Retail Policy - Ministerial Response - 1 October 2014

Findings

Comments

(ED unless otherwise specified)

1

Retail  remains  an  important  sector  of  the Jersey  economy,  accounting  for approximately  7%  of  the  total  GVA  and nearly  8000  employment  positions. However,  the  value  and  volume  of  retail sales have notably declined since 2008 and there  are  signs  that  this  trend  is  likely  to continue,  particularly  with  regard  to  non- food products.

2

The overarching retail policy since 2006 has been  the  Retail  Framework,  which  has focused  predominantly  on  food  retailing, food  price  competition  and  supermarket operators. It was last updated in 2010.

3

Although slow to react, since August 2013 the Minister for Economic Development has recognised and begun to act on the need to engage  with  retailers  to  develop  initiatives and  plans  to  help  address  the  downward economic  trends  and  challenges  associated with the on-island retail sector.

4

The Chief Executive of Jersey Business, who has played a significant role working with the Economic Development Department on the  development  of  the  draft  Retail Development  Plan,  is  leaving  the

Findings

Comments

(ED unless otherwise specified)

organisation. It is unclear if this will have an impact  on  any  of  the  draft  initiatives currently  proposed  to  involve  Jersey Business.

5

Doubts about the positive outcome of a free parking  trial  on  Saturdays  were  raised amongst  TTS,  EDD  and  the  Town  Team. The  approximate  cost  of  such  a  trial (£300,000)  has  since  been  earmarked  to assist alternative retail initiatives.

6

The  Economic  Development  Department created avoidable confusion and delays to its own  and  the  Panel's  work  in  relation  to retail,  by  developing  the  draft  Retail Development Plan with inadequate inclusion of  and  communication  with  other stakeholders, and failing to notify the Panel of  the  ongoing  work  despite  procedural requirements to do so.

7

Despite  the  highly  promising  purpose  and membership of the Town Team, its future is uncertain.  There  are  proposals  from  the Economic Development Department for the Town  Team  to  be  incorporated  within  or perhaps  even  replaced  by  a  new  Retail Jersey'  brand  via  the  Retail  Development Plan.

8

Online  competition  represents  the  most significant challenge to Jersey's high street' retailers.

9

Online retailers are notably more appealing than  traditional  bricks  and  mortar  retailers around  the  issues  of  price  and  shopper convenience.

10

It is estimated that 35,350 (85% of the total) Jersey  households  are  purchasing  products and  services  online,  with  the  total  online spend in 2013 amounting to £258 million.

11

The average annual online household spend in Jersey in 2013 was just over £7,000.

12

Research  demonstrates  that  mobile  tablets and, particularly, smart phone devices have become increasingly important as a means of purchasing products and services online. The

Findings

Comments

(ED unless otherwise specified)

trend in 24/7' purchasing culture is expected to continue to develop as mobile technology increasingly  facilitates  anytime-anywhere shopping.

13

82%  of  respondents  to  a  shopping  habits survey  said  they  would  welcome  the opportunity to spend more money with local retailers  if  only  they  had  suitable  e- commerce websites. In general, however, the online  sales  platform  and  marketing/social media  presence  of  local  retailers  has  not adequately developed to meet the challenge of off-Island online retailers, although some creditable  and  co-ordinated  platforms  have begun to emerge.

14

Jersey's high street retailers can continue to aspire to a positive future, but to help achieve this must harness the opportunities provided by ever improving technology.

15

The Minister for Economic Development is broadly supportive of the general concept of the  Jersey  Chamber  of  Commerce's Jamazon'  initiative,  but  is  not  convinced that  it  represents  the  best  value  or  most suitable  option  to  deliver  the  desired outcome for the Island's retailers.

16

Retailers in Jersey will need to continue to develop  multi-channel'  retailing  models combining  bricks  and  mortar,  online sales/booking, click and collect and/or home delivery.

17

Jersey's  many  small  retailers  may  require significant  co-ordination  and  some government  assistance  to  overcome  the challenges of scale and cost in developing multi-channel' retailing models.

18

Face  to  face  customer  service  is  widely regarded as one of the opportunities for high street' retailers to gain advantage over online competition.  However,  the  quality  of customer service in Jersey has been found to be  highly  variable.  Retail  owners  and managers  are  ultimately  responsible  for improving this situation, but can be assisted by government.

