Chichester Local Plan 2021 - 2039: Proposed Submission

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

Modify paragraph to acknowledge that the development requirements of the horticultural industry have evolved over time and these need to be accommodated going forward.

The horticultural policy has remained largely static since over many years and has failed to acknowledge changing working and production trends within the industry.

Whilst the Council’s tradition of supporting the horticultural industry, to the extent that it has and proposes to do in the draft Local Plan, is welcomed, it should be acknowledged that the restrictive policies that have been in place to date have directly obstructed growth in the industry by constraining the ability of the HDAs to accommodate ancillary and functionally-linked land uses that are now essential to realise the growth potential of the food cluster.

The draft Local Plan currently fails to allow for the functionally linked and associated development required to support and maintain the competitiveness of a world-class horticultural cluster.

See Section 4 of the Savills SREBR for further detail.

The importance of the horticultural industry should be recognised within policy E1 to inform the provision of land for functionally-linked employment uses in the right locations.

The centrality of the horticultural industry to providing sustainable economic growth within the Chichester District and the wider south of England is not acknowledged within Policy E1. This is contrary to the Council’s evidence base, with the 2020 HEDNA stating that the Local Plan will need to ensure that ‘the District’s horticultural industry remains nationally and internationally competitive’ for the duration of the Local Plan period.

The lack of connectivity between the provision of employment land under Policy E1 and the needs of the horticulture industry for well-located land for functionally-linked employment purposes will have the effect of suppressing the ability of the horticulture industry to meet its 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.

Soundness test not fully met. The draft plan does not adequately allow for suppressed demand. Consequently, the option for HDA associated uses to locate on industrial land is restricted. However, our analysis concludes that most such uses are best located on the HDAs. Which requires a more flexible approach to functionally linked uses on the HDAs.

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 Coast to Capital Local Economic Partnership (LEP) acknowledge the specific and important contribution of horticulture to the economy of CDC. In accordance with Savills representations in respect policy E4 and the supporting text, the council’s approach to restraint of the draft LP on development that is functionally linked to the horticultural industry within or close to the designated HDAs will suppress the productivity and prosperity of the industry and thereby its significant contribution the wider local economy.

The 2020 HEDNA predicates future growth of the horticultural sector on past planning consents and developments, which does not fully account for the demand for functionally linked activities as CDC have not been granting consents for these.

The 2022 HEDNA [para 80] identifies that Chichester’s industrial market is severely undersupplied. However the HEDNA does not adequately assess the scale of suppressed demand and make allowance for it in industrial allocations. Whilst the LP seeks to provide office, factory and warehouse space (110k to 117k sqm), the likely insufficient supply and competition in the market will mean that there is no certainty that this space would be available and/or sufficient to meet the immediate and future needs of the horticultural/food production industry, constraining overall growth in the sector.

Savills SREBR report (attached) identifies that the constraint on co-locating functionally-linked forms of development at Runcton HDA will have a negative impact on the strength, diversity of the CDC economy.

The restrictions of policies of E3 and E4 with regard to the range of uses permissible in the HDAs means that the opportunity to maximise carbon reductions by co-locating associated functions of the food chain is lost - refer to para 4.4.2 of Savills SREB report.

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 acknowledgement of the importance of the horticultural sector to Chichester District Council’s administrative area is welcomed.

The horticultural industry is capable of supporting higher value jobs in areas such as research and development as well as associated business functions. This is however constrained by the current and proposed wording of the Council’s horticultural policies E3 and E4 which inhibits the economic potential and competitiveness of the industry.

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 states that the need to support economic activity in rural parts of the plan area. Under the Council’s policy maps, the Runcton HDA would be located within the Countryside.

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 of the economic significance of the horticultural industry in the Chichester District and beyond is welcomed.

The attached Savills SREBR Report and the HEDNA 2018 both flag that the existing and proposed draft policy E4 do, and will continue to, constrain the future capability of the horticulture industry to grow and contribute to the local and UK economy, food resilience and carbon reduction ambitions

Consolidation of horticultural and functionally linked development within the HDAs will facilitate growth and competitiveness, and reduce food miles.

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 attached Savills SREBR Report and the HEDNA 2018 both flag that the existing and proposed draft policy E4 do, and will continue to, constrain the future capability of the horticulture industry to grow and contribute to the local and UK economy, food resilience and carbon reduction ambitions

The importance of associated uses to the cluster is also acknowledged within The Council’s evidence base and other key Government and Industry publications.

Consolidation of horticultural and functionally linked development within the HDAs will facilitate growth and competitiveness, and reduce food miles.

Accordingly, it is suggested that the Council 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.

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 declaration of a climate emergency is welcomed, however there is an opportunity to better align this the Council’s economic strategy within the Local Plan.

Supporting the growth of the horticultural industry to include functionally linked uses, such as food processing/production and consolidated storage and distribution capabilities within the HDA, would allow for greater food production on site. This in turn would allow for greater home grown food production and export to the rest of the UK. Accordingly, there would be a reduction in food miles as home-grown food consumption would increase. This would lead to a reduction in greenhouse gas emissions.

Refer to Savills SREBR para 4.4.2 – effective storage and distribution hub at Runcton HDA would achieve reduction in food miles by 84000 per annum