Why is evidence important
No matter how important you think it is for land to be provided for local food growing, every planning policy must be backed up by up-to-date evidence that this is a locally relevant and realistic aspiration.
An independent planning inspector will hold an examination into the draft local plan to ensure that it has been prepared following the correct procedures and that it is “sound”. This means Local Plans should
- be tailored to the specific needs of the area;
- focus on the key issues that need to be addressed locally;
- be aspirational yet realistic in what they propose;
- be consistent with policies in the National Planning Policy Framework.
The inspector will look at the evidence which has been used to justify the policies. That is why Sustain cannot write a model policy for all sustainable food cities to use – the policy which is drafted for your area has to meet the needs and aspirations and possibilities relevant to your own location.
However, since the English government were considering if there should be national development management planning policies, we do now have a set of policies which local authorities can adapt and apply according to the needs in their areas. You can download them from this link https://www.sustainweb.org/reports/jan23-review-of-national-planning-policy-framework/
How much evidence is needed
Planners will want to avoid prohibitive costs of gathering detailed evidence so you can help them by sharing your local knowledge.
For example, you will be best placed to list, map and describe the current local food growing scene such as how many food growing spaces are being used, the number of people already growing, any knowledge of unmet demand for space.
This information will raise awareness of the topic of food growing. Many councillors and planners have not yet discovered the benefits of community food growing. Any information which you can provide will be a powerful demonstration of local interest.
Any information which you can put together will be useful for subject based studies (open space, sustainability, housing etc) which will be produced either in-house or by external consultants.
How much evidence depends on the level of detail which will be covered by the local plan document being prepared. Higher level, strategic/council-wide policies will need less evidence than detailed policies which guide planning applications.
What information is useful
Evidence of current provision
Maps tell powerful stories. You could mark up a steet map to show existing food growing spaces. This will show the current level of activity. It will also show up areas with no provision and you can use your local knowledge to wonder why. Might people living in these areas be interested in community food growing? Is there unused land which might be suitable? Do people already have their own gardens?
Transition Cambridge organised a community gardens open day in 2014 & were delighted that more gardens than they were aware of joined in. They plotted these on a map on their website which provides public evidence of the extent of local food growing.
Evidence of need
Allotment waiting lists are widely used by planners to identify demand for food growing space but this will not help meet the need for community food growing spaces. Instead, use your map of community food growing spaces to highlight where spaces are needed.
Allotment waiting lists do not tell the whole story about the demand for space for food growing because:
- It reflects demand only from individuals already interested in food growing. Community food growing often involves people new to food growing;
- Some councils have closed their waiting lists because they are over-subscribed, so demand is underestimated;
- Community food growing spaces are located close to where participants live, making them more accessible to a wider range of people;
- Projected increases in the number of households will result in further demand for food growing spaces. Higher densities mean that a high number of homes without gardens are being built;
- The production of food is not the sole reason that people join a community gardening project – some may not be interested in the commitment of running an allotment.
Think about areas that are going to be redeveloped over the next few years and how the needs of the future residents will be met. Regeneration and urban expansion will create opportunities for new landscaping to incorporate edible plants and fruit and nut trees. New community gardens can be incorporated as part of the overall design.The shared gardens will help new residents meet each other and start to form a new community.
Do volunteers on your open days come from neighbourhoods without community food growing spaces?
Durham undertook food mapping using market research techniques. This included 400 on-street surveys with members of the public and focus groups to establish views and experiences of local access to food. Overall, the findings indicated that despite awareness of their health and eating healthily, obesity is at high levels amongst the population of County Durham, especially in more deprived areas. The majority of survey respondents indicated a high level of satisfaction with their food shopping provision, although financial constraints and the inconvenience of transport were identified as barriers. In the focus groups, difficulties with food shopping were more widely described, and many participants felt that shops in their local area had declined, with the emergence of an excess of takeaways.
One of the recommendations is to utilise enthusiasm for growing initiatives and develop food education and cooking programmes for families and schools. It is hoped that communities preparing neighbourhood plans will pick up on the relevant recommendations to improve their local area.
