Monitor and respond to consultations on planning applications
In this section we will look at how you can contribute to improving the quality of new development.
Planning applications are evaluated against the policies of the Development Plan (Local Plan / Core Strategy/ Development Plan Policies etc). Some policies will be given greater weight according to circumstances. If support for local food growing is important to you – make sure the relevant policies are being applied. In this part of the toolkit find out how to monitor planning applications and how to send in comments based on the adopted policies in your area. If there are no up to date policies you will find out how to make the case for community food growing andaccess to healthy food. Responding to planning applications is a good opportunity to raise awareness of the food system in relation to planning.
If this is all new to you we suggest you go to the Getting started page first.
How decisions are made
It is your councillors who make planning decisions. They will meet on a regular basis to consider major or sensitive planning applications. Not all planning applications will be heard by the planning committee. The committee will have agreed types of planning applications for which planning officers can issue decisions on their behalf. (This is called “delegation” and there will be a schedule of delegated powers. You may need to use a search engine to find the list eg schedule of delegated powers + (Council name) + planning applications.)
How to find out about planning applications
Your local planning authority will have a page on its website with links to the list of planning applications received in the last week, a list of decisions made in the last week and a link to the online planning applications system where you can search for current or previous applications, view the plans and make comments.
What you could do
One of your members could monitor the weekly list. They could look out for larger scale developments where new space could be allocated as part of the landscaping or where temporary space could be provided if the site is being developed in phases. It is worth checking the lists to ensure there are no development proposals which will adversely affect existing food growing spaces. Then write into the planning officer (or use the online system if there is one) and even speak to the local ward councillor, making the case for a designated community food growing space. (You can refer to the same information that you can use to support a planning policy – link to section on evidence)
Respond to planning applications
The public has 21 days from the date of the weekly list to make comments on proposals. If you miss this deadline your comments may not be taken into account when the decision is made or when the planners have further discussions with the applicants.
These are some of the points you could think about:
- What might the future occupants need?
- Is there already a community looking for space or could the site be safeguarded for future use?
- Could a community food growing space be shown on the landscape plan of a new housing development?
- Is there potential to incorporate growing spaces within, around and on the building?
- On a small or high density site, creative ideas might be needed. Green roofs should be structurally to enable food growing planters and greenhouses.
- Is the provision of space for food growing part of the essential infrastructure required for that development?
- Could a temporary growing project use land before it is needed by the developer?
- Would edible trees and plants enhance the shared spaces on a business park? Do you think the landscaping of the proposal makes the most of opportunities for planting edible plants and trees? Integrate community food growing spaces, productive trees and plants in any landscaping proposal as part of a cohesive design of the development – recognising that these are good for wildlife and people.
- Could a community food growing space be incorporated in green space as part of flood protection (sustainable drainage).
- Ensure the design and layout of open space in new development is flexible so that spaces may be adapted for growing opportunities in the future. Include maintenance plans as part of an application to ensure spaces will be managed successfully. Is the growing space in a good position (ideally south facing, easily accessible, with a water supply, shelter from wind etc)?
- What quality is the soil?
- Does a proposed development impact on an existing food growing space? Check for overshadowing.
- Request landscape plans demonstrate the potential use of any open space for community food growing
Brighton’s Food Growing and Development Planning Advice Note would give you some ideas.
Remember – your responses will be a public document. Don’t just object – offer practical solutions.
Read the section on making responses to local plan consultations.
Using local plan policies
Are there relevant planning policies?
Planning applications are evaluated against the policies of the Development Plan (local plan). The local plan is the starting point for assessing whether the proposed development is appropriate. When you are making your comments on a planning application, try to base them on relevant planning policies (even if there are no policies which specifically mention food growing). Are there any policies specifically related to community food growing and the proposed development? Are there any more general policies eg sustainability, health, green infrastructure, design or amenity?
Double Check: Your local planning authority may have published their detailed “Development Management” policies in a separate policy document or may have “Area Action Plans” for specific development sites.
Is there useful supplementary planning guidance?
See if your local planning authority has published detailed advice for developers, perhaps on the quality of open space to be provided or on design. How would providing for community food growing help the developer meet some of the planning authority’s criteria?
