Island Plan (revised) 2011: site to be rezoned for Category A housing – Field 632 and part of Field 559, La Route du Manoir, St. Peter (P.39/2019) – comments [P.39/2019 Com.]

STATES OF JERSEY

ISLAND PLAN (REVISED) 2011: SITE TO BE REZONED FOR CATEGORY A HOUSING – FIELD 632 AND PART OF FIELD 559, LA ROUTE DU MANOIR,

ST. PETER (P.39/2019) – COMMENTS

Presented to the States on 16th April 2019 by the Minister for the Environment

STATES GREFFE

2019  P.39 Com.

COMMENTS

Introduction

This proposition (P.39/2019) seeks to impose an ad hoc approach to delivering homes, focussing narrowly on a single parish, and using a mechanism that will result in the loss of open countryside.

It  is  being  lodged  at  the  same  time  as  we  are  embarking  on  complementary comprehensive reviews which will address the following – how best to deliver the Island's need for homes, through the work of the Housing Policy Development Board; and where and how we should be providing them, through a comprehensive review of the entire Island Plan.

An interim review of the current Island Plan, as proposed by this proposition, has no guarantee of delivering a successful outcome, as it will be considered within the existing strategic policy framework provided by the current Island Plan; it will likely be regarded as premature by any Planning Inspector appointed to review it, given the ongoing comprehensive review of the Island Plan; and it will undoubtedly detract from the effort and resource that is needed to deliver the comprehensive Island Plan Review.

In addition, it also conflicts with an explicit resolution of a St. Peter Parish Assembly taken last month to pursue the proposal as an integral part of the comprehensive Island Plan Review – as opposed to seeking the course proposed by this proposition.

The view of the Parish Assembly reflects mine. I believe that the provision of new homes in the parish is better addressed as part of the comprehensive Island Plan Review, which is currently scheduled for delivery in 2021. A comprehensive Island Plan Review will include a strategic review of where homes should best be provided across all parishes, and will allow a full and thorough assessment of the policy options that are available to effectively deliver homes to meet the Island's housing needs.

Background

A planning application (PP/2017/1444) to build 65 three-bedroom first-time buyer homes on Green Zone land in St. Peter was refused in 2018. The development was not permitted due to substantial and significant conflict with the current Island Plan, and because sufficient justification' to override the Island Plan had not been provided.

It was considered that the proposal would –

1. be premature ahead of the completion of work to establish a clear and detailed understanding of the Island's affordable housing needs and how best to meet them;
2. harm the protected Green Zone; undermine the Island Plan's approach to spatial planning and the strategic delivery of housing; and
3. in particular,  result  in  the  loss  of  agricultural  land,  without  sufficient justification; and harm local character and the natural environment.

Island Plan Review

The  Planning and Building (Jersey) Law 2002 requires that the Minister for the Environment prepares and presents to the States Assembly for approval, a draft revision of the Island Plan within 10 years of the approval of the previous Plan. The current Island Plan was adopted in June 2011, with an interim review of parts of the plan in July 2014 and, therefore, a new draft Island Plan must be lodged during 2021.

A comprehensive review of the Island Plan, as required by law, is already underway. A revised Island Plan is scheduled to be lodged in the States Assembly by the end of 2020 before consideration and adoption in early 2021.

Any proposed interim review of the Island Plan, to bring forward individual sites such as that in St. Peter , would still take 9–12 months, owing to the statutory requirement for public consultation and review by an independent Planning Inspector, before lodging and consideration by the States Assembly. An interim review – as proposed by this proposition – would not be delivered until early to mid-2020.

There is also no guarantee that the outcome of an interim review to rezone land in St. Peter for housing would be positive, as bringing forward such a proposal may be deemed to be considered premature by an independent Planning Inspector, having regard to the ongoing, comprehensive Island Plan Review.

It is also considered that the resources required to effectively run 2 Island Plan review processes in parallel is inefficient, and will serve to detract from the comprehensive Island Plan Review process.

The need for and delivery of homes

That the Island needs more homes is not disputed. This was accepted by the Planning Inspector when considering the proposal that is the subject of this proposition –

"Whilst I recognise that there is evidence of large and rapidly increasing demand for affordable first time buyer housing, I find that the provision of information to demonstrate that the proposed development responds to a specific area of demand, is not the same thing as evidence to demonstrate that the Island Plan under-provides for affordable housing.

