Torbay Local Plan Regulation 19 Publication Version and Consultation

Comment

Representation ID: 3141

Received: 11/09/2026

Respondent: Devon and Cornwall Police (Statutory / General Consultation Body)

Just to note a typo 4.92 refers to TC9 referring to crime and anti-social behaviour, but is TC10

Comment

Representation ID: 3142

Received: 11/09/2026

Respondent: Devon and Cornwall Police (Statutory / General Consultation Body)

I would also like to add i support the reference to designing out crime, anti-social behaviour or crime in this section.

Support

Representation ID: 3143

Received: 11/09/2026

Respondent: Devon and Cornwall Police (Statutory / General Consultation Body)

I support the inclusion of "Proposals likely to attract crime and anti-social behaviour unless it is demonstrated that they can be sufficiently controlled and a mechanism provided for so doing." Would it also be possible to include the fear of crime or anti-social behaviour, i feel this could also be particularly important especially when considering Violence Against Woman & Girls as referred in the Angiolini Inquiry (report 2)

Support

Representation ID: 3144

Received: 11/09/2026

Respondent: Devon and Cornwall Police (Statutory / General Consultation Body)

Again i support the reference of reducing and preventing crime and the fear of crime and designing out crime, within this section.

Comment

Representation ID: 3145

Received: 11/09/2026

Respondent: Devon and Cornwall Police (Statutory / General Consultation Body)

5.6 makes reference to architectural liaison officer (ALO) which is an old job title that no longer exists in Devon and Cornwall Police, would it be possible to update this to Designing Out Crime Officer (DOCO)?

Comment

Representation ID: 3146

Received: 11/09/2026

Respondent: Devon and Cornwall Police (Statutory / General Consultation Body)

I would like to raise that 11.5 refers to the Architectural Liaison Officer (ALO), this does not exist in Devon and Cornwall Police anymore, would it be possible to amended this to Designing Out Crime Officer (DOCO), thank you.
I also support the inclusion of number 4 which refers to designing out crime along with preventing & reducing crime and anti-social behaviour.

Support

Representation ID: 3356

Received: 23/09/2026

Respondent: Devon and Cornwall Police (Statutory / General Consultation Body)

The relevant policing area which covers the Torbay Local Plan is focussed around the three main towns of Torquay, Paignton and Brixham. Both Torquay and Brixham are served by existing Police Stations, while in Paignton, the Police have an office within the Paignton Library and Information Centre.

Please note that we comment on matters that concern the Police’s existing Estate within Torbay in our response to Policy SC5.

The proposed growth and development planned for the planning authority area over the next 15-20 years, save the implications of LGR which has been placed ‘on pause’, will result in an increased population that will have consequential impacts on crime, disorder, and public safety, leading to an increase in the number of incidents that the Police have to respond to.

As such, the policies within the new Local Plan should be consistent with the Rule of Law to be able to achieve the “safe places” which are fundamental to the achievement of sustainable development contained within the Government’s National Planning Policy Framework (NPPF). It follows that the Council’s primary duties above all else should be to make planning policies that seek to uphold the Rule of Law and recognise that “public safety is the state’s first job” which was recently stated by Sir Mark Rowley, Commissioner for the Metropolitan Police.

It is therefore important that emphasis is placed on maintaining visible and accessible policing provision, including Police infrastructure, in the new Plan, particularly in those locations where there is a need for town centre policing to be able to respond to the key issues of:

Violent crime, especially against women and girls;
Anti-social behaviour;
Drug and alcohol misuse;
Vulnerability demand and safeguarding;
Road safety; and
Pressures arising from seasonal tourism.

These are likely to be the key concerns of the local communities and our partners and, together with the Police, the Local Plan should help to identify long-term solutions to tackling these local problems.

The Police continues to strongly support the draft wording proposed in Policy TC10 which clearly recognises those uses or developments that have an impact on “policing” in the town centres and states that they “will be required to make appropriate contributions towards the costs of monitoring, maintaining or policing arising from the development.”

