Find out about the results of the Regulation 18 of the Draft Local Plan consultation.
This Consultation Statement has been prepared in accordance with Regulation 22 of the Town and Country Planning (Local Planning) (England) Regulations 2012. It sets out how Torbay Council has undertaken consultation under Regulation 18 of the Local Plan preparation process and how representations have been taken into account in preparing the Regulation 19 Submission Local Plan.
The Regulation 18 consultation invited comments on the Draft Local Plan 2025 to 2045, including policies, site allocations and the supporting Sustainability Appraisal. This statement summarises the main issues raised and explains how these have informed revisions to the Plan.
The Regulation 18 consultation was undertaken over a period in line with statutory consultation requirements. The council engaged a wide range of stakeholders including residents, statutory consultees, developers, businesses and neighbouring authorities.
Methods of consultation included online engagement via a consultation portal (using Opus Consult), live events at the three main towns of Torquay, Paignton and Brixham, publication of documents on the council’s website, online presentations with question and answer sessions, direct notification to consultees, attendance at local interest group meetings, and availability of supporting documents. In support of the online consultation site, a short survey was hosted online to gather anonymous public opinion on a range of planning matters.
1,813 representations were received, demonstrating high levels of engagement across the authority area.
Representations were received from a broad range of respondents including:
Statutory consultees provided detailed technical responses focusing on infrastructure, housing delivery, environmental requirements and compliance with national policy.
1,813 representations were received from a combination of online consultation, email and paper responses.
| Ward | Local Authority | Count | Respondent IDs |
|---|---|---|---|
| Duke's | Sefton | 1 | 3327 |
| Hinckley De Montfort | Hinckley and Bosworth | 1 | 3672 |
| Dartmouth and East Dart | South Hams | 2 | 3522, 3553 |
| Marldon and Littlehempston | South Hams | 2 | 3408, 3556 |
| Totnes | South Hams | 3 | 3377, 3651, 3655 |
| Backwell | North Somerset | 1 | 3646 |
| Central | Bristol, City of | 3 | 3502, 3645, 3650 |
| Clifton | Bristol, City of | 1 | 3633 |
| Newtown and Saint Leonard's | Exeter | 1 | 3642 |
| Pinhoe | Exeter | 1 | 3668 |
| Priory | Exeter | 1 | 3530 |
| Saint David's | Exeter | 1 | 3644 |
| Saint Loyes | Exeter | 3 | 3640, 3641, 3643 |
| Castle | Hastings | 1 | 3647 |
| Broadclyst | East Devon | 1 | 3648 |
| Buckland and Milber | Teignbridge | 2 | 3532, 3545 |
| College | Teignbridge | 1 | 3664 |
| Kenn Valley | Teignbridge | 1 | 3684 |
| Kerswell-with-Combe | Teignbridge | 2 | 3552, 3607 |
| Kingsteignton East | Teignbridge | 1 | 3537 |
| Shaldon and Stokeinteignhead | Teignbridge | 31 | 3332, 3336, 3378, 3404, 3405, 3406, 3463, 3464, 3471, 3472, 3475, 3497, 3498, 3500, 3501, 3510, 3534, 3535, 3541, 3546, 3596, 3599, 3601, 3603, 3609, 3612, 3615, 3631, 3709, 3736, 3747 |
| Boyd Valley | South Gloucestershire | 1 | 3564 |
| Chorley North West | Chorley | 1 | 3567 |
| Saint James's | Westminster | 2 | 3494, 3656 |
| Long Rock, Marazion and Saint Erth | Cornwall | 1 | 3443 |
| Taunton South | Somerset | 1 | 3667 |
| Berry Hill | Mansfield | 1 | 3400 |
| Kings Hill | Tonbridge and Malling | 1 | 3669 |
| Letchworth Wilbury | North Hertfordshire | 1 | 3621 |
The main issues raised through the Regulation 18 consultation can be summarised as follows:
Overall, there is strong and consistent support for the strategic vision underpinning the Plan. Respondents broadly endorse the ambition to deliver regeneration-led growth, support inclusive economic development, and protect Torbay’s natural and built environment. The emphasis on climate change mitigation, sustainability, and place-making is widely supported and aligns with national planning priorities.
