Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Support

Representation ID: 1244

Received: 02/02/2026

Respondent: Home Builders Federation

As highlighted earlier HBF would question the range and scope of this Chapter especially in light of the proposed new approach to Local Plan content set out in the current Dec 2025 NPPF consultation. It will be important for this suite of policies to be fully evidenced and justified and do not repeat national policy.

In light of the housing crisis and the need for the Council to clearly evidence it is trying to do all it can to meet its own housing need within its boundary, there will be a need to consider green field allocations, and this is likely to require a comprehensive review of strategic gaps and countryside to see if they could in fact accommodate some housing.

HBF strongly support the need for more housing in Torbay variety of reasons including addressing the current housing crisis, meeting housing need, providing affordable housing, to support small and medium house builders and to support employment growth. The Council should set its housing requirement as planning to meet the standard method as a very minimum. Indeed, HBF would re
quest that the Council considers all of the issues that may result in a need for a higher housing requirement, including the need to provide a range and choice of sites, the need for flexibility, viability considerations and whether higher levels of open-market housing are required in order to secure increased delivery of affordable housing, as such the need for housing will need to be balanced against environmental protection policies.

The Plan needs to be clear how all the natural environment policies are intended to work together. For example, how does the requirement for the 10% national mandatory Biodiversity Net Gain for work with the other proposed policies on protecting trees and hedgerows and woodland. It is unclear if and how the Devon Hedge Guidance compliments or conflicts with the BNG metric Similarly, how does mandatory BNG work with the policies on Blue and Green Infrastructure?

Comment

Representation ID: 1247

Received: 02/02/2026

Respondent: Home Builders Federation

A fundamental rethink of the Plan is recommended so that it focuses on how the housing requirement can be met rather than questioning whether it can be met.

Object

Representation ID: 1248

Received: 02/02/2026

Respondent: Home Builders Federation

The Council’s proposal to plan for only 400 of the 950 homes required by the standard method is deemed untenable and contrary to national policy.

Support

Representation ID: 1249

Received: 02/02/2026

Respondent: Home Builders Federation

Good design does not have to reflect the existing character of a place, new development it can be an agent of change. Current planning policy and the new NPPF clearly set out expectation that density should be maximized. Housing densities are impacted by a number of factors including house types and sizes, on-site policy requirements should as on-site BNG and SUDs. There is therefore a need to consider density both from a wider policy perspective and on a site by site basis for allocation. National planning requires that the Council fully explores all options to meet their housing needs before concluding it cannot. Further work on tall buildings, densification, another Call for Sites, and more urban regeneration work and will be needed.

Object

Representation ID: 2973

Received: 02/02/2026

Respondent: Home Builders Federation

HBF suggest that the area policies in the Plan should be more explicit about the need to meet the housing needs of Torbay in full. We would also encourage the Council to fully consider the implications of the growth agenda on the future housing needs of Torbay and the wider Bay area.

With regards to the Spatial Strategy for Torbay, HBF does not comment on individual sites but we would expect the Plan to set out a logical settlement hierarchy which meets all the housing needs and addresses all areas of the housing market, with a range of sites proposed for allocation. The Plan will need to provide for a wide range of deliverable and developable sites across the area in
order to provide competition and choice to ensure that housing needs are met in full, or where this is not possible a clear strategy exists that will deliver any unmet needs elsewhere.

HBF note that Council’s recognition of the need for Neighbourhood Plans to be updated. We also note that Neighborhood Planning is a voluntary activity. It will be important to clearly set out the timeframe for the preparation of the review of the Neighbourhood Plans, including if and how they are anticipated to contribute to housing delivery in Torbay.

Object

Representation ID: 2974

Received: 02/02/2026

Respondent: Home Builders Federation

Strategic Policy IN1: Prioritisation of planning obligations needs to refer to the national mandatory requirement for the provision of BNG on eligible sites. This is set out under the Environment Act- and is non-negotiable.