Findings

Comments

(ED unless otherwise specified)

19

In  general,  Jersey  retailers  have  not  fully reacted to changing customer habits and are potentially restricting shopping opportunities through  outdated  9  to  5'  opening  hours. Later closing times on a more regular basis have  been  identified  as  being  attractive  to shoppers.

20

Sunday trading remains a contentious matter. Opinion  on  the  Minister  for  Economic Development's Sunday trading trial has been split,  with  54%  of  respondents  to  the associated White Paper not in favour of the trial.

21

It is not clear whether current Sunday trading restrictions are a significant barrier to retail in  Jersey.  Very  few  retailers  are  currently restricted from opening on Sundays.

22

Relaxation  of  Sunday  trading  restrictions appears  to  be  of  more  obvious  potential economic  benefit  to  certain  out-of-town retailers,  such  as  garden  centres,  than retailers in town.

23

Amending current weekday/Saturday trading hours would appear to be a greater priority than  changes  to  Sunday  trading.  It  could provide greater positive consequences for a larger  number  of  retailers  and  consumers than a Sunday trading trial with significantly less contention.

24

At  the  end  of  Minister  for  Economic Development's proposed liberalisation' trial of Sunday trading legislation, although the legislative  position  would  revert  to  the current situation restricting those with a sales area of more than 700m², there is concern that it would be difficult culturally to turn the clock back'.

25

Certain  negative  impacts  that  might  result from the proposed Sunday trading trial, such as small business closures due to increased competition  from  larger  retailers,  could  be irreversible.

26

Local  retailers  are  effectively  forced  to compete on an uneven playing field with off- Island/online retailers, due to the application

ED and T&R

Findings

Comments

(ED unless otherwise specified)

of 5% GST on the price of locally sold goods and  the  existence  of  the  £240  de  minimis level under which imported goods attract no GST.

27

Potential GST revenue is being missed out on by the Treasury, and increasingly so, with the  growing  trend  in  off-Island,  online shopping.

T&R

28

Reducing or removing the de minimis level would not be straightforward. For instance, although  it  is  estimated  that  its  removal would achieve an increase in GST collection of  approximately  £800,000,  at  Jersey  Post alone it would necessitate at least an extra 241,000  consignments  (averaging  660  per day)  requiring  customs  clearance  per  year. This would represent an increase in workload of approximately 28%, which would require funding.

T&R

29

Amending the de minimis rules with a view to the States forming agreements with off- Island online retailers to collect GST on its behalf for sales to Jersey-based customers, has been raised as an idea to help level the playing field'. Nevertheless, such a solution holds challenges and potentially significant, if unintended, negative consequences.

ED and T&R

30

It  is  widely  agreed  that  the  Retail  sector would  benefit  from  the  attention  provided and  generated  by  an  appropriate  Retail Champion'. To carry the required authority and  ability  to  influence  on  retail  related matters within the States, it was identified that  the  Retail  Champion'  should  be  a sitting politician.

31

The Retail Champion' should be supported with suitable executive support on a day to day basis. This role would include much of the retail related work currently undertaken within  the  Economic  Development Department,  and  additional  work  emerging from initiatives such as the proposed activity and co-ordination around an events calendar (see  also  7.8.2).  Regular  liaison  through  a comprehensive  stakeholder  group,  such  as the current Town Team, remains important.

Findings

Comments

(ED unless otherwise specified)

32

Within  the  draft  Retail  Development  Plan, the  Minister  for  Economic  Development Department is considering the establishment of  a  Jersey  Retail'  brand  within  Jersey Business, through which support to the retail sector could be delivered. The merits of such a structure are not apparent to the Panel.

33

Building on current practice, there is wide support  for  increased  retail  activity  to  be undertaken linking directly into a range of current  and  potentially  new  events  and/or themed days. It has been widely agreed that this  should  be  actively  co-ordinated,  with necessary scheduling and focus provided by a dedicated events calendar for retailers.

34

It is not unusual for event organisers to be required to complete significant processes in order to obtain permissions to hold events. The requirements do not always appear to be in  proportion  to  the  size  or  nature  of  the event.

35

There  can  be  restricted  access  for  events during the year in some of the more suitable and attractive sites.

