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Thank you for the opportunity to comment on the proposal for an interim Island Plan.
I attended one of the Island Plan public consultation meetings and would like to offer a few thoughts.
Should we have a 3 year plan?
We are obviously in a very difficult situation with the disruption to the economy caused by Covid 19 – but we also face risks that some groups will try to influence policy in a way that would not be sustainable or in the best interests of the island. This is apparent in some other jurisdictions where it seems that the difficulties caused by controlling covid are being used to relax polices in the interest of developers.
We are also missing some key elements that are essential if we to have an effective plan – the most notable of these is an agreed and effective policy for migration and population. This was one of the main concerns of some of the people at the public meeting.
Having thought about this for some time I now feel that it would not be appropriate to have a 3 year plan.
We already have an Island Plan. As drafting a new one has been disrupted and we are missing an essential dependency – the population policy - I suggest that the existing Island Plan is extended for a limited period – say one year. This should be sufficient to enable the States as a whole to agree a migration and population policy and so give the Planning department the material needed to inform the new Island Plan.
Although this approach might be questioned by some people – particularly in view of the recent rise in population – it should be seen as consistent with the States' previously policy.
What if an interim plan is agreed?
If a decision is made to have an interim plan, I have to ask that it is based on control rather than expansion.
Any extension period should be as short as possible and should aim to strengthen controls rather than relax these.
Protection of employment land
We are currently overdependent on a single sector of the economy and need to develop a more diverse economy to protect employment in the future
The last 10 years have seen considerable loss of commercial space which has been converted for domestic use. This applies to both general commercial buildings but also to agricultural land. The President of the Farmers Union has written in support of for new entrants to Agri business. I would like to support this. Jersey has lost much of its character through the urbanisaton of agricultural land.
Recent studies have shown the wholesale loss of biodiversity and the encouragement of smaller agricultural businesses with less monoculture may help.
Conversion of viable fields to parkland for expensive houses removes land from productive use.
We also seem to have an approach that allows that if a landowner has breached planning requirements for 8 years then they may continue to do so.
I would suggest that any new planning process should seek to enforce the existing policies that we have until we have a clear policy for the population and economy regardless of how long a property has been in breach. This would encourage the return to agricultural land to agriculture and make it more affordable for those who genuinely want to farm the land.
Use of older agricultural buildings
I note there have been suggestions that these buildings could be converted for self catering accommodation to support agriculturalists. Unfortunately existing laws do not provide the protection needed to ensure this only benefits active agriculturalists. I am aware of situations where buildings have been approved for conversion to Self Catering (claimed to be exempt under policy E1) and then applied for change to residential without actually being developed.
I believe there should be no change in use until laws are strengthened to ensure they are only used for the agreed purpose and any future application assumes the previous state of the property
At a personal level I believe that if there is no suitable agricultural use then these building provide opportunities for commercial use to help diversify the economy and provide opportunities for people who do not wish, or are not able, to work in finance.
I hope the above is of use and would be happy to do discuss this if appropriate. In the meantime can I ask that that if this response is published then it is kept anonymous.
Kind regards
