Torbay Heritage Impact Assessment Summary Report May 2025 Torbay Heritage & Design Team

Table of Contents

Introduction	3

Purpose and Scope	4

Methodology	5

Step 1 - Identify which heritage assets are affected by the potential site allocation	6

Step 2 - Understand what contribution the site (in its current form) makes to the significance of the heritage asset(s).	7

Step 3 - Assess the effects of the proposed development on the significance of the heritage asset and its setting	7

Step 4 - Maximising enhancements and mitigating/avoiding harm	8

Outcome of site assessments	9

Summary of Results	9

Torbay HIA Summary Report Appendices	10

Appendix A: Screened out Sites	10

Appendix B: Heritage Impact Assessment of Identified Sites	15

Red list	15

Amber list	16

Green list	17

Introduction

Torbay has a rich and distinctive historic environment that is valued and enjoyed by residents and visitors alike. The bay has a rich urban heritage, contains 24 conservation areas, 5 Grade I Listed Buildings; 28 Grade II* Listed Buildings; and 832 Grade II listed buildings. There are also 15 Scheduled Monuments. Inevitably, there will be sites proposed for allocation where there is a potential conflict between development and the conservation of heritage assets and archaeology. This needs to be considered as developments are being planned, designed, and implemented.

Historic England within their HEAN 3 (2015) – ‘The Historic Environment and Site Allocations in Local Plans’ recognise that “A positive strategy for the historic environment in Local Plans can ensure that site allocations avoid harming the significance of both designated and non-designated heritage assets, including effects on their setting. At the same time, the allocation of sites for development may present opportunities for the historic environment”

The National Planning Policy Framework (NPPF (December 2024)) requires at paragraph 203 that planning authorities deliver sustainable development by ensuring that plans should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay, or other threats. This is supported by related given within Planning Practice Guidance (PPG – Historic Environment).

Locally, Torbay Local Plan Policies SS10 ‘Conservation and Historic Environment’ and HE1 ‘Listed Buildings’ provide the local policy context for historic assets in Torbay, alongside the relevant Neighbourhood Plan Policies and Design Statements.

Local Plans must be prepared in accordance with the presumption in favour of sustainable development at paragraph 11(a-b). The effect on designated heritage assets (and undesignated archaeological assets of equal value to scheduled monuments) should be considered in applying these tests. Paragraphs 212-21 of the Framework are also relevant to plan making. In particular the tests of harm at 214-216 of the Framework are relevant in applying the Presumption tests.

Purpose and Scope

The purpose of the Heritage Impact Assessment is to support the Local Plan by demonstrating how the historic environment has been considered in the site selection process and to assess the likely impact on heritage assets, both designated and undesignated. The assessment identifies the significance of any heritage assets affected by the allocation, assesses whether allocation might lead to potential harm (or benefit) to this heritage significance, and how any harm could be reduced or mitigated.

For each allocation, an overview of the area and the site is presented which includes a contextual overview of extant heritage assets. A table then presents an assessment of potential impacts of new development on the key heritage assets on the site or in the surrounding area.

For the purposes of the assessment the NPPF Glossary definition of significance and setting were used:

Significance of a heritage asset:

“The value of a heritage asset to this and future generations because of its heritage interest. This interest may be archaeological, architectural, artistic or historic. Significance derives not only from a heritage asset’s physical presence, but also from its setting.”

Setting of a heritage asset:

“The surroundings in which a heritage asset is experienced. Its extent is not fixed and may change as the asset and its surroundings evolve. Elements of a setting may make a positive or negative contribution to the significance of an asset and may affect the ability to appreciate that significance or may be neutral.”

The assessment evaluated:

Contribution of the site to the significance of any designated heritage assets in its vicinity, either directly or through development within its setting.

What impact the development of the site might have on the elements that contribute to their significance?

If it is likely to result in harm, what measures will be necessary to remove or reduce that harm?

If there is potential for an allocation to enhance or better reveal the significance of a heritage asset.

The assessment focused on designated assets including statutorily listed buildings, scheduled monuments, nationally designated historic parks and gardens, and conservation areas.

Non-designated assets such as archaeological sites, parks and gardens of local historic interest and any buildings of local interest that may be revealed during the process were also considered where appropriate.

Methodology

The identification of sites was reached through an evaluation of all deliverable land parcels listed in the Council’s Housing Employment Land Availability Assessment (HELAA, 2021) which were then mapped against a 50m buffer placed around each of the designated heritage asset types identified. This is to assess the potential impact of allocations on the setting of designated heritage assets.

