Chichester Local Plan 2021 - 2039: Proposed Submission

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

The Council’s acknowledgment of the site’s location, situated within the best location for transport connections, is welcomed. The site should therefore be considered suitable for delivering economic growth, comprising increased production, processing, storage and distribution of products to the rest of the UK as well as internationally. This is as a result of site’s proximity to the A27 and subsequent ease of access to the rest of the County’s nationally significant highway network..

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 Runcton HDA is home to a number of the most high performing horticultural operations in the south of England. These businesses are well-established and are capable of supporting sustainable and continued economic growth. This in turn will benefit the wider horticultural sector in the South. The current and proposed HDA policies do however act as a barrier to economic growth.

The current HDA policy is acknowledged within the 2018 HEDNA 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.

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 associated uses, such as food processing/production and increased storage and distribution capabilities, 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.

A wording of the HDA policy that facilitated the colocation of functionally linked elements of the food cluster would reduce the greenhouse gas emissions associated with the industry through reduce vehicular trip generation –
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

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 desire to support the horticultural industry is welcomed, however the mechanism for delivering this growth is fundamentally flawed and bakes in unwarranted constraints to realising the growth and competitiveness of the food production industry. Please refer to attached Savills SREBR.

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

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 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.

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.

In order to remedy the undersupply of commercial property within the district, and ensure that the Chichester food cluster continues to provide economic growth and job creation, The Council should allow for the siting of functionally linked developments within the Runcton HDA. This is currently prohibited by the wording of draft Policy E4 which only allows for ancillary developments rather than the suite of development uses required to support a world class food cluster. This would provide investors and businesses with the certainty required to continue to invest within the Chichester District. Furthermore, the colocation of such developments would provide a range of benefits associated with agglomeration including reduced costs, reduced greenhouse gas emissions and increased innovation arising from knowledge spillovers.

Chichester has a highly constrained commercial property market that has an extremely low vacancy rates, along with generally high rents. This is recognised within the Council’s evidence base, with the 2022 HEDNA describing the district’s commercial property market as ‘extremely undersupplied’. It is not considered that the employment allocations proposed within the Local Plan will address this substantial unmet need and indeed a number of the employment land allocations are not preferentially sited relative to the Runcton HDA.

This undersupply of commercial property, taking account of the allocation and the trajectory of delivery and availability of premises at Land south of Bognor Road, is likely to continue to have a significant impact upon the ability of the Chichester food cluster to meet the industry’s requirement for functionally linked commercial premises that are necessary to maintain competitiveness. This requirement for functionally linked operations such as R&D, storage and distribution and office space is detailed in a number of industry reports.

Recognition of the sustainable location of the Runcton HDA.

Provides ability to promote renewable energy source on or adjacent to HDA to support horticulture and functionally linked development.

It is therefore suggested that the Local Plan states that development associated with horticulture coming forward in the Runcton HDA, or within the setting of the Runcton HDA, should be assessed against the Policy E4 of the Local Plan as opposed to Policy NE10.

The Council’s evidence base and Policy E3 acknowledges that substantial land outside of the proposed HDA’s will be required to meet the needs of the horticultural industry. This is welcomed.

The Runcton HDA, and surrounding land, is located outside of any settlement boundary area and is therefore defined as countryside by the Local Plan. In such a situation it is acknowledged that Policy NE10 would apply.

A number of the criteria of policy NE10 are not consistent with policy E4 of the Local Plan. It is therefore suggested that the Local Plan states that development associated with horticulture coming forward in the Runcton HDA, or within the setting of the Runcton HDA, should be assessed against the Policy E4 of the Local Plan as opposed to Policy NE10.

The policy needs to recognise that the density of development will need to increase within the Runcton HDA during the plan period and the Council should proactively plan for this in order to maintain the economic momentum of the Chichester food cluster.

The reference to making the most efficient use of land is recognised. The policy does however need to recognise that the density of development will need to increase within the Runcton HDA during the plan period and the Council should proactively plan for this in order to maintain the economic momentum of the Chichester food cluster. The need to increase density will assist in addressing the conclusions within the Council’s evidence base that substantial land will be required outside current HDA’s to meet the industry’s needs. Increased densities will reduce the industry’s land requirements, whilst also maintaining the countryside and ensuring economic growth.