SECTION 10 – ALLOTMENTS

10. Allotments

Introduction and definition

10.1 This typology includes all forms of allotments. The primary purpose of allotments is to provide opportunities for people to grow their own produce as part of the long-term promotion of sustainability, health and social inclusion. This type of open space may also include urban farms.

10.2 Like other open space types, allotments can provide a number of wider benefits to the community in addition to their primary purpose. These include:

• bringing together different cultural backgrounds

• improving physical and mental health

• providing a source of recreation

• making a wider contribution to the green and open space network.

Context

10.3 Allotments are becoming increasingly popular nationally, following the recognition of the role that they can play in encouraging all sectors of the community to participate in active recreation. Allotments offer an alternative active pastime to participation in formal sport, particularly for older residents.

10.4 The Department for Communities and Local Government (DCLG) 2008 is responsible for national policy on allotments and consider allotments to be important in terms of bring together all sections of the community, as well as providing opportunities for people to grow their own and promote health and wellbeing.

10.5 DCLG aims to ensure that allotments are well managed, and are only disposed of where there is no demand for them and established criteria are met.

10.6 It details the duties of Borough, District and Parish Councils covered by [Section 23 of the 1908 Allotments Act (as amended)]..

10.7 Contributions towards allotments in Charnwood from new development are not currently required by the Charnwood Borough Council Local Plan.

10.8 This section considers the quality, quantity and accessibility of allotments across Charnwood.

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Current Provision

10.9 There are currently 34 allotment sites across Charnwood. These sites are predominantly distributed across the larger settlements and service centres.

10.10 The average size of sites is 37 plots. Provision varies significantly however from 7 plots (East Road Allotments, ) to 90 plots (Cambridge Road, ). There is no clear pattern relating to the size of the settlement and the size of the allotment. Although smaller settlements predominantly contain smaller allotments sites, the main towns contain a mixture of small and large sites. In addition to varying numbers of plots, the size of plots also varies significantly.

10.11 In total there are circa 1293 plots. In some instances plot sizes are estimates. Where site size is not known, it has been assumed that the site is average size (37 plots).

10.12 Sites are managed by a variety of bodies but predominantly by Parish Councils and Charnwood Borough Council. The Borough Council manages 10 sites.

10.13 As highlighted above, demand for allotments has increased in recent years and this is reflected in the presence of waiting lists at sites across the Borough. This additional demand is now evident in all parts of the Borough. Analysis of approximate take up of existing plots indicates that there are over 1200 plots tended. The majority of vacant plots are located in Quorn. There are also some vacancies at sites in Birstall and Barrow although there are waiting lists at other sites in these areas.

10.14 30% of respondents to the household survey indicated that they would be interested in managing an allotment. Levels of interest vary across the borough, with 27% of respondents in larger settlements indicating that they would be interested in tending an allotment plot, 32% in the service centres and 37% in the smaller settlements.

10.15 The quantity of allotments across the Borough is summarised in Table 10.1.

Table 10.1 - Provision of allotments across Charnwood Settlement Settlement hierarchy provision Current (hectares) sites of Number Smallest site (hectares) site Largest (hectares) LDF population (2021) 1000 Provision per population (2021)

Larger settlements 20.09 17 0.50 2.5 101,368 0.20 Service centres 18.71 13 0.39 2.49 61,779 0.30 Smaller settlements 2.52 5 0.16 0.83 12,253 0.21 Overall 41.32 35 0.16 2.49 175,400 0.24

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10.16 The key issues emerging from Table 10.1 and consultations relating to the quantity of allotments include:

• a difference in opinion regarding the quantity of allotments is evident. 40% of respondents to the household survey feel that provision is insufficient (15% ‘not enough’ and 25% ‘nearly enough’) and 33% of residents state that provision is sufficient

• the distribution of allotments is uneven, both in terms of number of sites, and site size. Provision per 1000 population is highest within the service centres. Despite this, opinions of the quantity of allotments are relatively consistent – although satisfaction levels are slightly higher amongst residents from the larger settlements where there is most provision:

- larger settlements - household survey results indicate that 38% of respondents perceive allotment provision to be adequate, whilst 36% consider it to be insufficient (20% ‘not enough’ and 16% ‘nearly enough’)

