Consultation on Housing Density
Updated: Apr 27
Grouville Community Environment & Change's response to the Government of Jersey consultation on housing density and on development of new houses in the countryside.
Dear Sirs,
We are responding to consultations on housing density and on development of new houses in the countryside.
We also believe that what is being proposed needs to fall within the bigger picture questions of short medium & long term population forecasts and the need to apply higher building, community & ecological standards to all developments. There is also the question, as we understand it, that these consultations follow from the Island Bridging Plan, which was rushed through to suit the previous Council of Ministers and its plans for inappropriate development at Overdale. Despite the effort put in, the plan only covers the period to 2025. We think it should be extended to run to say 2032, but that this will require reconsideration of some key issues, for instance these highlighted below.
Consultation on Housing Density
The consultation is a difficult one to respond to, in particular getting your head around some of the definitions, specifically dwellings per hectare (dph) & habitable rooms per hectare (hph). Examples are given of dph. However the examples themselves show the difficulty of applying these standards. You would much prefer to live in the flats at the highest density 230 dph which are those at Westmount, with sea views sited against the hill ( at least so long as Overdale isn’t over developed!) rather than the 150 dph at Le Clos Couriard on the Rouge Bouillion ring road.
Habitable rooms are rooms you can live in, so a two bedroom flat with a lounge-diner has three habitable rooms, excluding say a kitchen & bathroom, which you don’t live in. However definitions at the margin aren’t easy. We are lucky enough to have a wide 1st floor landing, where I regularly sit reading. Has this become a habitable room?
The major failing of the consultation is that generally it is setting minimum numbers of dwellings in a given area where a development includes at least 5 dwellings. It should surely also set maximum numbers of dwellings in developments.
If maximum and minimum densities are set, so too should the maximum number of floors in specific areas. This is relevant for instance in St Helier where 6 out of 10 areas are analysed as having high sensitivity. In our view The Parade/ People’s Park, Havre des Pas to Greve d’Azette and Town edges and slopes should also be rated highly sensitive. This would only leave the New Waterfront as of low sensitivity. Unsurprisingly this is being rapidly developed leading to accusations of overbuilding at inappropriate heights of an area that could have been an elegant gateway to town and the Island. Maybe a finer analysis is required so high sensitive Havre des Pas to Greve d’Azette is separated from medium low Georgetown.
There is a real problem here as developers will tend to pack in dwellings in 1 & 2 bedroom flats, but these do not form the basis of family homes or stable communities, so there should be restrictions on the numbers of 1 and 2 bedroom flats, relative say to 3 & 4 bed dwellings arguably prohibiting I bed flats altogether. This is probably the matter to which further consideration needs most to be given.
That maximum developments should apply generally is shown by what has happened at Keppel Tower Grouville, where the site as approved by Planning is clearly overbuilt or was it that what was approved was then expanded & overbuilt by the developer in line with what he wanted & Planning then turned down?
There are specific concerns, in particular in the Les Quennevais area, which is described as the Island’s “secondary urban centre” with “further work proposed to explore the potential to provide new, higher density development whilst enhancing the quality of the neighbourhood & the local shopping centre”. It needs it but it is difficult with flats above the present shops in private occupation and the impression that much of the area is a car park. Those participating in the St Brelade Community page were asked what they thought of all this. Their response was Les Quennevais isn’t a town, If I wanted to live in a town I’d live in St Helier etc. So generally we object to the higher densities suggested specifically for Les Quennevais
The definition of the area of Les Quennevais is also very wide to include La Moye; Le Saut Falluet; La Petite Route des Mielles; Tabor Heights; and Park Estate, wider than locals might think, giving planners & worse developers the maximum opportunity to expand urban spread. We think this wide area for Les Quennevais should be restricted to the area recognised as Les Quennevais by locals. As with the 2021 changes to the voting system radical changes were made in a rush in the Bridging Island Plan by the last Government, with the significance of the changes not appreciated by the electorate. They should be paired back.
The problems with it are shown in the response to a planning appeal against refusal to build 11 homes on a site off Route Orange so within “greater Les Quennevais” & surely in line with the minimum number of dwellings proposed for that area.
Generally there needs to more, and more radical, moves away from car culture, so if Les Quennevais is to redeveloped, car parking should be reduced and/or underground car parks built, as is done in Germany, with more homes built where before there were above ground car parks, providing a partial solution to the housing crisis.
We suggest that if minimum & we would argue maximum dph & hph are set that future planning proposals are expressed in these terms.
Welcome are the ideas for managing superdensity & the widened schedule of accommodation, to which should be added cycle routes within residential developments.
The inclusion of place-making in the paper is to be welcomed, but the failure to recognise that in Jersey parishes are places is not. A clear example of the failure is in suggesting Les Quennevais as a “secondary urban centre”. In Jersey parish centres grew up around nine out of twelve parishes, where at a minimum the parish hall was next to the parish church. There is no parish centre in St Brelade as the parish church is on St Brelade’s Bay and the parish hall at St Aubin. At Les Quennevais there is neither, so at present it is not generally considered the parish centre. What it should be called is also uncertain as signposts point to Red Houses, not Les Quennevais. Again all this makes its recognition as the secondary urban centre inappropriate
The reference to “historical harbour villages” also looks wrong. These places are not villages, as nucleated rural settlements, are usually understood
2. Consultation on Houses in the Countryside
Generally we are very much in favour of what is in this consultation
3. Restrictions on new large homes throughout the Island
The inclusion of prohibitions on larger homes (whether new builds or conversions or extensions) is to be welcomed & should be made permanent. The level of the prohibition 279 sq m or 3,000 sq ft as proposed would only cover very large houses indeed. It therefore should be reduced, say to begin with being halved. It also should be fixed as a maximum number of habitable rooms, perhaps 8.
We also suggest there should be a presumption against development of new private swimming pools, billiard rooms, domestic cinemas etc
We are happy to come in to discuss our comments
Yours sincerely
Peter Hargreaves Sarah Howard
Grouville Community, Environment & Change
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