What we'd like the Council to do next

Risk Assessment

The first thing we'd like the Council to do is undertake a proper risk assessment of the contamination found on the site.

As the Minister for Environment and Agri-Environment says Ministerial and the Council's own Contamination Officer agrees Steve Moreby email, the CLEA figures are "guideline values" to be used as "intervention levels". This means that the Council is under a statutory obligation to take action if there is evidence of the levels being exceeded. In the case of the Town Ham elevated levels of certain contaminants were found. However the Minister points out "it seems unlikely that every allotment with an elevated level of a contaminant faces closure or expensive remedial work. In some cases further risk assessment may lead to the conclusion that no intervention is needed"

Other local authorities we have contacted who have had to deal with allotments registering above the CLEA 2002 guideline figures for contaminants have dealt with it in similar ways.

Camden Newcastle Spennymoor

By doing a complete risk assessment, using the latest technologies such as bio-availability testing, these authorities have been able to show that the level of risk was low enough to be almost beyond measure. Intervention and remediation were then able to be pitched at an appropriate level - providing 'washing stations' and advice about supervision of children etc..

You can read more about bio-availability testing here:
British Geological Survey
Geoenvironmental Research Centre

Types of Remediation

Initially we were encouraged by the officers of the Council to research funding for remediating the soil. We were led to believe that 'remediation' in the case of contaminated land meant 'dig and dump' (remove the old soil and replace with clean). This is an extremely expensive way to tackle contamination (especially as the Government is committed to an EU target to progressively reduce the amount of land available for landfill over the next decade). It is now only considered viable where potential revenues greatly outweigh the costs (e.g. new housing on highly contaminated land). 'Dig and dump' is not an option for allotment land except in the most extreme cases (Newcastle City Council did replace the soil on one site - with special outside funding and they were able to develop half the site for housing to recover costs).

In our investigations however we discovered that the latest technique for risk assessment in these circumstances is submitting the soil to a 'bio-availability' test. In the laboratory, soil is subjected to treatment which models the human gut, the products of this test can then be analysed to show how much of the contaminant is 'available' to be metabolised.

It is likely that in the case of the Town Ham contamination it is at such a level (similar to other cases) that no risk is involved in continuing to use the land for vegetable growing. A proper assessment would prove this one way or the other.

Costs

When we were considering the option of 'dig and dump', costs were in the region of 'hundreds of thousands'.

Bio-availability testing is a laboratory procedure developed precisely to provide an inexpensive answer to the question we have to deal with here, "How dangerous is this soil to human health?" Also, these costs may not fall to the Council. As the Minister said in his letter, "If remediation is required, and costs fall to an authority, they can apply to my Department for support under the Contaminated Land Capital Projects programme and the City are aware of this."

Why the Council must act

The Council's own policy on allotments Policy May 04 as recently as May this year, restates its commitment to allotments and notes that:

1. Gloucester is under-provisioned with allotments as per its statutory duty
2. Westgate, the City Centre and Linden are particularly badly off as regards provision (now virtually non-existent with the shutting of the Town Ham)
3. Occupancy is high and rising on the City's sites (although, as we discovered when we tried to find one of the '15 empty plots' we were assured existed on the Escourt Road site and then found there was only 1, occupancy may be higher than the Council figures state)
4. There is no money to buy land to create new allotments that are required.

To this might also be added that the population of Westgate, as an example, is set to rise by a third in the near future as extra housing is built. In the City centre much of this will be 'apartment' style - i.e. no gardens. So demand in an already 'allotment lite' area of the City is about to grow dramatically. As the Council's planning rules state:

Policy A1 – New Housing and Allotments
Planning permission will only be granted for new housing developments of 30 units or more that provide an allotment site to the Council standard of 0.2 hectares (½ acre) per 1000 residents. The City Council will consider the payment of commuted sums for the provision of allotments off-site where it is not feasible on-site.

With 3000 new residents planned in Westgate alone, where are the Council thinking the new one and a half acres of allotments are going to be created? The Council can consider the 'payment of commuted sums' if on-site provision of allotments is not feasible - is this not perhaps a source of revenue which could be used regenerate the City's allotments? For example, where is the allotment provision envisaged for the housing proposed at 'St. Oswalds's Park' (the old Cattle Market site)?

The City cannot afford to lose such a valuable resource as the Town Ham Allotments at such a time.