Yes

ID sylw: 103712

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Kineton Road, Wellesbourne

Asiant : Turley

Richborough generally supports Draft Policy Direction 40 “Green and Blue Infrastructure” however the introduction of a “Greening Factor” for the area needs more clarification and justification. The policy needs to include further detail on how such an approach would work in practice before stakeholders can provide a robust response.

Other

ID sylw: 103713

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Wellesbourne Road, Wellesbourne

Asiant : Turley

Richborough generally supports Draft Policy Direction 40 “Green and Blue Infrastructure” however the introduction of a “Greening Factor” for the area needs more clarification and justification. The policy needs to include further detail on how such an approach would work in practice before stakeholders can provide a robust response.

Yes

ID sylw: 103716

Derbyniwyd: 07/03/2025

Ymatebydd: Richborough - Plough Lane, Bishop's Itchington

Asiant : Turley

Richborough generally supports Draft Policy Direction 40 “Green and Blue Infrastructure” however the introduction of a “Greening Factor” for the area needs more clarification and justification. The policy needs to include further detail on how such an approach would work in practice before stakeholders can provide a robust response.

Yes

ID sylw: 103984

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Amarjit Gill

It is very important to support the existing local area

No

ID sylw: 104021

Derbyniwyd: 07/03/2025

Ymatebydd: Ms Camille Newton

Green and Blue infrastructure will be important to consider within any development, however this strategy should have already been considered as part of the process of selecting sites for strategic growth and housing. It is crucially important that this be considered with some urgency and in line with NPPF so that sites are chosen which have the least impact on the existing green and blue infrastructure.

No

ID sylw: 104166

Derbyniwyd: 07/03/2025

Ymatebydd: Mrs Clare Kimpton

Again this seems small scale and not updated by current knowledge

Yes

ID sylw: 104271

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Stephen Norrie

It sounds like a potentially useful instrument, and it is good to know it derives from Natural England.

Yes

ID sylw: 104462

Derbyniwyd: 07/03/2025

Ymatebydd: South Warwickshire Foundation trust

We agree and support this approach

Yes

ID sylw: 104685

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Neal Appleton

Actual green space (eg a park) should take priority over constructed green space (eg a green roof). The benefits of the former exceed those of the latter.

Yes

ID sylw: 104848

Derbyniwyd: 07/03/2025

Ymatebydd: Miss Ann Colley

agree, expansion is required of the existing open spaces, areas of natural beauty.

No

ID sylw: 104871

Derbyniwyd: 07/03/2025

Ymatebydd: Dr Susan Hood

It is unclear how this will deliver wider connecting corridors which are more substantial than the proposed small scale on-site improvements. The councils should update their Green/Blue Infrastructure evidence base, in line with the NPPF and in time to influence chosen housing sites in the Local Plan.

Yes

ID sylw: 105015

Derbyniwyd: 07/03/2025

Ymatebydd: Ms Susan Ingleby

Yes

Yes

ID sylw: 105033

Derbyniwyd: 07/03/2025

Ymatebydd: Fern Arnold

I agree with the GBI and greening. This is essential for 30 by 30.
Also don't allow new housing on flood plains

Other

ID sylw: 105786

Derbyniwyd: 07/03/2025

Ymatebydd: Wates Developments Ltd

Asiant : Savills

We support Draft Policy Direction 40 in principle, however we note that no evidence has been produced to date in support of the proposed “Greening Factor” mechanism. We consider that robust evidence will need to be provided to demonstrate that any proposed Greening Factor is feasible, deliverable and does not impact on the viability of sites when combined with other requirements placed on development such as Biodiversity Net Gain and the provision public open space.

Yes

ID sylw: 106376

Derbyniwyd: 07/03/2025

Ymatebydd: West Midlands Housing Association Planning Consortium

Asiant : Tetlow King Planning

The WMHAPC agrees that integrating existing and new Green and Blue Infrastructure (GBI) is important in order to support sustainable residential growth.
We also support the approach that a site’s BNG contribution will also count towards the overall Greening
Factor of a site. The WMHAPC recommend that the Councils provide further guidance on how GBI will be implemented and measured.
The WMHAPC advises that this draft policy is viability tested to ensure that it does not hinder the delivery of affordable housing in SW.

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.

