Comments from Michael Dun on the Revised
Plan Draft Jersey Island
11 May 2011
1) Only in
Jersey could the Island Plan be prepared in advance of the Census.
My first comment is therefore that the Plan should be withdrawn entirely until the 2011 Census has been digested and reported upon. Then the Plan can be reconsidered and re-drafted on the basis of reliable statistics and information. The existing 2002 Island Plan should remain in force in the meantime.
2) I gather that Deputy Sean Power has expressed a similar point of view about the Census.
He has also proposed by virtue of his 27th Amendment P48 that the Housing Chapter should be removed from the current Plan and a revised Chapter prepared instead. In the meantime he proposes that the 2002 Housing Chapter should remain in force.
I support that proposal as an alternative
3) I note that yet another St Helier Northern Plan has just been published.
All of a sudden such Plans for this patch seem to be appearing with absurd regularity whereas they have been required to be prepared ever since the 1980s under previous Island Plans.
Similarly, plans for many other Built Up Areas have been promised for decades but have still not materialised.
4) I say that until all or most of the area plans have been published and agreed that it is absurd to proceed with the rest of the Island Plan. In other words, I suggest that the whole Island Plan be suspended until all the future implications for St Helier and other built-up zones have been agreed based upon realistic aspirations for housing, commercial, retail, transport, industrial, recreation, and other development needs.
Only then will it be realistic to consider developments in the rural areas of the
Many of the aspirations in the current Plan for office, retail and housing development are just fantasy and are totally unrelated to economic reality or even Jersey’s own contradicting policies for CSR (cost cutting) on the one hand and Growth (population and business) on the other.
5) The Planning Inspectors (Messrs Shepley and Langton) recommended that the needs of the Non-Qualified residents of
Jersey should be better addressed (8.140 – 142).
I can see no change in this Plan so far as these 10,000 or so working adults (20% of the working population) are concerned. This is a moral disgrace and a planning absurdity. The Island Plan should be altered or withheld until research is undertaken to determine the specific housing demand from this group and their families. Current policies that largely ignore them are blatantly discriminatory and wholly inconsistent with best planning practice.
Furthermore, the substantial reforms that are already planned in the re-organisation of the Housing Department, States Social housing stock, Housing legislation and regulation of people and properties is so profound that the implications must be acknowledged and planned for.
6) The proposition currently before the States in the name of Population control will categorise and control all units of living accommodation from Alhambra splendour to Zinc covered slums All residents too will be labelled in accordance with their housing and work status and there will be all sorts of supporting rules about security of tenure for ALL etc. The implication for the housing stock are immense and there will be huge implications for housing provision – especially among those who are currently “off the radar” or living in sub-standard or unofficially sanctioned or “non-quals” units.
7) This Island Plan fails to accommodate so many other major reforms that are already in the pipeline by several government departments so that it is more like a plan for another Island That all this is proceeding against the background of CSR policies that demand public spending cuts of £65 millions before 2013 and reduced budgets thereafter for evermore whilst at the same time expanding the economy and population is so absurd as to be hopelessly flawed. Health, Education, sustainability, and transport plans etc that are already being discussed and promoted are not adequately reflected in this Plan if at all.
There are immense proposals yet to be digested and agreed by the States that will be implemented during the life-time of this Plan. It is just plain silly that the Plan does not include them.
8) During the previous Draft Plan discussions I raised repeatedly questions about discrimination, Human Rights and international obligations.
The Inspectors hardly fell over themselves in support (anymore than does the
Jersey government) but they do ask that the Plan shall be confirmed as Human Rights compliant before it is adopted (1.23).
Such an assurance is not just a bland endorsement. It cannot be done without a proper examination of the policies that are included.
Thus, where discrimination is promoted between qualified or non-qualified under Housing laws or agricultural workers or agri-business in preference to others, or rural dwellers above urban – then I say that it should be spelled out that such contradictions re compatible. And, I don’t just mean compatible with the European Convention of Human Rights – I mean that the Plan shall be declared as compatible with ALL the international obligations that are relevant to this Plan. It is not just a question of non-discrimination either because there are human rights obligations relating to privacy and the peaceful enjoyment of property etc - besides important environmental safeguards that should all be recognised and acknowledge BEFORE this Plan is adopted.