Rules and Regulations – a letter and an inivitation to Glasgow Allotment Holders

Dear Glasgow Plotholders,

We think that the 17 page draft Allotment Rules and Regulations published by Sandy Paterson and his team on September 7th is both far too detailed and at the same time far too vague (see our analysis below).

We suggest that Glasgow City Council, given its commitment to engagement, should provide additional time for a proper consultation (extension to November 31st) which includes a face-to-face meeting open to all GCC plotholders and their committees. This meeting should allow plotholders the opportunity to clarify aspects of this proposal with the Food Growing Team and contribute to shaping the final version that goes forward for adoption.

We would like to invite you to an Open Meeting on Sunday October 22nd at the Garnethill Multicultural Centre from 11.45 am to 12.45 pm to discuss the issues that these draft  Rules and Regulations raise for Glasgow’s plotholders and their committees.

The GAF Committee

Download letter as a PDF to send to your fellow plotholders

The consultation link for a copy of the document is  where you will find it under Current Consultations

Our Analysis

On 7th September, Glasgow City Council sent an email to all allotment site members (tenants) with an invitation to review draft Allotment Rules and Regulations by filling in an online consultation form which closes on October 30th. The massive increase in bureaucracy proposed in the 17 pages of the draft Rules and Regulations is, in our opinion, likely to prove unworkable. This is not a document that tenants are going to find accessible or memorable.

What is proposed threatens to remove the autonomy of associations and plotholders to make the many of the day-to-day decisions and arrangements that are essential to running an allotment site. The draft rules and regulations propose that all plot allocations will be performed by the Council. This includes members moving plot within current allotment site in the case of downsizing,or moving from a raised bed to a plot. The allotment associations will have no involvement or oversight in this process, for example by ensuring that an available plot is suitable for a member.

Allotment associations will have no oversight of site waiting lists. There is no information about how the multiple waiting lists from each association will be integrated and migrated into a centralised list. Whilst it is recognised that a centralised list is important to measure demand for allotments, it is not clear how this list will be maintained. The process of allocating plots will be transferred to GCC but criteria for allocation (by proximity to the site, or the length of time on the waiting list, postcode/area of Glasgow, or the size of available plot) requires clarification.

Whilst the new R&R specify that every tenant must be a member of their site’s Association the role of the Association, other than co-ordinating tenants to do general maintenance on the site 9.2, is unclear. There’s a mention of delegated functions being agreed with an Association in 9.7 but no hint of what exactly these functions are likely to be. In relation to Inspections and Enforcement 16.1. and 17.1 mention is made of a person acting on behalf of the Council – its “appointed agent”.

Otherwise, almost all administrative decisions, however minor, will be reserved to the Council’s officers. For example, the draft R&R specify that tenants (and/or Association?) will have to apply to the Food Growing Team to build a shed/greenhouse on a plot, dig a pond, for additional keys to be cut, if they want to change their plot and so on and so on. 

In contrast to this detail about the tenants’ obligations the responsibilities of the Council are vague and imprecise, stating in section 5.3.1 that:

 “The services provided by, or on behalf of, the Council to the Allotment Tenants, which may include but is not limited to, site improvements, general repairs and maintenance, utility charges, arboricultural and grounds maintenance works, treatment of invasive species where necessary, treatment of vermin where necessary, waste uplift generated by reletting of plots, administration costs, and water provision where applicable.”

The legal responsibility of both the tenants and the Council should be made clear for each allotment site prior to any new rules being applied.

In a recent GAF survey, to which 15 sites responded, the dire record of communications between allotment sites and GCC was highlighted. The majority of sites reported unacknowledged/ unanswered emails about important health and safety issues on allotments, such as pest control, electricity, and sewage leaks. For some, trying to secure responses in relation to exclusions and terminations had been extremely stressful.

Recently, a 400% increase in rent for allotments was not communicated directly to allotment members, but instead emailed to association secretaries to distribute to members.

Due to a botched process, the involvement of allotments and their members in drafting these proposed rules and regulations, which will radically change the role of the allotment association, the management of plots and waiting lists, was at best tokenistic.

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