The proposed development seeks to address a single area of demand for affordable housing outside this comprehensive, Island-wide context. It seeks to do so in a manner that would result in additional land being developed for affordable housing during the Plan period, over and above the existing supply, which is, itself, considerably greater than that required by the Island Plan.[1]"

What is, therefore, at issue, is how many homes are needed; what type and tenure of homes; how best to deliver them; and where they should go. The answers to these questions are best dealt with through a comprehensive Island Plan Review.

A comprehensive Island Plan Review will need to be informed by the outcome of work to consider the Island's migration policy, and will have regard to the relevant findings of the Objective Assessment of Housing Need Report ("OAHNR") 20182. This is a long-term assessment of housing need for the next Island Plan Period (2021–30), not current demand. It will also need to have regard to the recent evidence provided by Jersey's Future Housing Needs 2019–20213.

It will also be informed by the outcome of work being undertaken by the Housing Policy Development Board, which will seek to identify measures to improve the supply and affordability of, access to, and standard of, housing in the Island.

Some of these measures will inevitably involve the provision of land and development opportunities for the provision of new homes. In considering the need for new homes, regard will need to be had of the provision of a significant amount of new affordable first-time buyer supply through the redevelopment of existing stock and some new site acquisitions  by  existing  housing  providers.  Andium  Homes,  for  example,  already propose to deliver an additional supply of 1,000 first-time buyer units and an additional 1,000 rental units by 2025.

Consideration should also be given to other policy options to deliver new and a better mix  of  homes  which  may  be  considered  and  developed  by  the  Housing  Policy Development Board, including –

• enabling downsizing to free up under-occupied existing family-sized homes;
• reducing the number of existing vacant homes by bringing them back into use: 3,000 vacant homes were identified in 2011;
• directing affordable housing providers to change the existing tenure of their estate to provide more first-time buyer homes (for example, Andium Homes have, within their portfolio, a range of existing homes within the village of St. Peter that could, if appropriate to do so, become available as affordable homes for purchase); and
• re-introduction of an affordable housing on private developments policy, requiring developers to deliver affordable homes as a proportion of private developments.

All of the answers do not, therefore, lie with the planning system and the Island Plan. It is only right that decisions to consider the potential rezoning of green field sites to deliver homes are taken in the full knowledge and consideration of robust evidence of need and supply, and having regard to all policy options to best deliver the homes that the Island needs.

Summary

The Island has a finite land-use resource, particularly of prime agricultural land, and I believe that the rezoning of green fields should be considered as the last resort in the policy hierarchy for the delivery of homes. Any rezoning should only be pursued as part

2 Using the OAHN report, the proposition identifies that based upon a migration level of 1,000

persons per year, up to 7,000 potential additional households up to 2030 will be required. This includes an estimate of around 2,000 affordable homes.

3 https://www.gov.je/SiteCollectionDocuments/Government%20and%20administration/R%20

HousingNeedsSurvey2018%2020190328%20SJ.pdf

of an overall careful strategic analysis of how best to meet the need for homes across the Island as part of a comprehensive and scheduled Island Plan Review, rather than through piecemeal rezoning decisions, as put forward in this proposition.

The previous planning application was refused, not just on the basis that the proposal would be premature ahead of work to establish a clear and detailed understanding of the Island's affordable housing needs at that time, and how best to meet that need, but also on the basis that:

1. The proposal would result in the loss of agricultural land without sufficient justification.
2. The  proposal  would  result  in  harm  to  local  character  and  the  natural environment.

Both of these reasons for recommending a refusal are still relevant when considering future housing site policy options that include the development of green fields, and would need to be satisfactorily addressed to ensure a successful outcome.

The 2011 Island Plan is a strategic 10-year plan (from 2011–2020) and is delivering a significant supply of over 1,000 affordable homes during this period. The OAHN report, along with other key demand evidence, such as the upcoming migration policy and latest housing gateway and housing needs surveys, will be used to inform the Island Plan Review for the next period 2021–30.

The comprehensive Island Plan Review will be the best vehicle to identify and progress the most appropriate and sustainable policy options to deliver future housing needs for the whole Island, between 2021–2030, having regard to all the available evidence. As this work is underway, I consider that this proposition is premature, and I urge Members not to support it.

Financial and manpower implications

There will be adverse human resources and financial implications arising from the need to carry out an interim review of the Island Plan at a time when existing resources are focussed on undertaking a comprehensive Island Plan Review.

The diversion of existing resources has the potential to detract from and undermine the preparation of the 2021–30 Island Plan.

Recommendation

I urge Members to reject this proposition.