The Island Development Plan, or IDP, is a baptism of fire for us new States Members – over a thousand pages, spread over two reports and eleven appendices, plus extensive supporting guidance and technical background. It is also the first time, for many of us, that we have experienced sustained lobbying over the propositions we will be debating.
The IDP is a very comprehensive document, setting out the rules by which development on Guernsey can take place over the next ten years. Here, I have:
- covered the origins of the IDP and its function;
- summarised the main policies in the Plan; and
- outlined the set of amendments that States Members will be asked to consider at the meeting on Wednesday.
It is possible that more amendments will be laid between now and that meeting, and I will attempt to provide an update if so.
The majority of the IDP has not been called into question by these amendments, but there are three particular areas where States Members have laid amendments that challenge the policies that have shaped the IDP – specifically, in relation to the protection of tourist accommodation, the standards to be applied to car parking, and the use of planning covenants to provide some supply of social and intermediate housing. All of these are significant issues which I have tried to delve into in depth below.
There are two areas of the Plan which I thought deserved particular, positive recognition. The first is the commitment to “regeneration” in the Main Centres of Town and the Bridge – especially around the two Harbours. A positive approach towards development in these areas could do a lot to refresh and enliven these important hubs. The second is the idea of the “community plan” in Local Centres, which offers little local communities a chance to really shape their local areas. Of course, the idea could grow dusty on a shelf, but I think it would be great if a school – or other organisation at the heart of a local community – could jump on board with the concept and see what they could do with it. If anyone decides to take it up, please let me know …
Context: Where does the Island Development Plan come from?
The Land Planning and Development (Guernsey) Law, 2005 provides the overall framework for development in Guernsey – which it defines, broadly, as “the carrying out of building, engineering, mining or other operations in, on, over or under land; and the making of any material change in the use of land” (section 13).
The Law exists “to protect and enhance, and to facilitate the sustainable development of, the physical environment of Guernsey”- including protection of the island’s natural beauty, heritage and biodiversity; with an emphasis on promoting quality of development and balancing competing demands; a commitment to sustainability and the assurance of a safe and healthy environment.
Section 5 directs the Committee for Environment and Infrastructure to maintain and update a Strategic Land Use Plan, consistent with the Policy & Resource Plan, which establishes the environmental, social and economic strategy for the use of the island’s land. Section 8 directs the Development & Planning Authority to prepare an Island Development Plan which sets out how it will make decisions about development in order to achieve the objectives of the Strategic Land Use Plan.
This is the source of some confusion. A ‘plan’ sounds purposeful – “here are the things we are going to do to reach our goal.” In fact, the Island Development Plan is more like the rulebook for how DPA will make its decisions. It is a set of guidelines for the Authority which approves or rejects planning applications. It does not automatically mean that any development will happen – that still relies on the fairly organic process of islanders and businesses making plans and acting on them.
Section 12 of the Law allows the States to specify the process for preparing and adopting the Island Development Plan. That process is specified in the Land Planning and Development (Plans) Ordinance, 2007. In brief, the Development & Planning Authority must consult with other Committees, parish authorities and public bodies in preparing the Plan; must receive confirmation that it complies with the Strategic Land Use Plan; and must have it checked by an inspector, who must ensure that the Plan complies with the Law, that the proposals are reasonable and evidence-based, and that there is enough flexibility in the Plan to cope with changing circumstances. The Ordinance allows the States to amend the Plan, but it also allows DPA to request that these amendments should be re-checked by the inspector before being implemented. Once approved, the Island Development Plan is in force for ten years, although it can be amended during that time.
- If successful, some of the amendments which have been laid by States Members are likely to result in DPA deciding to pause the Island Development Plan and ask the inspectors to review the proposed changes. This will push back the start of the IDP, and mean that planning decisions will continue to be made on the basis of the current Urban and Rural Area Plans.
The current Strategic Land Use Plan was adopted by the States in November 2011, with minor amendments. The Plan was “prepared on the basis that development will be concentrated within and around the edges of the urban centres of St Peter Port and St Sampson / Vale, with some limited development within and around the edges of the other main parish or local centres, to enable community growth and the reinforcement of sustainable centres” and was adopted by the States on that basis. The objectives (s1.6) are similar to those of the Land Planning and Development Law, but with an emphasis on business and employment opportunities, including the rural economy, small-scale business and industrial development, which is absent from the Law. The Strategic Land Use Plan is intended to remain in force for around 20 years – although it, too, can be amended during its lifetime.
