Please see below a copy of our recently submitted objection to the proposal by the States of Guernsey to seek outline planning approval for accommodation on the field known as Le Bordage Seath, adjacent to the Princess Elizabeth Hospital.
Dear Planning Service,
The National Trust of Guernsey would like to register its objection to the above outline planning application. The application seeks to establish the principle of development on an agricultural field within the agricultural priority area. We understand that the proposal to develop the land falls outside the published policies of the States of Guernsey, which would normally provide adequate protection for such land, but that such development may be made permissible through Policy S5, relating to development of strategic importance.
The requirements of policy S5 are clear, but are not fully stated in the applicants covering letter, where they present their evidence to the Authority. We do not believe that the evidence presented is sufficient to demonstrate that there is no alternative site available that is more suitable for the proposed development.
We would, for example, expect that as a minimum there ought to be specific assessments provided for alternative sites. Paragraph 3.6.2 of the supporting text of Policy S5 states that a detailed and comprehensive site selection study, together with more technical evidence such as environmental, economic and social assessments, will be expected. In our opinion, this should include a presentation of the parameters for the development, diagrams indicating possible alternative sites that meet those parameters, with an objective assessment of each of those sites by the same criteria applied to the application site. Without such evidence it is impossible to make an objective consideration of the applicants assertions.
Paragraph 3.6.2 of the supporting text states that the Authority will need to be satisfied that the particular choice of location for the proposed development can be clearly justified. The word justify relates to being ‘just’, to do justice to. It encompasses a principle of right, and reasonableness.
The absence of demonstrative evidence relating to the choice of this site, over others, raises questions over how the choice was reached, and therefore, in our opinion, currently fails the test of Policy S5.
With regard to whether the proposals accord to the Principal Aim and relevant Plan Objectives, it is clear that the proposals are not developed sufficiently to judge this, and the statement provided on sustainable development fails to address how the wholesale development of a green field laid to pasture, including buildings that appear to be cut into the ground, large areas of car parking and a generally low-rise, sprawling use of the site, constructed in two phases, will fit the requirement of representing a wise use of natural resources, or the need to mitigate, adapt and become more resilient to climate change. No mention is made of any mitigation of the effect of the proposed development other than that it may include a photovoltaic roof covering. To provide 120 car parking spaces for half the number of units, where the reasoning offered for the units themselves is that the accommodation facilitates essential workers living close to their place of work, seems utterly at odds with any form of sustainable development.
Even though this is an outline planning application seeking approval for the principle of development on the site, it is our view that the information presented is scant, under-developed and lacks the evidence required to set aside the established policies of the IDP.
Additionally, it is worth noting three further points.
The National Trust of Guernsey regularly raises objections to the change of use of agricultural land to domestic gardens, and have raised this a number of times both with the Authority and in the local media. Every public statement we have made has received support from the public. It is misleading for those representing the applicant to make public statements suggesting that this is not the case.
The National Trust of Guernsey is not against development per se, and may support an application for accommodation built at the hospital that sought to avoid disturbance of the field and protected the function of the land for agriculture for future generations. If the field was bought with the intention of expanding the hospital, which no doubt it was, the States of Guernsey have failed to translate this in to an effective planning policy that permits this to happen. If the Authority requires evidence relating to other sites, the National Trust of Guernsey would be willing to provide input into the process if this would be considered helpful.
We were surprised to read in the applicants cover letter that the Authority has confirmed that no Development Framework would be required. Reading the Policy wording we understand that this can be the case, but note that the applicant fails to identify the provisions of paragraph 3.6.3, which states that proposals that are clearly demonstrated to be essential to the well-being of the island community but are of such a scale or nature to as to have an island-wide social, environmental or economic impact, but we’re not envisaged at the time the Island Development Plan was prepared… …will require a Local Planning Brief. We would assert that the provision of accommodation on a green field, contrary to established policy, will set a precedent for the same or similar development from providers other than the States of Guernsey, and that without thorough and specific examination of this proposal, with a robust series of tests identifying the uniqueness of this situation, the Authority may be creating a gateway for non-governmental agencies to pursue an aggressive legal argument to justify their own, less altruistic development proposals. It is therefore of a nature to have an island-wide social and environmental impact and should be subject to a Local Planning Brief, if it is to be allowed to proceed at all.
We hope these statements and opinions are helpful to you in your current considerations and look forward to receiving further information and updates as the application progresses.
National Trust of Guernsey
26 Cornet Street, St Peter Port, Guernsey GY1 1LF