Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Object

Representation ID: 1286

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

The firm objects to Policy SC4 (Sustainable Food Production) for being too restrictive and proposes it be revised.

This policy expects that new development, wherever practicable, should protect existing and new local food growing spaces.

The Policy states that ‘development which would result in the detriment to or loss of the best and most versatile agricultural land will only be permitted where there is an overriding need for the development and it is demonstrated by the applicant that it cannot be accommodated on lower grade land. Where development is proposed and there is a choice between sites of different grades, development should take place on land of the lowest grade feasible. Where development is approved on the best and most versatile agricultural land, the local authority will require a schedule for the reuse of soils to be provided in accordance with an agreed agricultural land assessment.

Additionally, residential schemes at all scales should include provision for sustainable food production, proportionate to the scale of development and food growing opportunities will also be sought from non-residential development on a case-by-case basis. Furthermore, for larger development sites, the Council will seek the specific provision of allotments or neighbourhood growing spaces. Where provision cannot be achieved on-site, off-site contributions to schemes within the nearby area will be sought.

Bloor Homes wish to object to this Policy as it is considered that the wording of this Policy is too restrictive and this will prevent sites coming forward that would help Torbay achieve the required housing delivery that is not currently being met and may not be met in future. In particular, the wording of the Policy, which relates to agricultural land grades, and requires a schedule for the reuse of soils to be provided in accordance with an agreed agricultural land assessment. Additionally, the Policy requires all scales of residential schemes to provide sustainable food production or the requirement for larger developments the specific provision of allotments. These elements of this Policy are considered to be unduly restrictive as they may impede suitable sites being brought forward for residential development.

Recommendation

As it is of vital importance for Torbay Council to provide a deliverable Five Year Housing Land Supply which may not be met by the draft site allocations, it is recommended that the wording of this policy should be altered to allow for a wider range of sites to be brought forward, in particular those of higher agricultural land grade but that are suitable in all other respects. Additionally, residential schemes should not be required to provide the sustainable food production as this may impact the viability of site sand prevent sites coming forward in a timely manner.

Object

Representation ID: 1287

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

Chapter 7 of the draft Local Plan considers transport issues, sustainable travel and the need for inclusive access. The draft Policy emphasises the ‘transport vision’ that the LPA wish to follow when guiding the future development of the wider Torbay area. This emphasises the importance of strategic connections, supporting the transport hierarchy, encouraging connection to the existing transport network, encouraging the development of multi-modal hubs, and ensuring that sustainability and the environment remain at the heart of the transport strategy.

Bloor Homes supports the overall transport vision and agrees that a particular priority should be given to walking, cycling, and wheeling to ensure that development encourages and reinforces connectivity across the Borough and agrees that the development of multi modal hubs and connections to the existing transport network will ensure that development provides sustainable travel and inclusive access.

Bloor Homes also supports the principles of Strategic Policy TAS: Integrated transport vision, transport hierarchy and strategic connectivity, and considers that this will set the appropriate strategic benchmark under which development proposals should be assessed throughout the plan period. Bloor Homes notes and agrees with the Transport Hierarchy’ illustrated at Figure 16 and considers that the proposed allocation and development of the Land off Broadpark Road and Land off Statnor Lane, Torquay is capable of being brought forward in compliance with this hierarchy and overall strategy.

Bloor Homes does, however, consider that adjustments should be made to the approach taken within Policy TAS to ensure that it is both consistent with national policy, effective and positively prepared. Bloor Homes considers that to ensure consistency with national policy, Policy TAS should be re-crafted to ensure that a ‘vision-led’ approach is adopted within development proposals and to ensure that the transport vision includes future resilience. This is specifically identified as an issue within the draft Policy’s supporting text (para. 6.3), where the need for the transport system and infrastructure to be resilient and capable of supporting needs both now and through future choice is emphasised.

In addition, Bloor Homes considers that to ensure the policy is effective, any required improvements to (or contributions towards) the existing transport network must be viability-assessed. A strategic policy will not be effective in its delivery, or resilient to respond to emerging and future transport needs and pressures if it fails to allow for flexibility to be applied when securing transport contributions, particularly where the viability of development proposals may be a key consideration

Bloor Homes agrees with the principles set out at draft paragraph 6.6 that junction improvements, mobility hubs and new cycle route will be important elements of contributing to this strategy. Bloor Homes does, however, consider that to ensure that the policy is effective and positively prepared, the anticipated safeguarding of land, in particular for bus and transport network improvements and location of mobility hubs should be specified clearly within site-specific allocations for development.

Bloor Homes also agrees in principle with the approach stated at draft paragraph 6.9 but again considers that to ensure the policy is effective and positively prepared, key areas of connectivity around major development proposals should also be set out in site-specific allocations.

Recommendation

For these reasons, Bloor Homes considers that the wording of draft strategic Policy TAS should be amended to ensure that the ‘vision-led’ approach is followed within development proposals, that the draft Policy acknowledges cases where development viability may be a consideration, and that the draft Policy specifically requires bus and transport network improvements, the provision of mobility hubs and other key areas of transport connectivity are set out clearly within site-specific allocations.

