Torbay Local Plan Regulation 19 Publication Version and Consultation

Comment

Representation ID: 3360

Received: 22/09/2026

Respondent: Teignbridge District Council (Statutory / General Consultation Body)

Teignbridge congratulates Torbay on publishing its Regulation 19 Local Plan, especially given recent intervention difficulties. On the whole, the Plan is a comprehensive well-presented document that builds on the previous draft versions with many elements of policy supported by Teignbridge. Key components, such as Shared Vision and Spatial Strategy offer a very clear approach towards shaping places and making the most of
local identity with the waterfront and harbourside related plans both ambitious and far-reaching.

Object

Representation ID: 3361

Received: 22/09/2026

Respondent: Teignbridge District Council (Statutory / General Consultation Body)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Plan proposes housing provision significantly below the identified level of housing need, delivering approximately 400 homes per annum against a local housing need figure of 972 homes per annum. Teignbridge recognises the constraints affecting Torbay, particularly its constrained geographic size, and accepts that accommodating the full level of need is likely to be challenging. However, we remain concerned that the
evidence has not yet demonstrated that all reasonable opportunities to increase housing provision have been fully explored.
We acknowledge the publication of Topic Paper 1: Strategy and Growth Level Justification August 2026 to justify this low level of provision and welcome the opportunity to comment on the Local Plan, Topic Paper 1 and the Landscape Sensitivity Assessment of Potential Future Growth Areas, prepared by Stephenson Halliday.

Object

Representation ID: 3362

Received: 22/09/2026

Respondent: Teignbridge District Council (Statutory / General Consultation Body)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Para 1.49 ‘Although Torbay is a largely self-contained housing market area (HMA) and Functional Economic market Area (FEMA), its population growth is entirely driven by inwards migration. This is largely from people moving from elsewhere in the UK. Whilst the closest neighbours are Teignbridge and South Hams, the council considers that unmet housing need, (as calculated by the Standard Method and demographic projections) is a sub-regional matter that needs to be resolved in cooperation with wider Devon Authorities through the Spatial Development Strategy’
Teignbridge has some concerns regarding the approach taken in paragraph 1.49 and, in particular, the expectation that unmet housing need will be addressed at a wider subregional level. Whilst there are merits to this approach in the long term, via the SDS, in the short term, every attempt should be made to explore possible additional
development sites within Torbay.
The Plan anticipates that a significant element of unmet housing need may ultimately need to be considered through future sub-regional planning arrangements. However, there has been limited discussion to date regarding the scale, distribution and practical implications of such an approach.
Depending on the outcome of the LGR Review, if the low level of housing provision is accepted through the Examination of the Torbay Local Plan, this immediately places any new unitary authority, which includes the former Torbay area, on the back foot in terms of meeting housing needs.
Whilst there is no longer a formal Duty to Cooperate, this cross-boundary matter has been the subject of limited discussions with local authorities within the sub-region,
including Teignbridge, to resolve. Whilst the emerging Spatial Development Strategy may provide an appropriate mechanism for considering strategic growth issues in the
longer term, Teignbridge considers that the Local Plan should set out more clearly the extent of any anticipated unmet need and how this issue could be addressed.
In addition, the assessment that ‘population growth is entirely driven by inwards migration’ represents an over-simplification of population trends for Torbay. It is clear
from ONS based data for the period 2011 to 2021, that such growth reflects a combination of demographic changes rather than purely migration-driven, implying that
indigenous factors still contribute, alongside migration to the overall population increase. Nevertheless, it is acknowledged that inward migration has been particularly
marked in recent years, as detailed in Public Health population overviews prepared by the council.

Comment

Representation ID: 3363

Received: 22/09/2026

Respondent: Teignbridge District Council (Statutory / General Consultation Body)

The Plan presents a very clear approach towards shaping places and making the most of local identity and the physical environment of Torbay, including the Torbay Premier Marine & Natural Experience concept.

Object

Representation ID: 3364

Received: 22/09/2026

Respondent: Teignbridge District Council (Statutory / General Consultation Body)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Explanation of Spatial Strategy and Area Policies
‘The Plan relies very heavily on regeneration of brownfield sites and other urban areas to maximise its development opportunities and deliver on town centre regeneration
programmes, drawing investment into our towns and breathing life into our town centres. The Local Plan contains a brownfield Presumption in Favour of Sustainable Development and is highly supportive of urban brownfield development, especially in town centres.’ (para 2.1)
Whilst the principles contained in para 2.1 are sound, it is questioned how much they differ from the current Torbay Local Plan approach, which has not delivered enough new housing over the last decade, and how much certainty can be given to others, including the Planning Inspectorate, that sites will be developed in a timely way.
The proposed level of housing provision remains substantially below the identified housing need figure. Whilst Teignbridge acknowledges the constraints identified by Torbay Council, it is not yet clear that every reasonable opportunity for additional growth has been assessed before reaching this level of provision. Torbay has a population of about 140k. The proposed housing delivery rate appears low when considered against the scale of identified housing need and the size of Torbay's resident population. In comparison, Teignbridge has a resident population of 131k and new local plan will provide for 720 homes a year. There are several other examples of higher levels of housing provision in similarly constrained coastal bounded Local Planning Authorities in the southwest.

