Chichester Local Plan 2021 - 2039: Proposed Submission

We welcome the acknowledgement of related facilities.

It is therefore suggested that Policy E4 of the local plan allows for development associated with the horticultural industry to come forward within HDA designations in order to comply with the objectives of Policy T1 of the Local Plan and in the interests of minimising congestion and vehicular movements.

Conflict with restrictions of policy E4 and associated text.

The Council’s desire to ensure that new development is well located and designed to avoid and minimise the need for travel is supported as stated within Policy T1. Minimising transport movements on the A27 corridor is particularly critical given the acknowledged constraints of the corridor (ref. policy T1)

This is in direct conflict with the wording of policy E4 of the Local Plan which allows for horticultural development and ancillary development only. This policy wording would seek to require associated development, such as office space and storage and distribution uses, to be located within settlement boundary areas or other established employment sites. The siting of associated functions within these locations would increase the number of vehicular journeys associated with the industry.

It is therefore suggested that Policy E4 of the local plan allows for development associated with the horticultural industry to come forward within HDA designations in order to comply with the objectives of Policy T1 of the Local Plan and in the interests of minimising congestion.

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.

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.

Objection: The plan has not been positively prepared and will not meet the needs of the horticultural industry and accordingly fails to take the opportunities available to deliver economic growth and create local jobs.

The national significance of the horticultural industry is acknowledged in paragraph 2.6 of the Coastal West Sussex and Greater Brighton Local Strategic Statement for Delivering Sustainable Growth 2015-2031. Accordingly, the Chichester Local Plan will need to ensure that the competitiveness of the industry is maintained.

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.

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

Paragraph 8 of the NPPF recognises an economic objective as one of the three core tenets underpinning achieving sustainable development.

The failure to allow for functionally linked development within the Runcton HDA that could not reasonably be construed as ancillary development, would unduly constrain the economic potential of the horticultural industry within the Chichester District. The development and siting of associated and functionally linked businesses within the Runcton HDA would support the continued creation of local jobs and assist at providing employment opportunities that meet the needs of the residents of the dwellings planned to be delivered within the Local Plan period.

The correlation between the draft allocation 20 for business development to locate at Land South of Bognor Road and Runcton HDA offers no guarantee that land or premises within that allocation would be suitable for, or become available at the right time, to perform a complimentary function for the Runcton HDA.

Amend text to qualify circumstances in which development is permissible outside the HDA.

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 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.

Please see Savills SREBR for more details

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.

Reference to ‘ancillary’ in the first paragraph of the policy should be replaced with '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 word ‘ancillary’ has proven, over the lifetime of the current adopted local plan, to be restrictive on the ability of the food production businesses at Runcton HDA to undertake beneficial development that would facilitate growth, competitiveness and market-responsiveness. The evolution of the sector, and the expectation of the onward consumer, is increasingly dependent upon co-location of the functions of food production.

The wording of paragraph 7.28 does not take into consideration the need to deliver associated and functionally linked development to support the continued growth and competitiveness of the Chichester Food Cluster located at Runcton HDA.

The current HDA policy is acknowledged within the 2018 HEDNA and the attached Savills SREBR Report as a barrier to growth due to the failure to support functionally associated uses. The importance of associated uses to the cluster is also acknowledged within the Council’s evidence base and other key Government and Industry publications.

Accordingly the Plan should incorporate a more positive and proactive wording of the HDA policy in order 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 Ructon 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 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.

Reference to ‘ancillary’ in the first paragraph of the policy should be expanded/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.

Policy E3 does not adequately take into consideration the need to deliver associated and functionally linked development to support the continued growth and competitiveness of the Chichester Food Cluster located at Runcton HDA.

The current HDA policy is identified by stakeholders in the 2018 HEDNA and the attached Savills SREBR Report as a barrier to growth due to the failure to support functionally associated uses. 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 plan should pursue a more positive and proactive wording of the HDA policy in order 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 Ructon 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 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.