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STATES OF JERSEY
GOVERNMENT PLAN 2022-2025 SCRUTINY REVIEW (ENVIRONMENT, HOUSING AND INFRASTRUCTURE SCRUTINY PANEL) (S.R.18/2021): JOINT RESPONSE OF THE RELEVANT MINISTERS
Presented to the States on 26th January 2022 by the Minister for the Environment
STATES GREFFE
2021 S.R.18 Res. (re-issue)
GOVERNMENT PLAN 2022-2025 SCRUTINY REVIEW (ENVIRONMENT, HOUSING AND INFRASTRUCTURE SCRUTINY PANEL) (S.R.18/2021): JOINT RESPONSE OF RELEVANT MINISTERS
Ministerial Response to: S.R.18/2021 Ministerial Response required 20th January 2022
by:
Review title: Government Plan 2022-2025 Scrutiny
Review
Scrutiny Panel: Environment, Housing and Infrastructure
Scrutiny Panel
FINDINGS
| Findings | Comments |
1 | There is currently a lack of transparency over how departmental budgets and resource are allocated to the Minister for Housing and Communities' remit. | It is the nature of the Minister's portfolio that it covers a range of different types of function – from face-to-face advice and support to Islanders to strategic planning, and stakeholder relationship management. The teams that support the Minister belong to different departments, each of which sets out its funding and priorities in a published Departmental Operational Business Plan. Similarly, all additional funding for the Housing portfolio is identified as such in the Government Plan. |
2 | There are no efficiencies assigned to the Minister for Housing and Communities and Minister for the Environment. There are proposed efficiencies totalling £500k under the remit of the Minister for Infrastructure which relate to proposed recurring spend reductions by Jersey Property Holdings. | Agree. |
3 | The Housing PDB and Long-Term Plan programme has been designated amber by the Panel due to a lack of co- ordination which has resulted in slow progress to date. Whilst it is | There has been a marked improvement in coordination on housing within government and across the sector during 2021. Key developments have been: |
| Findings | Comments |
| acknowledged that measures are proposed to improve co-ordination moving forward, the Panel will continue to monitor the progress of this programme throughout 2022 in order to determine whether coordination has improved and funds are sufficient to deliver the intended aims of this programme. | • new post of Head of Strategic Housing and Regeneration created and interim appointed. The development of the team is under way, which will further support the coordination of housing policies across government, with input from across the housing sector. • new Strategic Housing Partnership in place, bringing housing sector players together. Terms of reference agreed and scheduled meetings in place. The first meeting held on 29 September 2021 and the next is scheduled for February 2022. • cross-ministerial Housing Political Oversight Group has been established and a Modern Methods of Construction (MMC) political working group has been set up to investigate the support required to facilitate these new building technologies within the Jersey island economy context. • Housing Ministerial input to the Regeneration Steering Group is now in place to ensure direct input and influence regarding the government estates strategy. Sufficient funds are in place (as applicable) to |
deliver this coordination. | ||
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4 | The Tenants' Rights programme has been designated amber by the Panel given the significant work which remains in respect of the workstream throughout 2022 and beyond including for social rent, rent stabilisation and the Residential Tenancy Law. The Panel notes that to progress this work, the direction regarding a licensing or registration scheme for landlords would need to be decided and approved by the States Assembly. | The Minister for Housing and Communities published his Fair Rents Plan on 31 December 2021. The plan sets out a strong programme for enhancing tenants' rights and includes: • reducing the cap on social rents to 80% market value as of 1/1/2022. • freezing social rents at 2020 levels throughout 2022. • widening of eligibility to the Affordable Housing Gateway. • a commitment to improve the Residential Tenancy Law through a package of measures to be brought forward in early 2022. |
| Findings | Comments |
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| re-appointment of the Rent Control Tribunal in 2022. Additionally, the Housing Advice Service became operational in 2021 and important work is underway in CLS to improve homelessness services, as set out in the Housing Minister's Creating Better Homes Action Plan. The proposals for Landlords Licensing were brought by the Minister for the Environment and were not adopted by the States Assembly. The licensing of rented dwellings is not an action for the Minister for Housing and Communities under Tenant's Rights. |
5 | Notwithstanding the notable success of the Jersey National Park to demonstrate its achievements to date, this programme has been designated amber by the Panel, due to the following:
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The draft bridging Island Plan proposes redefinition of the CNP boundaries, and this proposal is currently the subject of active consideration through the Island Plan Review process. The proposition to approve a new Island Plan is the subject of an amendment to create a specific legal framework for the creation, definition and objectives of a national park in Jersey (see: P36/2021 (30)).
