Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Comment

Representation ID: 1264

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

Sladnor Park should be re‑categorised from “Red” to “Orange” in the council’s heritage assessment, reflecting that impacts can be mitigated.

Support

Representation ID: 1265

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

Although supportive of the principle of regenerating urban brownfield sites, our clients have fundamental concerns that draft policies SS1 and HS, in applying the presumption in favour of sustainable development only to previously developed land ‘within the built-up area’, the
emerging plan eschews opportunities for brownfield regeneration elsewhere, significantly limiting the capacity for additional windfall sites and environmental enhancements elsewhere.

The sustainability of such locations would be assessed through other policies of the plan and therefore there is no reason, in our client’s view, why policy SS1 should be so narrow in its approach in this respect, when national policy sets a lower bar of previously developed land ‘physically well-related to existing settlements’ in respect of this principle.

Support

Representation ID: 1266

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

Our clients support as a matter of principle the broad objectives outlined in Strategic Policy SS1 for shaping future development needs within the unitary authority area. In particular, it is noted that Torquay is intended to remain the authority area’s principal settlement, reflecting its size, role and degree of self-containment relative to other settlements in the area. Housing Need It is noted that SS1 states, inter alia, that: “The Plan also seeks to deliver at least 8,000 new dwellings over the Plan period of 2025-2045 equal to an average of around 400 dwellings a year over a 20-year Plan period.”

This is however much less than half of the Council’s housing need based on the national standard method, which sets a requirement of 947no. dwellings per annum based on the 2024 Affordability Ratios. The background to the policy suggests that annual delivery of 400no. dwellings is reflective of the average dating back to 1980, however this belies the uncomfortable fact that over that time plainly that number has not been sufficient to meet the public’s need for housing, especially in relation to affordable housing. Consequently, at a recent appeal the Council has been found to have less than 1.8 years’ supply.

For this reason, it is clear that – even expressed as a minimum – delivery of just 400no. homes per year will not come close to meeting in full or even majority the need for new homes, nor unlock the wider investment in public infrastructure that the emerging plan seeks to facilitate.

No exceptional justification is put forward as to why Torbay should be treated as a ‘special case’ as constrained to such a severe extent as to be different from all other authorities (an estimated 78no. of which are also coastal authorities) or in any case how such an approach can be reconciled against the NPPF’s objective of significantly boosting the supply of homes through strategic policies ‘informed by a local housing need assessment, conducted using the standard method in national planning practice guidance’.

As such, whilst our client supports the Council's commitment in principle to a plan for growth, in practice the emerging plan’s aspirations currently fall well below minimum levels required in accordance with the NPPF and the standard method.

Support

Representation ID: 1267

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

Our client acknowledges that, where supported by appropriate evidence, it is reasonable to allow for a modest amount of ‘windfall’ development despite the relative uncertainty of these coming forward by their very nature. It is agreed that the focus should be on smaller, non major sites and that no reliance should be placed on ‘major’ sites given the limited likelihood of these coming forward as windfalls.

In this instance, there is historic evidence that an annualised rate of 120no. homes per year has been achieved in relation to urban windfalls, although this varies year on year. While urban land is finite and opportunities may already have been exploited in this respect, the potential for changes of use and conversions to residential, for instance through the ‘hotels to homes’ program, make such windfalls a more realistic proposition in this location.

Notwithstanding, plainly even including this appropriately cautious allowance, the overall annualised housing target falls well below expectations in terms of the standard method, and proportionally these relatively unpredictable windfalls would still form an alarmingly sizeable element of overall supply (30%). This is of concern where it would be significantly less so if instead part (c.12.5%) of a NPPF-compliant overall housing figure.

It should also be noted that anticipated small scale windfalls sites are not realistically expected to make any contribution to remedying the severe shortfall in affordable housing within the unitary area, as it is unlikely that developments of nine units or fewer could financially sustain exceeding a 1,000 sqm floorspace trigger for the provision of on-site affordable.

Accordingly, no affordable homes whatsoever can be presumed to be delivered in association with nearly a third of the anticipated source of supply, exacerbating an already critical shortage and/or placing an undue burden on larger sites to remedy.

Comment

Representation ID: 1268

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

The site lies in Flood Zone 1 and will remain there, indicating no flood‑risk concerns from development.

