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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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Back to Regulation 18 Consultation review

Chapter-by-chapter review of main consultation representations (detailed version)

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

Statutory and key consultees

Statutory consultees broadly support the overall vision and direction of the Plan, particularly its emphasis on regeneration and sustainable growth. However:

  • MHCLG (Minister Pennycook) raised significant concern regarding the housing target, noting it is substantially below assessed need and must be justified at examination
  • Devon County Council highlighted implications of unmet housing need, particularly cross-boundary infrastructure impacts. This was echoed by district councils including Teignbridge DC.
  • Historic England supported the inclusion of heritage considerations within the vision
  • National Trust noted that unmet housing need is not clearly addressed

Overall, statutory consultees support the strategic direction but highlight soundness risks relating to housing delivery and cross-boundary strategy.

Non-statutory consultees (public and local groups)

Public responses broadly support the ambition for a prosperous and healthy Torbay but raise concerns regarding:

  • The deliverability of the vision
  • Potential conflict between growth and environmental protection
  • Lack of clarity on how objectives will be achieved

Policy/representation themes

  • Supported by Brixham Town Council and Regeneration Partnership
  • MHCLG, National Trust, Devon County Council object to housing levels
  • Historic England supports heritage recognition
  • Police request inclusion of anti-social behaviour
  • Key issue: soundness risk due to housing requirement

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

Statutory and key consultees

Consultees generally support the place-based approach, including regeneration corridors and spatial strategy. However:

  • Concerns raised about growth in rural and sensitive areas (e.g. Monksbridge)
  • Issues around transport accessibility and sustainability of locations
  • Need to ensure landscape, heritage and ecological considerations are embedded

Non-statutory consultees

Public responses strongly emphasise:

  • Protection of local identity, countryside and settlement gaps
  • Concerns regarding:
    • Traffic impacts
    • Flood risk
    • Loss of farmland and rural character

Policy/representation themes

  • SS1: objections on flood risk and transport
  • SDBCG3: strong objections on landscape and ecology
  • Requests for improved infrastructure integration

Chapter 3: Housing and Regeneration Policies

Statutory and Key Consultees

This chapter generated significant objection from statutory consultees, particularly on housing numbers and site allocations:

  • MHCLG, Exeter City Council, Teignbridge District Council, National Trust: Strong concern that the 400 dpa target is unjustified.
  • There needs to be a no-stone left unturned approach to identifying housing land. Teignbridge District Council note that this should include existing and prospective holiday park uses.
  • Authorities claimed that they are unable to accommodate unmet need.
  • Concerns regarding:
    • Site sustainability
    • Development in sensitive landscapes
    • Lack of evidence for distribution of growth

Some consultees (e.g. Regeneration Partnership) support:

  • Brownfield regeneration
  • Delivery-led housing approach

Non-statutory consultees

Public responses strongly object to:

  • Greenfield and rural site allocations
  • Scale of development in villages and edge-of-settlement locations

Common concerns include:

  • Flood risk
  • Traffic and highway safety
  • Impact on wildlife and habitats
  • Loss of landscape character

There is consistent support for:

  • Brownfield redevelopment
  • Town centre regeneration
  • Delivery of genuinely affordable housing

Policy/representation themes

  • Strategic Policy HS criticised
  • H1/H3 mixed responses
  • Affordable housing supported but viability concerns

Chapter 4: Building a prosperous and inclusive Torbay - Unlocking opportunity for all

Statutory and key consultees

General support for:

  • Town centre regeneration
  • Economic diversification

Specific comments include:

  • Need to address crime and anti-social behaviour (Police)
  • Support for tourism and rail connectivity (Network Rail)
  • Need for clearer policy wording and definitions

Non-Statutory Consultees

Strong public concerns about:

  • Decline of town centres
  • Safety and antisocial behaviour
  • Empty and poor-quality buildings
  • Reinstate Babbacombe as a Local Centre.

