Green field requete opening speech

We failed to get the States to agree to a debate before any agricultural priority area can be the subject of a planning application but people will have the chance to object and have their say when an application goes in! Speech follows:

Mr acting presiding officer

Why did I feel the need to bring this requete?

Not because the requerants “think we know better” – as alleged by one deputy during the Government Work Plan debate – but because we feel accountable for what would be a big, and we think unnecessary and destructive departure from planning policy.

I fully understand that we need more housing – let me make that very clear from the outset - and certainly more keyworker housing, particularly as I’m a member of ESS and responsibility for key worker housing sits under the ESS mandate - but this is not about territorialism. Barely a meeting of the committee goes by without some reference or other to keyworker housing. We receive frequent contact from people struggling to find somewhere to live, where they can afford to live, so we’re on the coal face and absolutely get the need for more housing.

In fact, four of the requerants are on ESS, the committee that urged P&R not to sell off two properties that could have been converted relatively quickly for use as keyworker accommodation.

The aim of this requete is actually to support the development of more key worker housing – but in the right places!

Whether or not a green Agricultural Priority Area should be built on, needs to be debated so that, if nothing else, Guernsey people can hear the rationale for building on a green field – the arguments for and against - rather than it be announced as a fait accompli off the back a housing crisis. Proposition 1 of the Requete states that unequivocally – the Requete is championing the need for more key worker accommodation - but the green field solution has not been properly thought through.

The news that some members of P&R and the president of HSC were considering building key worker accommodation on the PEH field rather seeped out a few months ago now. This had not been discussed with their full committees or widely among other relevant committees or with States members.

Deputy Mahoney approached the DPA in April this year to inquire whether the appropriate policy gateway for building on the field would be S5 – a development of strategic importance, in the public interest and, it seems, intends to build the case on that basis.

Without this requete, the first thing that most of us would have known about the plan to build on this green valley could have been when a planning application went in to the DPA.

“Agriculture Priority Areas are defined as large areas of contiguous agricultural land and other areas well related to established agricultural operations, which represent Guernsey’s most valuable agricultural land”.

The requete asks the States to agree that Agricultural Priority Areas should not be used for the building of accommodation without a policy letter to the States seeking permission to do so – BEFORE any application is made to the DPA. And, of course an amendment that may be laid shortly will clarify this intent and put it beyond doubt.

The ability to bust established policy should not be allowed to be left in the hands of a few deputies alone. This assembly is the policy maker and the guardian of policy.

To quote an email sent to All Deputies last week: “You as deputies are appointed to represent us but increasingly have your own agenda and letting the public who voted you in, down.”

I am not a dyed in the wool, deep-rooted, tree hugger although I did state in one of five bullet points in my election manifesto: “Emphasis on the Environment.?We must preserve what is good about our wonderful island, further enhance the environment and counteract climate change.”

Guernsey has limited open space, limited green space. A building cannot easily be undone and, if built on, the PEH field would never revert to a green valley in the future.

The E&I letter of comment states: “Various studies show positive effects of green spaces on physical and mental health, including

·?????improved healing in hospitals with green spaces outside windows

·?????decreased anxiety and increased workspace satisfaction in offices with plants and/or views of nature

·?????and improved mental and physical wellbeing with greater exposure to green spaces”.

We have to place a value on this field’s other qualities including the farming activity that has taken place there for generations, the biodiversity it supports and, not least, the 130-year-old veteran tree that defines its character.

That Sycamore tree has survived two World Wars and a German occupation. It has stood testament to the comings and goings at the Vauquiedor for four generations

Only to be potentially lopped down on the whim of a few States members?

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I asked the principal environment services officer at Agriculture, Countryside and Land Management Services, an expert, about the value of the field, and here’s what he said: “I have estimated the age of the Sycamore in the middle of the field by Vauquiedor House to be in the region of 130 years old. It’s difficult to be precise partly because the tree has two stems from the base and age is assessed by measuring the circumference of the stem at around 1.5m above ground.?In general, most open grown trees put on an average of one inch of girth a year.??Guernsey is rather short of very large mature trees of age and stature, and which have such prominence in the landscape, and although it is not a very old tree by UK Mainland standards, for Guernsey I would regard it as something of a veteran tree.?Whilst developers often opine that the loss of a tree can be simply mitigated by planting lots of new trees somewhere, the loss of value of a veteran tree would take over a century to recover.