36

Although visually attractive and creating an often improved atmosphere, it is difficult to strike  the  right  balance  between pedestrianisation and the needs of retailers to service  premises.  Pedestrian  priority initiatives, already seen in some parts of the Island,  appear  to  provide  an  appropriate compromise.

ED/P&E/TTS

TTS  –  Island  Plan  proposal  23  supports  the concept  of  Halkett  Place,  Library  Place, Dumaresq  Street  and  Hue  street  as  potential pedestrian priority areas. TTS also supports this concept  and  the  Sustainable  Transport  Policy (STP)  (Recommendations  5.10)  proposes  that Halkett Place (south of Waterloo Street) should be subject  to  a  pedestrianisation  scheme.  However resources  to  develop  and  implement  these schemes are currently unallocated.

37

Maximising the physical attraction and the ease of moving through town were identified as important means of encouraging people to choose to shop in town. However, inadequate pavements and clumsily placed bollards and street  furniture  were  cited  as  examples  of existing  physical  barriers  that  negatively impact on the ability of people to enjoy the experience of shopping in town.

ED/TTS

TTS is supportive of the removal of street clutter and  the  provision  of  improved  pavements, particularly in the town area. Works are ongoing, though subject to resource constraints.

38

The covered markets should be a jewel in

ED/T&R

Findings

Comments

(ED unless otherwise specified)

the crown' of Jersey's retail sector, acting to stimulate  footfall  in  town  and  attracting shoppers to a vibrant retail core. Presently however, whilst architecturally attractive, the markets fail to live up to such expectations and radical change has been widely called for to  improve  on  the  tired  atmosphere  and generally underwhelming offering.

39

Although  there  have  been  recent  moves towards the creation of a trader's association, there  has  been  a  lack  of  cohesion  and collaboration  amongst  the  covered  market traders that has been a barrier to progress in the markets

T&R

40

Issues regarding parking featured in almost all submissions received by the Panel during the Review. Parking matters present a very real  challenge  to  retailers,  but  there  are workable initiatives that could help improve the situation.

ED/TTS

TTS is working to deliver the parking provisions as  identified  in  the   St. Helier  Parking  Needs Study. Further to this TTS is actively pursuing opportunities for flexible payment and charging systems.

41

Overall capacity amongst town's car parks is adequate  to  accommodate  demand  from commuters and shoppers, but the geographic distribution of  spaces  is  not.  The  north  of town  is  under-served  by  the  current  car parking provision, and Pier Road car park is too frequently under-capacity.

TTS

The St. Helier Parking Needs Study identified that long-stay  commuter  car  parks  reach approximately 82% of capacity, short-stay 60% and on street 79%. The spare capacity in off street car parks is however almost entirely in the south of St. Helier and TTS is working to deliver key recommendations  of  the  study,  principally  200 short stay spaces at Ann Court and at least 200 spaces at a long-stay site (to be identified) in the north town.

42

Minden Place is a vital shopper car park, but, as  with  others,  it  is  outdated  and  requires significant refurbishment, modernisation, or complete replacement.

TTS

Agreed, St. Helier Parking Needs Study refers.

43

There continues to be significant frustration with  the  scratch-card  system,  whilst  the automatic number plate recognition system in Sand Street has been widely welcomed.

TTS

Agreed, TTS is actively pursuing opportunities for flexible payment and charging systems.

44

There is wide acknowledgement and support for more bus services to be provided to help people  access  town  at  points  other  than Liberation Station, along with a service that would  link  urban  areas  whilst  penetrating towards  the  town  centre.  The  latter  could

TTS

TTS  agree  that  there  is  potential  for  improved town bus services, though with short trip distances and potentially high proportions of bus users of pensionable  age,  it  is  inevitable  that  a  high subsidy cost will arise. A proposition for a town

Findings

Comments

(ED unless otherwise specified)

encourage more shoppers to visit town and other  retail  areas  such  as  Les  Quennevais Parade.

bus service was approved by the States in 2011 and  accordingly  TTS  has  developed  a  notional town network for implementation should funding become available.

45

There is some confusion over the status and continued  relevance  of  existing  planning strategies  for  town,  notably  the  North  of St. Helier Master Plan.