- service centres - 48% of respondents to the household survey regard the provision of allotments to be insufficient (33% ‘not enough’ and 15% ‘nearly enough’). However, 24% of respondents feel that provision is adequate

- smaller settlements - 43% of respondents to the household survey consider the provision of allotments to be insufficient (32% ‘not enough’ and 11% ‘nearly enough’). 36% of residents indicate that provision is adequate

• general comments from residents emphasise the need to increase the provision of allotments in Charnwood. In addition to a lack of provision, residents highlight a high demand for this type of open space, with waiting lists evident on a number of sites

• feedback from other surveys undertaken for this study also highlighted demand for additional allotment provision, with 76% of respondents from the Officer Survey and 63% of respondents from the on-line survey deeming current provision to be insufficient

• at the Parish Council workshop, it was noted that there were shortfalls of allotment provision across the Borough. In particular shortfalls were noted in Anstey, , , , Birstall and Barrow. Increased allotment provision was one of the main issues identified at the workshops

• shortfalls of allotments provision were also identified during the stakeholder workshop with many attendees making reference to the waiting lists evident on current sites – for example, detailed waiting lists held for allotments in by Charnwood Borough indicate that there are currently 284 plots and a further 190 residents on the waiting list for a plot

• analysis of feedback from Parish Council surveys suggest that the majority of allotment sites are near or at capacity. There are some spaces at sites in Quorn, and Birstall.

Setting quantity standards

10.17 The recommended local quantity standard for allotments has been derived from the local needs consultation and audit of provision and is summarised overleaf. Full justification for the local standard is provided within Appendix E.

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10.18 The standard recommends an increase on the existing level of provision. This is based on the existing waiting lists in addition to expressed demand from local residents.

Quantity Standard (see Appendices D and E – standards and justification, worksheet and calculator)

Existing level of provision (hectares Recommended standard (hectares per per 1000) 1000) Larger settlements – 0.22 0.33 ha per 1000 Service centres – 0.33 Smaller settlements – 0.23 Justification Findings from local consultation identify high demand for allotments, with 40% of respondents to the household survey indicating that they need additional allotments are required and 30% of residents suggested that they would be interested in renting an allotment if sufficient plots were available. Shortfalls and waiting lists were also identified during consultations with Parish Councils, stakeholders and internal officers, reinforcing the need for higher levels of provision. The local standard has therefore been set above the existing boroughwide level of provision placing an emphasis on new site development and also the protection of current allotment sites. The standard takes into account the amount of additional space required to meet current and future waiting lists (and assumes that waiting lists will be filled by providing half plots). This standard should be applied to each settlement to enable the identification of specific deficiencies and the application of the accessibility standard will inform decision making on new allotment provision. In addition to maximising the amount of allotments provided, consideration should be given to alternative management practices, such as half plots.

Quality

Current position

10.19 The quality of existing allotments was assessed through site visits undertaken by the Borough Council. Each site was measured against the factors defined in the quality standard (summarised later in this section) and received a total percentage score.

10.20 The quality of allotments is summarised in Table 10.2. This table summarises the total percentage achieved at each site (in accordance with the methodology set out in Section 2). The overall quality rating in line with the local standard is discussed later in this section.

10.21 The key issues at each site are recorded in Appendix D, site quality scores database.

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Table 10.2 - Quality of allotments in Charnwood Settlement Settlement hierarchy of quality Range (%) scores Quality Average Score (%)

Larger settlements 20 – 83% 55% Service centres 20 – 87% 56% Smaller settlements 43 – 87% 65% Overall 20 – 87% 57%

10.22 The key issues emerging from Table 10.2 and consultations relating to the quality of allotments are summarised overleaf:

• 30% of respondents to the household survey consider the quality of allotments to be average. 13% of residents state that the quality of this typology is good and 10% consider it poor. As would be expected, a large proportion of respondents (48%) did not have an opinion on the quality of allotments

• the difference in opinion regarding the quality of allotments is reflected in the range of quality of scores, with the quality of sites ranging from 20% - 87%. The average quality score of an allotment is 57%, indicating that the quality of some allotments needs to be improved. This also suggests that the average quality of allotments is lower than many other types of open space in the Borough

• findings within the three sizes of settlement are consistent with the overall results although a higher proportion of respondents within the smaller settlements (25%) deem the quality of allotments to be good. Only a relatively small proportion deems the quality of allotments to be poor; 9% in the larger settlements, 10% in the service centres and 11% in the rural communities