Support

Representation ID: 1288

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

Draft Policy TA1 develops the overall transport strategy further and provides clarity on how the LPA propose to consider development proposals in transport terms. This includes ensuring compliance with design codes and supplementary planning documents to support high quality, safe and accessible places. The draft Policy also sets out the detailed information that will be required in support of planning applications (for example, Transport Assessments and Travel Plans).

Bloor Home supports the principles of Policy TA1: Reducing the impact of transport and promoting sustainable travel and considers that for the policy to be justified and effective, the content of design codes and/or SPDs will be crucial in delivering high quality, safe and accessible places. It is therefore essential that these design codes and/or SPDs are brought forward early in the Local Plan process and with the support and involvement of key stakeholders and developers. This should be reflected within the wording of draft Policy TA1.

Recommendation

For these reasons, Bloor Homes considers that draft Policy TA1 should be re-worded to confirm that any design codes or supplementary planning documents that are brought forward to guide transport and sustainable travel within site proposals are done so early in the Local Plan period, and with the engagement of all relevant stakeholders, developers and landowners.

Comment

Representation ID: 1289

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

Bloor Homes recommends that Policy TA2 (Effective and Inclusive Transport) incorporate proportionality and viability assessments for transport contributions.

Object

Representation ID: 1290

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

Draft Policy TA4 sets out in more detail the specific requirements in terms of parking provision and the delivery of shared parking provision, and Bloor Homes both supports and welcomes the principle of this approach. Bloor Homes considers that this provides both stakeholders, landowners and developers important clarity when it comes to the design and promotion of development proposals, with more certainty that they will be supported by the Local Planning Authority.

Bloor Homes supports the requirement for minimum parking standards set out within TA4 to be delivered within development proposals, including the emphasis on shared transport provision (that is, cycle spaces and shared car provision).

Consistent with our comments regarding draft Policies TAS and TA2, however, Bloor Homes considers that to be effective and justified, it is important for draft Policy TA4 to acknowledge that the provision required is both proportionate and subject to viability testing.

Bloor Homes also considers that the stated minimum number of two car parking spaces per house (Table 13) is excessive and contrary to the overarching aims of Policy TAS, which is hierarchy-led (Figure 16) and seeks to ensure that sustainable transport is fully embedded into new developments (as stated at draft paragraph 6.30). To ensure that it is positively prepared, the policy (and the specific parking standards set out in Table 13) should therefore be re-crafted to place a greater emphasis on walking/wheeling, cycling and the use of public and shared parking, and to remove the requirement for a minimum of two parking spaces per house (not including garages).

Recommendation

Bloor Homes considers that the wording of draft Policy TA4 should be amended to ensure that explicit reference is included to the assessment of development viability when determining the level of transport provision that will be required as part of development proposals. To ensure that the parking standards are consistent with the over-arching transport strategy and transport hierarchy (draft Policy TAS), Table 13 should also be amended to remove the reference to a minimum of two car parking spaces to be provided per house (excluding garage provision).

Object

Representation ID: 1291

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

This Policy describes how development proposals will be required to be designed to be resilient to climate change and minimise greenhouse gas emissions. Policy CERS details the requirements for developments. This Policy also sets out that applications will be required to be supported by an Energy and Climate Change Statement. As part of this, a climate resilience statement, transport assessment and travel plan will also be required. This document will be expected to include details of how the development will demonstrate these requirements, including the adoption of a climate resilient approach and reducing energy demand. Development will also be required to minimise flood risk and be designed with a fabric first approach to maximise energy efficiency, among others.

Bloor Homes supports the Council’s approach in seeking to ensure that the effects of climate change have been fully taken into account in development proposals. However, they would note that such Statements are likely to replicate much of the information that is required to be submitted in support of application for major developments.

Bloor Homes therefore object to this Policy. It is not considered that an Energy and Climate Change Statement is required and it will add extra experience and time to the planning application process. These matters can be adequately addressed in other supporting information and through negotiation and agreement with Officers during the application stages. As such, it is not considered to be justified.

This is not to say that Bloor Homes does not wish to support the need for climate change resilience and, as a company, their schemes will seek to ensure that consideration of the impact of climate change is built into their proposals. Indeed, measures to address climate change are incorporated at the design stage. However, it is felt that there are better mechanisms to achieving this goal than the provision of an additional statement or report. Rather Bloor Homes would wish to work closely with the Council during the application stage to agree and confirm the approach to be adopted.

That said, it is considered that should the Land off Broadpark Road and Land off Statnor Lane, Torquay be allocated for residential development, the subsequent development would incorporate the criteria listed in this Policy with regards to build development that minimises greenhouse gases.

Recommendation

Policy CERS should be amended to exclude the requirement for an Energy and Climate Changer Statement to be submitted with applications.

Object

Representation ID: 1292

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

This Policy sets out the requirements for new development with regards to Net Zero. This includes how residential development, as a minimum, is required to achieve ‘75% carbon dioxide emissions reduction from that required under Part L of the 2013 Building Regulations’. Further, all development will be required to achieve net zero carbon emissions. This Policy also requires an Energy and Climate Change Statement.

