Torbay Local Plan Regulation 19 Publication Version and Consultation

Comment

Representation ID: 3283

Received: 24/09/2026

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

Economy and Employment Land
A number of policies relate to the development of employment land, however natural context is missing from the policies. Reference should be made to the inclusion of space for nature within employment areas in order to ensure that people are able to work in areas where they are connected with nature.

Comment

Representation ID: 3284

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’ (Strategic Policy SDB3). Reference to this policy must be included within Strategic Policy TO3 as
it potentially undermines SDB3.

Comment

Representation ID: 3285

Received: 24/09/2026

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

As previously, reference to Strategic Policy SDB3 is required.
‘The development does not have an adverse impact on the landscape, conservation, nature conservation’ and ‘Where proposals fall within Greater Horseshoe Bat consultation zones, they must protect foraging habitat, commuting routes and dark corridors’. Reference to enhancement is
missing from these pieces of text.

Comment

Representation ID: 3287

Received: 24/09/2026

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

The policy currently lacks specific 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 high quality green infrastructure, including street trees, green roofs, green walls, sustainable drainage
features and the creation of biodiverse public spaces’.

Comment

Representation ID: 3288

Received: 24/09/2026

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

‘Do not have an unacceptable impact on landscape sensitivity, biodiversity’ This needs to be rephrased to include reference to ‘enhancement’.

Comment

Representation ID: 3289

Received: 24/09/2026

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

‘Development does not have an unacceptable impact, including cumulative impact, on residential amenity, landscape character or wildlife’. This needs to be rephrased to include reference to ‘enhancement’.

Comment

Representation ID: 3293

Received: 24/09/2026

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

This policy places emphasis on reducing or mitigating climate impacts, but opportunities should also be taken to secure positive climate outcomes. Policies should encourage development to contribute actively to climate change mitigation and adaptation through measures such as carbon sequestration, habitat creation, urban greening, sustainable drainage and climate-resilient design, rather than merely minimising adverse effects.

Comment

Representation ID: 3294

Received: 24/09/2026

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

‘Proposals must seek to reduce surface water discharge to the combined sewer network and will be supported where this is achieved. Development must not discharge surface water in the combined sewer network.’
We welcome the clear statement that development must not discharge surface water in the combined sewer network, however this is directly contradicted by the preceding text. Text should be amended to clarify the position.

Comment

Representation ID: 3295

Received: 24/09/2026

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

‘Outside settlement boundaries, the following forms of development may be permitted, provided that the rural and landscape character, wildlife habitats, green corridors and historic features are not adversely affected and necessary mitigation measures are carried out to minimise any harm
to the environment’. This needs to be rephrased to include reference to ‘enhancement’.

Comment

Representation ID: 3296

Received: 24/09/2026

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

‘Proposals within the setting of a National Landscape must not harm the setting and should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas’. This needs to be rephrased to include reference to ‘enhancement’.