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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.