Such comments from the public must be lodged by 25 September and are centred upon some specific areas that include "glass house" sites. The invitation however appears to allow for more general comments to be submitted and for other sites to be put forward.
Here I am copying my own submission which calls for the scrapping of the entire Island Plan.
This is not some spiteful and ill-considered comment. I have been submitting reasoned arguments to the "Planning Department" for years and lobbying States Memebers on these and all sorts of related matters.
My efforts have of course been a complete waste of my time and effort.
Undaunted however, I have prepared this latest document and sent it off to the Department and I shall be circulating it too to all States Members and anybody else who might be "interested".
Submission to the Environment Department on the re-zoning of land under the
Plan for housing purposes by Michael Dun 20 September 2013 Jersey Island
Before and during the Island Plan Review – Examination in Public - I devoted weeks of my time preparing submissions and attending the meetings.
I addressed the Inspectors on several occasions.
The main – but not only – focus of my concern was with the abysmal inadequacy of the proposed “Housing” section of the Proposed Island Plan.
I pleaded with the Inspectors to recommend that the whole Plan should be aborted until such time as the “Housing” part might be reconsidered and rewritten. Or, at the very least, the Housing section should be extracted and reconsidered if the remainder of the Plan were to proceed.
The whole Plan had been prepared in advance of the Census taking place or the results analysed and it was visibly defective being based on out of date statistics.
Of course, my pleas were disregarded. Yet it is now absolutely clear that the Housing proposals in the Island Plan are, as I predicted, totally inadequate and they are being re-considered just two years later.
Last week I attended the latest Scrutiny Panel meeting where the current Housing Minister explained that his “waiting list” for known families had grown to over 700 families needing “social housing” and the delivery of potential building sites was not going to meet any known demand.
Many of these were people needing “accessible” housing due to their disabilities but no attempt has ever been made in
Jersey to quantify the actual numbers who might require such accommodation. Yet the Health Minister is currently peddling a wholesale reform of services that includes a policy of the sick and aged “caring for themselves in their own homes”. It is of course meaningless PR speak without a supportive Island Plan based upon research.
In fact, the Housing Department (soon to be scrapped) has no overall knowledge about supply and demand for housing in
Jersey because the largest sector – that of private housing provision – is not monitored in any way. There simply is no reliable information about the vast majority of Jersey residents who have not appeared on the “social waiting list” of the Housing Department.
Even that list is wholly defective because it precludes most married couples less than 50 years of age without children or single young people under 25 etc and of course the Department has no legal responsibility to house anybody at all, no matter how desperate might be their need.
That there is no supply of “affordable housing” in
Jersey and how this is related to the absurd housing control laws or other discriminatory policies ought to be the subject of examination. Unfortunately, this Island government prefers to proceed on the basis of no knowledge.
So the whole history of housing provision is based upon totally inadequate and misleading information so far as those with “qualifications” are considered.
Yet even more extraordinary is that 10,000 working adults (about one fifth of the entire working population) are entirely excluded from the so called Social housing list or meaningful consideration under the Island Plan.
Although I pleaded with the Planning Inspectors that the Plan made no provision for the “unqualified” - and they included a limp note to acknowledge this in their final Report – the planners have (as always) ignored the needs of the 10,000 and the Housing Minister was not even asked about them at last week’s Scrutiny hearing referred to above.
Yet the Health and Housing Departments have published proposals that will supposedly give security of tenure to all tenants and lodgers (qualified or not) besides minimum standards of accommodation whilst the Island Plan includes no indication how such reforms might be achieved.
The 10,000 “without qualies” are like a tribe that does not exist – yet it is they who hold the economic key to providing the rents and mortgages that
Jersey housing market needs to fund new housing developments. Of course, it is just another part of the discrimination scandal that their “rents” fill the pockets of the privileged rentiers and property owners who extract probably £30 millions or more each year from this sector (which includes a substantial – but unmeasured – contribution from “public taxes” in the form of “rent rebates” from the Social Security Income Support fund).
A previous Island Plan offered the extraordinary excuse that the
Island’s building industry was too small so that any attempt to end the housing shortage for those “without qualies” must be put off for another day. But now that the building sector is screaming out for new projects, nobody suggests that building homes for those without “qualies” might be a realistic and necessary option.