Many councils prepare corporate strategies such as food strategies and health and well-being strategies. These strategies come with data sets that planners could use to identify which areas are in greater need of community food growing spaces. Health inequality mapping identifies priority areas for actions that benefit health and well-being. Maps from retail studies (hot food take-aways / shops selling fresh food) can be overlaid by maps of obesity and maps of unemployment and compared with the locations of spaces for food growing.
Government evidence on healthy food environments
Spatial Planning for Health, An evidence resource for planning and designing healthier places, PHE (2017) https://www.gov.uk/government/publications/spatial-planning-for-health-evidence-review#163961_20170807125822 This evidence review examined the links between health and the built and natural environment to help inform policy and support local action. Contains a section on food.
Green infrastructure studies and open space assessments should include consideration of local food growing (and not be confined to allotments). Open space deficiency maps can identify areas where innovative solutions for residents to access open spaces are needed such as temporary spaces, green roofs, balcony planters, raised beds.
Councils may be looking at the physical and social infrastructure needed by the existing and future population. As well as roads and schools, this includes “green” infrastructure such as parks and open spaces including formal food growing spaces such as allotments. Make sure local food growing is included under the topics for public health and sustainable development.
Some of this information can be gathered by residents using their own local knowledge to start the conversation with planners and councillors.
Oldham Council is set to make a linear path a hub of healthy eating and exercise. The path will be known as a ‘Fruit Route’. It means that a variety of fruits and berries will be planted along each side of the path so people can have a healthy snack fresh from the tree. Planting a wide variety of plants and fruit trees will also help increase biodiversity and attract new wildlife. In addition to encouraging healthy eating, the Fruit Route will be a great place for residents to exercise. Money has been invested in making the path level and easier to walk or cycle along.
The Fruit Route will be linked to the Alexandra Park Hub, a specialist site for teaching people more about gardening and healthy eating. The Hub will soon have a mock up ‘back yard’ similar to that of houses on terraced streets to show how much can be done with a small space.
How locally specific must evidence be
A local area policy, an area action plan, a masterplan or neighbourhood plan will benefit from very detailed evidence specifically based on the character of that area and the degree of change that is proposed. You could highlight opportunities for temporary community spaces prior to sites being built on. What clubs or community organisations are there in the area? Is there a health centre or doctors’ surgery with a garden? List activity in schools, highlight use of land which is at risk of flooding where use as a community food growing space could reduce risk.
Different parts of your area may need different approaches. Leicester City Council identified the need for more greenspace for food growing in its central, higher density developments than in the rest of the City where new development is of houses with gardens.
Keep track of how much food you grow and how much money you save so that you can see how much you and your volunteers can grow, impress funders and show policy-makers that growing food has a high value. The on-line harvest-ometer used in Birmingham, Manchester and London is designed to record harvests https://www.goodtogrowuk.org/
Download and read the Reaping Rewards II report http://www.sustainweb.org/publications/reaping_rewards_ii/?section=
Other supporting evidence
National planning policies set the framework for local plans. You can quote national policy relevant to food growing as an important starting point for your evidence.
The 2021 National Planning Policy Framework (NPPF) for England states that planning policies and decisions should aim to achieve healthy, inclusive and safe places which enable and support healthy lifestyles, especially where this would address identified local health and well-being needs – for example through the provision of safe and accessible green infrastructure, local shops, access to healthier food, and allotments.(paragraph 92)
The Guidance to the English National Planning Policy Framework expands on the policies. It outlines how planning can create a healthier food environment, "Local planning authorities can have a role by supporting opportunities for communities to access a wide range of healthier food production and consumption choices." (Paragraph: 004 Reference ID:53-004-20190722, Revision date: 22 07 2019)
"The design and use of the built and natural environments, including green infrastructure are major determinants of health and wellbeing. Planning and health need to be considered together in two ways: in terms of creating environments that support and encourage healthy lifestyles, and in terms of identifying and securing the facilities needed ................." (Paragraph: 001 Reference ID:53-001-20190722, Revision date: 22 07 2019)
The 2021 NPPF continues to support the circular economy for food from food production through to supporting healthy lifestyles. Local planning authorities should be thinking how their policies and decisions are:
- protecting soils
- recognising the benefits of the best and most versatile agricultural land
- providing local shops, access to healthier food and allotments
- ensuring access to a network of high quality open spaces
- ensuring that shops, facilities and services are able to develop and modernise, and are retained for the benefit of the community
- retaining and enhancing existing markets and re-introducing or creating new ones
- guarding against the unnecessary loss of valued facilities and services, particularly where this would reduce the community’s ability to meet its day-to-day needs.