It is worth recalling that the Strategic Land Use Plan seeks to promote “planning as an activity that provides opportunities to meet strategic needs and enables private sector investment” and to remove “the perception that planning automatically discourages development and change” (s5.3.3). It is intended to provide a positive spur for development that achieves the government’s strategic objectives, while leaving plenty of space for private initiative where development is not strategically significant. The Island Development Plan is intended to translate that ambition into clear guidance.
What is in the Island Development Plan?
Start with the policy letter from the Committee for Environment & Infrastructure. This brief document is where the recommendation to approve the Plan is formally put to the States. The most significant papers, however, are the report from the Development & Planning Authority; Appendix 1: the Draft Island Development Plan; and the sets of amendments in Appendix 6, Appendix 7, and Appendix 8. Combined, these documents will make up the final version of the Island Development Plan, if approved by the States.
Appendices 2 to 11 set out a range of supporting information, from the environmental impact of the Plan to the independent Inspectors’ review. These documents are the result of checks and balances required by the Law, but won’t formally be part of the finalised Plan. There have also been a considerable number of amendments laid by States Members, and these could become part of the final Plan if approved – I’ll come to these in the next section.
We note from the Development & Planning Authority’s report (s5.12) that the impact of the Island Development Plan will be monitored on a regular basis by DPA, together with the Committee for Environment & Infrastructure, and those regular Monitoring Reports will be published. The reports – which will have a particular emphasis on delivery of housing, employment-related development, management of natural resources, and delivery of infrastructure (IDP s21.3.1) – will help the States to keep an eye on whether there is a need to amend or replace the IDP, or even change the overall Strategic Land Use Plan.
The DPA report sets out the reasons for developing the Island Development Plan and the process by which it has done so – including an exhaustive consultation process in several stages (fully detailed in Appendix 4), the first of which took place four years ago in 2012, and a thorough independent planning inquiry which attracted nearly 2,000 representations. It also comments on the recommendations made by that independent inquiry.
The document of most interest, of course, is Appendix 1, the draft Island Development Plan. The objectives of the Plan, which include a healthy and inclusive society, thriving economy, adequate housing and infrastructure, and the effective management and use of land, natural resources and the built environment, evidently share common principles and work towards the same aims as the Law and the Strategic Land Use Plan.
A positive attitude to development: The general aim of the Island Development Plan is to support the sustainable and balanced development of our island. It includes greater flexibility for planners to approve types of development which aren’t covered by specific policies (s2.6.2). This reflects its general ethos of taking a more “proactive” or supportive approach to development. It is also clear that, on an island with limited land and many competing demands, the best development is done in a coordinated way. The IDP therefore has a constant emphasis on using land effectively and efficiently, and insists that it “will not support the division or piecemeal development of sites or land” where this would lead to under-development (s19.11). The Plan recognises that there is a balance to be struck between development in the public good, and the rights of individuals to do as they wish with their private property, and adopts a generally favourable approach to domestic development by householders (s19.14-16).
Town and the Bridge: The Strategic Land Use Plan designates much of St Peter Port, St Sampson’s and the Vale as urban or Main Centres. Accordingly, the IDP is geared towards most development happening in and around these areas. (s3.1.1-3). It’s not intended for the size of the Main Centres to increase massively over time: this means that the Plan emphasises the importance of buildings with smaller groundfloor footprints (s2.2.7), promoting reuse of redundant buildings (s2.2.8), and encouraging development on brownfield [previously developed] sites (s2.2.10).
Main Centre development policies are intended to promote a vibrant mix of living, working and leisure facilities (s4.1.9), with a friendly bustle that goes on well into the evenings (s4.1.12); while respecting the historic character of the area (s4.1.8) and protecting areas of green, open space (s4.1.10, s5) that provide “breathing space” in an otherwise densely-developed area. There is, nevertheless, also an expectation that the majority of industrial activity will continue to take place in and around the Main Centres (s7.2), especially in St Sampson’s, with heavy industry being concentrated at Longue Hougue (s7.2.5). The focus here is on consolidation, rather than expansion, of industrial land.
The IDP protects Core Retail Areas in the heart of Town and the Bridge, and restricts the development of new comparison retail (literally, things like clothes which you might “shop around” for) to the Main Centres, in order to ensure they remain lively, sustainable shopping destinations (s7.3.4). It also emphasises the importance of the public realm – the spaces we all share – in the Main and Local Centres, and encourages their enhancement, through the provision of street furniture, public art, and improved accessibility (s19.19).