• other survey results show that:

- 34% of respondents to the officer’s survey consider the quality of allotments to be average whilst 23% of respondents identify the quality of this type of open space as good/very good

- 25% of respondents to the on-line survey consider the quality of allotments to be average, whilst 19% consider them good/very good and 25% consider them to be poor

• research carried out by the Council with tenants of Council managed sites during 2009 highlighted that users are generally satisfied with existing facilities (average satisfaction score was 73%). In particular users scored the following aspects well; removal of rubbish, boundary maintenance, on-site water provision and promotion. By comparison the road and pathway maintenance and management of overgrown plots were less well regarded (particularly at Alan Moss, Great Central and Lodge Farm allotment sites, all in Loughborough)

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• site visits concluded that the key issues at allotments were unclear entrances, poor lighting, a lack of toilet facilities at some sites and varied infrastructure (parking, footpaths etc). In general, the cleanliness and maintenance of these sites was good.

Setting quality standards

10.23 The recommended local quality standard for allotments is summarised below. Full justifications and consultation for the local standard is provided within Appendix E.

10.24 The quality standard summarises the features that residents consider to be an important determinant of the quality of provision. These key criteria will then be incorporated with the quality scores during the application of local standards.

Quality Standard (see Appendix E)

Recommended standard – Allotments Local consultation, national guidance and best practice suggest that the following features are essential and desirable to local residents: Essential Desirable Clean and litter free Compost and litter bins Water supply Toilets Parking facilities Appropriate entrance Well managed, appropriate access routes Security

Accessibility

10.25 The accessibility of sites is paramount in maximising usage as well as providing opportunities for all people to use the sites. The recommended local standard is set in the form of a distance threshold and is derived directly from the findings of the local consultations.

10.26 A small percentage of respondents to the household survey stated that they use allotments most frequently and it is therefore difficult to produce sound analysis on current usage patterns based on the sample size provided. Of the nine users, 67% travelled on foot and the same proportion travel under 10 minutes to their allotment.

10.27 62% of respondents to the household survey expect to walk to an allotment while 28% would travel by car. The proportion of respondents that would expect to walk is slightly higher in the larger settlements and less in the service centres and smaller settlements.

10.28 At the stakeholder’s workshop, access issues to allotments were raised, particularly with regards waiting lists. It was suggested that temporary allotments should be created out of parkland. Quantity of allotments was perceived to be the key issue at the Parish Council workshop sessions.

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Setting accessibility standards

10.29 The recommended local accessibility standard for allotments is summarised overleaf. Full justification for the local standard is provided within Appendix E. The standard takes into account the expectation that allotments will be provided locally.

10.30 Waiting lists at sites were perceived to be the main barrier to the usage of allotments. Few other issues were raised.

Accessibility Standard (see Appendix E)

Recommended standard – Allotments

Long Term - 15 minute walktime (720m)

Consultation demonstrates that opinions are split between those who expect to walk to an allotment (62%) and those who would expect to drive. Many allotment plots are however located outside of settlement boundaries and it is in these areas where there is greater potential to increase the provision of allotments. The long term intention is to maximise the number of residents who are within walking distance of their nearest accessible allotment plots. Quantity of allotments is perceived to be a particular issue borough wide. In the short term, areas where the access to allotments is particularly poor will be prioritised. This will be based on the minimum criteria that all residents should be within a 10 minute drive time of their nearest available allotments. This is the modal response of those residents who expected to travel by car.

Applying provision standards

10.31 The application of the recommended quality, quantity and accessibility standards provides an understanding of the existing distribution of allotments. In light of the demand led nature of allotments, this should be treated as an indication only. Table 10.3 summarises the application of the quantity standard.

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Table 10.3 – Application of the quantity standard Future shortfall / shortfall Future surplus against local standard / shortfall Future surplus against local standard Analysis areas Analysis areas per 0.33 hectares 1000 population) per 0.33 hectares 1000 population) Larger Settlements -9.95 hectares -13.36 hectares Service Centres 0.4 hectares -1.68 hectares Smaller Settlements -1.11 hectares -1.52 hectares Overall -10.66 hectares -16.56 hectares

10.32 Table 10.3 indicates that the provision of allotments is insufficient to meet demand, with deficiencies found in all areas of the Borough except the services centres. Longer term, there are also deficiencies in these areas. In addition, waiting lists are evident on all Borough Council owned allotment sites and almost all Parish Council owned sites are full. This suggests that new provision will be required.