Yes

ID sylw: 106666

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

In principle, we support the approach laid out in Draft Policy Direction – 40.We do, however, have several concerns:
• Presently it is not clear what is actually required in terms of a “baseline assessment of existing GBI” to demonstrate that high value assets have been retained and enhanced where appropriate; no specific guidance is provided or referred to.
• There is also ambiguity over when the submission of a long-term maintenance plan for major developments is required; we would not support any requirement for such information to be provided at the Outline Planning Application stage.
• In order for this Policy to be included in the Plan, the Councils must have an understanding of the impact of this Policy on the net to gross development ratio of schemes and by default scheme densities.
• Draft Policy Direction 40 also has the potential to add additional development costs that must be factored into the Viability Assessment produced with the Pre Submission SWLP.

Other

ID sylw: 106902

Derbyniwyd: 06/03/2025

Ymatebydd: Historic England

Historic England is supportive of the integration of GBI into new and existing development and we consider that the Local Plan should also recognise the value of the historic environment in contributing to the multi-functionality of GBI via cultural heritage, recreation and tourism, through assets such as historic parks, gardens and canals.

Yes

ID sylw: 106954

Derbyniwyd: 03/03/2025

Ymatebydd: Coventry and Warwickshire ICB

The ICB is supportive of draft Policy Direction-40 Green and Blue Infrastructure (GBI) which recommends that new development will ensure that existing and new GBI is considered and integrated into the scheme design from the outset.

No

ID sylw: 106982

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

We object to the proposed production of a ‘greening factor’. The SWLP notes that the ‘greening factor’ will be used to establish the level of green infrastructure required for major development. We consider that robust evidence will need to be provided to demonstrate that any proposed Greening Factor is feasible, deliverable and does not impact on the viability of sites when combined with other requirements placed on development such as Biodiversity Net Gain and Environment Net Gain the provision public open space. It is unclear whether the ‘greening factor’ will replace standard public open space requirements. Any requirement needs to be appropriately justified and evidenced (NPPF paragraph 36).

Other

ID sylw: 107019

Derbyniwyd: 07/03/2025

Ymatebydd: Cherwell District Council

DTC RESPONSE:

Green Infrastructure
We note your approach to green infrastructure and would encourage recognition with your Local
Plan of the green infrastructure links with Cherwell.
We hope you find the above comments constructive and look forward to our continuing on-going
engagement in the progression of the next stages and finalisation of your South Warwickshire
Local Plan and our Cherwell District Local Plan (2042).

Yes

ID sylw: 107085

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Yes, the Cotswolds National Landscape (CNL) Board agrees with the approach outlined in Draft Policy Direction 40.
We are pleased to see that Draft Policy Direction 40 is underpinned by Natural England’s Green Infrastructure Framework.

Other

ID sylw: 107181

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

Draft Policy Direction 40 for green and blue infrastructure will cover many of the same broad areas with similar goals. Care must be taken to ensure each policy area is distinct and has its own clearly delineated and monitorable aims and objectives that do not duplicate each other.

Yes

ID sylw: 107220

Derbyniwyd: 06/03/2025

Ymatebydd: Catesby Estates

Asiant : Mr Will Whitelock

Catesby Estates are supportive of the approach laid out in Draft Policy Direction 40. As shown on the Vision Document (Appendix 2) and Concept Masterplan for Land South of Allimore Lane, Alcester, it is proposed to retain and enhance the route of Spittle Brook through the Site with a green and blue infrastructure corridor. It is proposed to create two large wet grassland areas along the Spittle Brook Local Wildlife Site, accommodating wetland scrapes and wildlife ponds to provide net gains in biodiversity and to provide multiple ecological benefits.
SuDS will also form an integral part of the development’s green infrastructure, providing ecological benefits and habitat creation, as well as performing their principal function of controlling and managing the flow of surface water run-off during periods of heavy and persistent rainfall.
7.6 The proposals will deliver a number of landscape benefits, including new Public Open Space, play facilities, recreational routes and a community orchard. New planting will include parkland and avenue tree planting as well as native tree belts.
Therefore, the proposals for Land South of Allimore Lane, Alcester demonstrate that green and blue infrastructure can be incorporated into development in many forms.