Finally, there is a particular focus on regeneration around the Town and St Sampson’s Harbours (s9.2), the Lower Pollet, South Esplanade, Leale’s Yard and the Bordage (s9.3.1; Annex IV). These areas are expected to provide additional opportunities for housing (s4.1.18) and leisure (s8.1.6), amongst other developments. Local Planning Briefs will be drawn up for both Harbours (s9.2.12) and there will be a Development Framework for each of the four other Regeneration Areas (s9.3.4) to coordinate and encourage development.
Local Centres: There are seven local centres in the IDP (s3.3.1): around St Martin’s Village; at L’Aumone, Cobo and L’Islet; around the Longfrie area of St Pierre du Bois; around Forest Stores to the east of the airport; and, at the suggestion of the planning inspectors, around the Forest and Le Rondin schools to the west of the airport (the ‘Forest West Local Centre’). You can use the “Select Area” drop-down box on the IDP Digimap to explore the boundaries of the local centres, with a separate report on Forest West in Appendix 9.
According to the DPA report (s11.2), “local centres are not intended to be growth points.” Local Centres are defined by having certain features – such as grocery stores, parish or community buildings, or other shared facilities – which make them community focal points, rather than simply residential areas (s10.1.3). The only development which is expected to take place in the Local Centres is small-scale change intended to promote their sustainability and inclusiveness as community spaces.
The kind of development permitted in Local Centres may include modest housing developments (s12.1), including the extension of existing specialist housing (s12.1.4); upgrading or creation of local community facilities (s12.2.4-5); small-scale office development (s13.1); convenience stores (s13.2); or the conversion of buildings into visitor accommodation (s13.4). The Plan also supports the development of some additional recreation or leisure facilities in Local Centres (s14).
The IDP also creates a new tool for communities to shape their own environment: the Community Plan (s19.20). This is especially intended for Local Centres, but can also be used elsewhere. It offers a way for local communities to come together and create a shared vision for their local area. These could be wonderful, creative, community-building opportunities – but we don’t yet know how they’re going to work, and someone is going to have to find the energy and imagination to pilot one. I’d love to see this done by a Primary School in a Local Centre, supported by local businesses, and drawing in the wider community through their PTA and broader connections. If anyone decides to do it, please get in touch – I believe this has such potential, and would love to hear how it goes, or help in any way I can.
Rural economy: There is a recognition that the rural economy, and some other kinds of small business, need land and development away from the hubs of main and local centres (s3.4).
There is very limited provision for development outside the Main and Local Centres. Housing can only be created by converting a redundant building or subdividing an existing unit (s16.1), and new community and social facilities or office space by conversion of redundant buildings (s16.2, s17.1). Buildings along the coast can be converted to provide convenience retail, including cafes or kiosks, in some circumstances (s17.2). Industrial and storage space can be created on brownfield or glasshouse sites, or through the conversion of redundant buildings, so long as there is a demonstrable reason for having it outside the Centres (s17.1). There is also allocated space for industry at the Villiaze site in Forest.
The Plan designates some land as Agriculture Priority Areas. In these areas, agricultural uses will take priority – other forms of development won’t necessarily be ruled out, but will have a higher bar to cross. Existing farmland within these Agriculture Priority Areas will not be allowed to convert to other uses unless a strong case can be made based on other IDP policies (s17.3). New horticultural developments will only be permitted on sites that are already intended for horticulture, or have been in the past (s17.4). Glasshouse sites are classed as agricultural land but, while the Plan recognises the problem of redundant greenhouses, it does not offer a solution for clearing them – this is something which requires wider government action (s17.5).
Access to housing: The majority of new housing development is expected to take place in and around Town and the Bridge (s6). The Plan is required to identify sites capable of meeting new housing need for the next five years, in keeping with the requirements of the Strategic Land Use Plan (s6.1.1). There is a presumption that there will be no net reduction in the level of housing available (s19.13).
All the policies in relation to housing emphasise the importance of a mix of housing types. This will additionally be secured by the use of planning covenants to provide limited social or intermediate housing as part of larger private housing developments. Development Frameworks will be required for developments of 10 or more houses, to ensure their sustainability and fit with the goals of the IDP.