The Police have a responsibility to police new developments and uses in the town centres to the same level as that of existing developments, without detriment to them, and as such they cannot be expected to meet the cost of the additional Police infrastructure required from their existing budgets. Therefore, we are pleased to note that Policy TC10 provides the mechanism to make appropriate contributions available to the Police to support measures towards the policing of the town centres, harbourside and waterfront, to ensure that they are safe and welcoming for all.

The Police are therefore content that draft Policy TC10 meets the tests of soundness. As proposed, it will enable the Police’s infrastructure needs for the area to be met and which are justified based on the most up-to-date information received from DCP.

Furthermore, it will be effective over the Plan period by making the town centres, harbourside and waterfront safe and welcoming for all. As such, this is consistent with the NPPF (2024), in particular the social objective for sustainable development, which recognises “safe places, with accessible services” as key within paragraph 8b). It also complies with Section 17(1) of the Crime and Disorder Act 1998, which places a duty on all local authorities to consider crime and disorder implications when formulating policy and determining planning applications for any new development or uses in Torbay.

Conclusion

No further modifications to Policy TC10 are sought.

Support

Representation ID: 3357

Received: 23/09/2026

Respondent: Devon and Cornwall Police (Statutory / General Consultation Body)

The Police strongly support the recognition given in Strategic Policy SCS at xv) for development proposals to be assessed as to whether they:

“contribute to health services, policing and other social infrastructure where development would exacerbate shortfalls in provision” (our underlining).

Therefore, we are content that draft Strategic Policy SCS meets the tests of soundness.

Based on the information provided by the Police, it has been positively prepared, is justified, and will be effective over the Plan period.

The support given to assessing development proposals as to whether they contribute to policing services, where development leads to shortfalls in provision, is also consistent with the NPPF.

Paragraph 5.6 and Policing Infrastructure:

The Police also welcome the inclusion of the additional text at paragraph 5.6 of the Plan which states that:

“where the Police identify that development would create additional pressure on services a contribution will be sought towards additional infrastructure.”

As such, this recognises the direct impact that new development can have on policing infrastructure serving Torbay, and its implications if unmitigated would be unsustainable.

However, for consistency, Policing Infrastructure should also be included within the Council’s Infrastructure Delivery Plan within the ‘types of infrastructure projects’ that would be eligible for Section 106/developer contributions and CIL funding, including the updated version of the Planning Contributions and Affordable Housing Statement which is due to be prepared.

It should also be noted that, in the context of police infrastructure, the types of infrastructure are not limited to buildings, but also include:

Personal Protective Equipment (PPE);
Vehicles;
Bicycles;
Communications equipment;
Technology; and
Surveillance infrastructure such as CCTV.

The Police have an established methodology for calculating potential developer contributions towards the provision of policing infrastructure which has been prepared in accordance with best practice recommended by the National Police Chiefs’ Council (NPCC) in collaboration with the National Police Estate Group.

This methodology has been strenuously tested at many public inquiries nationally and found to be wholly in accordance with the three statutory tests set out in the CIL Regulations 122 by the Secretary of State and the Planning Inspectorate.

As such, the principle of seeking developer contributions towards policing infrastructure is well established:

Jelson Ltd v Secretary of State for Communities and Local Government [2016] EWHC 2979 (Admin), upheld [2018] EWCA Civ.24; and
R (Police and Crime Commissioner for Leicestershire) v Blaby District Council [2014] EWHC 1719 (Admin).

The recognition given to the increased demand on Police services which justifies the request for developer contributions towards additional infrastructure in the updated version of paragraph 5.6 is also strongly supported and should be retained going forward.

Conclusion

No further modifications to paragraph 5.6 are sought.

Conclusion

No further modifications to Strategic Policy SCS are sought.