Yes

ID sylw: 107366

Derbyniwyd: 06/03/2025

Ymatebydd: National Trust

Green and Blue infrastructure – Many of the National Trust’s places are integral to South Warwickshire’s green and blue infrastructure (GBI) network, particularly the extensive walks across countryside between Packwood House and Baddesley Clinton, across Charlecote Park and the extensive parkland of Farnborough Hall. The National Trust are supportive of the acknowledgement by the Local Plan that GBI provides multiple benefits, including providing habitats for wildlife, enhancing health and wellbeing outcomes in an area by providing space for recreation, and building resilience to a changing climate including flood control and preventing urban heat islands.
We are pleased that the Local Plan identifies the risks that new development presents for GBI, particularly in respect of increased numbers of residents in an area as a result of housing growth, which can exacerbate pressures on existing areas of green space. This can reduce tranquillity and availability of space, weakening its recreational value, and it can have negative impacts on on-site biodiversity due to increased levels of disturbance and disruption to habitat connectivity. We therefore would expect new development to incorporate proposals for open space and green infrastructure within the development site to ensure that this contributes towards the existing GBI network but also protect existing open space and recreational sites from excessive use and the associated recreational impact that would result from it.
In respect of the regional park proposals, whilst we thoroughly support the measures to maintain and enhance the green infrastructure network, we would recommend that the 8 Hills Regional Park is referenced in this policy and designated on the Policies Map as land to the north west of Forshaw Heath Lane. We consider that this would both strengthen South Warwickshire’s green infrastructure network and present an opportunity to enter into a partnership with a governance structure for the Regional Park and engage in a cross-boundary relationship when it comes to truly integrated green infrastructure for the benefit of people and nature across the West Midlands conurbation and beyond.
We are supportive of policy direction 40 and consider that many policy directions set out within the draft Local Plan (preferred options consultation) will contribute towards the successful achievement of a strong GBI network, including LNRS, BNG and the protection of habitats and species.

No

ID sylw: 107389

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Wildlife Trust

No. It is unclear how this will deliver wider connecting corridors which are more substantial than the proposed small scale on-site improvements. The councils should update their Green/Blue Infrastructure evidence base to include ambitious new areas shown on the map, in line with the NPPF and in time to influence chosen housing strategies and chosen sites in the Local Plan.
It is not enough to rely on general GI strategies that don’t set out ambitious new areas.

Yes

ID sylw: 107468

Derbyniwyd: 05/03/2025

Ymatebydd: Temple Grafton Parish Council

Fully support

No

ID sylw: 107759

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

We object to the proposed production of a ‘greening factor’. The SWLP notes that the ‘greening factor’ will be used to establish the level of green infrastructure required for major development. We consider that robust evidence will need to be provided to demonstrate that any proposed Greening Factor is feasible, deliverable and does not impact on the viability of sites when combined with other requirements placed on development such as Biodiversity Net Gain and Environment Net Gain the provision public open space. It is unclear whether the ‘greening factor’ will replace standard public open space requirements. Any requirement needs to be appropriately justified and evidenced (NPPF paragraph 36).

No

ID sylw: 107861

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This policy direction encourages green and blue infrastructure (GBI) and proposes delivery through a Greening Factor for South Warwickshire. Various Greening Factor requirements are to be calculated for different types of development, and BNG will contribute towards the Greening Factor of a site. The Warwickshire, Coventry & Solihull Sub- Regional Green Infrastructure Strategy (August 2024), which is part of the evidence base, provides some support for this policy. It refers to seizing opportunities to introduce landscaping, trees/woodland, green roofs, and allotments, all of which are listed in the policy direction as features which can contribute towards the Greening Factor. The policy is justified to an extent, in encouraging GBI. The need to impose a numerical Greening Factor lacks justification, as this is not explicitly recommended within the evidence. The Greening Factor requirement must be justified for the policy to be sound.

The policy direction makes no reference to how and where green infrastructure can be delivered to meet the Greening Factor. No clarity is provided on what the approach would be where the developer is unable to provide sufficient green and blue infrastructure on site. If this policy is taken forward, the Councils must confirm whether off-site provision would be acceptable, adopting a similar locational hierarchy to BNG, and whether financial contributions are an option. It is imperative for the Greening Factor threshold to be reasonable and to allow a degree of flexibility so that it does not risk rendering developments unviable due to ceding potentially substantial amounts of otherwise developable land to provide green infrastructure, which may be surplus to requirements. Proposals should be considered on a case-by-case basis. Overall, the policy direction and the Greening Factor seem poorly thought through and this needs to be carefully considered by the Councils moving forward.

Other

ID sylw: 107888

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

The Draft Policy Direction sets out the intention to apply a “Greening Factor” to major development, this is considered to be akin to a net gain policy, specifically targeted at environmental enhancements. This ultimately repeats Draft Policy Direction 39 and therefore they aren’t considered to both be necessary.
Any additional Green Infrastructure requirement should be considered in respect of the existing nature of the site and site constraints.
Clarity on how the greening factor will be calculated for an area should be provided and the methodology for developing this should also be consulted upon as part of the emerging plan.