Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Comment

Representation ID: 1218

Received: 02/02/2026

Respondent: Home Builders Federation

The DTC section of the draft Plan should be rewritten to reflect the removal of the legal Duty to Cooperate test and to clearly quantify any unmet housing need.

Comment

Representation ID: 1219

Received: 02/02/2026

Respondent: Home Builders Federation

The Plan must set out more detail on Torbay’s unmet housing needs and demonstrate how it will work with neighbouring authorities to address them.

Comment

Representation ID: 1220

Received: 02/02/2026

Respondent: Home Builders Federation

Local policies should avoid duplicating national requirements such as parking standards and accessibility percentages that are already covered by the NPPF.

Object

Representation ID: 1221

Received: 02/02/2026

Respondent: Home Builders Federation

Although HBF recognise the challenges of meeting housing needs in full within the Torbay area, we are concerned that the Council has already arrived at a figure of 400 homes per year without having updated its evidence base, undertaken a new Call for Sites, or fully explored if there are other policy changes, and indeed funding, which could increase the amount of housing that could be delivered within the Torbay. This is a key requirement of current (and future) national planning policy.

Comment

Representation ID: 1222

Received: 02/02/2026

Respondent: Home Builders Federation

A clear timetable is needed for updating master‑plans and exploring a full range of housing types, sizes and tenures, while recognising viability issues on brownfield sites such as remediation, Section 106 costs and Biodiversity Net Gain.

Support

Representation ID: 1223

Received: 02/02/2026

Respondent: Home Builders Federation

The Sustainability Appraisal should be used to test options beyond the 400‑home baseline rather than accepting that figure without further analysis.

Support

Representation ID: 1224

Received: 02/02/2026

Respondent: Home Builders Federation

The Home Builders Federation supports the need for more housing in Torbay to address the housing crisis, provide affordable homes, support small‑ and medium‑size builders and stimulate employment growth.

Object

Representation ID: 1225

Received: 02/02/2026

Respondent: Home Builders Federation

HBF would note that even if the whole of the National Landscape is excluded from the consideration
of any new housing growth, other undeveloped parts of the district can and should still be considered. HBF would wish to see, and comment on, the evidence that supports the conclusion that the full needs of the district cannot be met within its boundaries. Our experience elsewhere has shown such evidence will be subject to very robust testing during the Examination in Public.

Comment

Representation ID: 1226

Received: 02/02/2026

Respondent: Home Builders Federation

The Plan should establish a logical settlement hierarchy with a diverse range of sites to ensure competition, choice and a clear strategy for any unmet need that cannot be met within the borough.

Object

Representation ID: 1227

Received: 02/02/2026

Respondent: Home Builders Federation

We are also very concerned about the specific policy requirements for all sites suitable for 100 units of housing are required to provide 25% of this as employment space. This seems an unreasonable burden that would place greater emphasis on bringing forward employment than housing, despite the current housing crisis and the requirements for the Council to do all it can towards meeting its housing needs in full.

HBF are very concerned that this policy will have a significant impact on the Council’s ability to meet the housing needs of Torbay. The policy lacks evidence and justification and there is a lack of detail on how this policy is intended to work in practice. It is also unclear how the 25% is to be calculated or provided. If this is to be an onsite requirement what implications does this have for the housing capacity for each site and how has this been calculated. Is there the option of an off-site contribution. We are very concerned that this policy will render many developments unviable, especially given the requirements to meet other local and national policy requirements such as Biodiversity Net Gain (BNG) which should be delivered on-site wherever possible.

Although HBF recognises the importance of employment space, policies requiring new employment land must be proportionate to need. The policy as it currently stands appears to be contrary to the accompanying Sustainability Appraisal that clearly expresses the need for high quality, affordable housing. There is a real risk that it will not be possible for developers to provide the Plans ambition for affordable housing with such a big ask on employment provision.

The policy wording is also ambiguous in setting out how the 25% would be applied and clarification is required should the policy remain. It is unclear if the policy would require 25% of the redline site area to be designated employment land or if the requirement is for 25% of the m2 residential accommodation. It is unclear what type of employment is required, and the policy fails to recognise the inherent non-compatibility between some employment uses and residential development. All of this suggests the policy has not been properly thought through to ensure it is effective, justified and deliverable.

Similarly, it is unclear if an off-site contribution would be an option to meet the policy requirement. If so, would this be based on job creation or purely site area. HBF are very concerned that the need for employment land to be provided within the site at all times would in practice be extremely difficult
Home Builders Federation and in some cases, impractical. Not every site is appropriate for employment development, especially where there are topographical or potential access issues.

Any off-site contribution would need to viable to pay and the calculation for it would have to be clearly set out. There needs to be a clear calculation method that can be applied to housing numbers, which must be assessed in the viability work to support the Local Plan. HBF note that the whole plan viability assessment will need to cover the whole Torbay Plan area, but we note that large areas of Torbay suffer significant depravation, and this is reflected in property values. As such this will affect viability. There are also notoriously difficult geological conditions in the Bay which result in greatly increased abnormal build costs means that development viability is already difficult. Any additional contributions are likely to undermine the likelihood of housing delivery at all. The SA process and the whole plan viability assessment therefore need to robustly test the implications of this policy.