Stage 1: Public consultation on issues
What is this stage of local plan making
Public consultation on the issues to be addressed is the first formal stage in preparing a local plan. The planning authority will publish its evidence base and prepare a consultation paper which outlines the priorities of the area, the issues which the new local plan will address and identify key buildings or sites to be protected or changed.
Most authorities will use different techniques to inform and involve local residents, organisations and businesses. If you are already known to the council, you may receive a formal notification. If not, you will need to look out for the consultation and make sure you respond strictly within the deadline. Don’t be put off by the high level (non specific) nature at this time because the planners want to draw out the concerns and ideas that businesses and residents are thinking about. The next time you will be asked the plan will be at an advanced stage. So let your views be known.
Looking at the evidence
Does the published evidence take into consideration local food? See evidence gathering. Send in any you think will be useful to fill in gaps in the planners knowledge.
Looking at the issues
The consultation document is often an easy to read conversation about local needs and opportunities. So, it won’t take long to see if the planning authority is tuned into your interests. However, as the next stage of local plan making is on a worked up plan your response should be clear about what you want to see in the final plan.
Sustain has carried out a review of many adopted local plans and we have found that local food growing can contribute to a wide range of planning issues. Decide which of these issues you think are relevant across your area.
Sustainability and climate change
Allocating land for community food growing contributes to achieving policies on mitigating and adapting to the effects of climate change and other sustainability priorities. Urban food growing spaces help achieve sustainable development.
Do your streets suffer from congestion and pollution - locally grown food reduces food miles and improves air quality. In hot summers are older people suffering from lack of fresh air and high urban temperatures - vegetated open spaces reduce the urban heat island effect. Does storm rainwater rush off roofs onto hard surfaces washing pollution straight into local streams - permeable surfaces of food growing spaces and the harvesting of rainwater contribute to sustainable drainage; and even in high density developments - green roofs provide accessible open space.
Carbon reduction: In Scotland, grants are being distributed to encourage food growing and reduce the impact of climate change. - These case studies are strong on evaluation and the data they collect may help you make your case locally. For example they estimate a 100m2 allotment community garden will produce 300 Kg of food, reducing carbon emissions by 12.18 tonnes CO2e over 10 years.
Green infrastructure / Open spaces / Environment
Look carefully at the open space sections of the Issues consultation. Ask yourself if community food growing spaces / community gardens are a recognised type of open space. Is “community food growing space” included in the definition of Green Infrastructure? Make sure this is the case in your area. You will need to clarify that you are not talking about allotments but space for growing that is integrated into the urban area.
You may want some of the special spaces that you know about to be recognised as “Local Green Space” on the proposals map and be specially protected.
Local Green Space designation is a way to provide special protection against development for green areas of particular importance to local communities.
Planners will have an open space assessment/strategy or green infrastructure plan that looks at open space deficiency – parts of your area that do not have a range of open spaces nearby. There will probably be some consideration of the number of allotments needed and how any new allotment space should be provided. Make sure that the multiple benefits to physical & mental health, sustainability and social cohesion of community food growing spaces is recognised. This means that policies are needed to ensure space is provided as part of the amenity provision within new housing developments. Raise the issue about the design and layout of new housing estates – will suitable space for food growing be included in the criteria.
Building with Nature
A pioneering project piloted in Gloucestershire and Bristol is to be rolled out across the UK. Building with Nature encourages housing developers to incorporate features such as play areas, street trees, parks, allotments and ponds. The aim is to create developments where people’s wellbeing, as well as wildlife, are given priority. http://www.gloucestershirewildlifetrust.co.uk/news/2017/11/07/gwt-pioneers-new-vision-housing
Health and Wellbeing
This would be a relevant place in the plan for cities to cover food and this would be compliant with national planning policy. The relationship of growing food & health is not just the eating of the food but the contribution of community greenspace projects to physical and mental health and wellbeing. The Institute of Health Equity (IHE) has published a report highlighting the growing evidence of the benefits of green spaces on health and wellbeing and the differences in access to natural environments across England, which contributes to health inequalities. Are there inequalities in your area?
An Institute of Health Equity report has found that older people live longer in areas where there is more green space close to their homes and that children who live close to green spaces have higher level of physical activity. It also found that people living in the most deprived areas are ten times less likely to live in the greenest areas and the most affluent 20 per cent of wards in England have five times the amount of parks or green space compared to the most deprived ten per cent of wards.
Education, skills and enterprise
Small-scale community food growing and urban agriculture projects can encourage the growth of the local food economy and develop skills and improved employability amongst participants. Many community food growing spaces provide a learning environment where participants develop transferable skills that increase skills and employability. Are there local spaces that run courses or which sell their produce or use it in community cafes, for example?
Do the neighbourhoods with high unemployment have space for community food growing?
Regeneration and community development
Community food growing spaces are known to foster community cohesion and inclusion, improving the local area and contributing to successful regeneration. Are there parts of your local area being proposed for major change? The temporary use of cleared sites waiting for development provides space for moveable garden plots (eg in builders bags or skips) which can be moved from site to site.
Residents in Canning Town, Newham, preferred looking at temporary community gardens to having boarded up sites in their neighbourhood. When the developer needs the site, it moves the temporary garden to the most recently cleared site in the neighbourhood.
