Torbay Local Plan Regulation 19 Publication Version and Consultation
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Torbay Local Plan Regulation 19 Publication Version and Consultation
Introduction
Representation ID: 3332
Received: 21/09/2026
Respondent: Torquay Neighbourhood Forum (Statutory / General Consultation Body)
Page 26, Item 1.46
Add: “The Plan also seeks to protect and conserve the rural villages in Torquay: Cockington, Edginswell and Maidencombe in accordance with Neighbourhood Plan Policies”
Comment
Torbay Local Plan Regulation 19 Publication Version and Consultation
Strategic Policy SS1: Torbay Growth Strategy - Prioritising our communities through improved health, housing, place making and opportunities for all
Representation ID: 3333
Received: 21/09/2026
Respondent: Torquay Neighbourhood Forum (Statutory / General Consultation Body)
Page 32, Other Housing Allocations
Flood risk is a major concern for Torbay. Therefore we recommend adding a further item to The proposal is subject to an environmental assessment that shows that:
“iv) it must not increase flood risk.”
Comment
Torbay Local Plan Regulation 19 Publication Version and Consultation
Strategic Policy SS1: Torbay Growth Strategy - Prioritising our communities through improved health, housing, place making and opportunities for all
Representation ID: 3334
Received: 21/09/2026
Respondent: Torquay Neighbourhood Forum (Statutory / General Consultation Body)
Page 32 Explanation Item 2.1
Reference also needs to be made to ‘Village envelopes’. Recommend revision: “The term “settlement boundary” is defined in the NPPF, and has the same functional meaning as “within the built up area” or “within the Village Envelope”.”
Comment
Torbay Local Plan Regulation 19 Publication Version and Consultation
Strategic Policy HS: Overall Housing Strategy and Presumption in favour of Urban Regeneration
Representation ID: 3335
Received: 21/09/2026
Respondent: Torquay Neighbourhood Forum (Statutory / General Consultation Body)
Page 69 Item 3.15
Recommend add text as shown: “Proposals on unallocated greenfield sites outside of the settlement boundary (i.e. in the Countryside Area) are likely to be in conflict with both the Local Plan’s strategy and Neighbourhood Plan Policies: therefore they will not be supported unless some other material consideration indicates otherwise.”
Object
Torbay Local Plan Regulation 19 Publication Version and Consultation
H3T.1
Representation ID: 3336
Received: 21/09/2026
Respondent: Torquay Neighbourhood Forum (Statutory / General Consultation Body)
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The Forum supports the Maidencombe Residents’ Association response. Site 21T065 is not sustainable development owing to drainage, access (all residents will require cars as walking & cycling is unsafe), and impact on protected species. It is outside the Settlement Boundary, does not comply with NPPF S5, nor does it comply with NPPF Section 18. It should be removed, reducing the total for H3T.1 to the 20 from 21T143.
Comment
Torbay Local Plan Regulation 19 Publication Version and Consultation
H3T.2
Representation ID: 3337
Received: 21/09/2026
Respondent: Torquay Neighbourhood Forum (Statutory / General Consultation Body)
Site 21T064 Sladnor Park is not a sustainable development location at the scale proposed due to drainage, access by walking and cycling, impact on protected species, and provision of a low carbon development.
The High Court decision did not establish the principle of development. It was a legal interpretation that the 2006-2009 retirement village development had commenced. The subsequent Appeal decision by the Inspector confirmed that development could continue provided that it complies with all the Conditions in the original 2006-2009 Decision Notices, and compliant with current design regulations, of which compliant drainage design is a key condition. It does not of itself establish the right to build a completely different housing scheme.
The 2006-2009 scheme comprised 24 assisted living units, 92 care suites and a 90 bed care unit spread across 4 buildings. The impermeable area for 120 dwelling houses would increase significantly with the greater footprint per dwelling and the necessary access roads. There would be a major adverse impact on both surface water and foul wastewater drainage. There would be a large increase in flood risk to the lower part of Maidencombe. Such a development would be outside the Village Envelope defined in Policy L1, and incompatible with the Guidelines in the Landscape Character Assessment. It would also be in breach of Policy L3: Coastal landscape. In addition Greater and Lesser Horseshoe bats have been recorded on the site along with Cirl Bunting and other protected species.
The allocation should be reduced to 36 dwellings comprising 16 houses and two 10-units apartment buildings which could be built on the footprints of previous buildings, and have less impact on flood risk and foul drainage.
Comment
Torbay Local Plan Regulation 19 Publication Version and Consultation
Policy TC3: District Centres
Representation ID: 3338
Received: 21/09/2026
Respondent: Torquay Neighbourhood Forum (Statutory / General Consultation Body)
Item v) from Policy TC2 should be included in Policy TC3 for St Marychurch, and Preston if Paignton NF agree.
Comment
Torbay Local Plan Regulation 19 Publication Version and Consultation
Policy TA3: Development layout, access and connectivity standards
Representation ID: 3339
Received: 21/09/2026
Respondent: Torquay Neighbourhood Forum (Statutory / General Consultation Body)
Access for emergency vehicles should be specified.
Comment
Torbay Local Plan Regulation 19 Publication Version and Consultation
Strategic Policy CERS: Climate resilient, net zero carbon developments
Representation ID: 3340
Received: 21/09/2026
Respondent: Torquay Neighbourhood Forum (Statutory / General Consultation Body)
Item iii)
Need to include other sources of energy demand such as 24/7 pumping of waste water.
Comment
Torbay Local Plan Regulation 19 Publication Version and Consultation
Strategic Policy L1: Protecting our countryside and rural economy
Representation ID: 3341
Received: 21/09/2026
Respondent: Torquay Neighbourhood Forum (Statutory / General Consultation Body)
The Torquay Neighbourhood Plan will include Village Envelopes for Cockington, Edginswell and Maidencombe, so this needs to be reflected here, and the Policies Maps amended.