Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Support

Representation ID: 682

Received: 02/02/2026

Respondent: Torbay Council (Statutory / General Consultation Body)

I recognise that sport and physical activity are priorities for the Government because they support public health, social inclusion, regeneration, and reduce anti-social behaviour. Sports facilities are essential for sustainable and healthy communities and should be integral to development planning. Torbay's 2022 Playing Pitch Strategy covers pitch sports, tennis, and bowls, but does not assess pools, sports halls, or tracks. An updated strategy is needed to align with NPPF requirements for comprehensive indoor and outdoor sports facilities.

Support

Representation ID: 984

Received: 29/01/2026

Respondent: Torbay Council (Statutory / General Consultation Body)

We strongly welcome the plan’s intention to provide new burial land, but we ask that the delivery mechanism be made as robust as possible to ensure suitable sites are allocated promptly and not diverted to other uses.

Support

Representation ID: 985

Received: 29/01/2026

Respondent: Torbay Council (Statutory / General Consultation Body)

The commitments in the draft plan to active and sustainable transport as well as reducing demand for private car use are extremely welcome. These will tend to reduce vehicle emissions even if air quality is not explicitly included as a reason for this policy. The results of our ongoing air quality monitoring is published in the Annual Status Report, which is available here Air quality - Torbay Council. The data shows that although all locations in the Bay currently meet the legal standards for local air quality,
this is only by a small margin at Kings Ash Road. There is almost no capacity for transport emissions on this road to increase without levels breaching the legal limit.
This would result in the Council having to declare an Air Quality Management Area and produce an Air Quality Action Plan. We believe that an acknowledgement of this situation should be included in the Local Plan because it has the potential to impact not only on the health of those living along this route but also on the reputation of the Council and the deliverability of significant areas of housing.

Support

Representation ID: 986

Received: 29/01/2026

Respondent: Torbay Council (Statutory / General Consultation Body)

As acknowledged in the draft plan, the focus on brownfield regeneration will mean that land contamination investigations and risk assessments will need to be undertaken at an early stage, so that the impact of any contamination on the viability and deliverability of the scheme is understood.
However I would suggest that the wording of Policy ER5 could be improved in places as follows:
I would remove the references to precautionary measures. This is not a term used in land contamination guidance and could cause confusion. (Land contamination risk
assessment processes as described in the EA guidance are inherently precautionary, so mention of further caution is unnecessary).

Bullet point 2 refers to the need to avoid risk to health which suggests that developments will be zero risk. This is potentially unachievable, or uneconomic and would rarely be ‘sustainable development’. I would recommend using wording from NPPF or the Planning Practice Guidance here instead to describe what level of risk will be considered acceptable. For example you could say that sites must be suitable for their intended use and as a minimum not be capable of being determined as
contaminated land under Part IIA of the Environmental Protection Act 1990.

Paragraph 8.92 contains more detail on some specific elements of the risk assessment process than is required. This ignores many of the complexities involved and is arguably unnecessary given the amount of authoritative guidance available. I would recommend simplifying this paragraph to just state that the land contamination reports submitted to the Council will be expected to follow current, UK-specific guidance such as the Land Contamination Risk Management guidance from the Environment Agency.

This paragraph also suggests that land contamination reports will be required for all major applications. I would suggest that this is amended both in the policy and the
explanation to reflect question 14 of the full planning application form. This says that an appropriate risk assessment is required where either:
 The land is known to be contaminated, or
 Contamination is suspected for all or part of the site, or
 The development is for a proposed use that would be particularly vulnerable to the presence of contamination.

Support

Representation ID: 987

Received: 29/01/2026

Respondent: Torbay Council (Statutory / General Consultation Body)

I’m sorry if I have missed it, but I could see no reference to impacts on neighbourhood amenity during the construction phase of any development. These can be significant, particularly as a result of noise, vibration and dust. Would it be possible to include a brief paragraph somewhere appropriate to explain that conditions will be used to manage these impacts so far as is practicable?

Support

Representation ID: 988

Received: 29/01/2026

Respondent: Torbay Council (Statutory / General Consultation Body)

There can often be trade-offs between the benefits of these technologies and their impacts on noise pollution, amenity and neighbours. Would it be sensible to include text on how these trade-offs will be navigated? (or would these be covered by Policy CER4?

Support

Representation ID: 989

Received: 29/01/2026

Respondent: Torbay Council (Statutory / General Consultation Body)

Policy W5 requires that new development must not compromise the operational effciency and environmental impact of the works. Does this include preventing development very close to the site? Or would other policies implementing the ‘agent of change’ principle be sufficient to prevent development in areas that may impact on the ability of the works to operate?

Support

Representation ID: 990

Received: 29/01/2026

Respondent: Torbay Council (Statutory / General Consultation Body)

Policy M1 bullet 9 seems contradictory. It requires that unavoidable noise, dust and particle emissions should be controlled, mitigated or removed at source. If they can be
controlled or removed at source, they are presumably avoidable (and should be avoided!). Could this section be re-worded to be a little clearer?

Support

Representation ID: 1003

Received: 02/02/2026

Respondent: Torbay Council (Statutory / General Consultation Body)

Sport is fundamental to the delivery of healthy, inclusive and sustainable communities. National policy places significant emphasis on the role of supporting public health, social cohesion, regeneration and the reduction of anti-social behaviour. It is therefore essential that sports facilities are fully integrated within the planning and development process.

Maximising investment in sport and recreation through the planning system is a key principle of Torbay’s adopted Playing Pitch Strategy. The Strategy seeks to protect sports facilities from loss through redevelopment, enhance existing provision by improving quality, accessibility and management, and deliver new, fit-for-purpose facilities capable of meeting current and future demand. Therefore, there would be strong objection to the loss of any existing sports land or buildings, including playing pitches.

While Torbay’s Playing Pitch Strategy addresses pitch sports, tennis and bowls, there is currently no current assessment covering other key facilities such as swimming pools, sports halls and track provision. It is recognised to meet the requirements of the National Planning Policy Framework (NPPF), the Council should ensure that supply and demand across all types of sports provision are robustly assessed and kept under regular review. The NPPF promotes sustainable development, it also provides vital clear protection for open space and land used for sport and recreation, including playing fields.
Such land should not be developed unless it has been clearly demonstrated that it is surplus to requirements, that equivalent or better provision will be provided in a suitable location, or that alternative sports or recreational provision would deliver benefits that clearly outweigh the loss.

Consideration should also be given to the continued use of standards in determining the provision of sports facilities, including playing pitches. Whilst standards can assist in quantifying demand arising from development, they may present risks if applied without an up-to-date and locally relevant evidence base.

The use of planning obligations (Section 106) and the Community Infrastructure Levy (CIL) is strongly supported as a means of securing the provision of new or enhanced sports facilities, together with contributions towards their ongoing maintenance, where needs arise from new development.

Residential development within Torbay during the plan period should contribute towards new provision or the enhancement of existing sports facilities, in order to increase opportunities for physical activity and deliver positive health and wellbeing outcomes.

Active Design extends beyond active travel alone. Active Design has an important role in improving health and wellbeing, supporting climate change objectives and encouraging active travel, including walking and cycling.
However, Strong support the Active Design principles to encourage development to be designed to secure sustainable and health-promoting environments. This approach may be demonstrated through the use of the Active Design checklist.