Object

Representation ID: 1269

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

Draft policy L3 seeks to conserve the character of the Undeveloped Coast, resisting development within this area unless proposals satisfy the following requirements:
1. ‘Maintain the unspoilt character of the coastline, coastal landscape and seascape;
2. Maintain or improve public access for recreation; and
3. Provide sensitively designed development, including tourism uses, where there are clear economic or sustainability benefits that cannot be realised in alternative locations'.

This replicates the adopted requirements of policy C2: The coastal landscape. The existing local plan was adopted over a decade ago and there is an opportunity to adopt a more flexible approach to the undeveloped coast through the emerging local plan process, bearing in mind the significant need for development within the district at the current time and historic failure to deliver the homes needed locally.

Retaining this protectionist policy essentially as adopted will ultimately continue to prevent the required scale of development being delivered within the district over the plan period and will therefore, be detrimental to meeting the overall objectives of the emerging local plan. The specific reference within draft policy L3 to tourism development and the need to demonstrate that development cannot be realised in alternative locations is considered to be unnecessarily restrictive and should be removed from the draft policy.

Notably, the area designated as Undeveloped Coast covers a significant part of the district and it is not considered appropriate to apply the same restrictive policy to the entirety of this area. Within the undeveloped coast, there are of course areas which should be protected where their specific character is worthy of doing so. There are however, also many areas which could be developed for a range of uses in a sensitive way.

This includes the various previously developed sites within the Undeveloped Coast which have the potential to make a significant contribution towards meeting development needs through their redevelopment. The draft allocation of this site under H3T.2 indicates that the Council are, rightly, open to allocating sites such as this within the undeveloped coast.

As such, Strongvox consider that unless the mapped extent of the Undeveloped Coast is significantly reduced, an approach we would support, draft policy L3 must be amended to provide additional flexibility to allow development on appropriate sites within the Undeveloped Coast, helping to deliver much needed development in a sensitive manner.

The assessment of proposed development in the Undeveloped Coast must be seen as a landscape and visual consideration and ensuring that there is a requirement to fully assess the landscape and visual impact of any proposal within the Undeveloped Coast will ensure that appropriate development is accommodated within the affected area in a sensitive way.
We note that such a requirement is already built into adopted policy C2 and emerging policy L3.

In this manner, the current application for the redevelopment of Sladnor Park, which is located within the Undeveloped Coast, includes an LVIA to assess the overall landscape impact of the proposals. As noted above, the LVIA concludes that the development of this site would not result in unacceptable effects on landscape or visual receptors, demonstrating that major development within this part of the Undeveloped Coast can be sensitively accommodated.

Based on the above, suggested alternative wording for draft policy L3 is included in the representation (p35).

Comment

Representation ID: 1270

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

The scheme will generate significant financial contributions for affordable housing, healthcare and other local infrastructure.

Support

Representation ID: 1271

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

Draft Allocation H3T.2: Sladnor Park, Maidencombe

Draft policy H3 lists draft allocation sites for housing and notes that such sites are allocated to create sustainable, inclusive and mixed communities. It seeks to secure a mix of decent, good quality homes on sites, making optimal use of the land that is available and developing at the highest appropriate density for individual sites. These overall principles are supported as this will help to deliver the scale of housing growth needed in an area that is subject to a range of policy and technical constraints.

H3 includes this site as an allocation for 120 dwellings under H3T.2, Sladnor Park, Maidencombe. The policy notes that the principle of development has been established in the High Court Decision for application ref. P/2020/0315. Our clients support the principle of this allocation and agree that this site could make a significant contribution towards the provision of housing in the district.

The representations are submitted in conjunction with a current planning application for 110 dwellings.
This application was submitted in June 2025, assigned ref. P/2025/0353 and is currently pending consideration while our client continues to work with Torbay Council to resolve outstanding matters raised by technical consultees. Section 4 of this report provides further detail on this site, referring to the current planning application, concluding that this is an appropriate site for allocation in the emerging local plan.

Comment

Representation ID: 1272

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

A sustainable travel plan aims for a 10 % reduction in car use and promotes active‑travel modes.

Comment

Representation ID: 1273

Received: 26/01/2026

Respondent: Strongvox Ltd

Agent: Pegasus Group

Climate‑change policies (CER1 and CER2) should incorporate flexibility for technical feasibility and financial viability to avoid becoming barriers to housing delivery.