P&E

46

The  current  withdrawal  of  proposals  for development  around  Bath  Street  by Le Masurier's has been a significant setback for retail regeneration opportunities in that area.

P&E

47

The town footprint and retail core is shifting south-westerly  with  the  influence  of  the developing  waterfront  area.  Additionally, there are indications that the town retail core could contract due to the challenging trading conditions,  to  be  increasingly  anchored  by King Street and Queen Street.

P&E

48

Despite  certain  improvements  in  Planning application  processes,  retailers  continue  to face  challenges  relating  to  change  of  use policies.  The  challenges  can disproportionately  affect  small  businesses and retailers with small premises. The time taken  to  gain  relevant  permissions  and compliance  with  bye-laws  such  as  those relating  to  the  provision  of  toilet  facilities were  identified  as  being  particularly challenging, Due to the impact of the shifting town  footprint  in  increasing  the  number change of use applications, such occurrences may become more frequent.

P&E

49

King Street and Queen Street have retained almost un-paralled full occupancy levels over recent  years  despite  the  challenging  retail environment.

50

Rents have not been identified as currently being  a  leading  challenge  to  retailing  in Jersey. It appears that a number of landlords recognise the challenging retail environment, generally leading to rents being established at  levels  that  have  not  deterred  tenancies being taken.

Findings

Comments

(ED unless otherwise specified)

51

Whilst King Street and Queen Street have retained robust occupancy levels, there have been  instances  of  short  and,  more significantly,  long-term  unoccupied  shops outside of the retail core. There is currently no  States  policy  designed  to  help  address such detrimental occurrences.

52

Retail, tourist, traffic and general information signage  is  too  often  underwhelming, inconsistent and outdated. This is a matter that  requires  the  co-operation  and  co- ordination of a number of stakeholder groups to  improve,  including  retailers  themselves and authorities such as Jersey Tourism (ED), other  relevant  States  Departments  and  the Parish of St. Helier .

ED/P&E/TTS

TTS  agree  that  signage  is  outdated  as  limited investment has been put into it in recent decades. A significant resource would be needed to design and  implement  a  comprehensive  update.  The Parish  of   St. Helier  are  currently  progressing  a new town centre pedestrian information signage scheme.

53

Increased use of flags and banners has been identified  as  a  relatively  quick  and inexpensive  means  of  refreshing  and animating  retail  areas,  although  concerns were raised about the possible nature of the associated planning process including by the Minister for Planning and Environment.

P&E

54

Despite related reviews, there are no clear signs  that  the  challenges  of  avoidable government  bureaucracy  is  easing.  This challenge to retailers is amplified by the fact that  the  majority  of  retailers  are  small businesses, often owner run and often with a workforce of below 5.

55

The  continued  presence  of  undue government bureaucracy can in no small part be attributed to a lack of co-ordinated cross- departmental  working  within  the  States. Whilst reform has been slow, there are some positive  signs  emerging  in  the  form  of initiatives such as tell us once' and unique user id's' that are intended to reduce such avoidable over-bureaucracy.

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

1

The  Minister  for  Economic Development  must  not underestimate the challenges faced by the retail sector and should,  as  a  priority, continue  to  engage  with retailers  in  a  structured manner.

ED

2

Working  with  the stakeholders,  the  Minister for  Economic  Development should  progress  initiatives and plans to help address the challenges  associated  with the  on-Island  retail  sector, and  develop  a  new,  more relevant and comprehensive overarching Retail Strategy.

ED

3

The  Minister  for  Economic Development  should  work with retail representatives to identify the most appropriate way to assist the retail sector to  embrace  technology. Support  might  include  the funding of a feasibility study into  an  appropriate,  co- ordinated  online  sales platform,  and  the  provision of  appropriate  training opportunities  and  shared practice workshops.

ED

4

The  Minister  for  Economic Development  should  work with  relevant  Ministerial colleagues,  and  potential private  sector  providers,  to put  in  place  and  promote suitable learning and training opportunities for retailers in areas  such  as  high  quality customer service.

ED

(SS/ ESC)

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

5

The  Minister  for  Economic Development should extend the  one-off  2013  Mystery Shopper  customer experience  audit  into  an annual  piece  of  research. This  will  help  inform  the need  for  and  nature  of relevant  future  training initiatives.

