Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Support

Representation ID: 3067

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

Bullet 3 - ‘Impact on the surface water flow regime and
groundwater sources’ – Could this criteria be reworded to
‘The sustainability of the impact on the surface water flow regime and groundwater sources under current and future climate change scenarios’ please as at the moment, there is no caveat to indicate that an impact could be unacceptable such as there is for other criteria.

Support

Representation ID: 3068

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

'Should demonstrate that… ' - Please change to must.

12.23 - The use of local materials, building methods and
details helps to enhance local distinctiveness * - Suggest adding *as well as avoid the carbon footprint of importation

BESS - Should the Plan include a policy on Battery Energy Storage and what the LPA will require of these? especially regarding surface water in the event of
a fire and environmental protection?

Support

Representation ID: 3069

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

Strat priority 4 - Para 1.51 - There is no bulleted objective relating to the environment. There should be one around enhancing the fresh and marine water environment

Para 1.60 - ‘At present, infrastructure ‘pinch points’, such as shared sewers in the town centres, the need for better
resilience to climate change,’ We welcome the inclusion and recognition of this.

Para 1.60 - ‘…water management and Green Infrastructure proposals… ‘ Please add in Green AND BLUE Infrastructure

Para 1.61 - ‘it is not thought that there are likely to be other infrastructure “show stoppers” in terms of water
or power availability’. Please see later comments regarding our position on Water resources.

Para 1.63 - The council will set these out in its Authorities Monitoring Report Adopted Local Plan (2012 2030) Evidence Base and Monitoring. Does this not need a 2025-2045 monitoring report and evidence?

Para 2,1 - ‘supported by high quality infrastructure…This will be achieved within the Bay’s built and natural environmental and infrastructure capacity.’ ' Without an IDP to review as part of this it is not clear what infrastructure will support the planned growth and what
the infrastructure capacity is.

2.2 (plus policies ER2 and W5) - The plan indicates ~1900 houses will be built as part of regeneration across Torquay, Paignton and Brixham (Table 2 Potential Broad Sources of Housing). Our concern is that these areas are
largely served by a combined sewer system. Will the regeneration in these areas practicably allow for ground infiltration, SUDs and other measures to prevent surface water infiltration?
Given the lack of other options as you move down the drainage hierarchy, we can see that connection to the
combined sewer network at greenfield discharge rates will be likely. This will require careful planning and engagement with South West Water. As mentioned in the Water Cycle Study (p31), South West Water will be
delivering improvement schemes to some of their CSOs in the Torbay area over the current WINEP period (AMP8;
2025-2030) We would hope that early and ongoing engagement with SWW will be conducted not just by
developers but by the Council as well.
https://www.southwestwater.co.uk/siteassets/documents/about-us/getinvolved/roadshows/torbay-roadshow
boards---12th-january-2024.pdf

WINEP dataset:
https://environment.data.gov.uk/dataset/39b11ea0-3cfa4cbb-b3a1b5950019f169

Support

Representation ID: 3070

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

Somewhere this needs to mention the delivery of timely required infrastructure to support growth, and ideally link to the IDP when it is done

Support

Representation ID: 3071

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

All development should achieve the following… - please replace should with must

‘iv) Resilience to extreme weather events
and incorporation of sustainable drainage and climate
resilience measures’ - We welcome the inclusion of this in the strategic policy

Para 3.2 - ‘NPPF will be applied it urban brownfield’ - ‘to’ Not it?

3.2 (1) - ‘Harm to *Habitats sites, irreplaceable habitats’ - *Add ‘protected species’ AND or flooding, *
and coastal change matters’ - *add ‘drainage’

3.13 - ‘Note also that the General Permitted Development
Order defines major development…’ - Majors etc are defined by The Town and Country Planning (Development
Management Procedure) (England) Order 2010

3.19 -…However, development should avoid sleeping accommodation on ground … - Please change ‘should’ to ‘must’

3.20 - Delete ‘where possible’ from the last line

Support

Representation ID: 3072

Received: 12/02/2026

Respondent: Environment Agency (Statutory / General Consultation Body)

no net increase into the sewer so will need to retrofit with
surface water items/attenuation to make room for the increase in waste water - Add an 8th bullet