What If there are no relevant local planning policies for community food growing or other food issues
If there are no specific planning policies or if the local plan is very out of date, you could:
Rely on higher level policies - national planning policies and its companion guidance on health and food, see next section Making the case and, in London, the London Plan;
- Liaise with Councillors
Making the case
Don’t worry if your council does not already have specific policies. There are national planning policies in place which you can draw on for support. You can then work with your council on getting local policies which reflect your local circumstances.
For example. Planning Practice Guidance for the National Planning Policy Framework in England requires planners to support the provision of space for food growing as part of building a healthy community - a principle that is relevant across the whole of the UK.
Some or all of these nationally important topics are likely to be priorities in your local authority. Access to growing and buying healthy food can help your local area contribute to achieving national objectives.
- Achieving sustainable development
- Promoting Healthy and Safe Communities
- Making effective use of land
- Achieving well-designed places
- Meeting the challenge of Climate Change
- Conserving and enhancing the natural environment
You can refer to these national policies if there is a planning application which you are concerned about. England, Scotland, Wales & Northern Ireland.
Under the theme of "Promoting healthy and safe communities", the 2021 NPPF says:
Planning policies and decisions should aim to achieve healthy, inclusive and safe places which:
c) 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, sports facilities, local shops, access to healthier food, allotments and layouts that encourage walking and cycling. (Para 92)
and under the theme of "Making effective use of land", the 2021 NPPF says:
Planning policies and decisions should:
b) recognise that some undeveloped land can perform many functions, such as for wildlife, recreation, flood risk mitigation, cooling/shading, carbon storage or food production; (Para 120)
The significance of food growing (food production) to healthy communities is reinforced in the Guidance to the NPPF
Promoting healthy and safe communities
Green infrastructure can improve the wellbeing of a neighbourhood with opportunities for recreation, exercise, social interaction, experiencing and caring for nature, community food-growing and gardening, all of which can bring mental and physical health benefits. (Paragraph: 006 Reference ID: 8-006-20190721, Revision date: 21 07 2019)
The National Model Design Code 2021 also forms part of the Government’s planning practice guidance. This means future planning applications should follow its approach to designing new places which includes:
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.
The National Planning Framework (NPF) and Scottish Planning Policy (SPP) are relevant to the preparation of Development Plans in Scotland. National Planning Advice Notes (PAN) provide more details to local authorities on policy making eg PAN 65 Planning and Open Space which covers allotments and community gardens.
The Welsh Government publishes planning policy for Wales which should be taken into account when preparing development plans. This guidance is supplemented by Technical Advice Notes (TANs) such as Technical Advice Note 16: Sport, Recreation and Open Space which covers community gardens.
The development planning system in Northern Ireland is changing. A Strategic Planning Policy Statement is being prepared in the context of wider planning and local Government reforms. It will have a key role in underpinning the delivery of the reformed two-tier planning system and give support to the planning reform legislation.
Community food growing is consistent with the proposed core planning principles of the reformed, two-tier planning system.
Your involvement in monitoring and responding to planning applications will help raise awareness of the demand for space for community food growing. It will give you the opportunity to boast of the benefits to people and the environment. As your experience grows, you are likely to be called on when planners or developers need advice and you will build credibility. Hopefully, when the local plan is reviewed, it will include policies which support local food.
You can demonstrate the current interest in food growing through open days and inviting councillors and planners. Perhaps there is a local celebrity or councillor who could be your champion. You could set up a website with some local case studies to demonstrate the benefits of community growing.
Help for communities
- CLAS provides useful advice on accessing land, enabling you to approach developers.
- Planning Aid Direct is a free web based resource which provides answers to questions people often ask about planning, clear, simple explanations of how the planning system works and signposting on where to go next.
- The Campaign to Protect Rural England has developed resources to help communities use the planning system to protect the countryside and promote urban regeneration. It explains the planning system and how to comment on a planning application.
- Local amenity societies will be experienced in monitoring and commenting on planning applications in your area.
Go to Plan Making section to refine your evidence based on experience of monitoring applications and send your views into the planners.
Make sure your planners have seen Sustain’s guidance for planners.
Identify a Councillor champion and invite local councillors to your open days.