7.24

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 Council’s recognition that existing horticultural HDAs will be insufficient to deliver the quantum of development expected during the local plan period is welcomed.

The implied 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.

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. This could generally be focused in the HDAs.

This in turn may require that the core “growing” elements of the Chichester Food Cluster are delivered in proximity to, but outside of, HDAs. It is notable however that 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. Additionally, prioritising the siting of associated development within the HDAs will encourage benefits associated with agglomeration and colocation. Please see Savills SREBR for more details