Regulation 18 Draft Local Plan 2025 Online Version and Consultation

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Object

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Strategic Policy SDB1: Brixham – A strategy for sustainable growth

Representation ID: 188

Received: 14/01/2026

Respondent: Acorn Property Group

Representation Summary:

What at least 400 dwellings provide a minimum number, given the failure of the Plan at this stage to provide for even half of its housing requirement under the Standard Method, this number is too low and would contribute to the plan failing at Examination stage.

Object

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Strategic Policy HS: Overall Housing Strategy and Presumption in favour of Urban Regeneration

Representation ID: 189

Received: 14/01/2026

Respondent: Acorn Property Group

Representation Summary:

The Plan proposes to meet less than half of the Local Housing need. Even with the constraints outlined, such a significant shortfall would almost certainly result in the Plan failing at examination, even more so given the direction of travel in the consultation draft NPPF Dec 2025. The full LHN requirement therefore ends to be accounted for.

Object

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Strategic Policy H7: Affordable Housing

Representation ID: 192

Received: 14/01/2026

Respondent: Acorn Property Group

Representation Summary:

The policy does not reflect reality, as brownfield sites that have not been developed in the last decade are less likely to do so if burdened with affordable housing. The policy makes no distinction between brownfield and greenfield sites despite significant cost differences, and lacks viability evidence to justify the levels, which is unlikely to be accepted at Examination. Additionally, SME house builders are collapsing nationally, and reducing affordable housing requirements on small to medium sites could encourage development.

Object

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Policy TA3: Development layout, access and connectivity standards

Representation ID: 193

Received: 14/01/2026

Respondent: Acorn Property Group

Representation Summary:

As worded, the policy does not allow flexibility for innovative design that meets evolving transport types. It seeks to constrain development solely into the 1980s car lead estate design, rather than be forward looking and future proofed. The policy needs to be reworded with far greater flexibility to ensure Torbay can be at the forefront of design rather than than stuck in the past.

Object

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Policy TA4: Parking and shared transport provision

Representation ID: 194

Received: 14/01/2026

Respondent: Acorn Property Group

Representation Summary:

2 bed houses do not need 2 spaces - one is acceptable, unless the Council is actively seeking to reduce density of development. The provision of an EV charging point per house should be changed to the provision of pre wiring to accommodate an EV charging point, as most home owners would rather fit the charger of their choice rather than have a type forced on to them.

Object

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Policy CER1: Net zero carbon development standards

Representation ID: 195

Received: 14/01/2026

Respondent: Acorn Property Group

Representation Summary:

As worded, the policy does not take viability and deliverability into account, nor the Government's current direction of travel on Local Plans not exceeding the remit of Building Regulations or unnecessarily repeating policy provided elsewhere.

Support

Regulation 18 Draft Local Plan 2025 Online Version and Consultation

Strategic Policy H3: Other Local Plan allocated sites

Representation ID: 217

Received: 15/01/2026

Respondent: Acorn Property Group

Representation Summary:

Support is give to the allocation of the former Northcliffe Hotel in Brixham, site H3B.3, for up to 15 dwellings. The site is brownfield and rightly a focus for residential development, albeit caveated by viability.

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