BASE HEADER

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.