Consider allocating Land at Tangmere Apron for housing should housing requirement for Tangmere increase.

This representation is made on behalf of our client, West Sussex County Council who wish to raise objection to the continued allocation of land within their ownership for horticultural development under Policy E3 of the draft Local Plan. The site is edged in red on the attached plan (dated 06-02-2014).
Site
The site is situated to the South of the main settlement of Tangmere and relates to an open area of brownfield land previously used as the apron for RAF Tangmere airfield. As a result of this previous use, the site comprises a large flat area of concrete. Most recently, the site has been rented out by our client to the NHS, who used it as a COVID testing centre.
The site borders residential development along its Northern boundary, which also provide a number of opportunities for access. Extensive areas of greenhouses are located to the East of the site, and the fields to the South of the site are in agricultural in use. The site has no planning constraints, other than being outside of the Settlement Policy Boundary and partly covered by the Horticultural Development Area (HDA).
Policy E3 Assessment
Policy E3 of the draft Local Plan sets out that there is a need to support the growth of horticultural industry within the plan area, which requires 204ha of additional land over the plan period. It sets out that large scale horticultural development will be focussed within the HDAs at Tangmere and Runcton.
We are of the view that the site is wholly unsuitable for horticultural use, as a result of it being hardstanding, but principally due to its proximity to residential properties and the only likely suitable use being for additional greenhouses. The significant light spill from such a use would harmful to neighbouring amenity and would not therefore be a suitable use of the land. When viewed within the Agricultural Land Classification maps, the site can be seen to be classified as ‘Other land primarily in a non-agricultural use’.
The site was submitted within the most recent HELAA, and has been considered developable for employment uses, and potentially developable for residential uses. Should the housing requirement for Tangmere increase, we ask Chichester District Council to consider allocating Land at Tangmere Apron for housing, as in accordance with the NPPF, brownfield sites should be considered ahead of greenfield. At present, it represents an area of under-utilised brownfield land, which will not find functional purpose in agricultural / horticultural use due to its concrete top and proximity to residential properties. The site represents a greater opportunity for allocation in alternate uses. Part of the site is already outside of the HDA. The site adjoins the adopted settlement policy boundary to its North, and therefore it is clear it relates well to the existing settlement.
In visual terms, the site is unsightly, and untidy, which is incongruous in comparison to the residential uses directly adjacent to the Northern boundary of the site, and the open, undeveloped nature of the land to the South of the site. Potential development of the site provides opportunity to provide a softer transition between the hard settlement edge and open countryside, through a landscape led development at the site. This could significantly soften the edge of the settlement, where currently it is abrupt and stark when viewed from the south.
We therefore ask that Chichester District Council consider removing the Horticultural Development Area (HDA) designation currently affecting part of the site for the reasons set out above. The site adjoins the settlement policy boundary to the majority of its Northern boundary, and can be considered as an area of brownfield land. Therefore, in line with the NPPF, its development should be considered ahead of greenfield land. Further, the site is currently of a poor visual quality, and any development would provide the opportunity to enhance and soften the edge of the settlement.