Regulation 18 Draft Local Plan 2025 Online Version and Consultation

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Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Strategic Policy SS1: Torbay Growth Strategy - Prioritising our communities through improved health, housing, place making and opportunities for all

Representation ID: 1180

Received: 02/02/2026

Respondent: Cavanna Homes Ltd

Agent: Angharad Williams Planning Ltd

Representation Summary:

The draft Local Plan’s housing target of 400 dwellings per year is far below the government’s need of 950 homes per year, risking under‑delivery.

Comment

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Chapter 1: Our shared vision - A healthy, happy and prosperous Torbay

Representation ID: 1181

Received: 02/02/2026

Respondent: Cavanna Homes Ltd

Agent: Angharad Williams Planning Ltd

Representation Summary:

The plan should prioritise all viable housing opportunities to meet the growing population’s needs.

Support

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Strategic Policy SS1: Torbay Growth Strategy - Prioritising our communities through improved health, housing, place making and opportunities for all

Representation ID: 1182

Received: 02/02/2026

Respondent: Cavanna Homes Ltd

Agent: Angharad Williams Planning Ltd

Representation Summary:

The plan appears overly business‑led, placing too much emphasis on employment‑led schemes.
There is a concern that the priorities of the plan are very business led, with a significant emphasis on favouring employment led schemes.

Of particular concern is the Spatial Strategy outlined within Strategic Policy SS1.
This policy stipulates:
The Plan supports the creation of at least 80,000 sq. m of Class E(g)/B2/B8 net employment space over the Plan period, equal to at least 20 ha. with an emphasis
on bringing employment space forward as early as possible in the Plan period. All developments capable of delivering 100 or more dwellings should provide at
least 25% of the area as employment space.
This policy would have a significant impact on the Council’s ability to meet their housing need, given that it would likely render many developments unviable,
especially given the requirement to meet other local and national policy requirements such as Biodiversity Net Gain (BNG).

Support

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Strategic Policy SS1: Torbay Growth Strategy - Prioritising our communities through improved health, housing, place making and opportunities for all

Representation ID: 1183

Received: 02/02/2026

Respondent: Cavanna Homes Ltd

Agent: Angharad Williams Planning Ltd

Representation Summary:

Spatial Strategy SS1’s requirement that developments of 100 + dwellings provide at least 25 % employment space could make many housing projects unviable, especially when Biodiversity Net Gain is also required.

The 25 % employment requirement conflicts with the Sustainability Appraisal’s focus on high‑quality affordable housing, making affordable provision difficult.

Support

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Strategic Policy SS1: Torbay Growth Strategy - Prioritising our communities through improved health, housing, place making and opportunities for all

Representation ID: 1185

Received: 02/02/2026

Respondent: Cavanna Homes Ltd

Agent: Angharad Williams Planning Ltd

Representation Summary:

The policy is ambiguous; clarification is needed on whether the 25 % employment must be on‑site or can be satisfied by off‑site contributions and how contributions should be calculated.

Support

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Strategic Policy SS1: Torbay Growth Strategy - Prioritising our communities through improved health, housing, place making and opportunities for all

Representation ID: 1186

Received: 02/02/2026

Respondent: Cavanna Homes Ltd

Agent: Angharad Williams Planning Ltd

Representation Summary:

Currently, the Council’s method for calculating an offsite employment scheme is not viable or transparent, and so a policy change in how the final contribution is calculated would also be required should the Council pursue this method. For example, a scheme that our client currently has under consideration with the Council (Wilkins Drive as discussed below), has requested a huge £1.4million towards employment, which it hugely out of proportion and would render any site unviable.
The scheme is already having to deal with the financial impact of challenging ground conditions, as well as what was an assumed contribution of £150,000 towards
employment. Even this much smaller financial contribution is pushing the scheme to an unviable position, as would an even smaller amount.

Object

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Strategic Policy E1: Strategic employment land allocation

Representation ID: 1189

Received: 02/02/2026

Respondent: Cavanna Homes Ltd

Agent: Angharad Williams Planning Ltd

Representation Summary:

The allocation of site EIP.3 Wilkins Drive as employment should be changed to 100 % residential because a live planning application for 46 dwellings (including 30 % affordable housing) is already under consideration, and the employment allocation would make the proposal unviable.

The draft Local Plan proposes to allocate EIP.3 Wilkins Drive for employment use despite strong evidence that this site can deliver much-needed homes. The site is currently being promoted for housing development via a live planning application which if approved, will secure and accelerate the delivery of a housing site, including
a substantial percentage of affordable housing.

The draft Local Plan’s strategic objectives include boosting housing delivery (at least 400 homes per year) and prioritising urban regeneration and sustainable
development. Allocating Wilkins Drive solely for housing supports these priorities by making efficient use of land that is already related to the urban edge of Paignton and
is appropriate for residential development.

There is no clear evidence presented in the Regulation 18 draft that Wilkins Drive is essential to meet Torbay’s employment land requirements, and without robust evidence that other employment sites cannot meet requirements, retaining an employment allocation on this site risks under-delivering housing without demonstrable economic benefit.

Support

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Strategic Policy E1: Strategic employment land allocation

Representation ID: 1190

Received: 02/02/2026

Respondent: Cavanna Homes Ltd

Agent: Angharad Williams Planning Ltd

Representation Summary:

The allocation of site EIP.4 (land north of Wilkins Drive) as employment is supported as the location is suitable for commercial use next to a sub‑station and aligns with economic objectives and national policy.

Support

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Strategic Policy H3: Other Local Plan allocated sites

Representation ID: 1191

Received: 02/02/2026

Respondent: Cavanna Homes Ltd

Agent: Angharad Williams Planning Ltd

Representation Summary:

The allocation of sites HT3.6 (Torquay Holiday Park north of Willows) and the land north of Nuthutch Drive for residential development (up to 250 units) is welcomed as it provides needed housing on brownfield land and matches emerging national planning priorities.

Comment

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Chapter 3: Housing and Regeneration Policies

Representation ID: 1192

Received: 02/02/2026

Respondent: Cavanna Homes Ltd

Agent: Angharad Williams Planning Ltd

Representation Summary:

The client asks the council to help engage current owners/occupiers of the HT3.6 sites to progress residential proposals.

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