Torbay Local Plan Regulation 19 Publication Version and Consultation

Abacus DFE supports the broad principles of the spatial strategy set out at Policy SS1. However, there is an imbalance of proposed employment and housing land allocations at the heart of the strategy which should be remedied in order for the Local Plan to be considered sound.
The Reg.19 Local Plan provides for a significant over-supply of land for new employment development, having regard to the published evidence base and Abacus DFE’s understanding and experience of the local economy and market signals. Approximately 32Ha of employment land is proposed against a stated requirement of at least 20Ha identified in the 2024 Torbay Economic Development Needs Assessment.

The Reg.19 Local Plan provides for a significant under-supply of land for new housing. Torbay’s Standard Method Local Housing Need (LHN) is 972 dwellings/annum at July 2026. The Reg.19 Local Plan is seeking to deliver an average of around 400 dwellings/annum over the 20-year plan period, less than half of what is required under the Government’s method.

Abacus DFE is appreciative of the constraints and sensitivities associated with development in the Torbay administrative area and beyond, but consider this scale of under provision to be too significant and unjustified. This is especially when experienced developers in Torbay (like Abacus DFE) are promoting suitable and available sites for new housing that have been rejected to date.

Abacus DFE note the recent intervention by the Minister of State and the concerns raised with Local Plan progress and housing delivery. Whilst the Minister was content to allow the Local Plan to progress, it is clear that it faces a significant challenge in being found sound with such a substantial shortfall in allocated housing land. The accompanying Topic Paper (Spatial Strategy and Justification for Proposed Growth) falls well short of the robust justification that will be required at examination.

Abacus DFE urge the Council to undertake an urgent strategic review of the listed employment sites as well as the housing opportunities that have been put forward, and to rebalance the growth strategy in Policy SS1 and associated Policies HS and ES with supporting evidence. In the face of a substantial under-provision in housing land, the Council should not be putting forward such significant headroom of new employment land, which could potentially equate to land for an additional 300+ dwellings.

The Reg.19 Local Plan provides for a significant under-supply of land for new housing. Torbay’s Standard Method Local Housing Need (LHN) is 972 dwellings/annum at July 2026. The Reg.19 Local Plan is seeking to deliver an average of around 400 dwellings/annum over the 20-year plan period, less than half of what is required under the Government’s method.

Abacus DFE is appreciative of the constraints and sensitivities associated with development in the Torbay administrative area and beyond, but consider this scale of under provision to be too significant and unjustified. This is especially when experienced developers in Torbay (like Abacus DFE) are promoting suitable and available sites for new housing that have been rejected to date.

Abacus DFE note the recent intervention by the Minister of State and the concerns raised with Local Plan progress and housing delivery. Whilst the Minister was content to allow the Local Plan to progress, it is clear that it faces a significant challenge in being found sound with such a substantial shortfall in allocated housing land. The accompanying Topic Paper (Spatial Strategy and Justification for Proposed Growth) falls well short of the robust justification that will be required at examination.
Abacus DFE urge the Council to undertake an urgent strategic review of the listed employment sites as well as the housing opportunities that have been put forward, and to rebalance the growth strategy in Policy SS1 and associated Policies HS and ES with supporting evidence. In the face of a substantial under-provision in housing land, the Council should not be putting forward such significant headroom of new employment land, which could potentially equate to land for an additional 300+ dwellings.

The Reg.19 Local Plan provides for a significant over-supply of land for new employment development, having regard to the published evidence base and Abacus DFE’s understanding and experience of the local economy and market signals. Approximately 32Ha of employment land is proposed against a stated requirement of at least 20Ha identified in the 2024 Torbay Economic Development Needs Assessment.

Abacus DFE urge the Council to undertake an urgent strategic review of the listed employment sites as well as the housing opportunities that have been put forward, and to rebalance the growth strategy in Policy SS1 and associated Policies HS and ES with supporting evidence. In the face of a substantial under-provision in housing land, the Council should not be putting forward such significant headroom of new employment land, which could potentially equate to land for an additional 300+ dwellings.

Abacus DFE is proposing to bring forward residential development at the western end of White Rock, within the ‘Western Bowl’ (HELAA Ref 21P060) (the ‘Site’). The Site and some neighbouring land is in Abacus DFE ownership and it was subject of pre-application consultation in 2024 (ref: DE/2024/0112). The Site is identified as an Employment Allocation (Policy E1 P.8 and P.9: Land North of Peter’s Copse and Land South of Peter’s Copse). At Reg.18 stage, Abacus DFE welcomed the proposed allocation of the Site for development within the Future Growth Area but invited the Council to amend the allocation from employment to residential use. This request is repeated in these representations for the Reg.19 Local Plan stage.

The Site is part of a ‘Future Growth Area’, proposed for strategic development including delivery of an additional 200 dwellings (over allocations in the adopted Local Plan) and new employment space.

Abacus DFE has fully supported the identification of the Future Growth Area and intends to work with the Council in bringing forward remaining opportunities for development on land within its ownership and control.

However, Abacus DFE is promoting the Site for residential use rather than employment use, with the reasoning and justification set out in detail in the representations made earlier this year at Reg.18 stage. The estimated capacity of the Site is around 60 to 80 dwellings.

Please also refer to the Abacus DFE comments on Draft Strategic Policy E1 which argue that the change from employment allocation to residential allocation need not adversely affect the Council’s economic growth strategy, principally owing to the significant headroom of proposed allocated employment land against the identified need.

The Site should be allocated for Housing under Policy H2

Abacus DFE is promoting the Site for residential use rather than employment use, with the reasoning and justification set out in detail in the representations made earlier this year at Reg.18 stage.

In total, approximately 32Ha of employment land is identified under draft Policy E1 against a requirement of at least 20Ha. As such, there appears to be significant headroom to allow for potential non-completions and/or lower than average site coverage on allocated sites. This also indicates that there is scope for alternative uses on some of this land without harming the Council’s economic growth strategy.

The Site should be allocated for Housing under Policy H2

Abacus DFE is promoting the Site for residential use rather than employment use, with the reasoning and justification set out in detail in the representations made earlier this year at Reg.18 stage.

In total, approximately 32Ha of employment land is identified under draft Policy E1 against a requirement of at least 20Ha. As such, there appears to be significant headroom to allow for potential non-completions and/or lower than average site coverage on allocated sites. This also indicates that there is scope for alternative uses on some of this land without harming the Council’s economic growth strategy.