Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Support

Representation ID: 1254

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

The draft policy H4, which seeks to achieve the maximum appropriate densities for individual sites, is endorsed.

Strongvox supports the overall aspirations of draft policy H4 to secure the maximum densities that are appropriate for individual sites following consideration of the standard of accommodation, residential amenity and access. Adopting a proactive approach towards density will assist with the delivery of the scale of housing growth needed in an area that is subject to a range of policy and technical constraints.

Support

Representation ID: 1255

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

The draft policy H7, which provides for affordable housing provision across the Torbay area, is supported.

Strongvox support the provision of appropriate affordable housing options to meet the needs across the Torbay area. Securing a proportion of new housing as affordable homes for major schemes of over 10 homes or 1,000 sq. m of floorspace is a standard approach. The flexibility built into this policy to allow offsite provision or a commuted sum in exceptional circumstances in relation to larger sites is supported as there are occasions where it is not technically feasible or indeed advantageous to the Council to provide affordable housing on site. This is particularly pertinent given the Council’s acute need for affordable homes and the proactive approach of its housing team to bringing forward affordable-led schemes in the most accessible locations.
Whilst as drafted, the policy allows for this in exceptional circumstances on sites of 15 or more homes, such considerations can also make it difficult to deliver affordable housing onsite for sites of up to 15 dwellings. We would therefore suggest that the policy is amended to remove the 15-dwelling threshold for offsite provision or financial contribution, applying it more generally to all housing proposals.
Regarding tenures, the need to have regard to up to date evidence of housing need is welcomed to give flexibility where the standard 70% social rent / 30% intermediate mix isn’t appropriate and where an alternative mix would better respond to local circumstances. Strongvox support the provision of appropriate affordable housing options which support the identified needs of the local area across the plan period. It is noted that the emerging spatial priorities of the new Local Plan state that the plan will maximise the delivery of housing that is affordable. Therefore, it is considered that a range of affordable housing tenures must be considered for delivery within the plan period.
PPG paragraph 2a-024 makes provision to encourage local authorities to consider increasing planned housing numbers where this can help to meet the identified affordable need: ‘The total affordable housing need can then be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, given the probable percentage of affordable housing to be delivered by market housing led developments. An increase in the total housing figures included in the strategic plan may need to be considered where it could help deliver the required number of affordable homes.’

Object

Representation ID: 1256

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

The policy wording for H9 is inconsistent with the title – the wording refers to a 2% self-build requirement for Future Growth Areas or on sites over 100 dwellings however the title only refers to Future Growth Areas. This point needs to be rectified. We would note that the requirement should apply to Future Growth Areas only to ensure sites in other locations are not overly burdened by this seemingly quite arbitrary expectation.

Support

Representation ID: 1257

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

Our clients consider that draft policy HS is overly restrictive of opportunities to meet the area’s housing need by stating that “Major greenfield development outside of the built-up area or Future Growth Areas will be resisted, unless brought forward though a Neighbourhood Plan or area allocation development plan document or meets the requirements of the Affordable Housing Exceptions Sites Policy H8.” In our view, the wording of this part of the policy is in the first instance misleading, as it does not recognise the proposed site allocations that might otherwise represent ‘major greenfield development outside of the built-up area or Future Growth Areas’ and is therefore internally inconsistent with other elements of the plan; this should be corrected.

Second, it must be highlighted that, although they can do, Neighbourhood Plans are not bound to allocate land for development and experience suggests that they are an ineffective tool for doing so given that they tend to be formulated with limited local resources and often with a strong bent towards protectionist, rather than proactive, policies.

In terms of reference to any ‘area allocation development plan document’, we are supportive of the principle of subsequent allocations DPDs, which can be a timely intervention in between full plan reviews. In this respect, however, a definitive timescale should be set as to when, or in what circumstances (e.g. a threshold in land supply shortfall), such an exercise is to be triggered.

Support

Representation ID: 1258

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

Given the ageing population, Strongvox support measures to ensure that people can continue to live independently in their own homes and live active lives within the community. The aim of having all new homes capable of adaptation for disabled people is supported in principle and the policy as drafted provides flexibility in point 1 by including the wording ‘as far as is practical’ to allow for considerations relating to technical feasibility and financial
viability on a case by case basis.

The suggested 25% compliance with Building Regulations Part M4(2) in point 1 is considered to be an appropriate starting point, seeking to ensure adaptability for a percentage of homes whilst encouraging mixed and balanced communities overall. The last paragraph of H11 as drafted relates to developer contributions where development places an additional need on health services or facilities and to provide adequate flexibility, we would note that there should be consideration of financial viability in such scenarios to bring this policy in line with draft Strategic Policy IN1: Prioritisation of planning obligations.

