Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Support

Representation ID: 866

Received: 02/02/2026

Respondent: Historic England (Statutory / General Consultation Body)

The draft Local Plan is praised for recognising the historic environment through Strategic Priority 4, policy TOS Sustainable Tourism and policy ER7 Coastal Change Management, in line with NPPF requirements.

Object

Representation ID: 867

Received: 02/02/2026

Respondent: Historic England (Statutory / General Consultation Body)

Conservation area appraisals are another element of the evidence base that are important given both the extent of the borough that is covered by such designation, and the likely development within them that the Plan envisages.

This includes the emphasis on the ‘hotels to homes’ programme referenced at various points. However, we would point out that a number of conservation area appraisals for the borough are now some years old –Torquay Harbour conservation area character appraisal (within which several key draft site allocations are located) was produced over 20 years ago. We are aware that work is underway to update at least some appraisals, but a commitment to the revision of all within the borough would be a significant step in ensuring an up-to-date evidence base for the plan.

As well as updating, the Plan should clearly signpost their use in terms of understanding key elements of local character and how development proposals can respond to their context. This is particularly true of the larger sites (in capacity terms) in Torquay town centre.

Object

Representation ID: 868

Received: 02/02/2026

Respondent: Historic England (Statutory / General Consultation Body)

We have some concern with the general approach to tall buildings in the draft Plan, including policy DE4 Building Heights and Urban Form. Strategic priority 5 includes a bullet point that indicates the Plan will ‘allow tall buildings in appropriate locations where this secures wider regeneration benefits’. The inclusion of this text within a strategic priority infers that tall building proposals are a priority in terms of future development, while we note the references to potential locations for tall buildings elsewhere – for example within policy H1 Town Centre
Regeneration Areas and at para 2.25 in relation to Paignton town centre (and with clear potential for impact on designated heritage assets). Given that the Plan does not identify which areas of the borough would be appropriate for tall buildings, this approach carries a risk that proposals will come forward in locations that are not appropriate in heritage terms and would conflict with other parts of the Plan.

We also note the reference to Torbay Council’s Building Heights Strategy at para 11.19. However, we would point out that this was produced in 2010, and note that both national planning policy and the development context within the borough have changed significantly since that point. The NPPF’s requirement for an up to date evidence base to underpin plans (para 32) is also relevant here.
Historic England has produced advice on planning for tall buildings: Tall Buildings: Historic England Advice Note 4. We therefore consider that the draft Plan should go further in considering the likely effects of tall buildings on townscape and the historic environment, and work to identify both appropriate locations for tall buildings together with design and height parameters. As drafted, we consider there is ambiguity in where tall buildings may be located in the borough and therefore uncertainty as to effects on heritage significance. We would refer you to the work done by Exeter City Council on views, heights and capacity in underpinning their draft local plan’s relevant policies and allocations as a helpful example of what can be achieved.

Further assessment would also help a clearer definition of what would be regarded as ‘tall’ in the borough (including across different locations and contexts), and which could then be included within Policy DE4. DE4 could also include a further clause explicitly requiring proposals to conserve heritage significance with a cross-reference to policy HES.

Comment

Representation ID: 869

Received: 02/02/2026

Respondent: Historic England (Statutory / General Consultation Body)

While Heritage Impact Assessments are welcomed, allocation policies should incorporate mitigation measures where an HIA rates a site as red.

Object

Representation ID: 870

Received: 02/02/2026

Respondent: Historic England (Statutory / General Consultation Body)

Site H3T.15 Meadfoot Beach Car Park
We note the HIA for this site is rated as red. The wider context for the site is the Lincombes conservation area which is characterised by villas set in relatively large gardens. The site is also within the setting of the Grade II* Hesketh Cresent, being located on the cliffside and prominent in views from the listed building. We agree with the conclusion of the HIA that development to the capacity envisaged in the draft Plan would cause harm to the open character of the conservation area and distract from the primacy of the listed crescent. We therefore object to the draft allocation as set out. We would be keen to discuss whether lowering the capacity of the site would ameliorate the effects on heritage significance and character.

Site H3P.9 Oldway Mansion
Given the existing Masterplan for the site and current repair works underway, we consider its continuation as an allocation in the draft Plan is potentially confusing and it should be removed.

H1T.5 Marina Car Park
This site is located within one of the most sensitive areas in terms of heritage in the borough, being within a conservation area and either adjacent to or within the setting of multiple other designated heritage assets. We note the emphasis in the HIA on the importance of the high quality of design of future proposals given the context, and as a result would wish to see detailed guidance on how to manage this in the site allocation policy. We would be pleased to discuss this approach and potential wording.

H3P.3 Stoke Road, west of Yalberton valley
We note the HIA status of red for this site, and again would wish to see clear guidance in the site allocation policy as to how harmful effects on heritage significance can be avoided, managed and mitigated. We would also point out the potential for combined/cumulative effects from other site allocations on designated heritage assets, including the listed buildings at Higher and Lower Yalberton. There will clearly need to be major infrastructure works, including
highways requirements, in order to deliver the envisaged number of new homes in this location. These needs to be taken into account and assessed against their likely impact on the historic environment.

Site H3T.3 Land North of Brunel Manor (HIA 23T007)
Again, we note the HIA status of red for this site. Given its adjacency and relationship with the Manor building, conservation area and registered park and garden, it will be important to ensure that considerations around setting and historic character are taken into account when
considering design and densities. These should be fully articulated in the site allocation policy.

Support

Representation ID: 871

Received: 02/02/2026

Respondent: Historic England (Statutory / General Consultation Body)

H3T.22 Former Stoodley Knowle School, Ansteys Cove Road
We note that this site is now in development and as such was not subject to a Heritage Impact Assessment. However, Historic England wishes to discuss a potential assessment of hydrological changes in the catchment and in proposed drainage channels with regard to potential impacts on the Scheduled Monument (Kents Cavern). HE has produced guidance on this subject Preserving Archaeological Remains: Decision-taking for Sites Under Development Guidance (2016), Appendix 3: Water Environment Assessment Techniques. This is not specific guidance for the complexity of cave environments, but the principles of the guidance can be applied, particularly tiered or staged assessment process to understanding water/environment interactions with historic environment receptors.

Other site allocations that require further detail/guidance on design parameters in relation to
effects on the historic environment, based on the conclusions of the relevant HIAs are:
H3P.2 Barton Pines H3P.5 Summerhill Hotel
H3T.7 Land adjacent to Watcombe Hall
H3T.14 Maycliffe Hotel
H3T.25 Brampton Court Hotel
H1T1 Castle Circus
H1T2 Union Street
H1T.3 Temperance Street
H1T.4 Abbey Road
HCBCGC.3 Monksbridge