Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Object

Representation ID: 1196

Received: 28/01/2026

Respondent: Baker Estates Ltd

Agent: Collier Planning

The draft plan’s housing strategy proposes too low a scale (8,000 dwellings) and provides no evidence to show it meets the soundness tests required by national policy.

Object

Representation ID: 1197

Received: 28/01/2026

Respondent: Baker Estates Ltd

Agent: Collier Planning

The plan delivers only 42 % of the housing need calculated by the new standard method, which is insufficient and would require clear supporting evidence.

Object

Representation ID: 1198

Received: 28/01/2026

Respondent: Baker Estates Ltd

Agent: Collier Planning

Basing the housing target on long‑term averages since 1980 is fundamentally flawed because it ignores the reasons for adopting the new standard method.

Object

Representation ID: 1199

Received: 28/01/2026

Respondent: Baker Estates Ltd

Agent: Collier Planning

The draft plan continues a failed strategy that has historically under‑delivered housing, contributing to a persistent affordable‑housing shortfall.

Object

Representation ID: 1200

Received: 28/01/2026

Respondent: Baker Estates Ltd

Agent: Collier Planning

The Development Strategy of the current Local Plan and its predecessors has created a number of issues and problems for the delivery of the level of housing that is actually needed in Torbay. As well as proposing a level of housing which has not in any way sought to meet the actual need, placing an over-reliance of new development within such a limited number of locations and on
relatively large sites within those locations has resulted in consistent levels and an ongoing trend of under delivery. This has been caused by complications and delays arising from a number of the site allocations, particularly the urban renewal sites which are heavily constrained and often subject to significant viability issues and the large urban extension sites which take a long time to
come forward. It is very worrying therefore that the draft Local Plan seeks to continue this failed strategy. Indeed, the historical Housing Delivery Test (HDT) results for Torbay reveal a persistent under-supply even during significant periods where the housing market in the south west region has been exceptionally buoyant. This is illustrated by much better HDT results during the same
period for the other Devon authorities of Mid-Devon, East Devon, Exeter City, North Devon, Torridge, West Devon, South Hams and Plymouth City, as well as in neighbouring Cornwall. The under delivery in Torbay cannot therefore be blamed on market forces.

This has had inevitable consequences on the delivery of affordable housing and has seen the need for affordable housing continue to rise and rise.

In an appeal decision (PINS ref: Appeal Ref: APP/X1165/W/24/3354507) in 2025 on land at
Copythorne Road, Brixham the Inspector concluded,

“83. The Council does not dispute that it has consistently failed to demonstrate a minimum five year supply of housing since 2016, despite the policies of the development plan that promote reviews and proactivity in the quest to ensure that such can be consistently demonstrated. This, coupled with the past record of recent under performance against the Housing Delivery Targets, suggests that Torbay is an area that, despite the Council’s efforts, has not granted enough permissions or facilitated the building of houses to meet needs. There is also an agreement that there is an ongoing and acute need for affordable housing across Torbay, generally reflective of the national situation.

The new standard method housing target represents a step change in the number of houses the Council is being asked to plan for. For a third time, the Council is now preparing for a Regulation 18 Plan which seeks to accommodate a number of houses far higher than
previous attempts and the engagement of the duty to co operate with neighbouring authorities is yet to prove that any shortfall can be met elsewhere”.

Continuing, as the draft plan appears to propose, the same strategy which has failed to deliver sufficient housing to meet the needs of Torbay and exacerbated the affordability of homes in the area does not appear to be one that can be found to be positively prepared, justified (taking account of reasonable alternatives), effective or consistent with the current national policy against which it will be examined. In particular, it is noted that even to meet the very low (compared with housing need) housing
requirement proposed by the draft plan, 1000 homes will be required to arise from the Council’s ‘hotels to homes’ idea and a further 2,400 homes from windfalls. Aside from the fact that a conversion of a hotel to dwellings would normally be considered to represent a windfall, taking
those figures in combination, that’s nearly half of the draft plan’s proposed housing requirement needing to be found in locations that have not yet been identified.

In the above-mentioned appeal decision from last year the Inspector commented on this,

“89. At the hearing, the Council raised its ambition to implement a ‘Hotels to Homes’ initiative which will see much of the older hotel stock within the district turned into homes. Despite not having the detail as to the yield, distribution and timeframe for delivery of such, this is a supportable initiative. However, the regeneration of existing brownfield sites alone is unlikely to deliver the quantum of houses or range of house types necessary to meet the area’s housing needs”.

It is also the case that the need for hotel accommodation to fulfil Torbay’s tourism role and function, which is essential to the local economy, will be severely compromised by losing such a very substantial proportion of its hotels to permanent residential accommodation.

Without a lot more detail and evidence underpinning this proposed approach, we are again concerned that this strategy will not be able to meet any of the tests of soundness.

Support

Representation ID: 1201

Received: 28/01/2026

Respondent: Baker Estates Ltd

Agent: Collier Planning

Baker Estates Ltd and Belstone Fox Ltd broadly support the proposed allocation within Strategic Policy H3 and Strategic Policy E1 of land which it owns at Monksbridge, Brixham (site refs: H3BCG.3/E1B.2) for 130 new homes and 0.25 ha (approx. 1000sqm) of Class E (g) employment uses.

In light of the concerns set above regarding the adequacies of the spatial strategy and proposed housing requirement of the draft plan, it is very significant that the Council has proposed to allocate this site and demonstrates clearly that it has assessed the site as being one of a very limited number of greenfield sites which it considers is suitable for development.

Support

Representation ID: 1204

Received: 28/01/2026

Respondent: Baker Estates Ltd

Agent: Collier Planning

The site could accommodate up to 175 dwellings, including affordable units and bungalows, and up to 0.6 ha of commercial/employment uses, suggesting a larger mixed‑use scheme than currently proposed.

Object

Representation ID: 1205

Received: 28/01/2026

Respondent: Baker Estates Ltd

Agent: Collier Planning

We are surprised to see that the affordable housing requirement for sites allocated in the National Landscape (35%) is proposed to be different to that which would apply to other allocated sites and where the policy would seek 30% affordable housing. There does not appear to be any valid justification for this and such an approach is not consistent with national policy. The viability of delivering housing within the National Landscape will, self-evidently, be no different than doing so outside of it.

Comment

Representation ID: 1206

Received: 28/01/2026

Respondent: Baker Estates Ltd

Agent: Collier Planning

The council needs robust, comprehensive evidence to underpin the affordable‑housing policy and to assess viability across different site types.