10.33 Application of the quantity standard at a settlement level suggests that provision falls below the recommended minimum standards in the majority of settlements. Only in , Woodhouse, Shepshed, Barrow Upon Soar, Wymeswold, , Rothley, , Quorndon and is provision sufficient to meet the standard. Even in these areas, there are waiting lists at many of the existing sites.

Accessibility

10.34 The application of the accessibility standard for allotments is outlined in Map 10.1 overleaf. The map indicates that there is a good distribution of allotments in Charnwood. The majority of residents have access to an allotment within a 15 minute walk time and the only key areas of deficiency are located in East Goscote, Queniborough, and .

Quality

10.35 The overall quality rating for each site is based on the total quality score achieved (outlined in Table 10.2) and the essential and desirable criteria listed in the quality standard. The methodology for calculating the overall score is summarised in Table 10.4 overleaf.

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Table 10.4 – Measuring sites against the recommended quality standard Overall Quality Overall Quality Rating Minimum Score Average

All essential criteria 3 or above 80% or above Excellent All desirable criteria 3 or above

All essential criteria 3 or above 70 – 79% Very Good

All essential criteria 3 or above 60 – 69% Good

Average 50 – 59% Poor Below 50%.

10.36 Table 10.5 therefore summarises the application of the quality standard based on the quality criteria set out in Table 10.4

Table 10.5 – Application of Quality Standard Settlement Settlement hierarchy % of sites excellent % of sites very good % of sites good % of sites average % of sites poor

Larger settlements 13 0 6 38 44

8 8 0 46 38 Service centres

Smaller 20 0 0 60 20 settlements 13 3 2 48 34 Overall Nb. Figures may not add up to 100% due to rounding

10.37 Table 10.5 illustrates that the majority of allotments were awarded ratings of average or poor. A higher proportion of allotments in the smaller settlements were of high quality than in the larger settlements and service settlements. Almost half of all allotments in the larger settlements are poor.

10.38 Map 10. 2 illustrates the quality of existing provision. It highlights where sites are of high quality and where there are particular priorities for improvement. It can be seen that poor quality facilities are spread across the Borough and high quality sites are also equally dispersed.

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Map 10.1 – Accessibility of allotments in Charnwood

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Map 10.2 – Quality of allotments in Charnwood

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Priorities for Future Delivery

Borough Wide Issues

10.39 This section considers the borough wide issues that need to be addressed. Consideration is then given to issues within specific settlements.

High Demand for new provision

10.40 While new provision should be sourced where possible (specific areas referenced later), in the short term, consideration should also be given to a change in management practice to maximise the number of residents that can use an allotment. These practices could be adopted at allotments Borough wide, regardless of ownership. In particular the following options should be considered:

• provide half plots where suitable opportunities arise to ensure that the site can accommodate a higher number of residents

• ensure that residents have only one allotment plot at any one time.

ALL1 Consideration should be given to the implementation of appropriate policies to promote effective usage of allotment sites including: • providing half plots where suitable opportunities arise to ensure that sites can accommodate a higher number of residents • ensuring that whilst demand continues to outstrip supply, tenants are not given the opportunity to acquire multiple tenancies • promoting appropriate use of allotments.

10.41 As well as addressing management issues relating to existing provision, all sites should be protected from development to ensure that they are available long term to meet the needs of residents. There are no recommendations for the disposal or redesignation of any allotments in the Borough.

ALL2 Include a policy within the LDF that protects allotments from development. Loss of allotments should only be permitted where it can be proven that the site is surplus to requirements and is unlikely to be required in future years. Ensure new housing developments contribute to any increase in demand as necessary through the inclusion of appropriate policy in the LDF. It may necessary to consider innovative solutions to the provision of allotments, for example the location of facilities at school sites.

Maximising the role that allotments play in conservation and biodiversity

10.42 The provision of high quality allotments is not just important from a recreational perspective but this type of open space plays an important role in providing wildlife habitats and contributing towards biodiversity.

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10.43 The and Rutland Biodiversity Action Plan highlight allotments as one of the key urban habitats in the County. The increased use of fertilisers and pesticides on allotments is highlighted as a key threat to conservation.