“Sycamores should not be underestimated in terms of the biodiversity they support. If one includes bryophytes (that’s mosses & liverworts) as well as insect and other invertebrate species, Sycamore ranks high as an important species.?Factor in the situation that we have lost Elm to Dutch elm disease, we will lose Ash to Ash dieback, we have just recorded the first case of Sweet chestnut blight in Guernsey last week – which has the potential to finish off our Sweet chestnuts, and?Acute Oak Decline, whilst not yet found here, is on the increase in the UK, then one has to regard what we have left as worthy of some level of conservation.

He continues: “As I touched upon before it is the visual landscape amenity value of the site that stands out for me. Perhaps more so than any biodiversity which may accrue to the area.?It represents one of the few open valley sites in the island which underpins the rural character of the area.

“The results yielded by the Bailiwick Bat Survey, a citizen science project which is now entering its second year has not only revealed the fact that Guernsey has several more species of bat than we realised but has demonstrated the importance of the different types of landscape to various bat species. We also know for example that bats navigate along clearly defined hedge and tree lines.?Any disruption of these navigation routes can have severe implications for bats.”

So, the environmental concern is an important one but there is more to this than just the environment.

The Requerants believe that, if indeed there is a requirement for keyworker accommodation to be so closely located to the PEH, then it would be better situated on the site of Vauquiedor House and the Duchess of Kent building, or other previously developed parts of the hospital site.

In its letter of comment ESS states in relation to the Duchess of Kent, “The site is a perfect location for health key worker housing with initial sketch designs showing that in the region of 120 units of John Henry Court style accommodation could be developed in a phased approach on this site (this figure is only indicative and would vary depending on the scale of development and the developed property type and sizes). The positive impact this could have on meeting the future key worker housing requirements is unquestionable and the committee feels strongly that this development should be further considered.”

Later ESS states, “The committee considers it irresponsible that greenfield sites are being considered for development before all other alternatives have been fully analysed.”

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The letter of comment from P&R states that it is estimated that 150 new units of accommodation could be filled by healthcare workers immediately – but in Appendix G we have been told it would be “circa three years overall until handover/occupation (of a building on the field) is achieved as a minimum.

That’s hardly “immediate”.

As I said, this field has consistently been in viable commercial use, farmed for generations, has cattle on it most years and is cut and topped, giving the tenant farming family the flexibility to farm other land less intensively. It measures approximately 7 vergees and forms part of the eastern edge of an APA which extends west to the proximity of Rocquaine, Perelle and Vazon. To quote the DPA, “all open agricultural land in Guernsey is valuable, and its retention is important for the island, particularly in the context of land scarcity, urbanisation, climate change and food security”. The nature of Guernsey’s farms is that they are geographically widespread so contiguous fields like this one with accessible links to other green spaces are important to farmers.

Still on the subject of farming, the DPA’s letter of comment states: “There may also be a requirement in the future to grow more fodder crops to allow the industry to become more self-sufficient and sustainable . . . that’s already happening as a result of inflation off the back of the Ukraine conflict.

The DPA says: “Preliminary work indicates an increase for livestock farming of an additional 885 vergees and an increase in the commercial dairy farming requirement to over 13,000 vergees.”

So, why are we wanting to build on an APA?

Moving onto the options appraisal and process, the brief given to the States Property Unit and consequently the way they scored the options is so narrowly defined it beggars belief. From the requerants conversation with the States Property Unit, it appears that the brief was to provide 150 units of 1 or 2 bedroomed accommodation, within 500 metres of the PEH and to be built soon.

The brief was not discussed or approved by the full HSC committee.

We haven’t seen the brief written down, just a list of three requirements as presented on page 46 of the letter of comment,?so we don’t know who drew it up or whether it followed best practice. Was it more of a chat in the corridor? It certainly wasn’t a carefully considered committee decision.

And in reply to Deputy Inder’s Rule 14s, HSC said that people who request staff accommodation ask to be as close to their place of work as possible “particularly those without transport” and yet the HSC plans for the field include 140 car parking spaces. That just doesn’t make sense.

The letter of comment states: “The Duchess of Kent site itself was not ranked because it did not meet the key criteria for delivery within five years . . . but it did otherwise score joint second. One of the reasons given for not being able to repurpose the Duchess of Kent/Vaquiedor House is that it is needed for health and health-related staff, yet the Property Target Operating Model has successfully decanted staff from other buildings to focus on Sir Charles Frossard House, Edward T Wheadon House and working from home, among other solutions. Why can’t this level of focus be given to emptying Duchess of Kent? If we wanted to do it badly enough, we absolutely could.