ED

6

The  Minister  for  Economic Development should seek to co-ordinate  an  agreement amongst retailers to be more flexible in their approach to opening hours where benefit can  be  accrued.  Particular attention  might  focus  on later closing times on a more regular basis, and, in a more targeted  fashion,  achieving more  flexibility  in  opening hours  during  peak  summer tourist season and events.

ED

7

If  the  States  approve  the proposed  18 month  trial  of liberalised  Sunday  trading, the  Minister  for  Economic Development must ensure a robust  process  for monitoring and recording of all  associated  aspects (including  economic, employees'  welfare,  social and cultural impacts).

ED

8

Specific attention should be paid  by  the  Minister  for Economic  Development  to mitigate the potential loss of small  businesses  due  to increased  competition  from larger  retailers  during  any trial  period  of  Sunday trading.

ED

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

9

In order to inform possible strategies to alleviate undue negative  impacts  of  the uneven  playing  field associated  with  the de minimis  level,  the Minister  for  Treasury  and Resources  is  recommended to  undertake  the  following studies –

an  immediate  (and subsequently  on  an ongoing basis) review of the de minimis provision, to ensure that it is set at the  lowest  appropriate rate;

a  feasibility  study  of entering agreements with off-Island online retailers for the collection of GST relating to sales to Jersey- based customers.

T&R

10

To provide suitable focus to the role Retail Champion', the  Minister  for  Economic Development  should  either more  actively  assume responsibility for promoting economic  development within  the  retail  sector,  or formally delegate the role to an  Assistant  Minister.  If delegating,  this  should  be clearly  reflected  within  the title  of  the  Assistant Minister.

ED

11

The  executive  support  for the  Retail  Champion' should  be  provided  by  the Economic  Development Department,  with  industry input  continuing  to  be sought  through  a comprehensive  stakeholder group,  such  as  the  current

ED

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

Town  Team,  or  an equivalent body.

12

The Economic Development Department  should undertake  the  active  co- ordination and promotion of an event calendar linked to retail  initiatives  in conjunction  with  all  the necessary stakeholders.

ED

13

The  Minister  for  Economic Development  (or  delegated Retail  Champion'),  should examine  the  current processes  related  to  event permissions and identify any work  that  might  be undertaken  or  support  that can  provided  to  reduce avoidable  barriers  to  such initiatives.  Similarly,  any restrictions  to  the  use  of event-friendly sites, such as the Royal Square, should be identified  and  addressed where appropriate.

ED

14

Pedestrian priority initiatives should  continue  to  be implemented,  and  a feasibility  study  of  such  a scheme  in  Halkett  Place from Amyson Corner along the  length  of  the  Central Market  should  be  co- ordinated as a priority by the Minister  for  Transport  and Technical  Services,  with input from the Town Team or equivalent comprehensive stakeholder organisation.

TTS

Reject

Although both the Island Plan and STP  propose  that  a  pedestrian improvement  scheme  should  be developed  for  Halkett  Place, resources  to  develop  and implement a scheme are currently unallocated and it is not accepted that  this  can  been  given  priority over  other  current  planned  STP infrastructure  schemes.  However TTS  supports  the  principle  and will  look  to  develop  proposals when resources permit.

15

Through the Town Team or equivalent  body,  the Minister  for  Economic Development  should  co- ordinate  a  plan  to  identify and  implement  relevant

ED

(with TTS)

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

improvements  to  the physical  town  environment, including  removal  of physical  barriers'  that negatively  impact  on  the ability of people to circulate easily through town.

16

A  clear  strategy  should  be developed  by  the  Minister for Treasury and Resources (the Landlord) regarding the covered  Markets.  This should  be  informed  by consultation with all relevant stakeholders  on  the  wide range  of  initiatives  and views  held,  and  include assessment of a fundamental overhaul  of  the  interior layouts  and  retail  offering. Changes  must  also  be considered  to  outdated opening hours.

T&R

17

The  Minister  for  Treasury and  Resources  (the Landlord) should explore the immediate  revision  of outdated  opening  hours within the markets to better reflect  customer expectations  relating  to  the both  the  overall  and individual  retail  offerings. Thursday  afternoon  closing should  be  removed  as  a priority.