There is an expectation, set out in the Strategic Land Use Plan, that developers of housing for the general market will also contribute to the provision of social and intermediate housing within those developments (s19.12). Larger developments will be covered by planning covenants, requiring a portion of land to be conveyed for the construction of social or intermediate housing, although there is scope to accept units in lieu of land, and to accept off-site land or units instead of those on the main development site (s19.12.5). It is recognised that the mix and number of units on a development will need to vary from site to site, depending on the nature of the development, and what we know about island-wide housing need at the time (s19.12.7).
According to the Non-Technical Summary of the Environmental Impact Assessment (p495), the IDP policies are likely to have a positive impact on population, “with increased housing and improved services” and an emphasis on inclusion and regeneration. However, it warns that there is little attention to specific deprived areas or households, nor to the need to prioritise housing and service development for those who need it most (p503).
In addressing the role of planning covenants in supporting the supply of social and intermediate housing, the Inspectors’ Report (para 219) reflects that non-developable land in Guernsey might fetch up to £90,000 per hectare, while developable land will sell for over £3.6m per hectare – a 4,000% difference in value. The effect of planning covenants is to redirect a portion of that massive increase in value into the public purse, through the provision of land or units of social or intermediate housing. It was the view of the Planning Inspectors that this would not make so much of a dent in the overall value of the land as to prevent landowners selling to developers in the hope of holding out for a better price in future (paras 216-222).
Tourism: The Island Development Plan supports growth in tourist accommodation, including conference facilities in the Main Centres (s7.6.6), and allows switching between different types of visitor accommodation (s7.6.5). However, it includes strict criteria for converting visitor accommodation to other kinds of use – it requires the property to be below a one-star standard, with it being physically impossible or financially non-viable to upgrade (s7.6.8, 13.4, 17.7.10). These strict change-of-use criteria apply to all visitor accommodation, whether in the Main Centres, Local Centres, or outside the central areas. Outside the centres, the Plan actively encourages the creation or expansion of camping and “glamping” facilities, to expand the island’s tourist offering (s17.7.4-6).
Heritage and biodiversity: The Plan designates “Sites of Special Significance” – places which, for reasons of history or geography, should be protected from development (s19.3). There are much stricter rules about the kind of activities that require planning permission in these areas (s19.3.2). The designated sites include cliffs, coast, common and marais – all protected because of their plant- or wildlife or other scientific interest (s19.3.3-4). In addition to these sites, there are a number of Areas of Biodiversity Importance (s19.4) which are not so strictly protected, but where there is still an expectation that any development will respect the importance of sustaining the island’s biodiversity.
The Island Development Plan also designates 25 places as Conservation Areas, in recognition of particular architectural or historic features which make them an important part of our heritage (s19.5). Here, too, some development is allowed, provided it protects or enhances the character of the Conservation Area. The IDP allows for the extension or alteration of Protected Buildings, in keeping with their character, but places tight restrictions on their demolition (s19.6), as it does for the island’s 350 or so Protected Monuments (s19.7). For sites of archaeological interest, it requires archaeological investigation before or during development, and provides for places to be designated Sites of Special Significance if relevant (s19.8).
Inclusion and sustainability: The design of buildings or larger developments will need to reflect the objectives of the IDP: an efficient use of land, with respect for the character of the area; a good standard of design and infrastructure; and a commitment to inclusion, through accessible and adaptable buildings and surrounding areas (s19.9), meaning that disabled and older islanders are positively embraced by the Plan (Appendix 7: PA6). The IDP also emphasises the importance of sustainable development, from the materials used in buildings, to their energy efficiency, to their resilience to floods or other damage from climate change (s19.10). The IDP also supports the development of renewable energy installations more broadly (s20.2).
Infrastructure: The IDP generally supports harbour (s20.4) and airport (s20.5) development, and the development necessary to implement the Waste Strategy (s20.3). It safeguards certain areas for possible future infrastructure development, where these are the only fit-for-purpose sites on the island (s20.6), and it promotes increased resilience to climate change through the development of flood defences (s20.11). The Plan supports small-scale infrastructure, such as phone masts or electricity substations, but requires these to be co-located with other similar infrastructure wherever possible (s20.12).
In respect of transport infrastructure, the Plan encourages mixed use development, with opportunities for walking and cycling built in as well as traffic (s20.7), in an environment that is as accessible as possible (s20.10). It imposes strict rules on increasing levels of car parking, with maximum parking standards for new private and communal developments (s20.8), and a presumption that there will be no increase in the amount of public car parking available in the Main Centres (s20.9). Despite this, the Impact Assessment considers that the Plan’s more “proactive” approach to development is still likely to lead to an increase in vehicle use and increased CO2 levels, with potentially negative environmental and health consequences (p504).
