BASE HEADER

No

ID sylw: 106439

Derbyniwyd: 05/03/2025

Ymatebydd: Porterbrook Mid Leasing Company

Asiant : Planning Prospects

Draft policy direction 40 sets out to ensure that existing and new green and blue infrastructure (GBI) is considered and integrated into scheme design from the outset. It says that the functionality, accessibility and quality of existing open space should be reviewed and increased wherever this is possible and suggests that one mechanism to ensure that GBI is delivered is to produce a ‘greening factor’ for an area. It explains that a greening factor is a planning tool used to improve the provision of green infrastructure in an area. When applied to a development site, it provides a threshold for the total area of a site which is expected to be covered by an element of GBI. It is proposed that the GBI policy will provide a green factor for development across the south Warwickshire region and will provide direction in line with: • different greening factors will be calculated for major residential development, minor residential development and commercial development. This is to take into account of the significant pressure major residential development places on existing GBI • the delivery of a greening factor on a site must be based on a baseline assessment of existing GBI, demonstrating that high value assets have been retained and enhanced where appropriate. This must be supported by the submission of a long-term maintenance plan for major developments. The draft policy direction suggests that a site’s BNG contribution will also count towards the overall greening factor of a site and ecological enhancements will be expected to be delivered in line with findings of the listed evidence-based documents and designations. Whilst further work is noted, and required, to develop any greening factor framework, the draft policy direction seeks to deliver an additional policy layer (and burden) and duplicates other policy requirements, including around BNG (in particular). As such, at the very least, flexibility is necessary to deliver any GBI policy requirement as it will not be necessary or justified for all development.
Proposals (including major investment sites for example – which may include policy support for expansion and intensification but whose expansion and intensification would require use of land that is currently ‘green’ or ‘blue’). Additionally, Porterbrook’s response to draft policy 38 (BNG) highlights that the current requirement for a minimum of 10% BNG is already a significant barrier for some development proposals to achieve, and in some cases makes development unfeasible and unviable. With this in mind it would not be justified or effective for the swlp to require a further policy requirement in the form of a GBI policy. In conclusion, the suggested GBI policy direction represents an unnecessary duplication of local (draft) and national policy, and legislation. As such it is not justified or effective.