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Part 2: Regulation 19 Consultation review

Find out how the results of the Regulation 18 consultation help us prepare Regulation 19.

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Introduction

This consultation review has been prepared to support the requirements of Regulation 22 of the Town and Country Planning (Local Planning) (England) Regulations 2012. It summarises the main issues raised through representations on the Torbay Local Plan 2025–2045 Publication Plan at Regulation 19 stage (‘the Plan’) and explains how those issues have informed the council’s approach to submission and proposed modifications.

Regulation 19 is the formal publication stage. Representations therefore focused principally on whether the Plan is legally compliant, complies with the duty to co-operate and is sound, including whether it is positively prepared, justified, effective and consistent with national policy.

Consultation undertaken

The Regulation 19 Publication Plan consultation ran from 13 August until 24 September 2026. The council invited formal representations on the Plan and supporting evidence, with particular emphasis on soundness and legal compliance. Consultation material was made available through the council’s online consultation platform and planning webpages, with direct notification to consultees and inspection copies available at Torbay libraries and Torquay Town Hall during opening hours.

The consultation followed three Regulation 18 stages: Growth Options (10 January to 28 February 2022), Housing Site Options (28 October to 5 December 2022), and the Full Draft Local Plan (28 November 2025 to 20 February 2026). The Regulation 19 Plan was informed by those earlier responses and by updated technical evidence.

Who responded

We received 416 representations from 98 individuals or organisations. Of these, 47 were recorded as support, 169 as objections and 200 as comments. The recorded soundness and legal-compliance fields include 243 “not sound” responses and 53 “not legally compliant” responses. A total of 94 representations requested participation at examination hearings.

Response category Representations Share
Support 47 11.3%
Object 169 40.6%
Comment 200 48.1%
Total 416 100%

Geographic origin of representations

Torbay postcodes (TQ1–TQ5) account for 81 representations from 43 respondent IDs. Wider Devon accounts for 85 representations from 22 respondent IDs, and locations elsewhere in the UK account for 85 representations from five respondent IDs. No postcode was supplied for 165 representations from 28 respondent IDs. Geographic interpretation is therefore incomplete and must be read alongside respondent type and the possibility of repeat policy-specific submissions.

Origin Representations Unique respondent IDs Support Object Comment
Torbay postcodes (TQ1 to TQ5) 81 43 8 54 19
Wider Devon 85 22 19 38 28
Elsewhere in the UK 85 5 5 23 57
No postcode supplied 165 28 15 54 96

Main issues raised

Housing requirement, spatial strategy and delivery

Housing generated the greatest concentration of representations. Respondents addressed the overall housing strategy, the scale and location of growth, reliance on urban regeneration, future growth areas and the treatment of existing or proposed allocations. The principal soundness questions concerned whether the strategy is justified by proportionate evidence, whether housing supply is deliverable over the Plan period and whether reasonable alternatives have been assessed transparently.

The shortfall of Torbay’s proposed housing target below the Standard Method Local Housing Need is a principal objection raised by the development industry and some other stakeholders. 

Site-specific allocations

Objections were strongly concentrated on particular housing allocations. The largest hotspot was the Maidencombe area, notably H3T.1, with 39 representations, including 35 objections. Policy H1cT5 Barton Hill Road, Torquay received two objections, and H3T5 Broadley Drive Livermead one objection. Other notable areas included the wider H3 policy, H3T.2 and the Brixham growth strategy. Issues raised across site-specific responses included suitability, landscape and ecological effects, access and transport, infrastructure capacity, drainage, heritage, cumulative impacts, deliverability and the form of mitigation required.

Infrastructure capacity and delivery

Representations sought clearer evidence that transport, health, education, water, wastewater, drainage, utilities and community infrastructure can support the proposed pattern of growth. Respondents also requested greater certainty about timing, delivery responsibilities, funding, viability and the relationship between development, planning obligations and infrastructure provision. There were requests for S106 Infrastructure contributions from several providers. 

Natural environment, climate and heritage

Representations generally supported strong protection for biodiversity, designated sites, landscapes, coast, heritage assets and local character, while seeking clearer policy tests and implementation requirements. Detailed comments addressed ecological networks and supporting habitat, biodiversity net gain, drainage and water quality, climate resilience, urban greening, design quality and the need to avoid, mitigate or compensate for effects in a policy-compliant sequence.

