Torbay Local Plan Regulation 19 Publication Version and Consultation

Comment

Representation ID: 3272

Received: 24/09/2026

Respondent: Devon Wildlife Trust (Statutory / General Consultation Body)

‘Particular attention also must also be given to Cirl Bunting habitat’ should be replaced with ‘Particular attention shall be given to the protection, restoration and enhancement of habitats supporting Cirl Buntings and other priority species’.

Comment

Representation ID: 3273

Received: 24/09/2026

Respondent: Devon Wildlife Trust (Statutory / General Consultation Body)

‘safeguard or enhance’ should be replaced with ‘safeguard and enhance’.

Comment

Representation ID: 3274

Received: 24/09/2026

Respondent: Devon Wildlife Trust (Statutory / General Consultation Body)

Figure 8. The phrase 'constrained by protected landscapes and conservation areas' portrays environmental and heritage assets as barriers to development rather than valuable features that
contribute to the area's character, attractiveness and sustainability. The wording should be revised to recognise these assets as opportunities and strengths that help shape high-quality places. ‘Shaped by nationally important landscapes, biodiversity and heritage assets’ would be
more appropriate text.

Comment

Representation ID: 3275

Received: 24/09/2026

Respondent: Devon Wildlife Trust (Statutory / General Consultation Body)

‘Should existing uses, including holiday parks in the SDNL and Core GHB Sustenance Zone cease to operate, there will be an expectation that they should revert to open countryside’. DWT welcomes this robust policy approach,
Figure 9 - again ‘safeguard’ alone does not comply with NPPF. This needs to be rephrased to include reference to ‘enhancement’.

Comment

Representation ID: 3276

Received: 24/09/2026

Respondent: Devon Wildlife Trust (Statutory / General Consultation Body)

‘Safeguard’ continues to be used in isolation throughout this policy. This needs to be rephrased to include reference to ‘enhancement’.

Comment

Representation ID: 3277

Received: 24/09/2026

Respondent: Devon Wildlife Trust (Statutory / General Consultation Body)

‘Particular attention should also be given to the protection and enhancement of Cirl Bunting habitat’. Whilst this is an improvement on protection alone, the text should be replaced with ‘Particular attention shall be given to the protection, restoration and enhancement of habitats
supporting Cirl Buntings and other priority species’.

Comment

Representation ID: 3278

Received: 24/09/2026

Respondent: Devon Wildlife Trust (Statutory / General Consultation Body)

We welcome the inclusion of the additional ecological requirements within this policy ‘These should achieve no increase in lighting above 0.5 lux in bat flyways’ and ‘Existing green infrastructure assets, trees, hedgerows, and connectivity between individual assets should be
safeguarded or enhanced’ which will result in a strengthening of the biodiversity value of the area
covered by this policy.
This information should also be included in a number of the policies highlighted above, which also contain areas which support important levels of bat activity.

Comment

Representation ID: 3279

Received: 24/09/2026

Respondent: Devon Wildlife Trust (Statutory / General Consultation Body)

The policy states that housing on previously developed land within the settlement boundary will be approved unless specified constraints provide a strong reason for refusal, or adverse effects significantly and demonstrably outweigh the benefits. The specified ecological constraints are principally protected species, Habitats sites, irreplaceable habitats and SSSIs. This does not expressly cover:
 County Wildlife Sites and other Local Wildlife Sites;
 priority habitats and species;
 ecologically important brownfield habitat;
 ecological connectivity;
 functionally linked land;
 the mitigation hierarchy; or
 significant cumulative biodiversity harm.
Previously developed land can support open-mosaic habitat, invertebrate assemblages, reptiles, nesting birds and other important ecological features. Brownfield status is not itself evidence of low ecological value.
Suggested replacement text:
‘Proposals for housing on previously developed land within the settlement boundary will be supported in principle where they accord with the development plan.
Previously developed status will not reduce the level of protection afforded to designated sites, protected or priority species, priority habitats, irreplaceable habitats, functionally linked land or ecological networks.
Development must be informed by proportionate and up-to-date ecological evidence and must apply the mitigation hierarchy by:
1. avoiding significant ecological harm through site selection and design;
2. minimising unavoidable impacts;
3. securing effective mitigation; and
4. providing compensation only as a last resort.
Development will not be permitted where significant harm to biodiversity cannot be avoided, adequately mitigated or, as a last resort, compensated, or where the proposal would adversely affect the integrity of a Habitats site.’

Comment

Representation ID: 3280

Received: 24/09/2026

Respondent: Devon Wildlife Trust (Statutory / General Consultation Body)

The policy currently lacks any reference to urban greening or green infrastructure. Given the important role that green infrastructure plays in supporting biodiversity, climate adaptation, sustainable drainage, air quality, health and wellbeing, the policy should include a requirement for
development to contribute positively to the greening of town centres through the provision of trees, green infrastructure and biodiversity enhancements. The following text should be included:
‘Development should contribute to the greening of town centres through the incorporation of highquality
green infrastructure, including street trees, green roofs, green walls, sustainable drainage features and the creation of biodiverse public spaces’.

Comment

Representation ID: 3282

Received: 24/09/2026

Respondent: Devon Wildlife Trust (Statutory / General Consultation Body)

‘Other urban brownfield sites will be supported subject to other Local Plan considerations’. As detailed previously, the strong policy support for brownfield redevelopment is concerning because previously developed land can support habitats and species of high ecological value. Brownfield sites are not necessarily of low biodiversity importance and can provide important refuges for
wildlife, particularly in urban areas. The policy should therefore avoid creating a blanket presumption in favour of redevelopment and should instead make clear that proposals must fully assess ecological value and deliver the protection, restoration and enhancement of biodiversity.
This text should be replaced with ‘Proposals for the regeneration of previously developed land within settlement boundaries will be supported where they constitute sustainable development, and protect, restore and enhance the natural environment, including securing biodiversity gains where appropriate’.