Response of the Quality Environment for Dartford (QED) Allotments Group to the SERPLAN 'Sustainable Development Strategy for the South East' Draft Regional Planning Guidance

 

The QED Allotment Group's Comments:

The QED Allotments Group welcomes the reference to allotments in Paragraph 3.1.10, as recognition of the value of allotments as a form of "urban green space", and also as evidence that the consultation process has genuinely taken on board submissions from the general public, for which SERPLAN must be congratulated. We are concerned, however, over the semantics of the final sentence of this paragraph, where it is suggested that new development should not take place on "open land". We would like some clarification as to whether "open land" is synonymous with "urban green space", and if not, whether the sub-set designated for protection as "open land" includes tenanted allotment gardens, which we believe it should. The effect of suitable clarification on this point should be to ensure that tenanted allotment gardens do not fall foul of the "sequential approach" to development specified in Paragraph 3.5.8, in that tenanted allotment gardens would not be included within the category of sites with an equivalent status to "brownfield" land covered by the phrase "productive use of other sites within urban areas", since their value and the need to protect them would be recognised in a clarified Paragraph 3.1.10.

The QED Allotment Group would like to see the following changes to the Draft Regional Planning Guidance:

Clarification of the status of allotments as a form of "open space" in the context of Paragraph 3.1.10. Ideally, we would prefer to see the term "urban green space" used throughout, instead of "open space", to make the status of allotments absolutely clear.

Richard Wiltshire (Research Officer: QED Allotments Group), February 9 1999

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