Legal compliance, soundness and evidence

Some respondents challenged the adequacy of the evidence base, the assessment of alternatives, viability, deliverability, legal compliance and cross-boundary working. The council’s submission material should maintain a clear audit trail between each representation, the issue raised, the officer response and any proposed main or additional modification.

Policies attracting the most representations

Policy or section Total Support Object Comment
H3T.1 39 0 35 4
SS1: Torbay Growth Strategy 19 2 9 8
HS: Overall Housing Strategy 18 2 9 7
H3: Other Local Plan allocated sites 13 1 7 5
Chapter 1: Our shared vision 10 1 5 4
H3T.2 10 0 9 1
SDB1: Brixham strategy 9 0 8 1
Chapter 3: Housing and Regeneration 9 1 5 3
H2: Future Growth Areas 8 0 3 5
SCS: Sustainable and inclusive communities 7 3 1 3

Chapter-by-chapter review

Chapter Representations Support Object Comment Not sound Review
1. Our shared vision 31 2 8 21 24 Mixed response; principal themes were housing, process and transport.
2. Shaping our places 65 2 31 32 34 Mixed response focused on housing, nature and the economy.
3. Housing and Regeneration 140 9 89 42 101 Objection-led; requires the most detailed response on evidence, deliverability and requested changes. Most responses from the public were site specific objections; whilst stakeholders raised soundness issues, especially around meeting need.
4. Prosperous and inclusive Torbay 44 7 15 22 30 Mixed response concerning the economy, heritage and housing.
5. Thriving communities 21 7 4 10 6 Generally balanced response on community, infrastructure and housing. The need to review sports/recreation provision and more burial space was noted.
6. Moving Torbay 10 2 2 6 3 Limited volume, with transport, infrastructure and community themes.
7. Infrastructure and contributions 11 5 4 2 4 Support-led, with requests for refinement and clearer implementation.
8. Climate Change 20 4 9 7 11 Objection-led; issues centred on climate, housing and process.
9. Our Natural Places 44 5 6 33 10 Comment-led, with detailed nature, heritage and process amendments.
10. Our Shared History 8 0 0 8 8 All recorded as comments; heritage, nature and process issues predominate.
11. Designed with quality 15 0 1 14 11 Comment-led requests relating to heritage, nature and housing.
12. Waste and Minerals 7 4 0 3 1 Support-led; comments sought refinement on resources, nature and heritage.
13. Sustainability Appraisal 0 0 0 0 0 No Regulation 19 representations recorded in the chapter field.

Chapter by chapter executive summary:

Chapter 1: Our shared vision – A healthy, happy and prosperous Torbay

The chapter attracted 31 representations, predominantly comments. Responses addressed whether the vision is supported by a deliverable housing strategy, clear priorities, sustainable transport and an evidence-led preparation process. The council should retain supported strategic aims while ensuring that the vision is translated consistently into measurable policies and delivery mechanisms.

Chapter 2: Shaping our places – Local identity and community-led planning

The chapter received 65 representations, evenly split between objections and comments. Responses focused on the spatial strategy, place-based policies, housing distribution, environmental constraints, town-centre regeneration and the relationship between strategic growth and neighbourhood planning. SS1 and SDB1 were prominent hotspots.

Chapter 3: Housing and Regeneration Policies

Chapter 3 attracted 140 representations—33.7% of the total—and 89 objections. It contained 101 recorded “not sound” responses. The main issues concerned the overall housing strategy, supply and deliverability, urban regeneration, future growth areas and site allocations. H3T.1 (Maidencombe) was the leading individual hotspot, followed by H3T2 Sladnor Park. The submission response should distinguish strategic housing-number issues from site-specific evidence, mitigation and requested policy changes.

Chapter 4: Building a prosperous and inclusive Torbay

The chapter received 44 representations. Respondents addressed economic growth, employment land, town centres, tourism, heritage and the relationship between jobs, regeneration and housing. Comments indicate support for economic renewal alongside requests for clearer policy tests, delivery expectations and environmental safeguards.

Chapter 5: Thriving communities – Wellbeing, safety and belonging

The chapter attracted 21 representations and had the highest proportion of support among the social-policy chapters. Issues included health and community infrastructure, inclusive communities, access to services, safety and how development contributions will respond to identified needs.

Chapter 6: Moving Torbay – Sustainable travel and inclusive access

Ten representations were recorded. Responses addressed transport capacity, active travel, public transport, accessibility and the relationship between movement infrastructure and the spatial distribution of development. Although volumes were low, transport also appeared as a cross-cutting issue in housing and place-based representations.

