PORTS OF JERSEY - Independent Response to the Jersey Infrastructure Levy Consultation
Wednesday 13 September 12:00
PORTS OF JERSEY - Independent Response to the Jersey Infrastructure Levy Consultation.
Jersey Infrastructure Levy (JIL)
Thank you for providing Ports of Jersey with the opportunity to respond to the proposed Jersey Infrastructure Levy.
At the outset, we presume (and would ask you to confirm) that Ports of Jersey would be exempt from such a levy, given our statutory purpose and enabling role in the islands economy, as well as our public ownership.
Nevertheless, we remain keenly interested in understanding the proposals given the impact on private sector parties with which we might partner in improving facilities and, more generally, on the private sectors demand for our transportation services.
Ports of Jersey has a primary mission of enhancing Jersey as a great place to live, visit and do business – and most of our projects are routed in this aim. As we are not a primarily commercial developer, our targeted rates of return are much lower than the envisaged 20%. Given the tight returns, the impact of a levy of the order proposed would make many of our developments unviable, and therefore would mean that the Island is deprived of the benefits of these projects in improving our critical transportation gateways. We do not believe this is an intended consequence of the proposed levy, but nevertheless would be the impact.
We appreciate the aim of the proposed levy, as it is attempting to achieve a fund for enhancing Jersey, specifically St Helier, which we support. However, we are concerned that if it were to be applied to our developments and that meant that they could not be funded, then the Island would not receive improvements in the gateways, nor would we contribute to the fund through a JIL as the projects would not be undertaken in the first place.
Additionally, Ports of Jersey have a number of Public Service Obligations (PSO) which must be funded through our commercial projects. A key principle of incorporation was to enable capex funding through commercialisation and efficiency and not from the tax payer.
We have carefully studied the proposal, and compared it with similar charges in the UK. To better understand the proposed levy we have some questions attached to this letter. Ports of Jersey would be more than happy to meet and discuss the States proposal and our initial questions/concerns in more detail.