However, a number of the consultation responses demonstrate a fundamental and consistent concern regarding the deliverability and soundness of the Local Plan in its current form. There is a clear perception that the Plan does not provide a credible framework for delivering the level of development required to meet identified housing needs.
The most significant issue raised relates to the housing requirement within the Plan. The proposed provision of approximately 400 dwellings per annum is widely considered to fall substantially below the standard method requirement of approximately 970 dwellings per annum. This gap is highlighted by MHCLG, developers, land promoters and statutory bodies and neighbouring councils as presenting a major risk to the soundness of the Plan at Examination. Many respondents argue that the Plan is not positively prepared, is not justified by adequate evidence, and is unlikely to be effective in delivering sustainable development.
A key area of contention relates to Policy H3, which identifies allocated housing sites. Representations demonstrate very high levels of objection to a number of proposed allocations, particularly those at Monksbridge/Mathill, Maidencombe and other edge-of-settlement locations. These objections raise concerns relating to flood risk, highway capacity, ecological impacts (including impacts on Special Areas of Conservation and protected species), loss of agricultural land, and the adequacy of local infrastructure. In several cases, respondents also question the deliverability of sites due to land ownership constraints.
Infrastructure capacity is a dominant and recurring theme throughout the consultation responses. Concerns are consistently raised regarding the ability of existing infrastructure to support planned growth. This includes pressures on healthcare provision, education facilities, drainage and wastewater systems, and the transport network. There is a clear and consistent message that additional development must be supported by robust and deliverable infrastructure planning.
Environmental protection is also a significant issue. There is strong public support for protecting designated landscapes, including the Area of Outstanding Natural Beauty, as well as safeguarding biodiversity and ecological networks. Many respondents object to the release of greenfield land for development and advocate for a stronger focus on brownfield regeneration. However, developers and agents highlight that reliance on brownfield sites alone is unlikely to deliver the required level of housing.
Viability and deliverability concerns are also raised, particularly in relation to the cumulative impact of policy requirements. Contributions required for affordable housing, climate change mitigation, infrastructure delivery and design standards are seen by some respondents as creating an excessive burden that may restrict development coming forward in practice.
The Sustainability Appraisal accompanying the Local Plan is broadly supported in principle, but several respondents indicate that it does not adequately assess alternative growth scenarios, particularly higher housing delivery options. Strengthening this evidence base will be essential to support the Plan at the next stage.
Representations raised a consistent set of issues centred on the protection of Torbay’s green spaces, countryside and coastline, with strong opposition to greenfield and coastal development.
Site specific concerns were raised including objections to sites such as Monksbridge/Mathill, Oldway, Meadfoot, Great Hill and other Maidencombe locations.
While there is recognition of the need for housing, support is conditional on it being genuinely affordable, focused on brownfield land and town centre regeneration, and supported by adequate infrastructure.
Respondents highlighted concerns about the decline of town centres, including vacancy, poor maintenance and antisocial behaviour, alongside strong support for regeneration and reuse of existing buildings.
Infrastructure capacity emerged as a critical issue, with widespread concern that development is outpacing provision of transport, healthcare, education and drainage.
Transport was also frequently raised, with calls for more reliable public transport and safer walking and cycling routes.
Finally, respondents expressed concerns about the accessibility and transparency of the Local Plan process, seeking clearer communication and reassurance that community feedback is influencing outcomes.
The council has carefully considered all representations received and has initiated several changes informed by the consultation process.
These include:
Further detail on specific changes is set out in the accompanying Appendix 2 ‘Recommended Changes to the Local Plan’ which includes officer commentary on key policy updates.
The council will continue to engage with stakeholders as the Local Plan progresses through Regulation 19 and Examination. Constructive engagement with statutory consultees and key stakeholders will ensure that the Plan remains deliverable and robust.
The Local Plan will return to full Council later in 2026 prior to submission to the Secretary of State by the end of 2026.
The Regulation 18 consultation has provided valuable feedback on the Draft Local Plan. While there is broad support for the vision and strategic direction, the council recognises that revisions were required to address concerns regarding housing delivery, infrastructure capacity and site allocations.
In order to progress to the next stage, it will be necessary to strengthen the evidence base, review housing requirements, reassess site allocations and provide a clear and deliverable infrastructure plan. Failure to address these issues is likely to result in significant challenges at Examination. Work on all of these matters is underway.