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| Findings | Comments |
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| circumstances. Changing Government priorities post-election may impact any policy area. |
6 | Funding allocations agreed in the previous Government Plan 2021 for the Marine Resources Management Programme has enabled the appointment of two fisheries officers. In addition, progress has been made for the resourcing of the vessel monitoring system and online logbook system. Funding of £92k is being requested in 2022 of £92k to continue to fund the retention of two fisheries officer posts. | Agree. |
7 | The implementation of the UK-EU Trade and Co-operation Agreement is still in its infancy and the vessel licensing regime is yet to be resolved. Consequently, uncertainty remains regarding whether the level of funding will be sufficient moving forward. However, the Panel notes that funds are available in the General Reserve to fund as required' the new Future Fisheries and Marine Resources Management Programme and has therefore designated this programme with a green RAG rating. The Panel will continue to closely monitor progress of Marine Resources Management during 2022. | Noted. |
8 | A total of £1,021,000 for the Covid-19 Bus Contract programme has been spent to date from the funding allocation agreed in the previous Government Plan 2021 and any underspend will remain with Treasury. The Government Plan 2022 requests a funding allocation of £1.2m which is deemed sufficient and will only be drawn down if required. | Agree, however the impact on the budget of the 6th Amendment to the Government Plan to provide Bus Passes to Under 18s cannot be accurately forecasted as this time. The £1.2m funding allocation was originally agreed because the Covid-19 outbreak led to reduced demand for the bus service, placing acute pressure on the bus network as passenger numbers fell to very low levels, with fare income falling far below break- even. As a strategically important service, it is pivotal to the aims of the Sustainable Transport |
| Findings | Comments |
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| Policy, providing environmental and social benefits, and reducing congestion on the roads and in public car parks. The funding was allocated to be drawn down as required, allowing the service to continue without significant changes and reductions having to be made, and avoiding a "vicious circle" effect of rationalised service levels making travel less desirable and further impacting upon income. While also preserving the employment of over 140 staff. The objectives of the funding: 1 – ensure a bus service remains in service that means it remains a viable alternative to the car, meeting the aims of the Sustainable Transport Plan and environmental goals for the future 2 – maintain public confidence in the bus service to ensure that the service provided by the operator is capable of being scaled back up to (and beyond) pre-Covid 19 levels as demand increases 3 – provide essential transport for those that rely on the service, including the elderly, school children and commuters. |
9 | Bus ridership is still down 65% on 2019's pre-pandemic levels, despite restrictions being lifted. The reason for this change in travel behaviour is not fully known at this stage, although it is surmised that the pandemic might have instilled a lack of confidence to resume use of public transport, as well as people continuing to work from home and there being less requirement to travel to and from the workplace. It is also unknown to what extent this reduction in ridership has had, and will continue to have, on the operator's profits. | |
The report also sets out the Jersey Franchise Model (p.43) as an exemplar as to how these strategies can be successfully deployed. In terms of specifically analysing and identifying the next | ||
| Findings | Comments |
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| steps for Jersey, this will be undertaken as part of the STP's Bus Development Plan, as detailed in the Second Interim Report on the Sustainable |
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10 | Whilst the continued leasing of the 28- 30 The Parade has provided unforeseen opportunity to accommodate the Covid- 19 Response Team, it does not appear to be providing value for money through its current under-utilised use. It has been identified that the intention is to not extend the lease beyond 2023, although the Panel is uncertain why indicative funding has therefore been proposed in the Government Plan 2022 for 2024 and 2025. | 28-30 The Parade is currently fully occupied, with Regulation, Team Jersey, Covid helpline, Track and Trace and media facilities for the Communications Team. The first break point in the Parade lease is in July 2027 which is why funding exists in the government plan for 2024 and 2025. The Intention is to transfer the occupants to the new government office when it is completed on the Cyril Le Marquand site and opportunities to sublet or assign the lease on the Parade will be investigated when the date of completion of the new office is confirmed. |
