A: Reference to ‘ancillary’ should be expanded/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.

B and C: Adjust the terms of the policy so that rational and effective location of horticultural and ancillary development outside the HDAs is not obstructed if alternative space remains within any of the designated HDA.

D: Modify the terms of criterion 5 to acknowledge that making most effective use of the designated HDAs for their intended purpose may have some landscape impacts, which should be accommodated here in order to protect the character of the wider undesignated landscape.

The Council’s recognition that existing horticultural HDA’s will be insufficient to deliver the quantum of development expected during the local plan period is welcomed and supported by evidence in the 2020 HEDNA and the attached Savills SREBR

However, the restrictive nature of the existing HDA policy is identified by stakeholders within the 2018 HEDNA (para 11.78) as having been a barrier to growth, whilst the importance of associated uses to the cluster is also acknowledged within The Council’s evidence base and other key Government and Industry publications. Landlink and Kingsbridge have identified in earlier representations that the restrictive terms of the current HDA policy have obstructed their ability to develop the function and productivity of the Food Park.

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.

Key failings of the soundness of the draft policy are:

A: The limitation that development should be new horticultural and ancillary development, which is defined at paragraph 7.29 of the draft plan, will perpetuate the obstruction to the realisation of growth which has occurred in recent years as a result of the restriction of uses within the HDA by the terms of the policy. The evidence base demonstrates a clear requirement for and clear economic benefits of co-location of food production, food processing and associated technology and logistics businesses to be able to fulfil market expectation, contemporary food business requirements, and to realise the effective resilience of food supply in the UK.

The evidence base for growth demand for non-horticultural business space relies upon visible past development from the approval and implementation of planning permissions. It fails to acknowledge the demands for business space that have not been realised specifically because they are obstructed by the adopted planning policy.

The main operators and businesses at Runcton HDA have been clear in representations over a number of years that the performance of the horticulture industry locally is constrained by the inability to modernise and co-locate functionally linked businesses and land uses at HDAs or in close proximity.

The effect of constraining the delivery of the business space needed to support the food and horticulture industry diminishes the viability and competitiveness of the industry on a national and international stage. The Savills SREBR identifies comparable evidence of the make up and productively of a food cluster in the East of England (Lincolnshire) where the benefits of co-location are being realised.

The adoption of a policy which continues to obstruct the realisation of a modernised food cluster in CDC for the life of the emerging plan would severely damage the prospects and productivity of the food industry in the District.

B: The requirement that land within the HDA should be used first (in advance of ‘other’ land’) to accommodate all forms of new horticultural development, albeit with caveats, does lack a progressive planned approach to the delivery of the range of development and infrastructure necessary, in the right locations, to realise the potential of the industry.

The Council’s approach to HDAs correctly acknowledges the hierarchy of HDAs with Runcton HDA a focus for large scale horticultural development. The terms of the policy imply that all of the allocated land in all four HDAs would need to have been saturated before development outside any one of the HDAs would be permissible. This would fail to acknowledge the specific locational needs of the operations and businesses occupying each of the HDAs and should be amended.

C: The requirement for development to demonstrate why it cannot be accommodated within the HDAs fails to take into consideration that the plan itself expects that approximately two-thirds of horticultural development across the Local Plan period will need to come forward outside of HDAs. Accordingly, the Council should plan positively for this growth by taking a sequential approach to horticultural development that includes provision for associated and functionally-linked development in the right way.

Associated and functionally linked development would include elements such as R&D, storage and distribution, linked office development and processing of the food produced in the area.

D: Criterion 5 seeks to preserve the rural character of the surrounding areas. However, the purpose of the HDAs designations at Runcton and Tangmere is specifically to accommodate and consolidate development at scale.

Developments previously granted consent at Runcton HDA have already created a general urbanised character. It is suggested that the Runcton HDA should therefore be the focus for associated horticultural development – a horticultural/food cluster or hub. By consolidating development in this form, the aim of preserving the amenity of the surrounding countryside may be better realised. This in turn may require that the core “growing” elements of the Runcton HDA are delivered in proximity to, but outside of, the HDA, and the land within the HDA focussing on the more intensive features of food production and functionally linked activity. Evidence shows that prioritising the siting of functionally-linked development within The Runcton HDA will encourage benefits associated with agglomeration and colocation. Please see attached Savills SREBR for more details.

Horticultural greenhouses are a core feature of Chichester coastal plain and therefore development of this type is likely to be deliverable without undue landscape harm.