10.44 Site assessments carried out as part of this study indicate that allotments provide important habitats with seven sites identified as having mature trees, and 20 sites containing hedgerows.

ALL3 As well as improving the function of allotments from a user perspective, ensure that the management, maintenance and future planning of these sites takes into account their role in nature conservation and biodiversity.

10.45 In light of the demand led nature of allotments, application of the quantity, quality and accessibility standards should be treated as a starting point only. Detailed research and monitoring of local demand should be undertaken prior to the development of new allotments. Consideration of existing waiting lists is a particularly useful indicator of latent demand.

10.46 The remainder of this section summarises the key issues for the delivery of allotments within Charnwood across each of the three settlement hierarchies.

Larger Settlements

10.47 Application of the quantity standard indicates that the current provision of allotments falls below the recommended standard, with there being an overall shortfall of 9.95 hectares. Based on the average size of an allotment plot (250m2) the current shortfall in the larger settlements equates to circa 400 plots. Additional demand for allotments further exacerbates this shortfall, with waiting lists evident on all sites in the area (190 people in total for Council managed sites in Loughborough).

10.48 Application of the quantity standard to provision in specific settlements indicates the following:

• Loughborough – the bulk of additional plots required are in Loughborough (although this may be slightly misleading due to the proportion of students in the area), this is to an extent supported by the waiting lists at Borough Council owned sites

• Thurmaston – there are shortfalls of almost 3 hectares and there may be demand for over 100 plots

• Birstall – although provision falls below the minimum standard, shortfalls are lower than in other areas. Circa 16 plots would ensure that minimum standards were met. At the time of the open space audit, there were some spaces at existing sites although consultation at the Parish Council workshop indicates that there is now demand for additional provision

• Shepshed – provision exceeds the minimum standards although all existing allotment sites are full.

10.49 Accessibility mapping highlights that there is a good distribution of sites in the larger towns, with the majority of residents within the recommended 15 minute walk time of an allotment. The only significant area of deficiency is located in Thurmaston (see Map 10.3 overleaf), particularly in the North West of the village.

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Map 10.3 – Deficiencies in North West Thurmaston

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10.50 In consideration of the large quantitative shortfall in the larger settlements, there is a requirement for additional allotments in Thurmaston, as well as in Loughborough. Application of recommendation ALL1 will ensure that existing sites are able to accommodate more residents, but longer term, there may also be a need for additional provision in Shepshed and Birstall. Priority should be given to Thurmaston and Loughborough as provision in these areas is already below the recommended minimum quantity standard.

ALL4 Provide new allotments in Thurmaston and Loughborough. Monitor usage and latent demand for allotments in Shepshed and Birstall and provide new facilities where appropriate.

10.51 While focus should be placed on increasing the quantity of provision in the larger settlements it is also important to ensure that existing and future provision is in line with the recommended quality vision.

10.52 The quality of allotments in the larger settlements is lower than that in the other settlement hierarchies. 44% of sites were considered to be average and a further 38% poor. Great Central Road allotments (Loughborough) and Cambridge Street Allotments (Shepshed) were both rated as excellent. The key issues and areas for improvement for each site are provided in Appendix J.

ALL5 Improve the quality of the sites which do not meet the recommended minimum provision standard.

Service Centres

10.53 Quantitative analysis indicates that the current provision of allotments is just above the minimum standard. Despite this, residents in the service centres exhibit higher levels of dissatisfaction than in other areas.

10.54 Application of the standard to each of the service centres highlights shortfalls in the following towns:

• Mountsorrel – the highest levels of quantitative shortfalls are located in Mountsorrel, with a shortfall of circa 80 plots

• Syston (72 plots)

• East Goscote (38 plots)

(34 plots)

• Queniborough (30 plots)

• Anstey (15 plots).

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10.55 Provision of allotments exceeds minimum standards in Barrow upon Soar, Rothley, Rearsby, Quorndon and Hathern although existing provision is predominantly at capacity. Feedback at the Parish Council workshop indicated that there is demand for additional facilities at Barrow and in Rothley, despite provision exceeding the minimum standard. There are plots remaining in Quorn and a few plots at one site in Barrow.

10.56 Application of the accessibility standard indicates that the majority of residents have access to an allotment within the recommended accessibility standard. However, key areas of deficiency are evident in East Goscote, Queniborough and to the east of Mountsorrel (Maps 10.4, 10.5 and 10.6).

