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ID sylw: 107944

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

Rainier Developments support a Green Belt review. The Green Belt in South Warwickshire Topic Paper shows several of the best-connected settlements are within or surrounded by Green Belt. So are most train stations. Half the SGLs are within Green Belt. The Topic Paper is correct that Green Belt options should be considered to ensure development is suitably distributed and directed to the most sustainable locations and that a full Green Belt review is essential.

Exceptional circumstances as required by NPPF Paragraph 145 exist because of the significant number of homes required and limited capacity in existing settlements as evidenced by the Urban Capacity Study. NPPF Paragraph 146 states that exceptional circumstances include when authorities cannot meet their identified housing need through other means. The December 2024 NPPF introduced the concept of ‘grey belt’. Paragraph 148 states that where Green Belt land needs to be released, plans should give priority to previously developed land, then grey belt, then other Green Belt locations. The Council will need to follow this sequential approach when considering sites to release.

The Green Belt Review Stage 1 doesn't consider grey belt but concludes only 9 out of 113 parcels made a strong contribution to the Green Belt purposes. With over 100 parcels not strongly contributing towards these purposes, Rainier Developments would expect that a significant number of grey belt sites can suitably accommodate development. The next stage of the Review should draw clear conclusions on this. The Green Belt policy should make reference to Grey Belt and acknowledge that development in Green Belt can be appropriate if the Paragraph 155 criteria are satisfied. The ‘Golden Rules’ for residential development may also be referenced.

The draft Policy Direction suggests areas of land may be safeguarded to meet longer-term needs. This is supported, and would align with NPPF Paragraph 149(c). This could be for future needs of the South Warwickshire authorities, or those in the two Housing Market Areas they fall within. Further discussions and evidence-gathering is required to ascertain the level of unmet need in the HMAs. ‘Safeguarded land’ would be in addition to ‘reserve sites’ referenced in Policy Direction 4. These would meet the shorter-term needs of neighbouring authorities over the plan period, not beyond it.