1.37

This is a comment only

There has been no further public consultation on the preferred approach since 2018/19, four years have passed since this time. The issues that were raised during that consultation are still relevant today, and have not been addressed within the new proposed Plan. The reduction in housing numbers in the revised plan does not adequately reflect the challenges and constraints of the infrastructure issues, particularly waste water treatment and the A27. The impact on sensitive landscapes has not been properly addressed, with 1,600 houses proposed on the Chichester Harbour AONB boundary without active engagement with Chichester Harbour Conservancy over the impact (particularly the allocated site A11 at Highgrove Farm, Bosham.

The inspector should investigate how many people's comments were deleted. Given the amount of responses they actually acknowledge, the plan should have been re-consulted on before the S19 consultation.

Some of my comments from the Preferred Approach consultation were deleted by the planning authority without warning. I only spotted this when I went back to see what I had written to help someone else with another matter. Their reason being that they 'thought they were a duplication' of comments written in another section. This was not the case - related points were linked by reference to each other but each was individually written and included proposed modifications to the wording.

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

It is welcomed that the Regulation 19 Local Plan has responded positively to the representations made previously by Kingsbridge Estates and Landlink Estates insofar as the Runcton HDA has now increased in terms of land allocation.

To realise the benefits of the HDAs in accordance with contemporary food production and distribution practices, the Council also needs to pursue a more positive and proactive wording of the HDA policy within this Regulation 19 consultation to allow for a greater breadth of associated 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.

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.

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.

See attached representation.