At its root in the 1949 Housing Law, the current housing problems are based upon prejudice and discrimination wrapped up in concepts such as “bona fide residents” which government departments seem determined to perpetuate. This in spite of the Jersey Court Judgement re BBC v Housing Committee (1980) which decided that the use of Housing Control Laws to attempt to control “immigration” were illegal.
Unfortunately, it is a judgement that does not fit in with the prejudices of our planners or others and so it has been ignored. As I write the Jersey Institute of Directors and other are joined in a call for more constraints upon “immigrants,” yet nobody is demanding equitable treatment for the 10,000. The prejudice is very deep-seated but should form no part of an “island Plan” produced by so called professionals.
The Island Plan should be scrapped and, at least, re-written to embrace the several hundred International Conventions that it mentions – but only in passing – in its opening paragraphs.
This lack of joined-up thinking between the various States Departments is of a world leader standard in incompetence yet it is abundantly obvious that the Housing Minister and several others do not even engage in meaningful discussions with the Environment Minister. Even the Constables are excused from the absurd Housing Department’s “Gateway” scheme for the allocation of homes in their Parishes in spite of this supposedly being an “all
Yet, as I have explained with monotonous regularity the Island Plan is also fixated upon the preservation of “Green Countryside” where cows and the stinking rich have an absolute priority over most humans and their diverse housing needs. Except of course that there is a discriminatory exception where the few hundreds cowhands and other “agricultural” workers are concerned so that development permissions may be granted for them to be housed “in the countryside” in spite of the lack of any practical, supportive reasons in the 21st century.
Why “farm-workers” have a prior call for a home in the countryside whereas they are engaged in a diminishing industry of little economic value to the
Island is a total mystery. It is another mystery why Planners allow “portacabins” and other supposed “temporary” accommodation to remain in use whereas these are clearly sub-standard, permanent homes.
At the same time, the existing built-up areas - notably of St Helier – are being turned into a ghetto in accordance with some absurd belief that the vast majority of the population should not live in the northern half of the
Yet even the policy to release the assumed 500 units of unused living accommodation over shops and other commercial premised in St Helier - included in a previously inadequate Island Plan - has not been followed.
Similarly, most of the special action areas in or adjacent to
St Helier identified in several previous Island Plans have also not been progressed or adequately resourced.
Yet the current grandiose schemes to build enormous “finance centre” developments on the “Waterfront” will cause much of the commercial centre of
St Helier to fall into further dereliction.
The “office to let” or “shop to let” signs will proliferate and the “ghetto-isation” of
St Helier will be intensified by deliberate design.
I can see no point in re-submitting my many articles previously offered to the Planning/Environment Department over the decades. They have clearly been ignored in the past and I have no doubt will be so ignored in the future.
The Department, through its officers and politicians evidently has a closed mind which is entrenched with regard to the production of successive Island Plans which have, by any impartial measure, failed miserably to achieve the lofty ideals and aspirations set down in the Planning Law(s) since the war.
The Island has experienced an extraordinarily buoyant economy since the 1950s which owes very little to the planning process but mostly to
policies on tourism, travel, currency restrictions, the development of the EU and peculiarities in international finance etc across a changing world. UK
Now, I believe that the Island Plan should be scrapped as a largely irrelevant document which actually does more harm than good. So far as housing provision is concerned the Plan is just a component part of a discriminatory policy package that will never address the housing needs of the whole population. It has and will continue to fail to deliver “affordable” houses to those who are seeking them or “social” housing to those in “need”.
The re-zoning of small parcels of land for housing developments is just a temporary expedient. As a stop-gap measure it may provide some housing accommodation and to this extent should be encouraged. But the need is for a totally new, fresh appraisal of housing provision in
Jersey alongside a wholesale re-examination of the purposes of planning, the use of land and all the other related issues.
I make no attempt to undertake such a task or to suggest how it might be done. I merely want to state that the very limited invitation extended to the public now with regard to the possible re-zoning of a few sites is wholly inadequate and that a much wider discussion should take place as soon as possible.
20 September 2013 4 pages