11 | There is uncertainty over whether the allocated funding of £2m for 2022 for Regeneration, including St. Helier ' is sufficient to make substantial improvements to the Island's public realm. In 2020, funding was significantly reduced by 75% to £3.4m over the four funded years of the programme and despite additional funds of £1m provided in March 2021, as well as the potential to draw down £730k from Jersey Development Company, the programme remains significantly under-funded against the funding projections made in the 2020 Government Plan. | The 2020 - 2023 Government Plan set out an objective to enhance St Helier's urban environment. A capital allocation of £14.4m was made for the development of a programme of Island Public Realm, Including St Helier' schemes. The impact of COVID-19 in March 2020 meant all capital projects were put on hold. The capital budget was cut by 75% to £3.4m over the four funded years of the programme and has been subject to further revisions. The 2022 -2025 Government Plan has further adjusted funding allocations to the programme, providing £2m per annum from 2022 to 2025 inclusive in addition to the funding of £1m for 2021. The Department for Infrastructure, Housing and Environment has a vacancy rate in the order of 50% within its transport engineering division, meaning it has severely limited resources to deliver more work. Meanwhile, the market for experienced engineers and urban designers is extremely tight, making recruitment difficult. To be able to create the on the ground momentum required for success, principally the public realm requires consistent and secure funding to allow a stable pipeline of projects to be established and |
| Findings | Comments |
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| permit the necessary development of on-Island skills and capacity required to deliver. The inclusion of £2m per annum within the Infrastructure Rolling Vote is a significant step towards this objective. The pipeline can then be expanded through bids for further funding in future years, as required, once the core technical capacity needed for efficient delivery is established. |
12 | Additional funds of £10.7m are required for the Sewage Treatment Works Major Capital Project. A breakdown was provided by the Minister for Infrastructure which includes additional funds for Biosolids Storage Facilities; STW Odour Mitigation; and Bellozanne Outfall Rehabilitation. Also included in the £10.7m is £1.85 which is required to fund additional costs incurred by the pandemic. | Agree. |
13 | There are likely to be delays to achieving project completion of the Sewage Treatment Works Major Capital Project by October 2023, although, it is hoped by the Infrastructure, Housing and Environment Department that it will be able to complete the project by the end of 2023. It is further considered that the IHE Department is sufficiently resourced in this area to able to manage the project through to completion now that the main contractor has gone into administration and the contract now having been terminated. | Agree. |
14 | The proposed increase in spend for the Dewberry House Sexual Assault Referral Centre (SARC) Capital Project from £500,000 to £882,000 in 2022 is to ensure space for Victims First (VF) thereby allowing Government to | Agree. |
| Findings | Comments |
| maximise synergy between the work of SARC, the Child's House, Jersey Domestic Abuse Support (JDAS) and VF and to realise economies of scale with having these services all co- located in the new building. The increased space will also allow services to support the recently released Children and Young Peoples' Emotional Wellbeing and Mental Health Strategy and provide services from the new building to those who have suffered all types of trauma and abuse. |
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15 | The removal of funds for the Piquet House – Family Court capital project is a result of the Family Court now relocating to alternative premises at International House following a States' approval to enter a lease contract. | Agree. |
16 | Anticipated funding of £1m for 2022 for the Drainage Foul Sewers Extension project has been withdrawn due to funding pressures and further funding is not proposed until 2023. The delivery of future extensions to the foul sewerage network will therefore be impacted by delays. | Agree. |
17 | The previous Government Plan 2021- 24 was set on the assumption that £1m in fees would be raised to enable food safety and housing legislation to be regulated on a cost neutral basis. However, the States Assembly did not support fees in relation to housing licensing at the time, nor the subsequent regulations, leaving the cost of activities surrounding the enforcement of the existing primary laws unfunded. | Agree. |
| Findings | Comments |
18 | The Jersey Landlords' Association has expressed concern regarding insufficient clarity in respect of the use of the funds and how the funding amount for the Housing and Food Licensing Schemes programme has been determined. The response from Government was that ongoing costs and the requirements are known. What is unknown is any works that would be included in post-Brexit requirement or with increasing workload going forward, for which an increased budget requirement has been made in the Government Plan bid for 2022. The £1m figure has therefore been estimated by Government on this basis and is deemed sufficient to fund the necessary requirements. | Agree, funding requirements are known by Government and have been sourced via the Government Plan as required. |