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Map 10.4 – Deficiencies in East Goscote

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Map 10.5 – Deficiencies in Queniborough

Map 10.6 – Deficiencies in the east of Mountsorrel

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Map 10.6 – Deficiencies to the East of Mountsorrel

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10.57 Consideration should therefore be given to increasing the provision of allotments in the service centres. Particular priority should be given to provision in East Goscote and Queniborough, where no residents have access to an allotment. In addition, the application of the accessibility standard indicates new provision should be made in south Anstey, south/ south western Syston and the south of Barrow upon Soar.

10.58 Application of recommendation ALL1 will ensure that existing sites are able to accommodate more residents, but longer term new provision should be considered in all areas where provision is indicated to be below the minimum standard.

ALL6 Provide allotments in East Goscote and Queniborough where there are currently no allotments. Provide new allotments in south Anstey, south/ south western Syston and the south of Barrow upon Soar. Monitor demand for new provision in Anstey, Rothley, Sileby, Syston and Barrow. Parish Council consultations suggest that demand already exceeds supply in these areas.

10.59 The quality of allotments in the service centres is only just above that of the larger settlements with 46% of sites rated average and 38% poor. Upper Church Street Allotments in Syston were rated excellent and Cemetery Road Allotments in Sileby were considered very good. The key issues and areas for improvement for each site are provided in Appendix J.

ALL7 Improve the quality of the allotments in the service centres using the quality standard as a guide.

Smaller Settlements

10.60 A total of 2.52 hectares of allotments is located in smaller settlements. Application of the quantity standards indicates that there is a current shortfall of 1.11 hectares spread across the settlements.

10.61 The current shortfall of allotments is equivalent to 44 plots and respondents to the household survey indicated dissatisfaction with the current provision. Therefore in light of the quantitative shortfall in the area and dissatisfaction with the current provision, opportunities to increase the provision of allotments should be considered.

10.62 Application of the quantity standard suggests that those settlements where existing deficiencies exceed 5 plots are:

• Cossington

.

10.63 The quantity standard suggests that provision in Woodhouse Parish and Wymeswold Parish is particularly high in proportion to the population, although almost all plots are taken.

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10.64 Of the smaller villages, analysis of access to allotments reinforces the application of the quantity standards, as it can be seen that Thurcaston and Newtown Linford are the largest settlements with no localised allotment provision (Map 10.1).

10.65 Demand for allotments in those smaller settlements where there is currently no provision should be evaluated and if demand is sufficient, support should be given to Parish Councils to provide new facilities.

ALL8 Consider opportunities to increase the provision of allotments in the Smaller Settlements. Assess demand for allotments within larger settlements, in particular Thurcaston and Newtown Linford where there is currently no provision and consider the location of new sites where demand is sufficient.

10.66 The quality of allotments in the smaller settlements is higher than the service centres and larger settlements. 20% of sites are excellent. Despite this, 20% of sites still achieved a poor rating. The key issues and areas for improvement for each site are provided in Appendix J.

ALL9 Improve the quality of allotments in Burton on the Wolds and Woodhouse Eves.

Summary

10.67 There are currently 34 allotment sites across Charnwood Borough Council. While many of these are located in the larger towns, Parish Councils also provide facilities in smaller and more rural settlements.

10.68 Consultation and analysis of waiting lists indicate that provision is insufficient to meet local demand and there are waiting lists exceeding 400 residents. It is clear that demand is increasing and the household survey demonstrated significant latent demand.

10.69 Application of the recommended accessibility standard (15 minute walk time) and the quantity standard highlight key priorities for new provision, in particular Loughborough, Thurmaston, East Goscote, Mountsorrel and Queniborough. Application of the quality standard suggests that there are 25 sites falling below the recommended minimum standard.

10.70 The key priorities for improving the provision of allotments over the Local Development Framework period therefore include the need to:

• ensure that allotments are protected from development through the Local Development Framework

• consider allocating new sites for allotments in the Local development Framework and ensure that contributions are required towards allotments as part of new development

• consider alternative management arrangements at existing sites to maximise the number of residents that can be accommodated

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• improve the quality of existing allotment sites in order to ensure that all sites are of adequate quality to meet the needs of local residents.

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