Torbay Local Plan Regulation 19 Publication Version and Consultation

Comment

Representation ID: 3409

Received: 24/09/2026

Respondent: South Hams & West Devon Council (Statutory / General Consultation Body)

Strategic Matter: Torbay’s Unmet Housing Need

Representation Type: Comment

Comment:

The Regulation 19 consultation specifically records concerns from neighbouring authorities and statutory consultees regarding Torbay's housing target and cross-boundary implications.

Torbay is planning for approximately 8,000 dwellings (400 dwellings per annum) rather than meeting the full Standard Method housing need. South Hams has consistently raised this as an issue, as it is unlikely to be able to accommodate any unmet need arising from Torbay.

The consultation notes support for the strategic direction to be provided through a future Devon-wide Strategic Development Strategy but identifies continuing soundness concerns regarding housing provision and cross-boundary strategy. There remains a risk at examination that Inspectors may question how unmet housing need is to be addressed and whether reliance on wider Devon arrangements is sufficiently evidenced.

The Council sympathises with Torbay’s difficult challenge of balancing levels of development with the protection of Torbay’s unique character and sensitive landscapes, including the South Devon National Landscape, and supports its aim of focusing on previously developed land first through the redevelopment of existing sites and buildings, including the conversion of some hotels to homes.

Comment

Representation ID: 3410

Received: 24/09/2026

Respondent: South Hams & West Devon Council (Statutory / General Consultation Body)

A385 Corridor Transport Impacts (Collaton St Mary / Totnes Road)

One of the strategic growth areas is proposed in the Collaton St Mary / Totnes Road (A385) corridor, where the development of housing sites is already underway.

Development in this location will inevitably add traffic to the main A385 through Totnes. This needs to be properly modelled and considered in transport assessments, and alternative modes of transport to the private car should be a requirement of any development scheme.

The Council has previously raised concerns regarding the need for infrastructure impacts arising from the proposed sites to be properly masterplanned and for sustainable travel measures to be delivered alongside growth.

Some of the strategic growth areas, specifically those proposed in the Collaton St Mary / Totnes Road area, are distant from existing services and facilities and could therefore be heavily reliant on private car use.

All sites proposed in South Torbay will also add pressure to the A385 corridor, as it is one of only two principal highway routes into Torbay.

We support the vision-led approach to minimising the transport impacts of new development through journey reduction and modal shift.

Development in the Totnes Road corridor remains a key growth location in the Regulation 19 Plan.

Whilst the Council recognises that there is potential for further development in this area, it has previously raised concerns that the sites proposed will lead to a linear form of development along the A385 without easy access to local services and facilities.

Sustainable transport links will be necessary within this area to provide an alternative to private car use, which is likely to remain the dominant mode of transport.

As highlighted above, we are concerned that development in this location will increase traffic flows through Totnes and could affect air quality, which will need to be monitored.

The topography of the area is quite complex. However, this means that parts of the growth area are less visually sensitive within the wider landscape. The area also contains landscape features which should be retained to help incorporate development into its wider setting.

The allocation appears to remain largely unaltered from the Regulation 18 consultation and has not been reduced or reshaped in response to concerns regarding linear growth, impacts on the A385 corridor, and access to services and facilities.

However, the Council appreciates that the availability of potential development sites is also an important factor when considering growth options and may mean that the resulting pattern of development is not ideal.

Support

Representation ID: 3411

Received: 24/09/2026

Respondent: South Hams & West Devon Council (Statutory / General Consultation Body)

The Regulation 19 Plan continues to contain strong habitat protections and recognition of internationally important ecological interests. The wider evidence base and environmental chapter continue to support mitigation approaches for protected sites.

The Plan states that any development should also have regard to the in-combination effects of multiple developments that could affect Greater Horseshoe Bats, calcareous grassland features and the integrity of the South Hams SAC.

To mitigate the impact of increased recreational pressure on the South Hams SAC, an 8km zone is identified and any development that comes forward within this area would be required to make a financial contribution towards mitigation measures for the South Hams SAC.

This 8km zone extends into part of the South Hams administrative area.

We support this approach to mitigating potential recreational impacts and welcome the commitment to an improved management plan for Berry Head.

Comment

Representation ID: 3412

Received: 24/09/2026

Respondent: South Hams & West Devon Council (Statutory / General Consultation Body)

H2P.2 Long Road / Yalberton / Inglewood

Representation Type: Comment

Comment:

The Council considers that there is potential for further growth in this area, providing a mixed-use extension to the existing development which includes residential and employment uses.

The proposals for new employment land are welcomed, recognising the benefits of providing more job opportunities within the Bay and potentially helping to reduce travel out of the area for work.

However, the Council has previously raised concerns that any extension would result in development within the countryside and therefore requires sensitive master planning.

Whilst higher-density development may be achievable immediately adjacent to the existing built form, to balance landscape integration with urban growth, built edges should be planned around compact, medium to high-density clusters embedded within generous, connected countryside corridors.

This cluster approach would help buffer visual impact and preserve biodiversity in the short term, whilst ensuring that each cluster of development remains walkable, viable for public transport and easy to integrate into a cohesive urban structure if the area expands in the future.

It is also noted that a further extension is proposed at the Inglewood development. Whilst the site proposed for the extension is not as prominent as the main site and is less exposed to distant views, development of this site will fill the existing rural gap and result in continuous ribbon development along Brixham Road (A3022), creating a hard edge to the built form rather than being interspersed with pockets of open countryside, which would be preferable and easier to assimilate into the wider countryside.

Support

Representation ID: 3413

Received: 24/09/2026

Respondent: South Hams & West Devon Council (Statutory / General Consultation Body)

Stoke Road (H2P.3 in Reg 18 draft plan)
The Council supports the removal of the housing allocation in the Regulation 19 plan.

Support

Representation ID: 3414

Received: 24/09/2026

Respondent: South Hams & West Devon Council (Statutory / General Consultation Body)

Monksbridge, Brixham (H3BCG.3 in Reg 18 draft plan)
Support the removal of this housing allocation in the Regulation 19 plan at this highly sensitive landscape location.

Comment

Representation ID: 3415

Received: 24/09/2026

Respondent: South Hams & West Devon Council (Statutory / General Consultation Body)

H3BCG.2 Archery Field, Churston

The Council remains concerned about the proposed allocation at Archery Field for approximately 50 dwellings.

Whilst the site lies outside the National Landscape designation, it is located within open countryside and forms part of the wider landscape setting experienced from surrounding areas. Development of this site would result in a detrimental impact on the rural and open character of the area.

The Council also questions the suitability of the location. Although the site is located at the edge of Galmpton and is situated close to the Railway Inn, it does not provide convenient access to a range of day-to-day services and community facilities.

Whilst geographically close to Galmpton village, the site is physically separated from the village by the South Devon Steam Railway line, reducing the degree to which residents could readily access local facilities on foot.

Inevitably, future residents are likely to be heavily reliant on private vehicle use for many everyday journeys.

Increased car dependency arising from the development has the potential to add further traffic to the A379/A3022 corridor and exacerbate existing congestion issues at Windy Corner, which is already recognised as operating under significant pressure.

The Council acknowledges the challenges associated with meeting the Bay’s housing requirement, particularly within the southern part of Torbay where environmental and landscape constraints limit development opportunities. It is recognised that Archery Field may represent one of the most deliverable options available to the local planning authority.

Nevertheless, the allocation appears to sit in tension with the wider spatial strategy of the Local Plan, which seeks to prioritise regeneration and growth within the built-up area in order to minimise impacts on the natural environment.