There is strong support for:

  • Regeneration
  • Reuse of vacant buildings
  • Improving attractiveness and safety

Policy/representation themes

  • TC2: request to strengthen crime wording
  • TCS: supported but needs clarity
  • TOS and E1 broadly supported

Chapter 5: Thriving communities - Wellbeing, safety and belonging

Statutory and key consultees

Support for:

  • Community infrastructure provision
  • Health and wellbeing objectives

Key issues raised:

  • Need for adequate policing infrastructure contributions
  • Importance of early engagement with infrastructure providers
  • Need for cemetery provision.

Non-statutory consultees

Public responses highlight:

  • Pressure on services such as:
    • Schools
    • GP surgeries
    • Community facilities

Concern that growth must be aligned with service provision

The role of faith groups in providing community benefits and alleviating social isolation should be recognised.

Policy/representation themes

  • SC5/SCS supported
  • Requests for crime assessments and stronger links
  • Need updated funding frameworks

Chapter 6: Moving Torbay - Sustainable travel and inclusive access

Statutory and key consultees

Support for sustainable transport objectives but concerns about:

  • Lack of delivery mechanisms
  • Need for stronger requirements on:
    • Walking and cycling infrastructure
    • Public transport improvements

Network Rail emphasised:

  • Rail connectivity
  • Safety around level crossings

Non-statutory consultees

Public responses highlight:

  • Unreliable public transport
  • Poor walking/cycling infrastructure
  • Over-reliance on cars

Strong support for:

  • Better bus services
  • Safer walking and cycling routes

Policy/representation themes

  • TA1 The wording should be strengthened.
  • Need measurable targets and funding clarity
  • Cross-boundary transport noted

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

Statutory and key consultees

Significant concerns raised, particularly by:

  • Environment Agency:
    • Lack of Infrastructure Delivery Plan
    • Uncertainty around water, drainage and sewer capacity
  • Utilities providers highlighted:
    • Need for early planning of infrastructure
    • Capacity constraints in some locations
    • Water supply and drainage constraints
    • No waste management capacity for growth

Non-statutory consultees

Public responses strongly emphasise:

  • Infrastructure is already under pressure
  • Development should not proceed ahead of infrastructure

Policy/representation themes

  • IN1/INS suggested as requiring inclusion of policing contributions
  • Environment Agency highlights evidence gaps
  • Poor viability to support S106/CIL particularly from brownfield sites.

Chapter 8: Climate Change - Our sustainable and resilient future

Statutory and key consultees

This chapter received substantial technical objection, especially from:

  • Environment Agency:
    • Need to complete the Strategic Flood Risk Assessment
    • Concerns about water quality, sewer capacity and climate adaptation
  • Need to strengthen:
    • Policy wording
    • Evidence base
    • Mitigation measures

Non-statutory consultees

Public concerns reflect:

  • Flood risk
  • Coastal change
  • Environmental protection

Strong support for:

  • Robust climate policies
  • Environmental safeguards

Policy/representation themes

  • Suggested as needing stronger policy wording
  • Drainage and water management concerns
  • Plan suggested as not sound without updated evidence

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

Statutory and key consultees

Strong support for environmental protection policies, but:

  • Natural England emphasised:
    • Protection of SACs (particularly bats)
    • Need for robust mitigation and evidence
  • Concerns about:
    • Impact on designated landscapes
    • Biodiversity loss

Non-statutory consultees

This is the strongest theme in public responses:

  • Strong opposition to development on:
    • Greenfield sites
    • Coastal sites
  • High value placed on:
    • Landscape
    • Biodiversity
    • Recreation

Policy/representation themes

  • GIS supported but suggested as needing more detail
  • BNG supported
  • Landscape policies require clarity. Special duty towards National Landscape.

