Provide greater protection for employment land, including hotels

Businesses provide both the jobs that create our economy, and provide services that make the island attractive and functional for both locals and visitors alike.

What virtually all businesses require, however, is a place to trade from.

Whether, industrial, offices, agricultural, recreation, retail, hospitality, visitor accommodation or something else entirely, land and sites are essential to run businesses, with each sector typically having their own requirements.

Island Plans’ have typically sought to ‘protect’ employment land, recognising we cannot just ‘create new sites’. This is typically done by ensuring that sites are retained in an industry, or marketed for sale and lease, prior to losing that site from the land stock.

These protections haven’t always been strong or wide enough, and so we’ve lost a range of good sites to housing, which provide only an insular benefit to the occupant, not the economy or community.

Despite most types of employment land having some form of protection, there have been two noticeable exemptions in both the 2011 and 2022 Plans. Hotels and Offices.

The need to protect hotels

Jersey needs a tourism industry. We know that island connectivity is essential, for finance, health and our wider economy, and tourism provides valuable use of our ports, whilst contributing to economic spend, and supporting local businesses like hospitality and leisure that make the island an attractive and enjoyable place to live.

Despite this, there has been constant push-back at protecting our hotel stock from conversion to housing, to the extend these sites are not ‘protected’. The arguments provided for this are weak and can be overcome. The main one I have heard is that hoteliers need a residential valuation of the land to be able to borrow to invest (Government could support with loans) and others just suggest ‘it’s the owners’ retirement fund’.

Because of this, we’ve lost hotel sites like the Waters Edge, Miramar, the Windmills, the Samares Coast Hotel to name just a few - and almost lost the Savoy.

Whilst some of these sites might have no longer suited visitor accommodation, our planning system should have at least ’tested the water for a new operator’, before allowing the loss of these sites. ‘Protecting’ does not mean a prohibition, it is simply a market test, to ensure new operators can buy or lease the site.

Many of our hotels were built in locations and to a scale because they supported the visitor economy. We cannot provide new hotels without harming the landscape and character of many areas - for example, how could we provide more accommodation in our northern bays.

We are fortunate that both The Savoy and Millbrook House Hotel are being retained, but the new owner of the Savoy may well have paid ‘over the odds’ for a site with residential permissions, compared to a purchase at a hotel valuation. This inflates land values, and makes it lowers money available to invest to make our sites relevant and suitable for this generation.

I want to see us bring in ‘market testing’ protections, to ensure these sites can be purchased at fair rates by those who wish to invest in our visitor economy.

A chance to look at office accommodation

The other exemption that currently exists is that for ‘office’ space. This exemption was provided in the view that office accommodation demands are changing, with greater investment shifting westward to the IFC and consolidating around newer ‘A grade’ stock.

As such, we have seen large amounts of less desirable and cheaper office accommodation be converted in to housing, typically flat conversions.

Whilst the loss of some of this stock in return for housing isn’t inherently bad, there doesn’t seem to be a good reason why ‘market testing’ shouldn’t also apply here. There is a demand for a range of office space, so especially if a sitting tenant wishes to remain, that should go to show the site is still in demand.

Looking beyond their current use as office accommodation, these sites are still ’employment land’, and I think we should consider how they could serve other employment uses, especially in St. Helier. Other sectors are feeling pressure for space, such as medical, recreational and hospitality, and a staged approach to ‘redundancy of use’ could help support businesses to start and grow.

Where we do allow office space to be converted to residential, we should ensure that greater protection is given to ground floor uses. Securing an active frontage and ground-floor spaces will help protect the vibrancy and economic vitality of St. Helier.

A wider look at how sites are marketed

In considering how we protect ’employment land’ - requiring market testing - I do have sympathy with those who find the current approach difficult to prove.

Planning guidance is clear (Protection of employment land) but its application is inconsistent, so applicants may not be sure that they need to market their sites for both freehold and leasehold, with fair market prices.

We could review this positively - where a site needs to be market tested, we could look to a simple portal as part of ‘pre-application’ planning. Site owners could list their site, upload images, floor plans, descriptions and rates - free of charge - and interested parties could subscribe to get notifications.

This way we could achieve a fairer system that achieves its desired outcomes;

• Costs are reduced on applicants ‘advertising their sites’
• Planning can have greater confidence that a site was correctly marketed, ensuring more consistent and faster decision making

and most importantly, sites can be genuinely retained in employment land where there is demand.