What’s in the amendments?
There have been 16 amendments laid to the Island Development Plan so far, covering a wide range of different topics. If amendments are passed, the Land Planning and Development (Guernsey) Law, 2005 permits the DPA to pause the debate and even ask the Planning Inspectors to consider whether the Island Development Plan, as amended, still delivers the objectives of the Strategic Land Use Plan, as it must do. Some of the amendments are only small changes and won’t trigger a deferral; but others, if approved, could have a significant impact. States Members will need DPA to share its view on which amendments are likely to result in a delay before getting stuck into the debate: it is important for us to consider whether the improvement which each amendment seeks to make is worth the delay in implementing the whole Plan which might arise from it.
Agriculture Priority Areas (Amendment 1): This amendment increases the amount of land designated as Agriculture Priority Areas around the island. I understand this is intended to ensure there is enough land available and affordable for farming, alongside other uses which would also count as agricultural activities (e.g. the keeping of horses).
Redundant Glasshouses (Amendment 7): This amendment requires that, when planning permission is given to redevelop an old glasshouse site, the development must include the removal of any remaining redundant glasshouses and related structures from the site.
Delancey Conservation Area (Amendment 6): This amendment designates the area around Delancey Park as an additional Conservation Area, restoring a conservation status it had up until 2002. The boundaries of the proposed new Conservation Area overlap with two areas designated as Housing Allocation sites in the IDP (Annex II), but I am advised that this should not prevent their use for housing, provided any development is done in a sensitive way.
Garden Centres (Amendment 13 and 16): Amendment 13 has the effect of broadening the number of places where convenience retail (including cafes and kiosks) can be developed, to include multi-purpose sites (‘Planning Units’) – specifically, such as Stan Brouard. As written, it can’t possibly be approved, because it only allows such development where it “will affect the vitality or viability of the Main and Local Centres” – but the addition of a ‘not’ would resolve that. Amendment 16 seems inherently more problematic. It is not clear how this contributes to Stan Brouard getting a café (except, perhaps, that it allows the organisation to regularise its position – see paras 125-130 of the Inspectors’ Report) but it seems to codify a set of planning permissions which would make it harder for rivals to enter the market.
Oatlands (Amendment 11): This amendment would permit all kinds of retail development at Oatlands, in order to sustain its viability as a tourist destination. This would be a distinct exception from the policy of only permitting new ‘comparison retail’ within the Main Centres.
Changes to Local Centres (Amendment 3 and 10): Amendment 3 removes a small, undeveloped field from the catchment of the Cobo Local Centre, to protect it from future development and preserve the coastal landscape. Amendment 10 rejects the Planning Inspectors’ recommendation to create a new Local Centre at Forest West.
Tourist Accommodation (Amendment 14 and 17): Both amendments are intended to make it easier to remove tourist accommodation from the market if it is not a viable business. Amendment 14 removes the requirement for properties to have fallen below a one-star standard in order to be eligible for a change of use. Amendment 17 allows all guesthouses which are essentially single dwellings (with or without self-catering units attached) to have more flexibility to change back from guesthouses into private residential use, regardless of the number of bedspaces they offered as visitor accommodation.
Affordable Housing (Amendment 2, 5 and 9): As discussed above, the IDP provides that developments of five or more dwellings should be covered by planning covenants requiring a proportion of the land (from 20% on the smallest sites, up to a maximum of 30% on sites with 30 or more units) to be conveyed to the States or a housing association for the development of social or intermediate housing. Each of these three amendments seeks to change those rules. Amendment 2 (Roffey) and 9 (Lester Queripel) are relatively straightforward: they retain the general principle, but change the threshold – in the Roffey amendment, planning covenants start at 26% of a 20 unit development, rising to a maximum of 30% of a development of 30 units or more; whereas, in the Queripel amendment, covenants start at 22% of a 10 unit development, again rising to a maximum of 30% of a 30+ unit development. In all cases, the percentage thresholds are phased in over a three-year period.
Amendment 5 (Ferbrache) is more far-reaching. Rather than applying planning covenants equally to all new developments, it requires simply that they be applied to developments in the areas formerly designated as Housing Target Areas under the Urban Area Plan.
