1.5

The Plan should be revised to forecast how climate change may alter land use planning requirements over the period of the plan and demonstrate how the Plan is sufficiently flexible to the changes which will occur albeit the timing of these changes are uncertain. As an example it is clear that some existing areas of housing in the Manhood Peninsular are very vulnerable to flooding due to storm surges. Climate change will bring an increasing risk of such events and some housing areas should be identified in the Plan for such displacement to take place.

While the Plan recognises climate change there is no forecast scenario of what climate the Plan is designed to cater for either in 2039 or any intervening years.

Support.

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.

Object- The proposed local plan has not been positively prepared and will fail to meet the economic needs of the Horticultural Industry. Specifically, the Regulation 19 Local Plan fails to take account of evidence that is critical to the Plan achieving the following criteria:

• Identifying the amount of development needed;
• Identifying development opportunities and infrastructure required to support and foster business enterprises and entrepreneurship;
• Providing opportunities to create new dwellings and jobs for present and future generations, with accessible facilities that support the needs of strong, vibrant and healthy communities;

The Horticultural Industry is a well-established and successful indigenous industry in the south of England. An especially high concentration of constituent elements of the industry are located within the administrative boundary area of Chichester District Council. Every effort should be made during the plan period to accommodate efficiencies that will foster economic growth and improve the competitiveness of the food cluster in the interests of promoting local economic growth and job creation as well as the resilience of the UK food supply. This will be achieved through ensuring that local development plan policies facilitate the expansion of the industry in terms of both land take (through planning policy allocations and subsequent development management decisions), as well as providing an environment in which associated elements of the food cluster (such as research development, logistics and distribution and linked administrative functions) can thrive (this will be achieved through the flexible wording of planning policy and subsequent decision making by development management).

The economic potential of the horticultural industry in Chichester is clearly acknowledged in the Council’s evidence base, including the 2018, 2020 and 2022 HEDNAs, Government reports and various industry reports. Accordingly, these representations assert that the findings of these research reports, in addition to a custom piece of research on Runcton HDA (Produced by Savills Economics Research (Savills SREBR), have not been but must be incorporated in full into the Council’s Local Plan submission to the Secretary of State in order to demonstrate that the Local Plan submission meets the definition of ‘sound’ as outlined within paragraph 35 of the NPPF.