Urban Growing

Bristol Food Network  response to the Allotment Fees and Rules Consultation  

By Bristol Food Network

The latest Bristol Good Food 2030 blog is from Bristol Food Network, articulating some of the network’s perspectives on Bristol City Council’s Allotment Fees and Rules Consultation, many shared by Bristol’s allotment and growing community. 

You may have seen our initial reflections on the debate around Bristol City Council’s Allotment Fees and Rules Consultation. As highlighted there, Bristol Food Network (BFN) was not consulted on the proposals before they were published. 

In the past few weeks, as well as holding an initial meeting with the council to better understand the rationale behind their proposals, we have been listening to the public debate and discussion among allotmenteers and gathering feedback from some of our stakeholders in the growing community. As a result of this, we submitted a detailed response to the proposals to the council this week. We share several of the concerns expressed by tenants about the impact of changes, from a social, equality, diversity and inclusion perspective, and from an environmental perspective. Some key points raised in our response are summarised below. 

Fee proposals 

Rental fees 

We understand the financial constraints Bristol City Council (BCC) is facing and the overall need to increase plot rental fees. Nevertheless, we would like to see these being applied in a more staggered manner with direct debits being available to all tenants. We also suggested evaluating the introduction of micro plots at a lower cost, to improve accessibility and success for first time growers.  

We asked why rental discounts for Collective Food Growing (CFG) and Community Orchards were not detailed and why discounts were not also offered to Community Interest Companies (CICs). 

Additional fees 

While we understand that the council needs admin charges to better reflect the work involved in managing tenancies, we are concerned that the cumulative effect of numerous charges could add up substantially and put tenants off making positive changes, or indeed make the rental of an allotment out of reach financially.  

The proposed set up fees for CFG and CICs feel inaccessible to organisations that run on very limited funding; £400 for even established CICs is substantial. To support the Food Growing & Allotment Strategy’s ambition of increased collective food growing, we would like to see these fees being reduced substantially. 

Coworkers  

Charging for registering co-workers feels contradictory to principles of inclusion and equity, particularly for tenants who may need additional support to manage their plot and whose circumstances may limit their income. 

Event charges 

Charging a fee for all events with more than 12 people would have a significant, negative impact on community building and the social benefits of allotment spaces. In particular for CFG and Community Orchards, who regularly run volunteering, educational and community events on their plots with more than 12 attendees. Additionally, these event fees would impact the feasibility of the annual Get Growing Trail organised by BFN, where up to 30 community growing spaces have opened to the public in the past. The Get Growing Trail attracted an estimated 1,000 citizens in 2022, around of third of whom we believe had not visited the community growing sites before. 

Rental reminder, late payment or Direct Debit refused fee 

This fee is significant and feels at odds with principles of equity and inclusion, and at odds with the support being offered for tenants on benefits. Such a charge could be problematic even those not on benefits, given the current cost of living crisis. We feel a fairer approach could be applied, for example with charges only being made after the 14-day grace period has passed, and/or payment plans being agreed, particularly for those tenants on benefits.  

Transitional arrangements 

We understand that BCC may wish to apply some new rules to existing tenants to maintain fairness, and to address issues such as overgrown plots and soil contamination. However, we are concerned that applying some of these rules to existing tenants will have negative impacts on site biodiversity and could discourage the valuable environmental stewardship undertaken by tenants.  

Hedge and tree removal 

From our discussions so far with BCC, we understand that the proposal is not to blanket remove mature trees on plots. We support the principle in Part 2, Clause 4.1 that mature trees should not be removed by anyone without discussion, and the principle in Part 2, Clause 4.2 that self-seeded saplings need to be proactively managed. The statement on trees in Transitional Arrangements could be interpreted as contradicting clause 4.1. 

The proposed, blanket removal of existing hedges on plots feels at odds with environmental principles and the council’s ecological and climate ambitions. Hedges can provide multiple benefits including increased biodiversity, natural pest control and improved soil quality, to name but a few, all of which support successful growing. 

