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Response of the QED Allotments Group to the Dartford Borough Local Plan Review Deposit Draft
1. The QED Allotments Group (Dartford Allotments Steering Committee) responded to the Local Plan Review Main Issues Discussion Paper in May 1997 (1), and is pleased to offer the following observations on the Deposit Draft as published on March 30, 2000.
2. Within the previous Dartford Local Plan, allotments were covered by policy CF12, which regulated the conversion of allotment land to other uses (2). This policy had been formulated in accordance with the relevant Allotment Acts, and we recommended that the policy should pass through the review process unchanged, along with paragraph 13.3.17, which qualified the policy (3). We are pleased to note that the substance of policy CF12 and the associated paragraph 13.3.17 have been retained in the Deposit Draft in the new policy LT13 and new paragraph 9.6.9.
3. With respect to the other paragraph which qualified policy CF12, paragraph 13.3.16 (4), we noted the major expansion in housing provision proposed for the east of the Borough, much of which will be at high densities with limited private garden provision, and observed that this was likely to result in a need for additional provision of allotment gardens in that area. We therefore welcome unreservedly the standard for new allotment provision established in the Deposit Draft in new policy LT11, which is set at the appropriate level of 0.25 ha per 800 households, and we would be pleased to offer whatever assistance we can in respect of maximising the contribution of any new facilities to local sustainable development objectives, within the context of the Council's policy on allotment site management as set out in Section 16 of the Leisure Strategy for the Borough of Dartford (5).
4. New paragraph 9.6.14 establishes locational criteria for new allotment sites (6) which are wholly sensible and which we are delighted to endorse.
5. We note the reference to existing allotments as open areas with amenity value within new paragraph 9.6.5, and welcome both the conclusion that "development proposals must not result in any reduction of these assets and should indeed enhance them wherever possible", and the associated new policy LT10.
6. We welcome the Green Grid concept as identified in section 2.5 of the Deposit Draft, and look forward to an appropriate inclusion of allotments within the supplementary planning guidance referred to in paragraph 2.5.8 covering "links" between key open spaces. We would welcome an opportunity to comment on this supplementary planning guidance prior to its adoption.
7. Finally, as regards the Sustainability Appraisal of new policy LT13, while this in no way recognises the contribution which allotments make to sustainable development in general and to Dartford's Local Agenda 21 Initiative (QED) in particular, it is predicated on the assumption inherent in policy LT13 of the loss of unused allotment land or transfer to a replacement site, and given that assumption the Appraisal is not unreasonable. The Appraisal of new policy LT11, which is predicated on the expansion of leisure facilities including allotments, is generally favourable, and while the overall impact on global sustainability of new open space may be mixed, the contribution of allotments to the reduction of "food miles" and recycling of wastes should help tip the balance in a positive direction.
In summary, we welcome the treatment of allotments in the Deposit Draft, and offer our thanks and congratulations to those who have been involved in its preparation.
(1) Available on the QED Website at http://www.btinternet.com/~richard.wiltshire/alldoc10.htm
(2) CF12: "Proposals for development resulting in the loss of allotment land not otherwise identified for development in this Plan will not be permitted unless the proposals either: establish an absence of need for the existing facilities, or make provision for its replacement or the relocation of occupied plots."
(3) 13.3.17: "The Council will retain allotment plots wherever they serve a local need. In situations where the need has declined, proposals for alternative uses will be considered provided that there is no longer any local need, or that alternative suitable sites can be provided in the locality."
(4) 13.3.16: "Most of the allotment sites in the Borough are provided by the Borough and Parish Councils. The level of usage varies considerably from site to site, but overall there is no quantitative need for additional provision."
(5) "The Council will:
- Encourage local associations to accept agreements for allotment sites wherever appropriate, in order to further utilise the benefits of local control of these facilities.
- Promote the advantages of allotment gardening as a leisure activity whenever it considers it to be appropriate.
- Seek to secure resources for continuing improvements to allotment facilities in the Borough where possible."
(6) 9.6.14: "Allotments - these should normally be provided on the edges of local parks, open space or playing fields to provide informal public surveillance and flexibility in case demand should change in the future"