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In my view, and I worked there for six months in 2019, the Vauquiedor House office is not fit for purpose, it’s not necessary for many of the people working there to be on the doorstep of the hospital. HSC clearly recognised this at some point when the sketch plans were drawn up to place staff accommodation there. It’s expensive to maintain and well past it’s sell-by date. The letter of comment itself states that Duchess of Kent would be cheaper to develop than building on a green field. It states that Duchess of Kent could be vacated in 2+ years – so, where’s the will to do that?

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HSC claims it remains integral to the HSC operation – but another building could fulfil that integral role? Health staff have traditionally been on the hospital doorstep but only a fraction of the admin staff working there actually need to be there.

The SPU produced two maps – one showing potential key worker housing sites within 500 metres of the hospital and one showing those within 1 km.

Even if we don’t challenge the logic of such a narrow brief – which of course we should - there are other brown field sites within that radius beyond those analysed. Many members of the public who have been in touch over this issue have named them. Some aren’t in States ownership and I know that this debate can’t stray into areas of sensitive commercial negotiations but where there’s a will, there’s a way to find suitable brownfield sites.

What’s more, the sizeable SCFH car park is within 1km of the PEH. Why wasn’t that option analysed?

Building on the PEH field is the lazy option, based on a narrow and biased brief designed to lead to only one outcome.

A little bit about S5.

The definition of S5 is: Proposals for development that is of strategic importance and which may conflict with the spatial policy or other specific policies of the Island Development Plan but which is clearly demonstrated to be in the interest of the health, or well-being, or safety or security of the community, or otherwise in the public interest may, exceptionally, be allowed where: a) there is no alternative site available that, based on evidence available to the authority (that’s the DPA), is more suitable for the proposed development, and b) the proposals accord with the principal aim and relevant plan objectives.

S5 has never been invoked for building anything of this scale on an Agricultural Priority Area. The only example in DPA officers’ corporate memory was a relatively small electricity sub station.

The strategic need is for housing, including keyworker accommodation – there is no doubt about that - but there is no strategic need to build on that field. The S5 policy spells this out: one of the criteria is that “there is no alternative site that is more suitable” and all the prima facie evidence suggests there could be ample!

The letter of comment states that under S5 “the Authority must be satisfied that the particular choice of location for a proposed development can be clearly justified and that the proposals represent the best practicable option . . . a detailed and comprehensive site selection study would be expectd as part of the submission of a planning application as would measure to mitigate any harmful effects. . .”

It also states “only the most contentious or high profile applications are referred to the elected members of the Authority and that where they are so referred that they are heard at open planning meetings . . . if proposals . . .?were submitted . . . it is understood that such a referral would likely be made”.

Well, this is certainly contentious, judging by the amount of public comment, letters to the paper and contact from members of the public to the All Deputies email – not to mention it requiring a 55 page letter of comment and appendices from P&R.

That’s contentious.

As has been highlighted by many islanders, it’s bad enough that a green field in the Oberlands is within policy for development because it falls within a “local centre”. But the field we are talking about today is neither in a main centre nor a local centre, and what is more, it is in an Agricultural Priority Area, which is zoned specifically and explicitly to prioritise and protect it for agriculture. If we build on this field, what does that mean for Agricultural Priority Areas in 2022 and, if we go ahead with this development what will it mean in 2023, 2024 and beyond?

The notion of building keyworker housing on this field is not a unanimously agreed approach across P&R and HSC. And the vice presidents of both committees are signatories to this requete.

The letter of comment states – “a detailed comprehensive site selection study would be expected as part of the submission of a planning application . . . (it goes on to talk about) measures to mitigate any harmful effects on the environment and opportunities for environmental enhancement”

But, we won’t need to do that mitigation that if we don’t blindly insist on building on a field in the first place. We’re just making work for ourselves.

Is S5 justifiable? Is there an “imperative need” the very phrase used by Deputy Ferbrache in the GWP debate on Deputy de Lisle’s green field amendment. Deputy Ferbrache also said: “We must do all that we can to protect our farmers, protect our growing industry” – protect fields wherever you can, I agree with the essence of that.”

All that we can!

Mr Presiding Officer, the option of building on a green field smacks of the worst kind of double standards. Who else owning a green field zoned as an agricultural priority area would expect to gain permission to develop it?

I urge members to support this requete and give a clear message to committees and to the island community that we will not seek permission from the DPA to build residential accommodation on an Agricultural Priority Area without first obtaining the agreement of the States by way of resolution.