Support

Representation ID: 1259

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

Strategic Policy TOS: Sustainable tourism and cultural investment strategy; Strategic Policy TO3: Redevelopment and reuse of holiday accommodation outside Core Tourism Investment Areas; and Policy TO6: Change of use or redevelopment of existing holiday parks to non-tourism uses

Point 3 of draft policy TOS facilitates the conversion of poorly located and outmoded accommodation outside of Core Tourism Investment Areas (CTIAs) to residential use subject to an appropriate impact on the character of the area, no adverse impact on the overall provision of the range of tourism facilities within an area and the regeneration and improvement of the built environment and overall character. Policy TO3 confirms this, seeking to ensure that for residential proposals, space standards set in draft policy DE3 are met.

As an overarching theme, these draft policies are supported and Sladnor Park is a good example of an historic tourism use which is no longer fit for purpose. Whilst it did at one time, provide a high quality of accommodation for tourists, it has remained largely vacant and underutilised for a significant period of time resulting in the degradation of the overall environmental quality of the site. The regeneration of the site for residential purposes would bring with it wide ranging benefits as recognised by its draft allocation under policy H3T.2. As demonstrated in the current planning application submission, a high-quality residential scheme would be established on this site.

Draft policy TO6 specifically relates to holiday parks and sets out criteria for the change of use of holiday parks where they are not allocated for alternative development in the local plan or other development plan document. As this site is allocated for residential development under H3T.2, this policy is not directly applicable in this case however the overall aspirations of this policy are supported as the reuse of underperforming holiday park sites would help to deliver much-needed new homes.

Object

Representation ID: 1260

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

Policy TA3: Development layout, access and connectivity standards

Draft policy TA3 requires for major development, unfettered connectivity through and around the development proposal, providing key links for access to services, commuting and leisure. Whilst this should be the overall aspiration for all development, land ownership and other physical constraints may limit this in some cases. As such, we would note that there should be consideration of this in the policy to provide flexibility where this is not feasible.

This draft policy also requires estate roads serving major developments to be constructed, completed and maintained to the Council’s approved highway standards. We would note that in many cases, internal road layouts are not adopted, remain private and are delivered in a way that varies from the approved highways standards but that remains safe in highways safety terms.

We would welcome further flexibility to allow for this where necessary rather than requiring compliance with approved highway standards in all cases.

Object

Representation ID: 1261

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

Policy CER1: Net zero carbon development standards and Policy CER2: Embodied carbon reduction and assessment

Draft policy CER1 seeks to impose a requirement for all new residential development to achieve as a minimum a 75% carbon dioxide emissions reduction from that required under Part L of the 2013 Building Regulations. It also requires all developments to achieve net zero carbon emissions and to connect to an energy network where there are existing proposals or schemes. High density proposals with expected high energy demands are expected to consider whether it is feasible and viable to develop a local energy network. It is noted that a Supplementary Planning Document will set out further guidance in due course.

Draft policy CER2 seeks to ensure embodied carbon is considered as part of the overall assessment for major development.

This principle of the climate change policies in general is supported and aligns with the Government’s aspirations for achieving net zero carbon emissions, but it is also important that this does not dominate the wider objectives of the Plan to the detriment of delivering a balanced, sustainable strategy that achieves the viable delivery of development to meet identified needs within the plan period.

The Written Ministerial Statement Planning: Local Energy Efficiency Standards - 13th December 2023 informed councils that the government expects examiners to reject local plans that go beyond current national policy and legislative provisions. This has recently been tested in the Court of Appeal1, which concluded that local authorities may set higher requirements exceptionally, subject to there being strong justification for such. Thus, there is an implicit evidential bar for doing so.

That evidential bar should also reflect real-world considerations including ensuring that development remains viable, having regard to other factors in this respect, and the impact on housing supply and affordability remains in accordance with the National Planning Policy Framework. This should be taken into consideration by the Council regarding this specific need, which, without substantive evidence otherwise, should not seek to push local standards beyond those established through Building Regulations.

For the reasons set out above, Strongvox consider that additional flexibility should be built in to the climate change policies to allow for consideration of technical feasibility and financial viability on a case-by-case basis. These considerations can, in some cases, make it difficult to provide climate adaptation and resilience measures or connect to a district heating network. Building in flexibility would ensure that the policies require these measures but would prevent them becoming a barrier to the delivery of much needed housing and economic development where technical feasibility or financial viability barriers exist.

Object

Representation ID: 1262

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

L1 notes that outside of settlement boundaries, new development will be limited to agricultural dwellings, tourism development, sport and recreation and renewable energy development. This approach is considered to be unnecessarily restrictive. It fails to acknowledge that there are other sites outside settlement boundaries, including previously developed sites, which could satisfactorily accommodate a range of development types in
response to the significant need for development in the district. As noted above in section 3, the emerging plan eschews opportunities for brownfield regeneration elsewhere, significantly limiting the capacity for additional windfall sites and environmental enhancements elsewhere. Additional flexibility should be built into this policy to allow for such situations.

Comment

Representation ID: 1263

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

The Heritage Impact Assessment methodology for non‑designated assets should be revised to use terminology that better reflects the level of harm.