Chapter 10: Our Shared History - Protecting and enhancing Torbay's heritage and identity

Statutory and key consultees

General support but key concerns:

  • Need for:
    • Updated evidence base
    • Clearer policy wording
  • Significant objections to some site allocations due to:
    • Harm to heritage assets

Non-statutory consultees

Public responses support:

  • Protection of heritage assets
  • Maintaining local character

Policy/representation themes

  • HE policies supported with suggested amendments
  • Requests for archaeology and dissemination detail

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

Statutory and key consultees

Concerns raised regarding:

  • Approach to tall buildings
  • Lack of clarity on:
    • Suitable locations
    • Design parameters

Non-statutory consultees

Public responses emphasise:

  • Need for high-quality design
  • Protection of character

Policy/representation themes

  • DE4 suggested as lacking clarity and up-to-date evidence

Chapter 12: Responsible resource use - Waste and minerals

Statutory and key consultees

Generally supportive, with:

  • Requests for:
    • Clarification of policy wording
    • Alignment with county-level policies

Yalberton WTC is operating at capacity.

Non-statutory consultees

  • Limited public engagement relative to other topics.

Policy/representation themes

  • M1 suggested as requiring better data
  • W1 suggested as needing clarification
  • Support for rail transport

Sustainability Appraisal (SA) – Representations

Statutory consultees

Key concerns raised include:

  • SA is outdated and requires updating
  • Insufficient assessment of:
    • Climate change impacts
    • Water infrastructure constraints
    • Reasonable alternatives
  • Need for:
    • Improved monitoring framework
    • Alignment with latest evidence

Overall assessment of SA responses

  • Strong expectation from statutory bodies that:
    • The SA must be revised and strengthened prior to Regulation 19
  • Key focus areas:
    • Climate
    • Water
    • Habitat protection
    • Infrastructure capacity

Short survey consultation analysis – Question by question review

Question 1: What matters most to you about Torbay’s future?

Responses show a clear dominance of environmental themes, with the protection of green spaces and coastline the most frequently selected priority.

This is closely followed by demand for affordable housing, improved public transport and connectivity, and the need for more jobs and economic opportunities.

Community safety, infrastructure provision, and preservation of local heritage are also consistently raised, indicating a broad expectation that future development should balance environmental protection, economic growth and quality of life.

Question 2: If you could change one thing about Torbay in the next 10 years, what would it be?

Key issues raised focus on reducing development on greenfield land, improving town centres, and enhancing infrastructure.

A strong theme is the desire for regeneration of existing urban areas, particularly through the reuse of empty shops and brownfield sites. Respondents frequently referenced improving transport infrastructure, addressing congestion, enhancing safety, and tackling visible decline in town centres.

Many responses highlight a need for better public services, including healthcare and education, alongside more employment opportunities.

Question 3: Do you have any further comments about the Local Plan?

Comments highlight concerns about the scale and location of proposed housing development, with strong opposition to building on greenfield sites and in sensitive locations such as Oldway, Meadfoot, Great Hill and coastal areas.

Respondents emphasise that housing should be focused on brownfield land and empty buildings, and must be accompanied by adequate infrastructure.

There are repeated concerns that infrastructure is already under strain and that development should not proceed without guaranteed provision.

A further theme is lack of trust in the planning process, with perceptions that the plan is developer-led and insufficiently responsive to community views. Accessibility of the plan and consultation process was also raised as an issue.

Comprehensive survey responses – Opus Consult and Short Survey

Appendices 1 and 2 include all representations received for review. These are available as separate files.

Late representations (those received after 2 February) are highlighted in grey in Appendix 1.

Let representation summary

There were 35 organisations and individuals who submitted late representations (post 2 February with last representation accepted 13 February) with a breakdown in topics covered below:

  • Monksbridge (Objection to sites H3BCG.3 and E1B.2): 31
  • Great Hill (Objection to site H3T.4): 1
  • Meadfoot Beach (Objection to site H3T.15): 1
  • Natural England (Various issues): 1
  • Environment Agency (Various issues): 1