Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Object

Representation ID: 2618

Received: 28/01/2026

Respondent: EEESafe Ltd

Strategic Policy WS: Waste spatial strategy (Draft Plan pp. 296–297)
Policy reference: Strategic Policy WS: Waste spatial strategy (pp. 296–297).
Draft Plan link:
https://www.torbay.gov.uk/media/2dgles4b/draft-torbay-local-plan-2025-45.pdf
Issue:
The Plan commits to maximising the "value" of household resources, but does not clearly define delivery mechanisms that keep value local, reduce unnecessary transport, and evidence outcomes at community scale.
Justification:

Local delivery routes matter – without explicit support for local reuse and repair delivery, resources can flow out of the area via centralised models, weakening local economic resilience and increasing transport impacts.
The Plan already frames "value" broadly – social, environmental and economic – so it is proportionate to add wording that enables measurement and local retention of those benefits.

Proposed change:
Add a new paragraph to WS:
“The Council will support place-based circular economy delivery models that retain value locally through repair-first approaches, safer local reuse and refurbishment, and that can evidence household and community-level outcomes (including material savings, safer homes, emissions reductions and local economic benefit).”

Object

Representation ID: 2619

Received: 28/01/2026

Respondent: EEESafe Ltd

Policy W1: Waste hierarchy and sustainable waste management (Draft Plan pp. 298–299)
Policy reference: Policy W1 (pp. 298–299)
Issue:
W1 properly includes repair and refurbishment within "Preparing for Reuse", but it does not address safety, traceability, and accountability risks for repaired or reused electrical and electronic goods. Whilst a good practices, a PAT test does not make an electrical item safe to use.
https://zurl.co/PATTestEEESafe
Justification:

Safety and accountability are material for electrical and electronic goods in second-life markets – traceability (who repaired, when) and preventing recirculation of unsafe or recalled items supports public confidence.
Repair-first reduces waste volumes and handling burdens.
Policy alignment: Supports OPSS Product Recalls and Alerts and Digital Markets, Competition and Consumers Act 2024.

Proposed change:
Add a new clause:
“Where preparing electrical and electronic goods for reuse (including repair and refurbishment), the Council will support approaches that improve consumer safety and accountability…”

Object

Representation ID: 2620

Received: 28/01/2026

Respondent: EEESafe Ltd

Policy W2: Waste reduction and waste audit (Draft Plan pp. 299–301)
Issue:
W2 does not explicitly encourage local reuse and repair pathways.
Proposed change:
Add bullet:
“Support repair-first and local reuse pathways where appropriate…”

Object

Representation ID: 2621

Received: 28/01/2026

Respondent: EEESafe Ltd

Strategic Policy W3: Safeguarding waste facilities (pp. 301–302)
Issue:
Does not explicitly include reuse/repair capability.
Proposed change:
Add sentence:
“Enhancements should… include provision that supports increased preparing for reuse…”

Object

Representation ID: 2622

Received: 28/01/2026

Respondent: EEESafe Ltd

Issue:
Does not recognise smaller distributed repair/refurbishment activity.
Proposed change:
Add criterion supporting smaller repair/testing/refurbishment facilities.

Object

Representation ID: 2623

Received: 28/01/2026

Respondent: EEESafe Ltd

Policy IN2: Digital connectivity (pp. 191–193)
Issue:
Does not link digital connectivity to circular economy participation.

Justification highlights:

Digital inclusion supports access to repair/reuse systems.
Local approaches reduce transport and emissions (Scope 3).
Community-based verification improves safety outcomes.

Proposed change:

Add sentence linking digital inclusion to repair, reuse and community participation.

Object

Representation ID: 2624

Received: 28/01/2026

Respondent: EEESafe Ltd

Strategic Policy INS: Sustainable infrastructure (pp. 186–188)
Issue:
Does not explicitly support pilot delivery models.
Proposed change:
Add sentence supporting pilot-scale, place-based circular economy initiatives.