Support

Representation ID: 3358

Received: 23/09/2026

Respondent: Devon and Cornwall Police (Statutory / General Consultation Body)

The Police support the revised wording to include “Policing” under Strategic Policy IN1 v) within the range of Broader Sustainable Development Contributions identified.

The inclusion of policing within the Broader Sustainable Development Contributions under Policy IN1 v) is now consistent with Policy TC10 and Strategic Policy SCS, both of which reference contributions towards policing.

It is therefore considered that Strategic Policy IN1 meets the tests of soundness and is consistent with the NPPF.

The Police support the revised wording to include “Policing” under Strategic Policy IN1 v) within the range of Broader Sustainable Development Contributions identified.

Paragraph 7.10 confirms that:

“these will be sought to support infrastructure and other requirements that development generates a need for”

and states under 5. that:

“this covers………safety facilities.”

The express recognition given to “safety facilities”, which covers Police Stations and other policing infrastructure, is welcomed and should be retained in future versions of the Plan.

Furthermore, the inclusion of policing within the Broader Sustainable Development Contributions under Policy IN1 v) is now consistent with Policy TC10 and Strategic Policy SCS, both of which reference contributions towards policing.

It is therefore considered that Strategic Policy IN1 meets the tests of soundness and is consistent with the NPPF.

Conclusion

No further modifications are necessary to paragraph 7.10(5). It should be retained as proposed.

Conclusion

No further modifications are sought to Strategic Policy IN1.

Object

Representation ID: 3359

Received: 23/09/2026

Respondent: Devon and Cornwall Police (Statutory / General Consultation Body)

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Policy SC5 seeks to support sustainable communities where residents enjoy a high quality of life by protecting, retaining and enhancing existing community facilities, including resisting the loss of needed community facilities and ensuring that new community facilities are located in accessible locations within existing settlements.

The policy states that:

“All development should contribute positively to the provision of the necessary community facility demand that will arise. Major proposals should provide the necessary supporting infrastructure and community facilities proportionate and appropriate to the scale of the development. These will include health, leisure, sport, education, meeting spaces, and cultural infrastructure, cemetery provision and other facilities such as allotments or community food growing.

Local services and facilities should be accessible via their location and have good transport connectivity.

The loss of existing community facilities and buildings will only be supported where it is demonstrated that they are not needed, or improved alternative provision is made.”

Policing is an existing community facility that should be identified within Policy SC5. The existing Police Stations serve the day-to-day needs of local residents and support the role of the town centres, villages and rural areas across Torbay. As such, they help to provide a safe place to live, work and visit.

The omission of policing as a protected facility within the range of supporting infrastructure and community facilities expressly referenced in SC5 is inconsistent with other policies within the Plan that refer to “safety facilities” and “policing”.

Proposed Modification 1

To resolve the Police’s concerns, Policy SC5 should be modified to include the following wording (shown in bold below):

“These will include health, leisure, sport, education, meeting spaces, policing and safety facilities, and cultural infrastructure, cemetery provision and other facilities such as allotments or community food growing.”

Draft Policy SC5 also states that:

“The loss of existing community facilities and buildings will only be supported where it is demonstrated that they are not needed, or improved alternative provision is made.”

It follows that, during the Plan period, the Police may determine that an existing Police Station is surplus to operational requirements and no longer needed. However, it is important that the Police are the appropriate body to determine the need for policing infrastructure within an area, with the overall decision resting with the Chief Constable and Police and Crime Commissioner.

Proposed Modification 2

To address this concern, the following amendment to Policy SC5 is proposed:

“The loss of existing community facilities and buildings will only be supported where it is demonstrated that they are not needed by the relevant provider, or improved alternative provision is made.”

If this amendment is made to Policy SC5, it would resolve the Police’s concerns and would assist in ensuring the policy meets the tests of soundness and is consistent with the NPPF.