19 | The funds for 2022 for the Housing and Food Licensing Schemes programme is deemed, by Government, to be sufficient enough to cover the costs associated with the backlog of works and will allow the works to continue. However, there is uncertainty regarding additional potential costs resultant of any post-Brexit requirements or increasing future demand. Moreover, uncertainty exists in respect of the evolving nature of the two workstreams and the impact thereof on resourcing for delivery of the objectives. Therefore, the Panel has designated this programme amber. | Noted. |
20 | The Government Plan 2022-25 requests funding of £250k for Increased Liquid Waste Processing within the pumping stations and tanker service. It was found that £170k of the £250k is due to increased electricity costs, with the balance relating to some of the maintenance within liquid waste and | Agree. |
| Findings | Comments |
| increased cost relating to tanker transportation. Increases in population and adverse, wet weather conditions have also contributed to increased costs in using Government of Jersey tankers, as well as contracted tankers. The Panel is satisfied with the level of funding requested and has designated this programme green. |
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21 | The Government Plan 2022 seeks approval for a funding allocation of 1.25m for 2022 in relation to Hazardous Waste Removal which seeks to support the effective disposal and processing of all hazardous waste while adhering to waste management regulations and ensuring that the construction industry has a route to dispose of its hazardous waste. The Panel received evidence which confirmed that the funds allocated for 2022 are a contingency measure for if income targets of hazardous waste are not met as a result of reduced activity. If income targets are met, and the allocated funds are not required, the funds would be returned to Treasury. The Panel has therefore provided a green RAG status for this programme. | Agree. |
22 | Previous funding allocations for the Vehicle Testing Centre Major Capital Project have been withdrawn on the basis that it is now expected this will be delivered by the provider. The implications of this have been assessed by Government and based on confirmation provided from potential providers who had made an expression of interest, this has been deemed a workable model. The outcome, therefore, is that this capital funding is no longer available, and the preferred option is that the provider will be required to construct and operate the | Agree, this business model is common practice in other jurisdictions for commercial operations of this type. |
| Findings | Comments |
| inspection centre, preferably on a site provided by government. |
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23 | A new fund as required' UK/EU TCA Biosecurity Border Controls and Vienna Convention Vehicle Testing programme is included in the Government Plan 2022 to support the adoption of new border control requirements in line with the UK-EU Trade Co-operation Agreement and practical steps the UK DEFRA requires the Island to implement. In addition, to enable the periodic technical inspection of all vehicles that will ensure the Island is fully compliant with the articles of the Vienna Convention for Road Traffic. However, it is uncertain at this stage how much funding will be required for 2022 and beyond. The Panel has therefore designated this programme with an amber RAG rating. | Noted. |
24 | The Climate Emergency Fund has been designated amber by the Panel given the significant work which remains in respect of the workstream throughout 2022 and beyond. The Panel notes that to progress this work, the policy direction within the Carbon Neutral Roadmap will still need to be approved by the States Assembly. Moreover, agreement will need to be reached on the additional revenue streams to fund the additional monies that will be required to meet the Government's ambitious aims to be achieved by 2030. | Noted. |
25 | The carbon neutral and sustainable transport workstreams are still in their infancy. Consequently, uncertainty remains regarding the level of funding and resourcing that will be sufficient moving forward. However, the Panel notes that the Carbon Neutral Fund will | Noted, please note that the fund is the Climate Emergency Fund, not the Carbon Neutral Fund. |
| Findings | Comments |
| fund as required' the new Carbon Neutral Fund and Sustainable Transport Programme. The Panel will continue to closely monitor progress of this programme during 2022. |
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26 | The Panel observed a willingness from private organisations/stakeholders to play an active part in assisting the Government to achieve its ambitious policy aims in respect of combating climate change. However, views expressed by stakeholders to the Panel suggests that Government should be doing more to involve those stakeholders and to form the partnerships required to impact timely change on carbon neutrality. | The Ministers for the Environment and Infrastructure have liaised with key stakeholders throughout the process of declaring a Climate Emergency in 2019 and beyond. The Ministers and their officers will continue to liaise with key stakeholders and encourage them to engage in the consultation on the Carbon Neutral Roadmap which is underway at time of writing. |
