Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Object

Representation ID: 1306

Received: 02/02/2026

Respondent: Vistry Homes

Agent: Savills

The draft plan proposes only 8,000 new homes for the 20 year plan period of 2025 – 2045. This equates to 400 homes per annum. This is only 42% of the government’s standard method target which is 950 homes per annum, or for a 20-year plan period would equate to around 19,000 new homes. This would not have been an acceptable and sound approach had the Regulation 18 consultation been published last year, however it is now even more unacceptable on the basis of the Government’s recently published proposed revisions to the NPPF for consultation in December 2025. Whilst this is still in consultation, it clearly sets out the expectations and direction of travel of the Government.

The new NPPF clearly shows the importance that is being placed on addressing the housing crisis and the clear need for a more rules-based planning system that provides more certainty. It is very clear that the Government is expecting Local Plans to do more to help address the housing crisis and there is an expectation that all Councils should be planning to meet their housing needs in full.

When looking at the requirements of Policy SS1, we do have concerns over the proposed blanket approach to the
need to deliver a minimum 25% employment uses on-site within these FGA’s.

Whilst we acknowledge the need to allocate land for employment to help address any identified employment needs through the plan, we consider that taking a blanket approach for the FGA’s and setting a broad target for a minimum amount of employment floorspace without any specific supporting evidence is not a helpful or sound approach.

The delivery of new employment must be based on demand, and should therefore be located in the right locations
to address such identified demand. By seeking to provide a minimum level of employment floorspace within the
FGA’s could result in the wrong type of employment in the wrong locations in areas where the demand for such
floorspace does not exist.

We encourage the Council to review the wording of this part of draft Policy SS1 covering the FGA’s, and rather than set a minimum percentage target, perhaps look to emphasise that mixed use development is encouraged where possible and that a mix of both residential and employment uses are supported within the FGA’s.

Support

Representation ID: 1308

Received: 02/02/2026

Respondent: Vistry Homes

Agent: Savills

The need for a masterplan for the Future Growth Area is criticised because much development has already been approved, making a late‑stage masterplan of limited benefit.

Support

Representation ID: 1309

Received: 02/02/2026

Respondent: Vistry Homes

Agent: Savills

We strongly support the proposal to extend the FGA at Long Road, Yalberton, the development of which will be vital to ensuring that the Council can meet its housing requirement over the plan period.

However, there is some clarification needed on the exact number of new (unbuilt as of 2026) dwellings that the policy is seeking to deliver. The policy text itself states that development is expected to deliver and “additional 650
dwellings”. Yet, the explanatory text for this policy appears to indicate that the 650 dwellings is inclusive of those
allocated in the Future Growth Area of Berry Acres, Yalberton and White Rock in the Local Plan 2012-30, and that the further expansion is expected to deliver at least 200 additional dwellings. For clarity, we suggest that the policy text makes clear the total number of new dwellings being allocated, as well as a breakdown of which existing
allocations and previously identified sites comprise the remainder of the allocation.

As demonstrated within these representations, the Land north of Long Road, Yalberton is available for development and is able to delivery approximately 320 dwellings. If, as the explanatory text suggests, and additional 200 dwellings not previously allocated need to be identified within the FGA, then the land north of Long Road, Yalberton is able to accommodate the entirety of the figure and more, making it a crucial element of the FGA.

Additionally, while we are broadly supportive of the delivery of employment land within the FGA, we have concerns about the blanket approach taken in this policy, which states that 25% of the FGA should come forward as Class E(g), B2 or B8. While the employment evidence which underlies the plan shows an overall need for employment floorspace in Torbay, it is unclear how that has translated into the approach taken in this policy. Rather, we would suggest that employment uses should be directed more conscientiously to sites that can demonstrably accommodate said uses, and where there is an evidenced need for them. It is noted that part of the Land north of Long Road, Yalberton is included within a draft employment allocation under Policy E1. This is addressed later in these representations as part of our response to draft Policy E1.

Support

Representation ID: 1311

Received: 02/02/2026

Respondent: Vistry Homes

Agent: Savills

As with Strategic Policy SDP5, we strongly support the proposal to extend the FGA to the west of Paignton. Additionally, we strongly support the identification of the site as a specific allocation for housing per the H2P.4 designation of Policy H2. However, it is considered that further clarification is required in order to align Policy H2 with the information set out in Policy SDP5.

Firstly, H2P.4 is identified as Long Road, White Rock and Inglewood, Paignton (and BCG Villages). The draft Policies Map shows a number of sites as falling within H2P.4, all of which fall within the wider FGA. However, there is a discrepancy in the number of dwellings identified in H2P.4 (700 dwellings) and the total number of dwellings allocated in Policy SDP5 (650 dwellings).

