Other

Representation ID: 107982

Received: 07/03/2025

Respondent: Rainier Developments Ltd

Agent: 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

Representation ID: 108093

Received: 07/03/2025

Respondent: Seven Homes

Agent: 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

Representation ID: 108236

Received: 07/03/2025

Respondent: Persimmon Homes (South Midlands)

Agent: 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

Representation ID: 108253

Received: 22/06/2025

Respondent: Simon 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

Representation ID: 108288

Received: 07/03/2025

Respondent: Spitfire Homes

Agent: 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

Representation ID: 108470

Received: 06/03/2025

Respondent: The Bird Group

Agent: 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

Representation ID: 108532

Received: 07/03/2025

Respondent: Catesby Estates

Agent: 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

Representation ID: 108557

Received: 29/06/2025

Respondent: 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

Representation ID: 108595

Received: 07/03/2025

Respondent: Corbally Group (Harbury) Ltd

Agent: 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

Representation ID: 108642

Received: 07/03/2025

Respondent: Kiely Bros Holdings Ltd

Agent: 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.

Yes

Representation ID: 108752

Received: 19/03/2025

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: Savills

We support Draft Policy Direction 40 in principle, however we note that no evidence has been produced to date in support of the proposed “Greening Factor” mechanism. We consider that robust evidence will need to be provided to demonstrate that any proposed Greening Factor is feasible, deliverable and does not impact on the viability of sites when combined with other requirements placed on development such as Biodiversity Net Gain and the provision public open space.

No

Representation ID: 108840

Received: 07/03/2025

Respondent: Bellway Strategic Land-Land east of Stratford-on-Avon

Agent: Savills

We object to the proposed production of a ‘greening factor’. The SWLP notes that the ‘greening factor’ will be used to establish the level of green infrastructure required for major development. We consider that robust evidence will need to be provided to demonstrate that any proposed Greening Factor is feasible, deliverable and does not impact on the viability of sites when combined with other requirements placed on development such as Biodiversity Net Gain and Environment Net Gain the provision public open space. It is unclear whether the ‘greening factor’ will replace standard public open space requirements. Any requirement needs to be appropriately justified and evidenced (NPPF paragraph 36).

Yes

Representation ID: 108951

Received: 07/03/2025

Respondent: Warwickshire County Council

WCC supports this policy direction and glad welcomes the use of the sub-regional Green Infrastructure Strategy and the evidence base, if not a SPD in its own right.