27 | Measures have been put in place to manage the crossover of remits through the establishment of the Carbon Neutral Steering Group and with the policy development function for the Carbon Neutral Roadmap and the Sustainable Transport Policy both falling within the Sustainability & Foresight team under the Strategy and Innovation Directorate within SPPP. However, it is the Minister for the Environment's view that the current arrangement for the climate emergency portfolio was predisposed to cause confusion as it crossed the remits of both the Minister for the Environment and the Minister for Infrastructure. The Panel observed that improved political oversight of the climate emergency portfolio may be beneficial through a dedicated ministerial role for the portfolio. | Agree. |
28 | Funding has been set aside in the General Reserve for the fund as required' Future Fisheries and Marine Resources Management Programme. | Noted. |
| Findings | Comments |
| Although funding amounts are uncertain, £263k has been estimated for 2022 with additional estimates of £253k in 2023 and £238k in 2024 and 2025. Since the implementation of the UK- EU is still in its infancy and the vessel licensing regime is yet to be resolved, uncertainty remains regarding the level of funding that will be sufficiently required moving forward. Considering the scope of work and the uncertainty regarding the level of funding, the Panel has designated an amber RAG status for this programme. |
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RECOMMENDATIONS
| Recommendations | To | Accept/ Reject | Comments | Target date of action/ completion |
1 | The Minister for Housing and Communities should, in his Ministerial Response to this report, provide a breakdown of the apportionments from relevant departmental budgets which are applicable to his Ministerial portfolio. The purpose and aim of doing so would be to aid better understanding and enable greater transparency in relation to the budget resources attributed to Common Strategic Priority 4 which seeks to improve the quality and affordability of housing and improve social inclusion. | MH C |
| Government spending, as approved via the annual Government Plan, is identified in detail through departmental budgets. Within the Government Plan report, the ministerial portfolio table on page 127 of the Government Plan provides a best efforts' estimate to allocate departmental budgets across ministerial responsibilities. This table shows an allocation of £650,000 to the Minister for Housing and Communities for 2022. The breakdown of the allocation of £650,000 to the Minister for Housing and Communities budget by department and service area is provided below: | As per recomme ndation, this is answered in commen ts' |
| Recommendations | To | Accept/ Reject | Comments | Target date of action/ completion |
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| Head of MHC Service Expenditure £000s Area |
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Infrastructure, Property Housing and Capital and Environment Delivery 500 Strategic Public Policy Policy, Planning and Performance 150 | |||||
Total 650 As expenditure is approved on a departmental basis, reporting does not directly align to areas of ministerial responsibility and this table is based on an apportionment of departmental budgets. | |||||
2 | The Minister for Economic Development, Tourism, Sport and Culture should provide clear guidance on Jersey National Park's role, purpose and responsibilities. Since the JNP is an arms-length organisation of Government, consideration should be given to whether its role can be separately identified, as well as how its objectives can be clearly defined. The Minister should consider how this clarity might be incorporated into the Rural Economy Strategy for 2022. | ME DT SC | N/A | The role, purpose, responsibility and objectives of the JNP will be formalised as a policy component of the revised Rural Economy Strategy (RES) which is due to be published in Q2 2022. The RES policy component will reference the Partnership Agreement which exists between the Department for the Economy (on behalf of MEDTSC) and JNP, which incorporates annual schedules specifying the objectives of the JNP and the KPIs used to monitor performance on set objectives. | Already underwa y |
3 | The Department for Infrastructure, Housing | MI NF | Accept | Changes to travel behaviours and tourism due to Covid is the immediate | End of 2022 |
| Recommendations | To | Accept/ Reject | Comments | Target date of action/ completion | |
| and Environment, in collaboration with LibertyBus, should undertake an evaluation of the reasons for decreased ridership, as well as an analysis on measures which can be further taken to promote and incentivise bus ridership as a sustainable travel option. This should work should be undertaken before the end of Q2 2022 and the outcome reported back to the Panel. |
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| reason for changes in bus ridership, changes of a similar order have been reported nationally and worldwide in other developed economies. The UK Government's Bus Back Better set out the national strategy for the recovery of the bus patronage, based upon universal principles for bus growth. The report also sets out the Jersey Franchise Model (p.43) as an exemplar as to how these strategies can be successfully deployed. In terms of specifically analysing and identifying the next steps for Jersey, this will be undertaken as part of the STP's Bus Development Plan, as detailed in the Second Interim Report on the |
