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 attached Savills SREBR Report and the HEDNA 2018 both flag that the existing and proposed draft policy E4 do, and will continue to, constrain the future capability of the horticulture industry to grow and contribute to the local and UK economy, food resilience and carbon reduction ambitions

The importance of associated uses to the cluster is also acknowledged within The Council’s evidence base and other key Government and Industry publications.

Consolidation of horticultural and functionally linked development within the HDAs will facilitate growth and competitiveness, and reduce food miles.

Accordingly, it is suggested that the Council should pursue a more positive and proactive wording of the HDA policy in order to allow for a greater breadth of associated uses within the Runcton HDA. The proposed wording of the policy does not provide sufficient certainty to investors and businesses (both established within Ructon HDA or looking to locate within it) that The Council will support the functionally associated uses that are necessary to foster and maintain the growth and competitiveness of a world-class food cluster.

The Local Plan therefore conflicts with paragraph 81 of the NPPF in its entirety which states:

Planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future. This is particularly important where Britain can be a global leader in driving innovation 42 , and in areas with high levels of productivity, which should be able to capitalise on their performance and potential.