Torbay Local Plan Regulation 19 Publication Version and Consultation

As above.

In choosing to promote a housing requirement of around 400 dpa, the entire process becomes meaningless and needs to be started again using the 970 dpa figure. If all other councils took the same approach, the national target would deliver under 42% of the actual requirement.

The approach is fundamentally flawed and because of that there is no point on any other draft sections as none have credibility as they stand.

The plan needs to be produced on the basis of meeting the Local Housing Need that has been produced using the Standard Method. This version of the plan is not even close to addressing that need and should not be progressed.

The entire concept of providing for under half of the housing requirement (i.e around 400 rather than 970 per annum) is flawed and has no justification.

If all Council's adopted such an approach, the national housing crisis would worsen and there is no justification for such an approach.

The Kingsland part of the site should be identified as suitable for residential development. This would contribute to meeting the objective of 550 dwellings in the area as it is clear that the larger parcel will not deliver anything close to the masterplan aims - indeed, it has been controlled by a housebuilder for over a decade and they are currently trying to dispose of it because of the challenges of delivering anything on site.

This representation specifically focusses on part of the Kingsland site that is protected for employment uses in the 2016 masterplan. The site is previously developed land and employment uses would not be viable.

The 2016 masterplan was prepared without any consultation with landowners or even a site visit to Kingsland. There are site specific factors (such as underground infrastructure) and mixed ownerships that render employment uses unviable. The fact that the adjoining land controlled by a housebuilder and not come forward in over a decade highlights the fact that the masterplan is not deliverable.

The site should be removed from the employment section and promoted for residential uses.

Employment development on site is not viable and this point has been made through numerous consultations.

However, the site continues to be protected for employment and consequently no development has come forward for over a decade.

Whilst the draft policy references the previous appeal refusal, it does not reference that the reason for refusal related to flood risk and draiange.