Other

ID sylw: 107982

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments 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: 108093

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

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.

No

ID sylw: 108236

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

This policy direction encourages green and blue infrastructure (GBI) and proposes a Greening Factor for South Warwickshire, through which GBI will be delivered. 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 a degree of support for this policy, as 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 meeting the Greening Factor. Therefore, the policy is justified to an extent, in encouraging GBI, however, the need to impose a numerical Greening Factor which must be met lacks justification, with such a requirement not being explicitly recommended within the evidence, raising questions as to whether it is needed. 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, and no clarity is provided on what the approach would be in a scenario 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. In any case, it is imperative for the Greening Factor threshold to be reasonable and for there to be a degree of flexibility, so that this policy tool does not risk rendering developments unviable, due to having to cede potentially substantial amounts of otherwise developable land for much-needed homes 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 all this needs to be carefully considered by the Councils moving forward.

No

ID sylw: 108253

Derbyniwyd: 22/06/2025

Ymatebydd: Sovereign Man Simon of the family Thomas

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, in line with the NPPF and in time to influence chosen housing sites in the Local Plan.

Other

ID sylw: 108288

Derbyniwyd: 07/03/2025

Ymatebydd: Spitfire Homes

Asiant : Harris Lamb

Draft Policy Direction 40 has the potential to add additional development costs that must be factored into a viability assessment produced with the Pre-Submission SWLP. In order for this Policy to be included in the Plan the Councils must have an understanding of the impact of this Policy on scheme density, the net to gross development ratio of schemes, and the overall scheme costs.

Other

ID sylw: 108470

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

In principle, we support the approach laid out in Draft Policy Direction – 40 and the use of the Greening Factor planning tool to ensure that existing and new GBI is considered and integrated into the scheme design from the outset. The Bird Group 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.

Yes

ID sylw: 108532

Derbyniwyd: 07/03/2025

Ymatebydd: Catesby Estates

Asiant : Mr Will Whitelock

Catesby Estates support the approach laid out in Draft Policy Direction 40. The Vision Document and Illustrative Masterplan for land east of Banbury Road, Southam show that the majority of existing landscape features, including hedgerows, will be retained and enhanced. The proposal will also deliver new public open space, recreational routes and a community orchard. Alongside their principle function, the SuDS will form an integral part of the development's green infrastructure, providing ecological benefits and habitat creation.

No

ID sylw: 108557

Derbyniwyd: 29/06/2025

Ymatebydd: Hayfield Homes

It is considered that the proposed requirement to produce a “Greening Factor” for an area is unduly onerous and should be deleted from Policy Direction 40.

No

ID sylw: 108595

Derbyniwyd: 07/03/2025

Ymatebydd: Corbally Group (Harbury) Ltd

Asiant : Pegasus Group

This policy direction encourages green and blue infrastructure (GBI) and proposes a Greening Factor for South Warwickshire, through which GBI will be delivered. 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 a degree of support for this policy, as 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 meeting the Greening Factor. Therefore, the policy is justified to an extent, in encouraging GBI, however, the need to impose a numerical Greening Factor which must be met lacks justification, with such a requirement not being explicitly recommended within the evidence, raising questions as to whether it is needed. 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, and no clarity is provided on what the approach would be in a scenario 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. In any case, it is imperative for the Greening Factor threshold to be reasonable and for there to be a degree of flexibility, so that this policy tool does not risk rendering developments unviable, due to having to cede potentially substantial amounts of otherwise developable land for much-needed homes 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 all this needs to be carefully considered by the Councils moving forward.

Other

ID sylw: 108642

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 40 – Green and Blue Infrastructure
10.7.
This policy direction encourages green and blue infrastructure (GBI) and proposes a Greening Factor for South Warwickshire, through which GBI will be delivered. 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 a degree of support for this policy, as it refers to 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 meeting the Greening Factor. However, the need to impose a numerical Greening Factor which
must be met lacks justification, with such a requirement not being explicitly recommended within the evidence, raising questions as to whether it is needed. The Greening Factor requirement must be justified for the policy to be sound.
10.8.
The policy direction makes no reference to how and where green infrastructure can be delivered to meet the Greening Factor, and no clarity is provided on what the approach would be in a scenario 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.
10.9.
It is imperative for any Greening Factor threshold to be reasonable and for there to be a degree of flexibility, so that this policy tool does not risk rendering developments unviable, due to having to cede potentially substantial amounts of otherwise developable land for much-needed homes 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 have not been justified through the Reg 18 Plan, and if to be promoted through the Reg 19 version, should be subject to the plan viability exercise, as they have the policy has the potential to materially add to development costs, especially for non-residential uses.