Chapter 7: Building for the future – Resilient and smart infrastructure and developer contributions

Eleven representations were recorded, with support the largest category. Respondents nevertheless sought clearer evidence of infrastructure requirements, delivery, costs, responsibilities, timing and funding. The council response should align policy wording with the Infrastructure Delivery Plan and explain how contributions will be secured without undermining viability.

Chapter 8: Climate Change – Our sustainable and resilient future

The chapter received 20 representations, including 9 objections. Issues concerned the strength, evidence and implementation of climate policies, their relationship with housing delivery and viability, resilience to heat and flood risk, sustainable construction, energy and consistency with national policy.

Chapter 9: Our Natural Places – Protecting and enhancing Torbay’s countryside, landscape and natural environment

The chapter attracted 44 representations, of which 33 were comments. Respondents sought detailed clarification or strengthening of policy relating to designated sites, functionally linked land, priority habitats and species, ecological networks, biodiversity net gain, landscape, coast, drainage, water quality and nature recovery. The volume of comments indicates substantial drafting engagement rather than simple support or opposition.

Chapter 10: Our Shared History – Protecting and enhancing Torbay’s heritage and identity

Eight comments were recorded, with no support or objection classifications. Responses focused on the clarity and application of heritage protections, local identity, evidence requirements and the relationship between heritage, regeneration, landscape and design.

Chapter 11: Designed with quality – Taking pride in Torbay’s place-making

Fifteen representations were recorded, 14 of them comments. Respondents addressed design quality, local character, heritage, nature, housing standards and the need for clear, usable policy expectations. The response should retain supported ambitions while clarifying implementation and avoiding duplication.

Chapter 12: Responsible resource use – Waste and minerals

Seven representations were recorded, including four in support and no objections. Comments sought policy refinement concerning resource use, waste, minerals, the natural environment and heritage. The low representation volume should be recognised when drawing wider conclusions.

How issues will be addressed

Officers will review the representations against the published Plan, supporting evidence, national policy and legal requirements. The detailed Regulation 19 response schedule will identify, for each substantive issue, the representation reference, the issue raised, the council’s consideration, the outcome and any action taken.

  • Main modifications should be proposed where a change is necessary to address soundness or legal compliance.
  • Additional modifications should be used for minor drafting, clarity or consistency changes that are not necessary for soundness.
  • No change should be recorded where the issue is already addressed, is not supported by evidence, falls outside the scope of the Local Plan or would conflict with national policy or the Plan’s strategy.
  • Further evidence or clarification should be identified where the response relies on updated technical work, delivery information or a clearer explanation in the submission documents.

Priority should be given to Chapter 3 and the H3 site allocations; the relationship between housing growth and infrastructure capacity; the evidence and audit trail for alternatives, viability, soundness, legal compliance and cross-boundary working; and detailed policy refinements relating to nature, heritage, community wellbeing, design quality and resource use. Supported policy direction should be retained where appropriate. 

Ongoing engagement

Engagement has continued with statutory consultees, neighbouring authorities, infrastructure providers, community organisations, landowners and other respondents where clarification or further technical discussion has been necessary. Statement of common ground with neighbours will be reported separately in the submission evidence. Following submission, the appointed Planning Inspector(s) will determine the examination process, including the matters, issues and questions and participation in hearing sessions.

Data limitations

  • The dataset records representations, not one vote per person; respondents may appear more than once.
  • Postcodes are absent for 165 representations and some supplied postcodes may be incomplete.
  • A contact address does not necessarily identify the location affected by a representation.
  • “Not sound” and “not legally compliant” totals reproduce recorded fields; a blank field does not necessarily indicate agreement.
  • Chapter and policy volumes should be read alongside unique respondent breadth, particularly where one respondent submitted multiple policy-specific representations.

Conclusion

The Regulation 19 consultation generated 416 representations from 98 respondents. Feedback was comment-led overall but objections were concentrated in Chapter 3 and particular housing allocations. The evidence shows that the principal submission-stage tasks are to respond transparently to strategic housing and site-specific objections, demonstrate infrastructure and delivery, maintain a clear soundness and legal-compliance audit trail, and refine policy wording where justified.

This review should be read alongside the full schedule of Regulation 19 representations, the council’s response and modifications schedules, the Sustainability Appraisal, the evidence base and the submission consultation statement.