7.29

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.

Para 11.66 of the 2018 HEDNA sets out the manner in which the document was informed by consultation with stakeholder. It says:

As part of our examination of the horticultural industry in Chichester we have approached most of the major employers seeking their views on the key drivers affecting the horticulture industry both nationally and locally and how these are expected to influence the future requirements of the industry within Chichester.

Para 11.78 of the 2018 HEDNA says:

Around half of the respondents believed that the industry would have grown at a much faster rate if it wasn’t for the restrictive planning issues placed on them by local government. They believed this went against government policy which aims towards greater food security and reduced food miles. It also goes against the commercial demands of the industry driven by supermarkets who want more production of every type of food.

The current HDA policy is acknowledged as a barrier to growth due to the failure to support functionally associated uses including food processing and associated logistics etc. The importance of uses that are functionally linked to flood production (a food cluster) is also acknowledged within The Council’s evidence base (2020 HEDNA) and other key Government and Industry publications.

Accordingly, the Plan should pursue a more positive and proactive wording of the HDA policy in order to allow for a greater breadth of functionally-linked uses within the Runcton HDA. The proposed wording of the policy does not provide sufficient certainty to investors and businesses (both established within Runcton 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 (refer to Savills SREBR).

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.

Refer to Savills SREBR para 4.2.9 in which the need for flexibility and co-location of functionally related development is explained.