Torbay Local Plan Regulation 19 Publication Version and Consultation

Comment

Representation ID: 3367

Received: 24/09/2026

Respondent: Lidl

Agent: Rapleys

We write on behalf of our client, Lidl Great Britain Limited (‘Lidl’), in response to the Regulation 19 Publication Version of the Torbay Local Plan, which has been published for consultation by Torbay Council (‘the Council’).

Lidl is a substantial and growing presence in the UK convenience retail market, with over 1,000 stores currently trading and more than 35,000 employees. As the fifth-biggest supermarket in the UK, Lidl is a key national employer.

As part of its ongoing expansion programme, Lidl is eager to bring forward new stores within the Torbay area. As such, Lidl is keen to ensure that the Council’s emerging Local Plan facilitates sustainable retail investment in the area.

With this in mind, this representation responds to those policies of particular relevance to Lidl’s interests in the area, namely:

Strategic Policy HS
Strategic Policy H2
Policy TC5
Policy TC6
Policy E4
Strategic Policy HS: Overall Housing Strategy and Presumption in favour of Urban Regeneration
Strategic Policy H2: Future Growth Areas

Lidl supports the identification of Future Growth Areas as specified under Strategic Policy HS and Strategic Policy H2 as areas for residential and mixed-use development.

If significant new residential development is coming forward which requires community facilities and public service infrastructure, in many cases, additional food retail provision is also required to meet the needs of these new residents and the potential increased population of a settlement.

By way of example, a 2,000-dwelling housing requirement and its associated population would create enough convenience retail expenditure to support a new Lidl store. It is therefore important that retail development needs can be appropriately met, especially given the importance of food retail to the functioning of the country and the vital role retailers such as Lidl perform in providing sustainable access to healthy, affordable food for communities.

It is Lidl’s view that sustainable mixed-use communities should be brought forward within Torbay, incorporating accessible and affordable food retail provision to support future residential neighbourhoods. Delivering a modern foodstore as part of a wider mixed-use scheme will help ensure that new and existing communities benefit from convenient day-to-day shopping facilities, reducing the need to travel and supporting the creation of well-balanced, sustainable places.

Object

Representation ID: 3368

Received: 24/09/2026

Respondent: Lidl

Agent: Rapleys

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Policy TC5: Managing Retail Outside Designated Centres
Policy TC6: Supporting Access to Local Retail and Services

Lidl objects to draft Policy TC5, which proposes a 500 sq. m retail impact threshold for retail proposals outside defined town centres.

Lidl also objects to draft Policy TC6, which proposes that out of centre retail shop premises should be no more than 280 sq. m.

Over the past 10 to 20 years, the food retail sector has undergone a significant shift. The majority of convenience shopping is now undertaken in mid- to large-format foodstores, many of which are located outside town centres. These formats are typically unsuited to central locations due to their size, parking requirements, and catchment-driven shopping patterns. As a result, the primary trade-draw impacts of new foodstore development tend to fall on existing edge- or out-of-centre facilities, rather than on retailers trading within defined town centres.

It is essential that food retail requirements align with wider policy objectives to ensure that local communities have convenient access to affordable foodstore provision close to where they live and work. Ensuring that retail impact thresholds are proportionate and responsive to local circumstances will help support sustainable patterns of development, reduce the need to travel, and maintain a competitive and accessible food retail offer for residents.

Object

Representation ID: 3369

Received: 24/09/2026

Respondent: Lidl

Agent: Rapleys

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Policy TC6: Supporting Access to Local Retail and Services

Lidl also objects to draft Policy TC6, which proposes that out of centre retail shop premises should be no more than 280 sq. m.

Over the past 10 to 20 years, the food retail sector has undergone a significant shift. The majority of convenience shopping is now undertaken in mid- to large-format foodstores, many of which are located outside town centres. These formats are typically unsuited to central locations due to their size, parking requirements, and catchment-driven shopping patterns. As a result, the primary trade-draw impacts of new foodstore development tend to fall on existing edge- or out-of-centre facilities, rather than on retailers trading within defined town centres.

It is essential that food retail requirements align with wider policy objectives to ensure that local communities have convenient access to affordable foodstore provision close to where they live and work. Ensuring that retail impact thresholds are proportionate and responsive to local circumstances will help support sustainable patterns of development, reduce the need to travel, and maintain a competitive and accessible food retail offer for residents.

Object

Representation ID: 3370

Received: 24/09/2026

Respondent: Lidl

Agent: Rapleys

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Lidl objects to the proposed wording of Policy E4, which specifies that employment comprises uses solely within Use Classes B2, B8 or E(g).

As detailed in the latest version of The Lidl Effect Report (Annex 1), Lidl invested £474m across Great Britain in new stores and distribution centres in 2024. In the same year, Lidl and its supply chain generated £14.5 billion in Gross Value Added (GVA), demonstrating the significant economic contribution associated with its continued expansion.

Lidl creates around 40 full-time equivalent (FTE) new jobs per store, aligned with the Living Wage Foundation rate for all eligible employees, and without the use of zero-hour contracts. It is evident that Lidl stores can deliver a significant contribution to job creation across the borough.

To ensure that investment and jobs are attracted into the borough, it is Lidl’s view that there should be flexibility around the types of uses which are permitted within safeguarded and allocated employment sites. The approach adopted must be consistent with national planning reforms to allow greater flexibility in land use planning, following the introduction of Class E (Commercial, Business and Service) into the Use Classes Order which came into force in September 2020.

It is clear that the Government regards Class E uses as employment generating economic uses. In many cases, Class E uses have the propensity to create more jobs and bring greater economic benefits than a Class B use of comparable size. There is, therefore, sense and logic in grouping Class E uses with Class B uses.

On this basis, Lidl suggests that all Class E uses should be explicitly supported within safeguarded and allocated employment sites, as opposed to just Use Class E(g).