Yes

ID sylw: 106664

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

While the policy direction aligns with national planning policy, before deciding on the appropriateness of imposing a BNG requirement above the statutory 10% we requested that Council explore, and evidence, how this might impact on:
• the development capacity of sites when balancing other technical and environmental considerations (i.e. making best use of land, maximising densities and delivering sustainable development); and
• the viability of development proposals when the BNG requirement is considered cumulatively alongside other policy requirements (e.g. net zero carbon) and likely
planning obligations.
Draft Policy Direction 38 has the potential to add additional development costs that must be factored into the Viability Assessment produced with the Pre-Submission SWLP.

No

ID sylw: 106665

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Whilst we recognise that by incorporating natural capital into planning, local authorities can, in theory, make more informed decisions that balance development with environmental sustainability, we are concerned that this subject area needs to mature further before it forms a part of local planning policy.
Quantifying the value of natural assets and ecosystem services is widely recognised as being both complex and subjective, where different methodologies can yield varying results, making it difficult to establish a consistent valuation framework. Furthermore, accurate and comprehensive data on natural capital is often lacking, which can hinder the ability to make informed decisions and effectively integrate natural capital into planning. While also we believe that trying to simplify complex natural processes into models can lead to an oversimplification and misrepresentation of the true value and function of natural assets.
Instead of looking to introduce a policy requirement on Environmental Net Gain through the SWLP, the Councils should focus on successfully implementing other policies which seek to protect and enhance the natural and local environment, and for which a proven policy framework exists.

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.

No

ID sylw: 106667

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Whilst we acknowledge that integrating carbon sinks and sequestration into planning policy can be beneficial for mitigating climate change, it also presents several challenges. For example, accurately measuring and verifying the amount of carbon sequestered can be complex and resource-intensive, which can lead to uncertainties and inconsistencies in reporting. Furthermore, ensuring that carbon sinks, such as forests and wetlands, are maintained and managed effectively over the long term can also be challenging, especially when climate change can affect their ability to sequester carbon. We therefore consider that this policy requirement should not, at this time be taken forward in the SWLP.
If, however, the Councils do decide to pursue Draft Policy Direction-41, before any requirement is introduced that requires a net gain in carbon sequestration, the viability of doing so should be undertaken taking into account and factored into the Viability Assessment produced with the Pre-Submission SWLP.

No

ID sylw: 106668

Derbyniwyd: 05/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

While we support the general intent of Draft Policy Direction-42, we do not support the Councils intention that developers will be “expected” to increase tree canopy cover on sites that are the subject of a planning application. We consider that this will be unnecessarily burdensome for developers, especially when considered alongside other policy requirements in the emerging SWLP and consequently could impact on viability. Furthermore, this requirement would have negative implications in terms of a developers ability to increase densities on many sites and would not support an effective use of land in meeting the need for homes and other uses.
Instead of an increase in tree canopy cover on sites being “expected” , we feel it would be more appropriate if the SWLP simply stated that this would be “encourage” by the Councils.

Yes

ID sylw: 106669

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Agree with the approach laid out in Draft Policy Direction 43a

Yes

ID sylw: 106670

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Agree with the approach laid out in Draft Policy Direction 43b

No

ID sylw: 106671

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

We recognise that new development should ensure adequate provision of open space to meet the needs of future residents and that this should be provided on site in the first instance and then off-site, when it can be adequately demonstrated that on-site provision is not feasible. However, the requirement for an off-site contribution to enhance or provide new open space, within 400m of the development should be removed from the policy as there may be cases where there is simply no existing open space within distance threshold or it would not be practical to deliver new open space within the same area. For these reasons such a policy requirement would not be found “sound” at Examination.

Yes

ID sylw: 106672

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

Yes, we agree in principle with the approach laid out in Draft Policy Direction 43d. However in the absence of details as to what “adequate play provision” represents for new developments, we reserve the right to comment further on this matter when future guidance has been published .

Yes

ID sylw: 106674

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

We agree in principle with the approach laid out in Draft Policy Direction 43d but would like to see the policy set out an appropriate site area threshold which explains when developers will be required to provide space for food growing on a given site. We consider this to be an important consideration given that not all sites will be sufficiently large enough to provide a suitable area for food growing. Furthermore, to avoid the piecemeal delivery of new allotments, orchards, and community gardens the Councils should first prepare an overarching strategy to guide future delivery. The guide should not only set out details on the optimum size for new provision and design advice for their delivery, but should also highlight where new allotments are most needed, and what opportunities exist to expand and improve existing community allotments, via off-site financial contributions, as this is likely to be the preference in many cases.