Reference to ‘ancillary’ with regard to the HDAs in relevant policies and supporting text should be modified to 'functionally linked' and include explanatory text clarifying that 'functionally linked' uses can include a range of activities including: food-related distribution; food manufacturing linked to the HDAs food preparation; on-site renewable energy to serve on-site activities; and R&D.

The Coast to Capital Local Economic Partnership (LEP) acknowledge the specific and important contribution of horticulture to the economy of CDC. In accordance with Savills representations in respect policy E4 and the supporting text, the council’s approach to restraint of the draft LP on development that is functionally linked to the horticultural industry within or close to the designated HDAs will suppress the productivity and prosperity of the industry and thereby its significant contribution the wider local economy.

The 2020 HEDNA predicates future growth of the horticultural sector on past planning consents and developments, which does not fully account for the demand for functionally linked activities as CDC have not been granting consents for these.

The 2022 HEDNA [para 80] identifies that Chichester’s industrial market is severely undersupplied. However the HEDNA does not adequately assess the scale of suppressed demand and make allowance for it in industrial allocations. Whilst the LP seeks to provide office, factory and warehouse space (110k to 117k sqm), the likely insufficient supply and competition in the market will mean that there is no certainty that this space would be available and/or sufficient to meet the immediate and future needs of the horticultural/food production industry, constraining overall growth in the sector.

Savills SREBR report (attached) identifies that the constraint on co-locating functionally-linked forms of development at Runcton HDA will have a negative impact on the strength, diversity of the CDC economy.

The restrictions of policies of E3 and E4 with regard to the range of uses permissible in the HDAs means that the opportunity to maximise carbon reductions by co-locating associated functions of the food chain is lost - refer to para 4.4.2 of Savills SREB report.