The proposed transitional arrangements for trees and hedges are particularly problematic for Community Orchards 

The rules on mature trees need to be more clearly worded, if the proposal is as we understand it – that they will be assessed case-by-case. The positive ecological and climate benefits of mature trees and hedges need assessing against potential gains from removal, so for hedges, we would also like to see a more flexible approach whereby they are assessed in collaboration with the Allotments team, rather than applying a one-size-fits-all all approach. 

Glass removal 

We would ask for consideration of allowing existing glass in cold frames and greenhouses to be allowed for current tenants, helping to minimise costs for tenants and to address concerns about the extensive use of plastic. 

Allotment rules 

We are pleased to see some rules included that support and encourage good environmental practice, such as rainwater harvesting, the ban on use of peat-based composts and encouragement to use organic fertilisers.

We would highlight that allowing tenants some flexibility on the growing of green manures, or growing plants such as nettles or comfrey for use as natural fertilisers, would support tenants using environmentally-friendly techniques. 

Overall, we feel that the proposed rules are overly stringent leaning towards more of a punitive stance rather than an incentivising approach that recognises the skills and knowledge of Bristol’s allotmenteers. Our specific areas of feedback, are as follows: 

Support for nature-friendly growing practices  

We feel that overall, the wording could better reflect nature-friendly and permaculture approaches such as companion planting and growing of green manures, that support the council’s ecological ambitions.  For example, providing clarification on what constitutes a weed and related rules on cultivation. 

BCC repairs obligations 

We welcome the inclusion of this clause but note that it provides a very limited ‘service level agreement’ in terms of what BCC deliver will deliver to tenants, particularly when compared with the length of obligations for plot holders. Expanding this section – for example adding timeframes in which reported issues would be dealt with – would lend itself to a more balanced agreement which tenants would no doubt appreciate.  

Community Food Growing (CFG), Community Orchards & CICs 

Feedback from our partners participating in the Get Growing Trail, indicates several challenges posed by the new rules as they do not fit with their operating model. We believe that flexibility on the rules is required at a site and CFG project level to support these initiatives and suggest exploring a separate agreement for these tenants. This will enable them to continue operating and delivering their invaluable environmental and social benefits.  

In addition to the problems posed by admin fees and event size limits/charges outlined above, other concerns for CFGs/Community Orchards are as follows: 

Limit on the number of co-workers  

A limit of four co-workers per plot would not be viable for these projects, as they have many more people involved. 

Rules around cultivation, trees and hedges 

CFG and Community Orchard spaces work to nature-friendly/permaculture principles, growing a wide range of plants and fruit bushes that support rich biodiversity and healthy soil, often with wildlife-abundant hedging in place. Many have mature healthy trees, producing heritage varieties and trees are unlikely to be formally spaced. They therefore do not fit the proposed definition of ‘Community Orchard’ and will not meet the requirements around cultivation. 

Public Liability Insurance requirements  

The value of Public Liability Insurance required by CFG and CICs is very high at £5m, and potentially out of reach financially for such organisations.  

Other community projects 

We would also like to highlight that the proposed rule changes will jeopardise other community-run projects if applied to them. We understand that in some cases, these projects are using allotment plots that might otherwise be hard to use for fruit and veg cultivation. For example, Street Goat, who lease allotments to graze their goats for local, sustainable milk and meat production, would not be able to viably operate within the rules and newly proposed fees. We hope that BCC will be able to assess these sorts of historic tenancies on a case-by-case basis and find ways to continue supporting them.  

Next steps 

Despite the initial lack of consultation, we have been working this past fortnight to ensure we voice concerns and insights from the allotment and growing community in our response, and that we evaluate these detailed documents from a food resilience and justice perspective. Our response emphasises key areas, including fee structures, concerns about cumulative charges, and potential impacts on community cohesion, as well as ecological concerns. 

Bristol Food Network will continue to be in direct communication with BCC concerning the next steps in reviewing the consultation’s feedback. We are optimistic that constructive discussions can be held to address these vital issues collaboratively. 

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