Existing and Future Police Infrastructure in Torbay
Paignton Police Accommodation

DCP is currently in discussions with Torbay Council regarding opportunities to improve police infrastructure in Paignton. Both organisations are seeking to secure an extension to the Police accommodation within the Paignton Library and Information Centre (PLAIC).

The extension is required because the existing accommodation is inadequate to meet the operational needs of policing in Paignton and cannot accommodate any future increase in officer numbers associated with planned growth. As a result, development in Paignton that generates additional policing demand would be unsustainable unless the existing accommodation is expanded.

There is therefore an immediate and important need to extend the existing Paignton Police Office. This priority should be identified in the emerging Local Plan, together with funding mechanisms to secure delivery of this critical infrastructure in support of the Council’s Vision and Strategic Objectives.

Torquay Police Station

In the longer term, a need may arise to replace Torquay Police Station, or at least plan for its replacement during the lifetime of the Local Plan. Whilst this may influence longer-term decisions regarding police infrastructure elsewhere in Torbay, the need for investment in Paignton is sufficiently urgent that it should not be delayed pending any future decisions regarding Torquay.

Furthermore, there may be a need during the Plan period for the Council and the Police to work together to identify an appropriate location for a replacement Police Station serving Torquay.

The existing accommodation is outdated, overcrowded and not suited to the requirements of modern policing. Torquay Police Station also serves a wider strategic function, accommodating services supporting policing across the whole South Devon Basic Command Unit (BCU). Consequently, this matter has implications beyond Torquay itself and should be considered as part of Torbay’s wider critical infrastructure planning.

Beanland Gardens

Adjacent to Torquay Police Station, DCP owns three listed Georgian buildings collectively known as Beanland Gardens.

Until recently, these buildings accommodated DCP’s Public Protection Unit (PPU) and Torbay’s Achieving Best Evidence (ABE) interview suites. During September and October 2026, these functions relocated to new accommodation at Edginswell, leaving the Beanland Gardens buildings surplus to operational requirements.

DCP cannot currently justify disposing of the buildings because of their relationship with the adjoining Police Station. However, a sustainable alternative use should be identified that:

Does not conflict with the operation of the adjacent Police Station; and
Does not result in the loss of police operational parking.

The Council and the Police should work collaboratively to identify an imaginative and sustainable alternative use for these assets.

Brixham Police Station

Brixham Police Station primarily functions as a neighbourhood policing facility and should continue to provide accommodation to meet local policing needs.

However, as a result of insufficient police accommodation in Paignton, the station currently fulfils a wider operational role than originally intended.

Whilst no immediate changes are proposed for Brixham Police Station, the ongoing review of policing accommodation across Torbay may identify opportunities to improve the visibility and effectiveness of neighbourhood policing in Brixham.

Brixham Police Station occupies a large and prominent site on Rea Barn Road and undoubtedly has potential for alternative residential use. However, any redevelopment could only be contemplated if a superior Torbay-wide policing solution were identified and implemented that demonstrably improved policing provision across the area.

Working with the Council

As a key infrastructure provider for Torbay, the Police would welcome the opportunity to continue discussions with the Council regarding these matters in support of the new Local Plan.

This aligns with the engagement encouraged by the updated NPPF between local planning authorities and infrastructure providers during plan-making. Such engagement is necessary to understand existing infrastructure deficits, identify future requirements arising from development, and respond appropriately to changes in population over the Plan period.

Accordingly, it is important that Policy SC5 supports this process.

Conclusion

The Police request that the proposed amendments to Policy SC5 are incorporated into the Local Plan. These changes would:

Explicitly recognise policing and safety facilities as community infrastructure.
Ensure that decisions regarding the ongoing need for police facilities are informed by the relevant service provider.
Better support current and future policing infrastructure requirements across Torbay.
Improve consistency between Policy SC5 and other policies within the Plan relating to policing and community safety.

The Police therefore consider that, subject to these amendments, Policy SC5 would meet the tests of soundness and be consistent with the NPPF.