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4 | The Minister for Infrastructure should outline in his Ministerial Response why indicative funding has been suggested for 2024 and 2025 in the Government Plan 2022 if it is not the intention to renew the lease on 28-30 The Parade after 2023. | MI NF | Accept | See response to Finding 10 |
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5 | It being acknowledged that there will be considerable funding constraints across Government going into 2022, the Minister for Infrastructure should ensure that funding for public realm is prioritised and allocated in gradual | MI NF | Accept | Agreed, there needs to be sufficient and sustainable funding for a meaningful programme of public realm schemes to enhance St Helier's urban environment to be developed in accordance with the St Helier Public Ream and Movement Strategy, in conjunction with other opportunity sites across the Island, and to allow an appropriate technical | 2023 - 25 | |
| Recommendations | To | Accept/ Reject | Comments | Target date of action/ completion |
| increases throughout 2023-25, to ensure that any shortfall resulting from these funding cuts is suitably addressed and that improvements to the public realm can be sufficiently funded moving forward. |
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| delivery capacity to be established on- Island. |
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6 | The Minister for Infrastructure should report back to the States Assembly in time for the next Government Plan 2023 to confirm whether it is the intention to make up the shortfall of funding for 2022 in future Government Plan bids for 2023-25, as well as providing a revised target date for when, wherever practicable, the whole Island will be connected to the foul sewerage system. | MI NF | Accept | Additional funding for foul sewer extensions has been requested for 2023- 2025. For the schemes to be viable the new sewage treatment works needs to be complete to accept more flow. The sewage treatment works construction is currently due to be complete by the end of 2023. Depending on the foul sewer extension scheme further network upgrades may also be required. Whilst it would be fantastic to get the whole Island connected, it is unfortunately not practicable. The Island is currently at 92% connected and we would like to increase that amount. The Liquid Waste Review currently underway will determine an achievable connection rate for the Island. | 2023 |
7 | The Minister for the Environment and the Minister for Infrastructure should, moving forward, actively seek to consult and involve, where appropriate, local organisations who are willing and able to contribute to the Island's journey to reach carbon neutrality. The Ministers should seek to form | ME NV / MI NF | Accept | Enabling Policy 2 in the draft Carbon Neutral Roadmap is to 'Create a Carbon Neutral Alliance' - Work with the Economic Council sustainability working group to support the development of a Carbon Neutral Alliance of businesses and voluntary, community, social enterprise and faith sector organisations; and establish a £500k Climate Action Fund to support grassroots projects to tackle the climate emergency. | Ongoing. |
| Recommendations | To | Accept/ Reject | Comments | Target date of action/ completion |
| partnerships with local organisations and stakeholders to accelerate the Government's aims to realise its ambitious plans. |
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8 | Given the crossover between the remits of the Minister for Infrastructure and the Minister for the Environment, further consideration should be given, before the next term of Government, as to how political oversight for the climate emergency portfolio can be strengthened and improved. Specifically, whether the climate emergency portfolio would benefit from a dedicated ministerial role. | Co M | Partially accept | As the Carbon Neutral Roadmap is due for debate in April 2022, the final sitting of this Assembly, this allows little time for the Council of Ministers to consider the outcome of the debate and/or the preference of the Assembly with regard to investigating and considering changes to ministerial portfolios. However, ahead of any debate, the Minister for the Environment is supportive of greater ministerial oversight as it relates to the Environment and would encourage the next Government to consider possible changes to ministerial portfolios. Strategic Policy 2 in the Draft Carbon Neutral Roadmap recommends A new ministerial portfolio for energy and climate change'1 New portfolios will be a matter for the next Chief Minister/Government. |
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CONCLUSION
The Ministers2 with responsibility for the Infrastructure, Housing and Environment Department thank the Environment, Housing and Infrastructure Scrutiny Panel for their report into those areas of the Government Plan 2022-2025 as they relate to the Ministers' and Department's areas of responsibility.
Re-issue Note
This Response was re-issued to fix a title error that omitted the Minister for Infrastructure. It was agreed to amend the title that was more reflective.
1 R draft Carbon Neutral Roadmap 20211216 JB.pdf (gov.je)
2 The Minister for Economic Development, Tourism, Sport and Culture; the Minister for the Environment; the Minister for Infrastructure; and the Minister for Housing and Communities