Any site which then interacted with any of the buffer zones was then selected. In addition to this any additional sites which were outside of the buffer zones but which were likely to have heritage implications were added into the selection. These additional sites included:

Stantor Barton 21T137 and 21T136 (a very large site close to Cockington Conservation Area but not within the 50m buffer zone)

21P027 – Victoria Square/Multistorey Car Park (extremely close to a 50m buffer zone for a conservation area)

21B033 – Land at Laywell Rd/Mathill Road (included because this site might form part of the wider parcel for Monksbridge 21B015 and 21B015a which fall within a conservation area buffer zone)

A Heritage Impact Assessment (HIA) was then produced for the remaining proposed sites where through the assessment of the significance of the historic environment, the likely impact of the allocation of sites on affected heritage assets (both designated and non-designated) was identified, and consideration given to whether such impact can be satisfactorily mitigated.

All selected sites were screened in line with the ‘Four-Step’ Site Assessment Methodology set out within this document, and HIA’s were prepared with reference to Historic England’s Advice Note 3 (The Historic Environment & Site Allocations in Local Plans) 2015 (HEAN3) and Good Practice Advice Note 3 (Second Edition): The Setting of Heritage Assets (2017) (GPAN3).

The methodology for the heritage impact assessment as described in Historic England’s Advice Note 3 'The Historic Environment and Site Allocations in Local Plans' was considered and the site selection methodology for the Torbay HIA was as follows:

Step 1 - Identify which heritage assets are affected by the potential site allocation

All of the HELAA sites were initially assessed as to whether they could potentially impact on heritage assets using the methodology outlined within this report.

The different categories of heritage asset were:

Designated Heritage Assets:

Conservation Area

Scheduled Monument

Listed Building

Registered Parks and Garden

Heritage at Risk Features

Non-designated Heritage Assets:

Buildings of Historic Significance (identified where appropriate)

Archaeological Site

Archaeological Activity

The designated heritage assets were assessed with regards to the potential impact to their significance. This may mean that assets which are outside but adjacent or close to a site will be identified as being affected depending on the level of harm that would be caused to the setting of that asset and the contribution that the setting made to the significance of the asset in question.

The non-designated heritage assets were assessed in terms of harm to the asset itself, and their setting only where considered appropriate.

A red/amber/green (RAG) rating system was used to give an initial assessment of the predicted level of harm that would be caused to the significance of the asset(s) should the site be developed. The table below sets out the basis for this assessment, applying the definitions in the National Planning Policy Framework (NPPF).

Development of the site is likely to result in harmful impact to the significance of designated or non-designated assets. It is unlikely that impacts can be mitigated.
Development of the site may result in harmful impact to the significance of designated or non-designated heritage assets. It is likely that impacts can be avoided or mitigated.
Development of the site is likely to either result in a neutral or positive impact to the significance of designated or non-designated heritage assets. It is likely that no mitigation is required.

Step 2 - Understand what contribution the site (in its current form) makes to the significance of the heritage asset(s).

A Heritage Impact Assessment (HIA) pro-forma was produced for each of these sites which incorporates the significance of any asset(s) relating to the site and an assessment of harm to the significance of the asset(s).

As the HEAN3 acknowledges, for a number of assets, it may be that a site makes very little or no contribution to significance.

Understanding ‘significance’ is essential to enable the assessment of the potential impact of development following the allocation of sites.

Step 3 - Assess the effects of the proposed development on the significance of the heritage asset and its setting

This stage looks identified what impacts the development of a site might have on the significance of a heritage asset or its setting and evaluate the resultant degree of harm. The evaluation extended to the consideration of cumulative impacts on multiple assets, as and where appropriate.

HEAN3 states that due to the wide range of circumstances in which setting may be affected and the range of assets that may be involved, different approaches will be required for different circumstances. However, in general, any assessment should address the attributes of the proposed development that may affect setting in terms of:

Location and siting (e.g. proximity to asset, position, topography, relationship and key views

Form and appearance (e.g. prominence, scale, massing, proportion, design and materials)

Wider effects (e.g. noise, odour, lighting, changes to skyline, changes to land use, changes to general character of the site and cumulative impact)

Secondary effects (e.g. increased traffic movements)

The level of harm needs to be established. This is categorised as ‘substantial’, ‘less than substantial’ or ‘no harm’ to the heritage asset. A definition of these categories is set out in the table below:

Assessment of Impact/Level of harm Scale of Impact	Definition
Substantial	Considerable change affecting the special character of designated heritage assets including their setting, where the significance of those elements is substantially harmed or lost.
Less than Substantial	Change affecting the special character of designated heritage assets, where elements which contribute to their significance and their setting are harmed; or limited change to elements that contribute to the significance of assets and their setting, where harm is minimal.
No harm	No designated heritage assets affected.