Object

Representation ID: 3365

Received: 22/09/2026

Respondent: Teignbridge District Council (Statutory / General Consultation Body)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

‘Torquay will deliver a minimum of 37,000 square metres (net) of Class E(g), B1 or B2 employment floorspace and at least 3,600 new homes over the Plan period, equal to an average of around 180 dwellings a year over the Plan period 2022-42.’
It would be helpful to identify how much new development is allocated in the Plan and how much is rolled over from adopted plan, in places such as Strategic Policies H1-3 in
Chapter 3 this distinction is rather blurred.
In relation to the following item: ‘A strategic green gap between Torquay and Kingskerswell will be maintained’ it must be emphasized that such a green gap policy cannot be applied to those areas beyond the plan area, particularly where the developed area of Torquay, east of Kingskerswell Cross, immediately adjoins the council/plan area boundary. These areas will be addressed in landscape terms by the requirements of Policy EN1: Setting of Settlements from the Teignbridge Local Plan
2020 - 2040 which represents an updated approach from the outstanding open breaks method followed by the adopted Teignbridge Local Plan. Residential development in this area of Torbay could be considered, as Policy EN1 would ensure that the settings of both Kingskerswell village and Torquay were conserved and enhanced and would prevent coalescence. (Policy EN1: Setting of Settlements is included at the end of these comments).

Object

Representation ID: 3366

Received: 22/09/2026

Respondent: Teignbridge District Council (Statutory / General Consultation Body)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The inclusion of the requirement for a transit site for gypsies & travellers in the third point of the policy causes some concern. Traveller sites are difficult to deliver and as
the site would not be located on a main through route, its merit is questioned. However, it is acknowledged that the evidence has shown there is no requirement for this
provision.

Object

Representation ID: 3372

Received: 22/09/2026

Respondent: Teignbridge District Council (Statutory / General Consultation Body)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Teignbridge remains concerned that the Plan relies on a relatively limited portfolio of development opportunities and that the overall housing strategy may not provide
sufficient flexibility to maximise delivery over the plan period. As such bullet vi is considered too strict:
‘Major greenfield development outside of the built-up area or Future Growth Areas will be resisted, unless brought forward though a Neighbourhood Plan or area allocation
development plan document, or meets the requirements of the Affordable Housing Exceptions Sites Policy H8.’
The limitations on the strategy of seeking to focus on previously developed land within the built-up area, as a major priority, appears to comprise of fundamental points which will place a firm brake on the actual level of housing development coming forward:
Para 3.6: ‘It is acknowledged that much of the urban area contains constraints such as flood risk and other infrastructure issues. In addition, a significant part of the built-up area, including the three town centres, are designated conservation areas. Nevertheless, the Plan’s key focus is to develop in these locations due to their wider sustainability benefits.’
Although we recognise consistency with most recent trends of supply, the proposed rate of windfalls at 120 dpa, identified in para 3.10 may not be realistic going forward as land becomes increasingly constrained.
Town Centre Regeneration Areas, identified in Table 3 and H1 may not be sufficiently robust in terms of potential deliverability of housing, the supporting technical work
identified, para 3.18 is open-ended.
Timings of the identified brown field regeneration sites may need a significant amount of negotiation with landowners and preparatory work before development comes forward. In some ways the approach towards housing strategy/delivery is similar to that followed in current Torbay Local Plan and which has not delivered enough housing.
Collectively, these factors create uncertainty regarding the extent to which the Plan has identified the maximum realistic level of housing growth capable of being delivered
within Torbay.

Comment

Representation ID: 3373

Received: 22/09/2026

Respondent: Teignbridge District Council (Statutory / General Consultation Body)

This policy provides the main basis for new housing development in the plan area. A number of the proposed growth areas build upon existing allocations and are
dependent upon updated masterplanning work. Whilst this approach is understandable, additional confidence would be provided if the evidence demonstrated more clearly the extent to which further opportunities for growth have
been considered.

Comment

Representation ID: 3374

Received: 22/09/2026

Respondent: Teignbridge District Council (Statutory / General Consultation Body)

Contain most new housing sites, but status is unclear, appears to be a mix of sites that have come from HELAA process, some have planning permission and therefore maybe should not be an allocation. Position requires more clarification in supporting text.