Also in 2021, a National Design Code set a baseline standard of quality and practice which local planning authorities are expected to take into account when developing local design codes and guides and when determining planning applications, including:
- how the design of new development should enhance the health and wellbeing of local communities and create safe, inclusive, accessible and active environments;
- provision of private open space including gardens and balconies;
- provision and design of communal open spaces;
- provision for new community facilities and related amenity space in larger schemes;
- need to consider allotments and community growing projects for food production, learning and community engagement on large developments;
- understanding the impacts of tall buildings on amenity spaces and public spaces in terms of daylight, sunlight, overshadowing, wind and micro-climate and taking into account how overshadowing of public and private spaces impacts on the quality of external spaces at ground level;
- all new housing should be within easy access of a range of local services including shops;
- guidance for the design of and access to local shopping facilities; and
- provision of public spaces such as markets as focal points at the heart of the community.
You could draw on evidence of inspirational projects locally or from other places that are similar to your locality. This will show that there is a realistic prospect that planning policies that supported local food growing would be successful. (ie helping the planning inspector to find the Local Plan “sound” at the examination).
For example, Food Plymouth compiled an extensive evidence based paper on the whole food system in the city which they submitted to Plymouth Council at the start of the review of their local plan. This gave local, national and international examples of relevant projects.
Food Plymouth’s paper pointed out:
This is of importance to Plymouth where the good health of people is generally lower than the England average. Levels of obesity and other food-related diseases are continuing to rise, along with increasing levels of household expenditure on food. There is a difference in life expectancy of 11 years between the city's richest and poorest wards, and food poverty is evidenced by the steep rise in numbers of Plymouth residents who seek help from food banks.
The Council subsequently used the information from the report to produce a topic paper on local food to provide information and support discussions with local people and organisations about the future of the city. The Council’s topic paper considers how the Plymouth Plan can increase access to healthy and local food for Plymouth’s growing population, and support a sustainable food economy.
The London Borough of Brent updated its allotment strategy following a comprehensive consultation process. For the first time, the strategy unites food growing and allotment provision. It sets out a vision, objectives and action plan for both food growing and allotment provision in Brent. It covers all 22 allotment sites under the council’s land management and the 49 independent food growing spaces that are run on a communal basis. As a result of preparing this evidence, the Council will propose a planning policy which seeks the inclusion of space for community gardening as part of appropriate large schemes.
The Health Agenda
The Local Government Association (LGA) has published two documents relating to the role of planning and health/tackling obesity. Mention these documents when you are talking to Councillors or planners as most councils are members of the LGA.
“Building the Foundations” is about tackling obesity through planning and development. It includes the Hackney planning policy, the Oldham ‘Fruit Route’ and in North Tyneside, ‘Grow and Eat’.
You may also be interested in “Tipping the scales” which looks at seven councils that have used planning powers to limit hot food takeaways.
Sustain has carried out a review of councils using their planning powers to control hot food takeaways. Hot Food Takeaways: Planning a route to healthier communities
What happens next
Local planning authorities should publish documents that form part of the evidence base as they are completed. This is to help local communities and other interests consider the issues and engage with the authority at an early stage in developing the Local Plan. It will also help communities working on neighbourhood plans, who can use this evidence to inform their own plans.
This phase of consultation on the local plan‘s preparation is a formal stage. It is sometimes known as “Issues and Options” but may be given a local name. For example, this phase of consultation for the Plymouth Plan was called 'Plymouth Plan Connections'. The City Council asked for comments on the many evidence base documents which will inform the Plymouth Plan.
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