I like to keep an eye on land use and transport planning back in my home island, so it was good to see the States of Guernsey committing to some long term policy development through the review of the two island Development Plans - the Rural Area Plan and the Urban Area Plan. Consultation is currently ongoing on a series of Topic Papers which cover a range of issues and can be found here. The deadline for responses is 16 March 2012.
I have read through one of the overarching Topic Papers ('A Sustainable Approach') and have put together a few thoughts on the issues it raises below. Not surprisingly I have focused on transport, which I think is the most important issue facing the island over the next 10 and 20 years.
With the publication of Planning Policy Statement 12, the UK planning system moved to an evidence-based approach. This placed a requirement on Local Authorities to present detailed evidence on a range of topics to inform public consultation and encourage informed representations. My main concern with the Plan Review is that the current consultation misses a key opportunity to present detailed evidence on a range of topics and instead asks broad questions backed up by reference to the Strategic Land Use Plan (SLUP). The effect of this is that I fear many responses will be characterised by misinformation and speculation, an issue that continues to hinder the island’s planning process.
For example, why on transport is there no data on modal splits to highlight the low levels of non-car based travel? Likewise, why does the climate change section ask which land uses will be affected by sea level rise when in fact this is a matter for scientific modelling to demonstrate those geographic areas of the island which will be most severely impacted?
I understand that this consultation is only the first stage in a multi-stage process, but I believe it has missed the opportunity to demonstrate the Environment Department’s commitment to evidence-based planning. The aim of this process should be for people to think about how the island will develop in the next 10 or 20 years. Currently the emphasis is on repeating existing SLUP policy and not on outlining future forecasts and trends which will impact the island’s economy, environment and overall quality of life.
My second major concern is that the consultation is misleading in what it can actually achieve. It is correct to engage the general public on a wide range of issues, but it should be clear that the Development Plans primarily set land use policy and cannot achieve many of the public policy interventions outlined in the ‘A Sustainable Approach’ topic paper. The Development Plans by themselves cannot initiate paid parking or access to alternative energy sources, to name just two, and this needs to come across much clearer in the consultation material. It also seems that some issues have already been expressed through strategic planning policy and repeating them in the Development Plans would be redundant. I support the attempts to link the Development Plans to other government strategies, plans and initiatives but it must also be clear on what the Plans will ultimately deliver. It would be regretful if people are disappointed in the final product because it promised too much at the beginning.
Specific comments on ‘A Sustainable Approach’
QSA5 – this question refers to which land uses will be affected by flooding. In the context of climate change forecasts, this is not a matter of which types of land use but which geographical areas will be adversely impacted. I would prefer to see climate change and flood risk modelling presented to highlight the different levels of risk across the island. Only after this is presented can we fully understand where development should not be encouraged and what mitigation is required.
QSA16 – Guernsey is not a large settlement. Therefore, whilst I support the need to promote development in identified centres, all of the island is comparatively accessible by non-car modes of transport. New housing, at higher densities, should be promoted within St Peter Port and St Sampsons to increase the accessibility of jobs and services. Likewise, commercial land use must be directed towards to the two main island centres and, where not possible, to sites accessible by walking, cycling and public transport. But even for those that live outside of centres there should be a reduced reliance on private car trips. This will require a mixture of carrots and sticks which is outside the remit of solely land use policy.
QSA17 – Different transport modes should not be balanced. Yes, there is a place for the role of the car but it must not be equally balanced with other modes. The SLUP and Development Plans needs to clearly articulate that there is a hierarchy to how transportation will be prioritised. This should be 1. Walking 2. Cycling 3. Public transport 4. Car. This hierarchy does not deny that the car is important for certain trips, but it recognises that the car should ONLY be used if the other modes are not possible.
Alongside this hierarchy the Environment Department must do a better job of articulating why this approach will not have negative economic impacts, which unfortunately is the assumption of many. A reduced reliance on the car will have a number of positive impacts for the island, including:
- Reduced greenhouse gases;
- Improved air quality;
- Reduced congestion, thereby increasing productivity in the economy;
- Improved health for islanders at a time of a growing health budget from an ageing population. Therefore this money can be spent elsewhere; and
- Road space is reserved only for those that truly have no other option (i.e. trucks, delivery vans).
QSA18 – New development should have car parking maximums, not minimums. Research has shown that developers often over supply their developments with parking, with negative impacts on the affordability of housing. More importantly, the debate needs to be reframed and parking needs to be seen within the wider transportation debate – not as a standalone issue. Pricing parking or reducing parking supply will only be successful if alternative transport options are provided. Therefore the revenue from parking must be directly allocated for improvements to walking routes, cycle routes, discounts for bikes etc. If the money raised goes elsewhere it will not be possible for people to see the direct benefits (and travel options) that paid parking is creating. Finally, the island must look at models of dynamic pricing such as San Francisco where the price is dictated by the level of demand and is responsive to changes.
QSA20 – I fear that the only way to reduce levels of car ownership and use in Guernsey is to introduce major road-based pricing. Islanders have had a good thing for too long and I believe that softer mobility management measures will not be effective. Walking and cycling will only become major travel options if the private car is disincentivised to such a degree that it is not viable. I would therefore recommend that the Environment Department and politicians seriously commit to exploring the potential for the following:
- Distance-based insurance where the price of insurance is tied to the amount that someone drives, thereby providing a disincentive to drive and an incentive to explore other travel modes;
- Road pricing. This could take a number of forms, including a congestion charge around St Peter Port and St Sampsons with a fee to drive into the area at set times of the weekday (7am-8pm) with certain types of vehicles excluded (e.g. delivery vehicles, electric cars). Alternatively this could take the form of all cars having GPS installed and all drivers being charged a fee for the amount they drive during the year. This has the advantage of promoting total reduced car use across the whole island and not just reductions in cars in the two main settlements; and
- A major public bike share scheme modelled on successful initiatives in London, Washington D.C. and Paris. This would include a number of docking stations at key locations in the major centres of the island. Use of the bikes would cost a fee but riders would earn points that they could use to get money off their social security contributions or other incentive-based programmes. This scheme could be part funded by the States of Government with the support of private business.