The requirement for 75% carbon emissions reduction form that required under the building Regulations is an onerous requirement that is contrary to the relevant national guidance. This requirement will therefore impact upon the viability of residential development and will provide an additional obstacle to overcome. Given that the delivery of housing is a critical matter within Torbay, the Local Authority should work proactively with developers to provide the required housing numbers. Bloor Homes would be happy to comply with the relevant guidance provided with the Building Regulations and other national policy.

Recommendation

It is therefore recommended that the wording of this Policy is changed to remove this requirement and to instead amend this Policy to be in line with the relevant national policy and guidance.

Object

Representation ID: 1293

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

Policy CER2: Embodied Carbon Reduction and Assessment

This Policy sets out how all new development will be expected to demonstrate how it will minimise embodied carbon emissions. It is stated that this will be through an Energy and Climate change Statement, which includes an embodied carbon assessment. This must use a nationally recognised embodied carbon assessment methodology and demonstrate actions taken to reduce embodied carbon emissions.

Recommendation

As set out within the commentary for Policy CERS, whilst Bloor Homes is supportive of the aims to reduce embodied carbon it is considered that the requirements for this additional document as part of a planning application will place an unreasonable and unviable requirement upon developers that will increase costs and slow down the planning application process. It is considered that much of this information can be provided within other submitted documents and that this is not a necessary requirement. In particular, given the critical housing need within Torbay shown by the lack of Five Year Housing Land Supply and failure of the Housing Delivery Test, it is considered that the Local Authority should work proactively with applicants to create an efficient planning process. As such, it is recommended that this requirement be removed or limited to schemes where embodied carbon impacts are demonstrably significant.

Object

Representation ID: 1294

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

Strategic Policy ER3: Water Management

Within this Policy, it is set out how all development must submit a water management plan that demonstrates how development has met the listed criteria. This includes minimising water consumption, maximizing water sensitive design and avoiding harm to surface waters and aquatic ecosystems.

Whilst Bloor Homes supports the principle of managing water and protecting the water systems within Torbay, it is considered that the provision of a water management plan for all development is an unreasonable requirement that will provide an unnecessary obstacle for developers and the development of housing within Torbay. It is considered that the introduction of another requirement would increase delay and cost without necessarily yielding meaningful benefits where development will have limited impacts upon water systems and where information may be provided within other documents such as Flood Risk Assessments.

Recommendation

As such, in line with the recommendations for Policies CERS and CER2, this requirement should be reduced and should only relate to developments that would result in a significant impact to water systems and aquatic ecosystems. This would therefore ensure that unnecessary barriers to housing delivery are removed.

Object

Representation ID: 1295

Received: 02/02/2026

Respondent: Bloor Homes

Agent: Mr Elliot Jones

Policy L1: Protecting Our Countryside and Rural Economy

Bloor Homes supports the general intention of Policy L1 to protect Torbay’s rural areas; however, the policy is overly restrictive as drafted and requires greater flexibility to ensure consistency with the NPPF’s presumption in favour of sustainable development (paragraph 11). To ensure the policy is positively prepared and capable of meeting local needs over the plan period, we consider the following clarifications and amendments are necessary.

Firstly, Policy L1 should explicitly support development outside the main urban areas where it addresses an identified local need, including but not limited to, housing requirements, specialist accommodation, community facilities, and forms of rural economic development. Without such flexibility, the policy risks preventing sustainable proposals that deliver clear social benefits and are necessary to meet Torbay’s identified needs.

Secondly, the requirement for applicants to assess in combination effects should be proportionate. It is unreasonable to require assessment of hypothetical, unsubmitted or speculative development proposals. Cumulative assessment should relate only to extant permissions, allocations, or live applications, consistent with national guidance. This ensures applicants are not burdened with assessing developments that may never come forward.

Finally, where the policy references the potential for housing development outside settlement boundaries, this should be expanded to confirm that such development may also be acceptable where it demonstrably addresses an identified need, aligning the policy with Policy HS and wider NPPF requirements for responsiveness to local housing needs.

Recommendation

To ensure Policy L1 is positively prepared, proportionate, and aligned with the NPPF’s presumption in favour of sustainable development, the following amendments are recommended:

Insert wording to confirm that development outside the main urban areas may be supported where it directly addresses a proven local need. This provides necessary flexibility and ensures the policy can respond to housing, community and economic requirements that cannot be accommodated within settlement boundaries.

Clarify that applicants will only be required to assess in-combination impacts arising from reasonably foreseeable development— namely, extant permissions, Local Plan allocations, or live applications. This avoids placing unjustified burdens on applicants to assess speculative or hypothetical schemes that may never come forward.

Amend the policy wording to confirm that housing beyond settlement boundaries may be acceptable where it demonstrably meets an identified local need, including affordable housing or specialist accommodation, subject to compliance with other relevant policies.

These refinements will ensure Policy L1 remains robust while also being flexible, deliverable, and consistent with national planning policy.