The identification of an FGA in Policy SDP5 and then the separate identification of specific sites within that FGA through Policy H2 is not in of itself an issue, however the way that it has been set out within the draft plan is both ambiguous and contradictory. If the sites identified within H2P.4 make up part of the FGA (as is shown in the policies map), then the number of dwellings in Policy SDP5 should be higher than the number in Policy H2.

We suggest that both policies are carefully reviewed and reworded to ensure it is explicitly clear the number of dwellings being allocated through the FGA, how many of them are existing/committed sites versus new sites, and which site already identified via the HEELA are included within the allocation. What is clear, however, is that the Land north of Long Road, Yalberton (Appendix 1) forms a key component of the FGA, and therefore we strongly support its continued inclusion within the plan.

We would suggest that the plan specifically identifies the site as being capable of accommodating a higher scale of development, as set out later in these representations and within the appended vision document (Appendix 2) and masterplan (Appendix 3) which outline the latest proposal for the site accommodating around 320 dwellings. In addition to the above, Policy H2 also states that “More detailed requirements for Future Growth Areas will be brought forward through updated Masterplans”. Whilst we are not adverse to the principle of bringing forward 5 February 2026 masterplans for the FGA’s, for this specific FGA much of the growth already been or is in the process of being developed.

These developments have come forward independently, and without a previous request from the Council for a FGA-wide masterplan. The request for a comprehensive masterplan for this FGA is therefore in our view a request which has come too late in the process. While such an exercise could be done, it would have a limited positive impact compared to such an exercise being undertaken before many of the individual developments had taken place.

Object

Representation ID: 1312

Received: 02/02/2026

Respondent: Vistry Homes

Agent: Savills

We consider that this draft policy needs to be reviewed.
Whilst the Policy is titled “Minimum Density”, the policy text refers only to maximum densities, stating “new housing should be developed at maximum densities consistent with protecting the natural and built environment and providing a decent standard of accommodation and residential amenity”.

It would help if the wording is reviewed to ensure it is clear and concise, ensuring consistency between the policy
name and requirement.

Current planning policy and the NPPF clearly set out expectations that density should be maximised. This is
particularly important given the need for the Council to boost housing delivery to meet its housing needs in full.

As a result, whilst we assume the intention of this draft policy is for proposals to maximise the densities on sites, our view is that the policy wording could be strengthened to make this clear.

Comment

Representation ID: 1313

Received: 02/02/2026

Respondent: Vistry Homes

Agent: Savills

Policy SDP5 should clarify the total number of dwellings to be delivered and provide a breakdown of existing versus new allocations.

Comment

Representation ID: 1315

Received: 02/02/2026

Respondent: Vistry Homes

Agent: Savills

A discrepancy between the dwellings numbers in H2P.4 (700) and SDP5 (650) is highlighted, and the policies are urged to be reviewed for consistency.

Support

Representation ID: 1316

Received: 02/02/2026

Respondent: Vistry Homes

Agent: Savills

Policy H2’s proposal to extend the Future Growth Area west of Paignton and to identify the site is supported.

Support

Representation ID: 1318

Received: 02/02/2026

Respondent: Vistry Homes

Agent: Savills

We are in broad support for the proposed 30% affordable housing requirement for sites of over 20 dwellings outside
of the South Devon national Landscape (AONB).

However, in terms of tenure mix, we strongly suggest the mix be based primarily on up-to-date local evidence of
need in the specific site area. The policy should be worded to state that the generic mix of 70% Social Rent and 30% Intermediate housing will be sought when either this is supported by up-to-date local evidence, or in the absence of any up-to-date local evidence.

Secondly, in regard to the design and integration of affordable housing, the principle is broadly supported.

However, we would suggest the language is carefully considered in the context of affordable housing providers often having specific clustering and management requirements. An overly prescriptive policy, particularly in regard to the integration of affordable housing, could make the overall affordable housing requirement harder to achieve.

We of course encourage the Council to ensure that the supporting evidence base is robust and supports the proposed affordable tenure splits.

Support

Representation ID: 1320

Received: 02/02/2026

Respondent: Vistry Homes

Agent: Savills

Whilst we support the Council’s efforts to deliver a diversified range of housing as part of the plan, we encourage the Council to ensure that the blanket requirement of 2% self-build housing within the FGA’s or on sites over 100 dwellings is supported by evidence.

Once the further evidence has been published this will enable effective input on how best to plan for the identified
need.