Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Object

Representation ID: 1275

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

Bloor Homes objects to the draft plan’s decision not to allocate the Land off Broadpark Road and Statnor Lane site for residential development and recommends that it be allocated.

Comment

Representation ID: 1276

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

The representation states no objection to the Shared Vision but raises concerns that the Council’s interpretation of the presumption in favour of sustainable development is too narrow.

Object

Representation ID: 1277

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

Bloor Homes objects to the overall housing requirement of 400 homes per year (8,000 over the plan period) as being far below the standard‑method figure and urges it be increased.

Object

Representation ID: 1278

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

The firm objects to Strategic Policy SS1’s target of 8,000 new dwellings, arguing it is inadequate to meet Torbay’s housing need.

Policy SS1 is not:
• Positively prepared – The Plan provides for less than 50% of the required overall housing need based on the standard method.
• Justified – There are no reasons provided as to why the Council should divert from the standard method and, at the very least, it should seek to optimise all viable housing sites. However, the Council has failed to do this, for example, Land off Broadpark Road and Land off Statnor Lane, Torquay is not constrained but is not allocated for development.
• Effective – The Council is relying on allocations that have not delivered for over ten years and have no prospects of doing so during the plan period; and
• Consistent with National Policy – the Local Plan’s overall housing requirement is contrary to the guidance set out in the Framework and in the Planning Practice Guidance.

This policy needs to be fundamentally re-drafted. The Strategic Priorities are supported by Bloor Homes but the approach to the overall housing requirement should be re-visited. It is recognised that there are constraints to housebuilding in Torbay such as topography and landscape designations, however, at the very least the Council should seek to optimise all available housing sites that are not sufficiently constrained and allocate them for development such as Land off Broadpark Road and Land off Statnor Lane, Torquay .

Any alternative approach such as the one adopted will exacerbate the housing issues that have been present in Torbay for many years. Therefore, the overall housing requirement should be significantly uplifted.


It is also suggested that allocations from the previous Local Plan should not be relied upon. It is clear that these sites are difficult to develop and the prospects that they will be delivered during the plan period are slim. Given that they account for a significant proportion of the overall housing requirement, there is a need for additional sites to be brought forward given the high likelihood that the allocated sites will not be built out for housing. If such alternative sites are not allocated, then housing delivery will fall even further behind.

Object

Representation ID: 1280

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

The representation objects to Strategic Policy H1’s proposed level of development/yield for town‑centre regeneration areas, deeming it unrealistic.

Bloor Homes considers that Strategic Policy H1 in its current form is not justified nor is it effective. Robust supporting evidence needs to be produced for each of the identified sites to indicate the anticipated site capacity.

Only once they have been assessed in detail can this source of housing supply be considered realistic and contribute to the overall housing requirement.

Furthermore, any reliance on the urban regeneration should be tempered by the delivery issues that often affect brownfield redevelopment opportunities. To ensure that there is a robust approach to housing supply, the urban regeneration area should form only one part of overall supply and that – together with Future Growth Areas – should be supported by additional site allocation on
greenfield sites such as Land off Broadpark Road and Land off Statnor Lane, Torquay , which meet sustainable development tests.

Object

Representation ID: 1281

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

Bloor Homes objects to this policy. The Land off Broadpark Road and Land off Statnor Lane, Torquay should be included in the list of allocated sites for the reasons set out above.

Object

Representation ID: 1282

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

The firm objects to Strategic Policy HS (Affordable Housing) as drafted, stating it is unsound and could undermine the plan’s deliverability.

It should be redrafted in relation to the following points:
• The overall housing requirement should be reviewed and supported and justified by a robust evidence base.
• The presumption in favour of sustainable development of urban regeneration should be deleted to ensure that any reference is fully compliant with the NPPF; and
• The presumption against major greenfield development should be excluded where such sites align with the presumption in favour of sustainable development (as set out in the NPPF) and are able to help meet the overall housing requirement.

Object

Representation ID: 1283

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

Bloor Homes object to this policy. There is a requirement to include more flexibility within the policy. The Council should seek to adopt an approach that accords more with national guidance that seeks the local authority to take the lead and work with developers to encourage more self-build plots.

In addition, further consideration should be given to the viability of sites and the competing requirements relating to affordable housing, housing for older people, and self-build (amongst others). There is a need to deliver much needed new housing and the Council should adopt a pragmatic, flexible to secure a mix of housing on each site.

Object

Representation ID: 1284

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

The representation objects to Policy SCS (Sustainable and Inclusive Communities) as currently worded, recommending it be amended to allow allocation of the Broadpark/Statnor Lane site.

Support

Representation ID: 1285

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

This policy sets out that ‘development must contribute to improving the health and wellbeing of the community by reducing health inequalities and helping to deliver the conditions to enable healthy lifestyles and sustainable neighbourhoods’. It further states that ‘development must have regards to the health needs of the population and have special consideration towards measures which will address reducing health inequalities’.

In order to achieve these requirements ‘development must, through its location, design and suitability to local context, maximise its potential to address the place-based determinants of ill health in the local area’. This includes a strong reference where relevant to (inter alia):

• Active travel – active mobility through walking, wheeling and cycling
• Housing – delivery of diverse house types; affordable housing and accommodation to address local needs and energy efficient homes
• Communal and community facilities • Employment opportunities • Reducing exposure to environmental hazards
• Public transport
• Providing opportunities to produce and increase access to healthier food

Bloor Homes broadly support this Policy and the principles set out. However, it is considered that the strict wording of this policy may restrict suitable sites from coming forward to help Torbay Council meet its required housing number. By using wording such as ‘must’ this reduces the potential for flexibility in the sites which may come forward and the nature of the development. As noted previously within these representations, Torbay Council does not currently, and is not predicted to meet, the required houses per annum and cannot demonstrate a five year housing land supply.

Recommendation

Accordingly, it is recommended that the wording of this Policy be changed to allow for more flexibility. It is also considered that the allocation of the Land off Broadpark Road and Land off Statnor Lane, Torquay would, in the main, coincide with the objectives and principles contained within this Policy. As such, it is considered that the allocation of this site would aid in the creation of development that supports public health and wellbeing, thereby supporting the objectives of the Local Plan.