Deputies have been lobbied extensively in relation to the affordable housing policies within the Island Development Plan. It is clear from the Inspectors’ Report that a similar scale of representations were received during the inquiry on the draft Plan. One major bone of contention seems to be that the latest annual housing target was rejected by the States in 2015; while the level of need for affordable housing (i.e. access to rental or home ownership at rates lower than the market will provide, or at market rates but with assistance) is also challenged.
This strikes me as a bit of a red herring. The IDP, at the outset, has to identify land capable of providing five years’ worth of housing supply (s6.1.1, Annex II) – this covers everything, including market, social and intermediate housing. It also requires planners, at any one time, to have granted about two years’ worth of planning permissions for new housing (s2.2.22). Of course, to calculate the size of the land required, or the number of planning permissions needed, one has to know how many new dwellings are expected to be needed per year – but that must be able to be adjusted, over time, as additional research is completed and the market evolves (cf. s6.1.7). In the meanwhile, the designation of Housing Allocation areas cannot really be said to do developers or landowners any harm, as those designations simply prioritise them for housing development over and above any other kind of development.
Again, it is claimed that, without a decisive figure for “housing need”, the use of planning covenants is not appropriate. However, this seems to me to miss the point, set out clearly in the DPA’s report (para 12.55) that “Policy GP11 will only potentially deliver a small percentage of the overall affordable housing requirement of the Island” – there is no expectation that planning covenants alone will fully meet the need for social and intermediate housing, and therefore no need for the housing target to be anything like an exact science. The figure of 20-30% ‘affordable housing’ per development, which forms the basis of policy GP11, appears to have been based on models of financial viability (2012 Report paras 10.34-10.41), rather than capacity to meet all, or a given proportion of, the island’s need for social and intermediate housing.
Arguments in favour of planning covenants can be made on the basis of the astronomical size of the planning gain (as discussed above); or the pragmatic need to access land, for social and intermediate housing, which would otherwise be swallowed up by developments intended for the general housing market; as well as the clear support for the policy indicated by the Independent Review completed in 2015. Arguments against the policy – or for a change in the size of the threshold, as in the Roffey and Queripel amendments – will be made on the basis of concerns about a slowdown in development, if landowners will not accept a drop in the value of their developable land (although, in this context, it should be noted that reductions in land value, and the scale of 20-30% affordable housing on all developments were trailed as early as 2012 – cf sections 15 & 16); or questions about the practicality of small, one-off social or intermediate housing developments. All of these are valid and reasonable considerations, and worthy of debate; but the question of target numbers, on which much of the lobbying has been based, seems to me to be largely a distraction.
Parking Standards (Amendment 4, 12 and 15): Finally, we have three amendments on parking standards within the IDP. These, too, have been the focus of a reasonable amount of lobbying. Amendment 4 seeks to change the policy on public car parking, although it looks like it would have a very similar effect in practice – the one real difference seems to be permission for new car parks to be developed where this would allow on-street parking to be removed. Amendment 12 turns the maximum car parking allocations for private and communal developments, as set out in Supplementary Planning Guidance, into minimum allocations instead. Amendment 15 retains the principle of maximum parking standards, but doubles the amount allowed per unit.
It seems to me that Amendment 12 would have the unintended consequence of requiring developments to have parking spaces, even when they are not needed, and would allow an absolutely open-ended approach to car parking, which is not in the spirit of the Plan. Arguably, Amendment 15, by potentially doubling the amount of space used for parking, compromises on one of the Plan’s core commitments, to the efficient and effective use of land – however, for those who are concerned about the level of parking provided in the current draft, it seems to offer the more elegant solution of the two.
The Island Development Plan is very wide-ranging and covers many areas of island life – most of which have not been the subject of challenge in the run-up to this debate. There appears to be a general will to see it passed, rather than to defer it, both among States Members, and among interested parties outside the States. The most controversial policies, as might have been expected, relate to the use of planning covenants to provide a portion of the island’s social and intermediate housing, and the standards applied to parking provision and tourist accommodation.
In respect of the amendments, I think their impact on the implementation or deferral of the Plan is a serious consideration, and I am waiting to make a final decision as to how I will vote until I have full information about the trade-offs involved. However, I think the Plan as a whole is an impressive document, which has clearly been put through a rigorous, expert process to try and ensure its consistency with (often complicated, sometimes contradictory) strategic objectives for Guernsey, as set out by a wide range of government policies, and above all the Strategic Land Use Plan. Given the scale of what’s been done over the past four years, the Planning team deserve real credit for the way they have managed the whole process, and their considerable patience with Deputies’ questions — which will no doubt carry on right up to the wire!