T&R

18

The  Minister  for  Transport and  Technical  Services should  undertake  the necessary  work  with colleagues  and  other stakeholders  to  achieve  the following:

A  clear  decision  on  the future  provision  of  north of town car parking.

TTS

(with P&E/ T&R)

Accept

The   St. Helier  Parking  Needs Study  has  been  accepted  by  the Ministers for TTS and P & E and identifies a clear decision on the future  of  north  town  public parking,  though  implementation will be dependent on affordability through the car park trading fund.

TTS is developing a pay by phone system  and  will  be  phasing  out

Parking  at Ann  Court dependent on  housing development timescales.

Payphone system to be put  out  to tender  Nov.

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

The roll-out of automatic number  plate  recognition systems (or similar) in all covered car parks to end the  predominance  of scratch-cards.

A fully developed strategy for  the  phased modernisation  and refurbishment  of  all  car parks.

A review of all initiatives, including  charging structures,  that  might encourage  a  more appropriate distribution of commuter  and  shopper parking.

scratch-cards,  firstly  in  multi- storey car parks and eventually at other  off-street  as  well  as  on street. Pay by phone systems will enable a smarter charging system which  will  allow  more  flexible distribution of parking.

A  programme  of modernisation/refurbishment  is being  developed.  1st  project  is underway at Pier Road.

Charging  structure  will  be reviewed  as  more  flexible charging  and  payment  systems become available.

2014  for implementati on in 2015

Refurbishme nt  at  Pier road underway (Sept. 2014)

Further programme ongoing.

19

The  Minister  for  Transport and  Technical  Services should  work  with  Liberty Bus to develop proposals for more buses to access town at points other than Liberation Station  and  a  service  that would link a range of urban areas whilst also penetrating towards the town centre.

TTS

Accept (in part)

It  is  unrealistic  to  significantly divert or extend established trunk bus routes further into town – but, given  adequate  funding,  TTS would  support  a  separate  town network  and  will  work  with Liberty  Bus  to  facilitate interchange  between  services through  refined  ticketing arrangements  and  well-designed connections at the bus station.

Town service currently unfunded. Discussions with  Liberty Bus  4th  qtr. 2014

20

The  Minister  for  Transport and  Technical  Services should  work  with  Liberty Bus to develop a service that would link a range of remote areas  to  bus  routes  that access  urban  shopping districts.

TTS

Accept

Liberty Bus is developing a trial community service and anticipates commencement  4th  qtr.  2014. Possibilities to reshape services to better connect urban areas will be discussed with Liberty Bus, with an associated streamlining of core routes  from  those  parishes  to St. Helier  to  enhance  their attractiveness.

Discussions with  Liberty Bus  4th  qtr. 2014

21

The  Minister  for  Planning and  Environment  should assess the merits of revising and/or clarifying the current strategies  relating  to development  in  town, notably with regard to their

P&E

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

relevance to retail. This will be  essential  in  providing  a structure  to  the  south- westerly  shifting  town footprint  and  potentially contracting retail core.

22

The  Minister  for  Economic Development  should  work with  the  Town  Team  or equivalent  body,  and  the Constable  of   St. Helier ,  to develop  plans  that  could help address and discourage long-term  empty  shop occurrences.

ED

23

The  Minister  for  Economic Development  should  work with  the  Town  Team  or equivalent body, and notably the  representative  from  the Environment Department, to ensure  that  change  of  use processes  and  laws  are  as appropriate  and  efficient  as possible.

ED

24

The  Minister  for  Economic Development should address the  issues  of underwhelming, inconsistent and  outdated  signage  with the  Town  Team  (or equivalent) to help improve the town experience for all users.

ED

25

The  Minister  for  Planning and  Environment  should examine  the  planning process  and  legislation associated  with  flags  and banners to ensure that they are  as  appropriate  and efficient as possible.

P&E

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

26

In his lead role in the States' Modernisation  Programme, the  Minister  for  Economic Development  should demonstrably  tackle  the issue  of  a  lack  of  co- ordinated cross-departmental working  within  the  States. Furthermore,  he  should ensure  that  initiatives  such as tell us once' and unique user IDs' significantly assist in reducing the bureaucratic burden  placed  particularly, although not exclusively, on small  businesses,  including many  of  the  Island's  retail sector.

ED