Step 4 - Maximising enhancements and mitigating/avoiding harm

If the assessment work concluded that there would be harm to the significance of an asset, consideration was given as to how development could maximise the enhancement of the asset or show how the harm could be mitigated or avoided. In respect of mitigation, this could include a reduction in density or enhanced design requirements. Such mitigation will be high-level at the plan-making stage and would need to be informed by a detailed assessment submitted as part of any planning application.

The NPPF sets out a hierarchy of significance and harm. In accordance with Section 16 (Conserving and enhancing the historic environment), the Council will seek to avoid development that harms a designated heritage asset where it cannot be reasonably mitigated. In accordance with paragraph 216 in respect of non-designated heritage assets, “a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the […non-designated…] heritage asset”.

In this respect, where a site is identified that will harm the significance of a heritage asset which cannot be mitigated, the HIA has identified the site as being ‘red’. This assessment only takes into account the heritage impacts of the development and any potential mitigation measures necessary to reduce harm. It does not consider any associated public benefits associated with the development which would be considered as part of a wider planning assessment.

Outcome of site assessments

The result of applying this methodology may justify a revision to the overall deliverability of specific sites in the HELAA due to the degree of harm to heritage assets that have been identified.

Summary of Results

A total of 160 sites were identified for initial assessment. Of these, 58 were screened out for the need for a HIA due to the site being a windfall site, the site yield being below 10, the sites having been, or in the process of, being redeveloped for housing and/or there being clear evidence of no heritage impacts at selection stage. These sites are identified within Appendix A.

A full Heritage Impact Assessment (HIA) was subsequently carried out for the remaining 102 sites using the methodology outlined above. A summary of the results is presented in the table below, and a list of sites grouped into three categories can be found in Appendix B. More detailed individual site HIA documents are available here.

Town/Area	No. of Red Sites	No. of Amber Sites	No. of Green Sites
Brixham	14	10	04
Paignton	04	11	05
Torquay	10	22	22
Total	28	43	31

Torbay HIA Summary Report Appendices

Appendix A: Screened out Sites

HELAA Ref	Site Address	Town	Reason for exclusion
21B011	St Kildas	Brixham	Site in development
21B012	16-26 Castor Road	Brixham	Site redeveloped
21B024	Washbourne Close Green	Brixham	Site yield below 10
21B035	Alston Lane/A3022, Churston	Brixham	Windfall site
21P003	Land south of Yalberton Road (Berry Acres)	Paignton	Site in development
21P004	Land R/O 188-190 Torquay Rd	Paignton	Site yield below 10
21P005	South Devon Police Station, Southfield Rd	Paignton	Site redeveloped
21P006	Astoria Court, 5 Belle Vue Rd	Paignton	Site yield below 10
21P007	38-40 Palace Avenue	Paignton	Change of use implemented
21P024	Lyndhurst Hotel, Lower Polsham Road	Paignton	Site yield below 10
21P025	Crossways Shopping Centre	Paignton	Site in development
21P029	Angleside House	Paignton	Change of use implemented
21P044	Land at Yalberton Road	Paignton	Site yield below 10
21P057	El Patio, 11 Alta Vista Road	Paignton	Site yield below 10
21P085	3 Keysfield Road	Paignton	Site yield below 10
21P089	Queens Park and Rugby Club	Paignton	No yield and Red HELAA site
21T001	Electricity substation adj Charlwood Ct, Chilcote	Torquay	Site yield below 10
21T002	Former Dairy Crest Depot, Parkfiled Road	Torquay	Site redeveloped
21T004	21 Old Mill Road	Torquay	Site redeveloped
21T005	3-5 Union Street	Torquay	Site yield below 10
21T006	Former Palace Hotel, Babbacombe Road	Torquay	Site in development
21T007	Wolverton and Mowbray, Asheldon Road	Torquay	Site yield below 10
21T011	Torre House, Falkland Road	Torquay	Site yield below 10
21T031	Zion Methodist Church, Zion Road	Torquay	Site yield below 10
21T035	Municipal Chambers, Union Street	Torquay	Site redeveloped
21T055	Watcombe Beach Car Park, Watcombe Beach Road	Torquay	Site yield below 10
21T060	Conway Court Hotel, Warren Rd	Torquay	Site in development
21T069	Hatfield House, Hatfield Cross	Torquay	Site redeveloped
21T074	Former Four Seasons Hotel, 547 Babbacombe Rd	Torquay	Site yield below 10
21T078	Genting Casino, Abbey Road	Torquay	Site yield below 10
21T082	Former Bakery Barn, Chilcote Close, St Marychurch	Torquay	Site yield below 10
21T084	Former Working Links, Lower Union Lane	Torquay	Site yield below 10
21T085	Former Stoodley Knowle School, Ansteys Cove Rd	Torquay	Site in development
21T096	18 Babbacombe Rd	Torquay	Site redeveloped
21T097	Rutland Hotel, Daddyhole Rd	Torquay	Site redeveloped
21T099	182 St. Marychurch Rd	Torquay	Site yield below 10
21T100	213 St Marychurch Rd	Torquay	Site redeveloped
21T101	Exmouth View Hotel, St Albans Rd	Torquay	Site redeveloped
21T133	Bishops Court, Lower Warberry Rd	Torquay	Site yield below 10
21T144	Land at Sladnor Park Road, Maidencombe	Torquay	Site yield below 10
21T148	Brunel Manor, Teignmouth Rd	Torquay	Site yield below 10
21T159	Watcombe Hall, Watcombe Beach Rd	Torquay	Site redeveloped
21T160	86 Abbey Rd	Torquay	Site yield below 10
21T161	30-34 The Terrace	Torquay	Site in development
21T162	15 Avenue Rd	Torquay	Site yield below 10
22B003	74 New Road	Brixham	Site yield below 10
22P004	4 Palace Avenue	Paignton	Site yield below 10
22T005	Former Bridge Club, Zion Rd	Torquay	Site yield below 10
24T007	Menzies House, Parkfield Rd	Torquay	No evident impact on heritage assets at selection stage – no HIA necessary
24P002	The Lime Tree, Dartmouth Rd	Paignton	Site in development
24P003	7-9 The Riviera	Paignton	Site in development
24T009	Rowcroft Hospice Associated Living	Torquay	Site in development
24T006	Thurlow House, 35 Thurlow Rd	Torquay	Site in development
24P007	Former AAH Pharmaceuticals Site, Manor Rd	Paignton	No evident impact on heritage assets at selection stage – no HIA necessary
24P008	Hollacombe Community Resource Centre	Paignton	No evident impact on heritage assets at selection stage – no HIA necessary
24P009	NHS Site (Chadwell Centre)	Paignton	No evident impact on heritage assets at selection stage – no HIA necessary
24T003	Livermead House Hotel Car Park	Torquay	No evident impact on heritage assets at selection stage – no HIA necessary
24T011	Land off Edginswell Lane	Torquay	No evident impact on heritage assets at selection stage – no HIA necessary

