Requete rights wrong

In the Annual Monitoring Report (AMR) debate, Deputy Merrett said, ‘We were told that policies [of the IDP] would be flexible and would be responsive to change.’ It is clear, from the huge amount of public concern, that this isn’t the case and that amendments are required. She also said that the Assembly ‘should take responsibility and have accountability for what they enacted’. We have great respect for the fact that she is doing exactly that. Deputy Gollop said that Deputy Merrett ‘was very much a catalyst for creating the AMR debate and that as a representative of the northern parishes, she has been particularly purposeful in bringing issues to our attention.’

Due to her continued support and communication, we believe that she is fully aware of the concerns of the community and that she has a full grasp of what action is required. She made many good points during the debate (or an ‘epic speech’, as Deputy Gollop described it), some of which we list below:

l Are the DPA prioritising brownfield sites? Who decides the prioritisation list? Since the debate, development frameworks have been approved on greenfield land, so we know the answer to the first question. It is also clear that there is no prioritisation; more a ‘first come first served’ approach, which is a far cry from the previous Urban Area Plan when greenfield land was held in reserve and brownfield sites were prioritised for development.

l How long will the Leales Yard development framework take to come to fruition and have conversations already taken place with the existing land-owner? It was explained that a proactive approach will be taken by the Authority regarding a development framework for Leale’s Yard, but not until the full permission has expired in August 2019. It will be interesting to see when a development framework will be drawn up for this brownfield site and we sincerely hope that it will take pressure off the greenfield sites listed in the IDP, before they are lost to development.

l We currently have granted planning permissions for more than a five-year supply, but we still have 15 housing allocation areas listed on the IDP. The number of granted permissions has the potential to further increase by a significant number in the near future, now that another three development frameworks have recently been approved (totalling approx 180 dwellings). This should be reviewed as a matter of urgency, in order to stop unnecessary loss of the island’s greenfield land.

l The AMR states, ‘the inspectors noted that any change to the housing indicator … may require consequential amendments to the IDP’. The indicator was debated in 2018 and the housing requirement almost halved. Given that IDP policies are based on a housing requirement of 300 per year and that this requirement has since reduced by approximately half, we believe that subsequent changes are urgently required to reflect this.

l Community plans – why have there been none to date? What resource does the community have, bearing in mind that they need to be produced in line with the constraints of the IDP and other statutory plans? Have there been any public meetings held to explain what a community plan is? Changes are required in order that the public are given the same amount of consideration as a landowner/developer. As an example, it was pointed out in 2017, both by the Delancey Conservation Committee and by individual(s) that, regarding the Pointues Rocques HAA, we had/have a ‘group of enthusiastic community volunteers that will lead the process and bring others on board, right at the outset’ (as quoted in the Community Plan Supplementary Guidance 2016 document). But we asked how this is possible if the public are not advised that a framework was being prepared in the first place? By the time we were aware that community plans existed, the development framework was already in draft form. The various landowners had been consulted but the community had not. This is neither fair nor democratic.

l Formerly protected green land within the main centres have lost protection from development. When the IDP superseded the UAP, the former well-protected SNCI sites (sites of nature conservation importance) were divided into two categories and renamed. Some were labelled ‘SSSs’ (Sites of Special Significance) and others were labelled ‘ABIs’ (Areas of Biodiversity Importance). The ‘ABI’ label was a new designation created for the purposes of the IDP but the policy surrounding ABIs affords them next to no protection. Planning permission has already been granted on some ABI land. Furthermore, all former well-protected SNCIs within the main centre of the north are now labelled ABIs.

As we know, it is the responsibility of the States to protect our natural and physical environment, including land use, biodiversity and agriculture. A core objective of the SLUP is ‘to improve the quality of life of islanders…’, but if in November 2018, members of the assembly believed that these responsibilities were not being fulfilled, it was irrelevant as they were not given the opportunity to suggest amendments to IDP policies when the Annual Monitoring Report was debated. The DPA published their first report as an appendix, meaning that it could be debated but no changes could be made.

We believe that this requete rights this wrong. We appreciate that there will be additional work, but given the amount of unrest, concern and sensible comments made by the community, we sincerely hope that the island’s politicians will seriously consider giving these amendments the support that they truly deserve.

DELANCEY CONSERVATION COMMITTEE