Stalled Spaces Scotland encourages communities to bring derelict and vacant land into temporary use. Funding and skills training and workshops help local communities realise their plans. See the toolkit here: http://www.ads.org.uk/stalled-spaces-scotland-toolkit/ An inspiring food growing case study is at: http://paisleywccc.org.uk/www.paisleywccc.org.uk/Growing_Grounds.html
Design and residential amenity
A major priority for most local planning authorities is the identification of sites to meet housing need. Hull Council even asked if any urban greenspaces should be developed for housing.
Some things to think about when sites are being proposed for development are – How do these proposals affect current food growing spaces? and, Can new developments on greenspace be built in a way that compensates for the loss of existing spaces?
You could ask for new developments to have well designed, useable open spaces that connect to the wider network of open spaces (green infrastructure) & that provide space for residents to grow food close to where they live. (Try to avoid the automatic assumption that spaces to grow food mean dedicated land for allotments rather than space for community gardens embedded into the design of new communities.) The inclusion of community gardens is part of good design of amenity open space in new developments. You could suggest the planting of food plants & trees (for wildlife & people) as part of the landscaping.
Creating an integrated community in Leicester
The Saffron Lane Neighbourhood Council provides a range of services to support disadvantaged residents of the estate, recognised as one of the most deprived in the country. A once neglected 12 acre site has now been transformed into a thriving allotment and community garden as part of a development with 68 affordable homes, all built to Passivhaus standards – eco-friendly and cheap to run and heat. Residents can work on the farm giving them a supply of cheap fresh food, improving personal well-being on both physical and mental health levels.
Neil Hodgkin of Saffron Lane, said:“This development will allow Leicester to regain the mantle of environmental city. It shows how proactive Leicester is when it comes to new ideas and ways of working.”
Check out policies for external amenity space in new development. Local plans generally contain policies and standards for provision of childrens playspace in new development. But why don’t they also include policies for growing space as a norm?
The Home Quality Mark (HQM) is a national standard for new homes. Credits are awarded for having growing space accessible to new homes. http://homequalitymark.com
Community gardens provide opportunities for intergenerational activities, socialising, skills development and outdoor physical activity. A report by Arup suggests a child-friendly approach to urban planning is a vital part of creating inclusive cities that work better for everyone. The amount of time children spend playing outdoors, their ability to get around independently, and their level of contact with nature are strong indicators of how a city is performing, not just for children but for all generations of city dwellers. If cities fail to address the needs of children, they risk economic and cultural impacts as families move away. https://www.arup.com/publications/research/section/cities-alive-designing-for-urban-childhoods
The Gifts of Urban Agriculture This 2017 video presentation succinctly captures the multiple benefits of urban food growing. http://www.ideacity.ca/video/dr-wayne-roberts-urban-farming/
Making your response
The consultation publication may include questions but you don’t need to keep your responses to these questions. It is possible that you may not find a direct reference to food growing.
Your response might ask for planning policy to:
- Protect existing community food growing spaces.
- Support the provision of new community food growing spaces in or near existing housing estates.
- Encourage the temporary use of vacant sites and land awaiting development community food growing spaces.
- Require, in detailed development management policies, development to incorporate on-site food production. This could include landscaping using edible plants and trees through to providing spaces suitable for food growing.
- Require the incorporation of community food growing space in all new major residential developments.
You could ensure that the authority’s evidence covers community food growing in open space assessments and strategies in its own right, distinct from consideration of allotments.
You could check that food growing is included in the definition of Green Infrastructure in recognition of the multi benefits of community food growing.
If the consultation covers development management policies which are used to assess planning applications, you could ask for policies for:
- innovative spaces for growing food, including green roofs, to be identified when considering applications for new developments.
- the construction of structurally suitable green roofs for food growing that can accommodate both growing beds and greenhouses.
- Use of planning conditions or legal (Section 106) agreements to secure space for food growing in new development as part of the essential infrastructure required for that development.
- landscape plans to demonstrate the potential use of any open space for community food growing.
- the design and layout of open space in new development to be flexible so that spaces may be adapted for growing opportunities in the future.
- community food growing spaces and productive trees and plants to be integrated in the design of the development – recognising that these are good for wildlife and people.
See the 'Responding to consultations' section of the toolkit for general advice.
The London Borough of Tower Hamlets already has a planning policy supporting food growing and a thriving community food growing network run by WEN. The Council is now starting a review of its plan and is asking residents what issues the new plan should address. However, food growing was not discussed in their consultation report.
In their response, WEN highlighted their main areas of concern - especially the removal of a commitment to community gardens and urban agriculture. Then they addressed four sections of the Plan which they thought relevant to community food growing in the borough: Health, Leisure and Social Facilities; Open Space and Green Grid; Waste Management and Biodiversity. Their letter can be viewed here: http://static1.squarespace.com/static/559d276fe4b0a65ec3938057/t/56af93ac3c44d836b90a84db/1454347192164/WEN+response+to+LBTH+Local+Plan+consultation+2016.pdf
The Next Stage
The consultation responses will be analysed and the policies will be drafted for a further stage of consultation.
You could offer to meet the policy planners to explain your aims in more detail. You could invite them to visit one of your inspirational community food growing spaces.
Set your food growing scene in a wider context with this presentation for councils. The slides show examples from our Guidance publication for planners. Embellish the presentation with inspiring examples in your area to persuade your council to be proactive and use their powers to support community food growing to achieve their big strategic objectives.
Give key councillors and planners a copy of the Guidance publication available here: https://www.sustainweb.org/publications/?id=295
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