Torbay Local Plan Regulation 19 Publication Version and Consultation

Object

Representation ID: 3486

Received: 24/09/2026

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Strategic Policy THS: Trees and Hedgerows

Policy THS is not considered to be sound as it is not justified and not effective.

106. The Plan needs to be clear how all the natural environment policies are intended to work together. For example, how does this policy on protecting trees and hedgerows and woodland interact with the requirement for the 10% national mandatory Biodiversity Net Gain.

Object

Representation ID: 3487

Received: 24/09/2026

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy NC3 is not considered to be sound as it is not justified, not effective and not consistent with national policy.

107. This policy needs updating to reflect the current policy and practice in relation to BNG. The first raft of intended changes to national BNG policy and practice have already been implemented. This includes the introduction of a 0.2 Ha ex-emption and small sites being able to deliver off-site.

108. National policy is clear that there is no need for Local Plans to repeat national guidance, or to seek to augment and change the national BNG policy and practice. The proposed wording of this policy does not completely reflect how BNG works in practice. Off-site units can be purchased wherever they are available. There is not yet universal coverage of all types of off-site credits in all locations across the country. It may therefore be necessary to purchase units outside of Torbay and wider Devon area, and indeed the outside the wider region, in some cases. The statutory BNG metric already penalises schemes that need to buy off-site credits further away from the development schemes, and as such there is justification for any other preference of location within a Local Plan policy.

Object

Representation ID: 3488

Received: 24/09/2026

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy GIS is not considered to be sound as it is not justified and not effective.

109. The Plan needs to be clear how all the natural environment policies are intended to work together. For example, how does this policy on GI interact with the requirement for the 10% national mandatory Biodiversity Net Gain.

Object

Representation ID: 3489

Received: 24/09/2026

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The lack of a Policy and a Monitoring Framework within the Plan is not considered to be sound as it is not justified, not effective and not consistent with national policy.

110. The Plan needs to set out more clearly how and when monitoring will be undertaken, and more information is needed on what action(s) will be taken when if monitoring shows under delivery of housing. Not doing so means the plan will be ineffective.