What is a call for sites?
A ‘call for sites’ gives landowners and agents the opportunity to let us know that they are interested in having some or all of their land considered for development or redevelopment. This is important to the plan making process as we need to identify land to tackle some of the issues we have highlighted before.
We ran a ‘call for sites’ alongside the ‘issues and options consultation’. All sites received, plus others identified by officers from other sources (as set out in the Planning Practice Guidance) have been assessed and considered – see below.
How have submitted sites been considered?
261 sites were considered as part of the Housing and Economic Land Availability Assessment (HELAA) which is published alongside the consultation.
Following the HELAA process - which eliminated sites that already have planning permission, are too small, are not available, or are subject to “showstopper” constraints - the number of sites under consideration was reduced to 112 potentially suitable sites.
These 112 sites were visited by officers and subject to more detailed transport, landscape, ecology, heritage and infrastructure analysis drawing on advice from Warwickshire County Council and external advisers. This process led to a shorter list of potential site options.
How have the proposed allocation sites been selected?
Following the assessment process outlined above, the final list of potential site options was then used to identify options for growth scenarios. The reasonable alternative growth scenarios are detailed in the Sustainability Appraisal report which is be published alongside the Preferred Option Consultation Document.
The proposed allocations are the sites we think best support the plan objectives and preferred development strategy.
Why is more housing not proposed on brownfield/previously developed land?
The use of brownfield land is given substantial weight in the National Planning Policy Framework, which encourages “..as much use as possible of previously developed or brownfield land” (paragraph 124).
The Preferred Option strategy does incorporate some brownfield housing allocations, such as two within the town centre boundary (see interactive map). However, there are not sufficient brownfield sites (based on the site assessment and selection outlined above) available to accommodate the amount of housing we must plan for up to 2045.
Why are sites in the Green Belt identified for housing allocations?
National policy advises that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified.
For housing, there were a relatively limited number of reasonable site options put forward/identified that could in combination deliver the necessary number of new homes. Advice received from Warwickshire County Council was that site allocations would need to be able to deliver a new secondary school to meet anticipated future needs. That school should be in the north of Rugby.
It would be possible to deliver the necessary additional housing land outside of the Green Belt if land promoted at Lodge Farm between Dunchurch and Daventry, which could deliver 2,680 homes overall with an estimated 1,800-2,000 by 2045, were to be allocated. This option is not favoured because of concerns about deliverability, infrastructure and risk that arises from allocating another large strategic site to meet the bulk of the residual housing need. It is also not favoured because it would not deliver a secondary school in north Rugby.
Furthermore, a pattern of concentrating housing on a further very large site, with no more housing allocated in the borough’s main rural settlements except for the non-Green Belt villages of Clifton upon Dunsmore and Dunchurch does not represent a sustainable pattern of development.
Overall, in combination these factors constitute exceptional circumstances which justify alterations to Green Belt boundaries.
Why are sites in the Green Belt identified for employment allocations?
Site options were put forward which could deliver the requisite employment land without the need to release Green Belt land. In particular, land on the A5 north of Houlton, land accessed from the A5 opposite Magna Park and land around Thurlaston.
Nonetheless exceptional circumstances are considered to exist justifying Green Belt release for the following reasons:
1) The need for strategic employment land is regional in nature. The functional economic market area (FEMA) in which Rugby Borough lies is centred on Coventry, as detailed in the Housing and Economic Development Needs Assessment (HEDNA) 2022. Coventry is the largest population and economic centre in the FEMA and so provides the deepest labour pool. Coventry City Council itself, because of land constraints, is only able to allocate one strategic employment site for 25ha. Absent of Green Belt constraints, a sustainable approach would allocate employment land close to Coventry as the main population and economic centre in the FEMA. By contrast, avoiding the Green Belt would necessitate only allocations which would be distant from Coventry and its labour force. This does not represent a sustainable approach.
2) The existing site at Ansty Park and the cluster of sites at Prologis Park Ryton, Middlemarch Industrial Estate, Coventry Gateway and Coventry Airport comprise regionally important mixed R&D, industrial and distribution locations. Allocating for expansion here has clustering and agglomeration benefits which would support more higher-skilled jobs and expansion in high value-added industries. These conditions are not replicable in more distribution-focussed locations along the A5 north of Rugby.
3) The site at Ryton could deliver a 55ha country park which is contiguous with the existing country park west of the Avon and would also link with Ryton Pools Country Park. No other site opportunity can deliver habitat creation on this scale. This supports the Corporate Strategy objective for a greener Rugby.
Changes to Green Belt boundaries are also proposed to remove the existing Ansty Park and Prologis Park, Ryton-on-Dunsmore from the Green Belt, for consistency.