The setting of minimum densities is good practice – but what about maximum densities? There are some allocated sites proposing a density of around 200 dwellings per hectare, which is without precedent in Norwich and is well above the London average for new housing approvals, which was 154 dph in 2015/16. Either a policy on maximum density, or a requirement for developments above a certain density to be subject to greater scrutiny, would help to ensure that new housing is compatible with a good quality of life for residents.


It is regrettable that higher water efficiency standards cannot be set, and I hope the Greater Norwich councils will continue to lobby government for an update to the regulations. I welcome the provision for higher standards to be adopted when this becomes possible. An explicit commitment to lobby for this change would be a welcome addition.

I welcome the increased ambition on sustainable energy compared to the Growth Options consultation. There could still be room for more ambition.
The plan claims that moving towards carbon neutral buildings is ‘unviable’ - but not doing so will render the buildings themselves unviable by the end of the plan’s lifetime, requiring a massive retrofitting programme at far greater expense than if the buildings were future-proofed at the outset. We should not be allowing new builds with little renewable energy provision and poor energy efficiency. More exploration is needed of how Greater Norwich can do better on this.
While the NPPF is not supportive of onshore wind, local authorities should be doing their best within these constraints to enable this cheap and popular form of energy to thrive. Could a framework be developed for areas working on a neighbourhood plan, encouraging them to explore the potential for onshore wind and guiding them on how to ensure proposals are acceptable to the community? Cornwall Council produced a renewable energy planning advice document in 2016 which is a useful reference point for this.
Salford’s local plan provides a good example of how renewable energy can be more explicitly supported within the constraints of government policy.

I would like to see the addition of a policy on supporting local food growing, which can contribute to climate change objectives, access to green spaces, health and wellbeing, community cohesion and the local economy.
While there are well-established local and national policies on allotments, these do not cover other forms of community food growing. Additional allotment space can be difficult to provide in densely developed urban areas; and it is important to note that allotment waiting lists do not tell the whole story about demand for growing space. They reflect only the demand from people already interested in food growing, whereas community growing often brings in new people. Community food growing spaces are located very close to where people live, and offer a more significant social element. Many people who might be interested in growing are unable to take on the significant commitment of running an allotment. Finally, projected increases in the number of households are likely to mean housing is built at higher densities and fewer houses will have private gardens, meaning that more people will potentially be looking for access to growing space.
There are a number of local authorities which have successfully supported community food growing through the use of planning policy, including Bristol, Lambeth, and Brighton & Hove. A policy could, for example:
require new developments of five or more dwellings to make provision for food growing on site, with the level of provision commensurate with the scale of development. This could include facilities for rainwater harvesting and composting of food waste;
include a question on food growing provision in pre-planning application questionnaires;
encourage schools, healthcare facilities and office developments to consider providing space for food growing;
encourage the innovative use of space for food growing, such as structurally suitable green roofs and green walls;
seek the inclusion of productive plants such as fruit trees in all new landscaping proposals, as an additional source of easily available healthy food.