Bath Voice News: Deadline to respond to Combe Down Allotments Consultation extended to Tuesday 16 April as campaigners urge supporters to use their DIY guide to respond

By Harry Mottram: the campaign to save the Combe Down Allotments from being developed for housing has reached a critical point as a consultation with residents is set to close this week. The Council are considering an application for to make the allotments into a Local Green Space under their Local Plan. This will give the allotments some protection against the belief that the owner of the land wants rid of them so as develop the land.

The consolation has been extended to Tuesday 16th April at 5pm – and the campaigners are asking residents and supporters to respond to the consultation. To help the public supporting their campaign they had given a useful DIY response that will ensure your views are taken into consideration and hopefully lead to the allotment holders to continue growing fruit and vegetables for another 130 years.

Jacky Wilkinson of the Bath Allotments Association (AA) wrote this introduction to the guide on how to respond to the Council: “The Association has made a number of Local Green Space Nominations but not all of these have been supported. The Association has also made representations to strengthen the wording of policies and to increase their coverage to currently un-protected sites.

“Now that the Council has declared Climate and Biodiversity Emergencies, the Association is asking for your support so that allotments are recognised and protected for their contribution to well-being, tackling climate change and increasing bio-diversity and community cohesion. Combe Down Allotments (also known as Church Road Allotments). This 130 year old Combe Down site is especially important historically and socially as well, as a testimonial to the everyday lives of generations of Combe Down workers and their benefactors.

“The reasons why it has been turned down for Local Green Space designation are complex but the need for it is pressing. This site is under immediate and real threat. A full briefing note has been prepared by the AA to help explain the complexities.”

The consultation document can be found here:

How to register your responses/comments: The AA has suggested some words for you to use and given links to the relevant paragraphs. We would like you to comment in two places. However, you are urged to read the Options and use your own words. This consultation is not like a petition -the number of responses is less important than what they say. Keep it short. Representations can be made in writing. Information is given at the end of this note.

START YOUR RESPONSE TO THE REJECTION OF THE DESIGNATION COMBE DOWN AS A LOCAL GREEN SPACE HERE: 1st Response: Go to this link to Local Plan Options Consultation on the Council’s website:

Scroll down. Choose the “Your response” box.

Suggested response – make sure you include the paragraph numbers. 9.329. The Combe Down allotments site was accepted in-principle for the Place Making Plan in 2015, but was withdrawn at a late stage with no in-depth examination of the issues. New evidence from the Allotments Association now justifies a full re-examination of those issues.

9.334 – 9.337. Combe Down should be included in the list of supported designations because it is an historic site which has been an important community asset for 130 years. It is under real and immediate threat. The maximum level of policy protection is urgently needed. The community has shown its grave concern and is preparing an application to have it listed as an Asset of Community Value. A petition has attracted over 5,300 signatures.

Policy LCR 8 (Protecting allotments) coverage of the Combe Down allotments site is welcomed, but is not strong enough to protect the plotholders from eviction. No other site is currently identified within the area which is available to replace it, or to satisfy the increased demand on the waiting list.

The Minerals Policies will protect the Bath stone resources under the allotments for the very long term. Retaining the site as allotments is the best way of protecting the Bath stone below ground and the biodiversity above. The adjacent Rugby club is also covered by the same Minerals Policy. It is also protected by policy as a sports facility, and it is in the Green Belt. Green Belt status has the same effect as Local Green Space designation, so Local Green Space designation on the allotments would be no different.

2nd Response: To Support strengthening Policy LCR.8 (Protecting Allotments). Go to this link to Local Plan Options Consultation on the Council’s website:

Tick the Strongly Support Box. Scroll down to the Extra Comments Box.

Add: Unless the wording of Policy LCR 8 (Protecting allotments) is strengthened, it is not strong enough to protect the plotholders at Combe Down from eviction. No other site is currently identified within the area which is available to replace it, or to satisfy the increased demand on the waiting list.

Landowners/developers should be required to provide a replacement or new high quality allotment sites within the area, not just pass money to the Council. Currently there are long waiting lists in Bath, but the Council is unable to find new sites.

How to send your comments by post

If you prefer to submit your comments on paper, please follow these steps:

• Read the sections you want to comment on

• Write your comments, using a separate piece of paper for each new Site or Policy Option.

• State clearly on each separate comment which paragraphs of the Local Plan Options document your comment refers to.

• Attach any additional printed documents or evidence to the comment it refers to, and also write the paragraphs you are referring to on the document.

• Mail your comments to the address below, leaving plenty of time to make sure they arrive before the closing date (16 April):

• Planning Policy, Bath and North East Somerset Council,  Manvers Street, Bath BA1 1JG

Please note that email responses or feedback that isn’t linked to individual Policy and Site Options will NOT be accepted. If you need to ask any questions please text me first on 07969 785929 (What’s App) or email me on  Jacky Wilkinson, Bath Allotments Association.

In a letter to Bath Voice the AA wrote: “Almost all allotments (including those in private ownership) within Bath are already designated as Local Green Space. A previous nomination in 2015 by the Bath Allotment Association to designate the Combe Down Allotments as a Local Green Space (LGS) was accepted, so there can be no “in-principle” reason why Combe Down Allotments should not be so designated. However, the 2015 LGS nomination for the site was removed from the Place Making Plan at the last minute. The Council stated that there had been an oversight, and gave the reason that there would be a conflict between LGS status and the Minerals safeguarding policies which also covered the site. This was a hasty decision and no in-depth examination was made at that point.

“A second LGS nomination was made by the Allotment Association as part of the New Local Plan June 2024 consultation. It is also recommended to be turned down, for the same reason. The consultation also states that as the matter has been subject to full examination, the Council does not intend to revisit the issue. The Bath Allotment Association contends that no such full examination ever occurred. It is in the interests of fairness, that the nomination should be fully examined in this round of designations and this is where you can help.”

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