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