The importance of public consultation

The Panel's review has found that unless there is a meaningful public consultation and adequate time to consider the views of those who contribute to the consultation, this could lead to a disenfranchisement of the key individuals and organisations who are considered vital to delivering the outcomes of any approved bridging Island Plan and thereby significantly inhibiting the success of the plan.

The Panel has therefore recommended that the Minister for the Environment should ensure that the public consultation period is as thorough and wide-ranging as possible. With proactive steps taken to invite key stakeholders and the general public to submit their views through a variety of forums that COVID-19 restrictions permit. Furthermore, that requests for views are actively targeted where appropriate and widely advertised, in order to stimulate as large a response as possible.

Is a bridging plan the most suitable option?

The Panel’s review found that the Minister for the Environment had originally intended that the best way forward was to finish the Island Plan in 2022 after the next election, however, it was a decision taken from the Council of Ministers that a condensed bridging Island Plan should be progressed and developed in the current parliamentary term. Furthermore, there is a lack of clarity as to what degree of analysis of all the options was undertaken in order to determine that this was the most suitable option. The Panel is aware that the Department’s Strategic Partner ‘Arup’ had determined that a 3-year bridging plan was a workable solution. Although, it is unclear as to whether it represented the most suitable solution.

It was also found that no stakeholder consultation was carried out during the process undertaken to evaluate the options of how to proceed with the Island Plan Review process and ultimately the decision to proceed with a bridging Island Plan.

As a result of these findings the Panel has recommended that the Minister for the Environment should publish, prior to the lodging of the bridging Island Plan, the options that were deliberated by the Council of Ministers with a clear and detailed rationale provided as to why the bridging Island Plan was deemed the favoured option and why alternative options were considered unworkable and consequently rejected.

Concerns over how a 3-year plan would have a long-term, sustainable focus

A recurring theme in submissions made to the Panel was that the current Island Plan should be extended until a 10-year plan was feasible. However, reissuing of the current Island Plan was not considered a workable option as it was considered that there were too many issues and areas which required reviewing with the current plan.

Concerns were also raised in stakeholder submissions as to the uncertainty that a shorter Island Plan might pose and that the process could be used as a means to exploit land use and create detrimental development opportunities. The Minister for the Environment dismissed these concerns, although further explanation on how a shorter bridging Island Plan would ensure sustainable outcomes could not be provided.

In light of these concerns, the Panel has recommended that the Minister for the Environment should ensure that further detail of how a shorter bridging Island Plan will ensure sustainability regarding land use and development is included as a key component of the bridging Island Plan when it is lodged in the States. The hope being that this will help to reassure States Members and the public as to how sustainability will be accomplished. For further added clarity, it is also recommended that the bridging Plan should seek to provide a clear definition of sustainability in the Plan.

Prioritisation of policies

A further finding of the Panel’s review was that the prioritisation process for assessing what should be included or excluded from a shorter 3-year bridging Island Plan was based on need, particularly any identified development pressures facing the Island. The prioritisation process also involved looking at what assessments, studies or policies are currently available to utilise as an evidence base and to help inform a new bridging plan.

In relation to the development of affordable housing, it was found that housing providers are not able to meet the current demand for housing and that they face obstacles in being able to secure properties or land for development. Furthermore, it is apparent that the current Island Plan is outdated, and the extent of housing provision has become more limited, which poses a challenge to responding to the current housing shortage. Consequently, this has been another factor in prioritising housing as a key component of the proposed bridging Island Plan.

The Panel has recommended that the views of affordable housing providers are proactively sought during the public consultation on the bridging Plan, so as to seek to ensure that the issues they face in being able to secure land for development, and expand provision for affordable housing, are adequately addressed by the policies contained within the Plan. In addition to this, the Council of Ministers should prioritise the identification and provision of affordable housing sites within the public estate and appropriate sites should be released for development within the lifespan of the bridging plan. The Panel considers it is important that the Estates Strategy should feed into and inform the bridging Island Plan and therefore has further recommended that this should be finalised and published prior to the adoption of a bridging Island Plan.

De-coupling the Plan from migration and population policy

It has been found that uncertainties created by Brexit and the continuing global pandemic make it difficult to model potential future population and demand figures for in-ward migration. However, whilst it is proposed that the 3-year bridging Island Plan will be ‘decoupled’ from a migration and population policy, the plan will still be based on the best available data and will have regard to any emergent migration policy.

The Panel has recommended that a communication drive takes place prior to the public consultation to ensure the right message is given to the public about what it means to ‘decouple’ the migration policy from a 3-year plan and how a shorter plan will still be as robustly informed as possible by various planning assumptions.

Concerns of unachievable outcomes

It is evident that there are numerous policy areas and identified development needs which will seek to be incorporated into the 3-year bridging plan. However, with a number of competing priorities, it is unclear as to what will need to be scaled back or excluded from the plan in order to have realistic and achievable outcomes within the lifespan of the plan.

Concerns expressed by stakeholders are that a bridging Island Plan might be over ambitious in what can realistically be achieved in the limited timescale, as well as how the bridging plan will join up with the next 10-year plan to provide certainty and longevity to those in the building and construction industry. There are also fears that a shorter term plan could create further uncertainty surrounding what the intended long-term focus is for the Island. The Minister for the Environment believes these fears are unwarranted as the bridging plan will aim to have a long-term focus but with targets and numbers based on a shorter period.

The Panel has recommended that an analysis is provided of how each key component of a shorter plan will be deliverable in the shorter timescale, so as to help to instil confidence for the States Assembly and the public that a shorter plan will be able to deliver its intended outcomes. This should also encompass how the bridging plan will interlink with the next full 10-year plan to ensure longevity and certainty for building developments through the lifespan of a project. This should be provided when the bridging plan is lodged to enable this analysis to be considered during the 12-week consultation period. Moreover, that a communications strategy is put in place to advise and assure islanders as to how a bridging plan will still ensure a long-term focus.