1.5km of the village centre (and cycling distance).

These spaces are not shown on the Minister's analysis plans.

14. St Ouen's Village is surrounded by countryside and there is easy access to the many beaches and the cliff paths that are within the parish.
15. The Minister's assessment also does not appear to take into account that any rezoned sites for affordable housing would have a policy requirement to include open plays-pace as part of any development brief approved for a site. The Minister  makes  no  suggestion  about  what  type  of  open  space  would  be appropriate for this location taking into account accessibility requirements and neighbours.
16. The reasons I am requesting that Field O630 is kept as Built-Up Area is because work has already been done to deliver affordable homes on the site for older parishioners.  If  Covid  had  not  happened,  the  parish  would  have  sought

permission to submit a planning application. The land has been identified by the parish as a site where affordable homes for older parishioners can be built.

17. Given the acute need for housing in the island, if there is already sufficient land in the village to meet the needs of parishioners, I consider that keeping the site available to meet the housing needs of five households takes priority.
18. Access to existing open space for St. Ouen 's Village residents is explained in the written submission already made.

Field O630

Village Green(top) and green open space Hydrangea avenue