Housing target 'no longer exists'
IT APPEARS that the Environment and Housing departments are conducting a PR campaign, as part of the Island Development Plan inquiry, through the pages of the Guernsey Press by publishing the legal advice they have received. This is yet a further disrespect, to add to the earlier disrespect, of a States department that failed to turn up for the public inquiry hearing.
Perhaps the departments' PR campaign is thought necessary because some unusual circumstances have arisen.
At the preliminary IDP meeting on 16 September, planning inspector Keith Holland explained that the inspectorate were not expecting any further written material from any parties and would rely on submissions already made, unless there were 'exceptional circumstances'. After consideration of the Housing Department's Policy Letter (dated 13 July 2015), in the States meeting of 29 September, the States of Deliberation decided against the proposition that the strategic housing target remains 300 new dwellings per year and for the proposition to initiate a 'detailed and independent wide-ranging review' of the operation of the local housing market.
Deputies expressed concerns about the lack of robust information available on the strategic housing target and asked that the proposed housing review be a 'separate full report' to be carried out 'now rather than later'.
These circumstances are indeed 'exceptional' and to ensure that the IDP continues, they have taken to explaining themselves in the media rather than directly to the inspectors. No other public representor would be allowed to get away with such disrespect, but that does not appear to trouble the departments concerned.
As your Opinion column on 12 October 2015 says, the letter from the Strategic Land Planning Group and the enclosed highly equivocal legal advice that it has chosen to publish demonstrates how uncertain they are of their position.
If the IDP is to follow an historic housing target which has not only not been endorsed by the States but has been expressly rejected by it, given how much of the IDP is underpinned by adherence to the Strategic Land Use Plan, the Corporate Housing Plan and the strategic housing target, it would be bizarre in the extreme.
In her own advice to the Environment Department, Crown Advocate Shorey refers on no fewer than five occasions to the 'lack of clarity' arising from the resolutions of the States.
She rather weakly suggests that notwithstanding that lack of clarity, it may nonetheless be reasonable to continue to use the historic housing target of 300. She seeks to argue that it would be reasonable to continue to follow a target that no longer exists and to follow a discredited Housing Needs Opinion Survey (the 2011 one) that has been roundly criticised. Her observations on the inconvenience and delay that may arise from having to resolve the lack of clarity can be no justification for ignoring the very clear resolutions of the States. To use the rejected housing targets and not to await the conclusions of the new Housing Needs Survey that has been directed for March 2016 would simply add to the lack of clarity with the current situation.
This will be the basis of my representations to the inspectors, but I will do them the respect of waiting and presenting these detailed and legally-supported representations in person. I would be amazed if the IDP can ultimately proceed on the basis of the expressly rejected 300 housing target in all the circumstances. Less haste, I say – it is far more important to get it right, even if it does incur a few months of delay. The IDP once finalised will last for 10 years or more and there is no one matter contained in the whole of the draft IDP more likely to permanently change the face of Guernsey than the discredited strategic housing target.
C. J. MCHUGH,
Strategic Development Partnership,
PO Box 245,
St Peter Port, GY1 3QD.