Appendix B: Heritage Impact Assessment of Identified Sites

Red list

Brokenbury Field, Bridge Rd, Brixham, 21B023

Northcliff Hotel, Brixham, 21B008

Land at Monksbridge, Brixham, 21B015a

Lupton Park Estate, Brixham, 21B028

Manor Farm, Galmpton, Brixham, 21B030

Churston Road, Brixham, 21B034

Alston Lane, Brixham, 21B036

Land at Broadsands, Brixham, 21B48

Land at Green Lane/Bascombe Road, Brixham, 21B052

Triangle West of Bascombe Rd, N of disused railway, Brixham, 21B055

Land at Long Meadow, Collaton St Mary, Paignton, 21P065

Land West of Lower Yalberton, 21P065a

Lower Yalberton Holiday Park, Long Road, Paignton, 21P066

Land north of Blagdon Road, Paignton, 21P073

Land North of Brunel Manor, Torquay, 23T007

Wider land at Broadley Drive, Livermead, 21T050a

Sladnor Park, Maidencombe, Torquay, 21T064

The Grove, Babbacombe, 21T120

Torquay Town Hall, Torquay, 21T121

Grand Hotel Garage Site, Torquay, 12T138

Land West of Ferrers Green, 22BCG001

Land Eest of Ferrers Green, 22BCG002

Elberry Farm, Broadsands, 22BCG003

Part Elberry Farm, Broadsands, 22BCG003a

Former Bowling Green, Lymington Road, Torquay, 23T001

Land Between Rock House Land and Brim Hill, Maidencombe, Torquay, 23T006

Car Park Between Meadfoot Sea Rd & Daddyhole Rd, Torquay, 24T001

Land off Seymour Road, Watcombe Park, Torquay, 21T083

Amber list

Field off Summercourt Way, Brixham, 21B021

Churston Golf Club, Brixham, 21B013a

Land at Churston (Brokenbury), Brixham, 21B003

Land at Mathill Road, Brixham, 21B015

Land at Laywell Rd/Mathill Rd, Brixham 21B033

The Piggery, Elberry Lane, Brixham, 21B042

Land at Greenway Road/Greenway Park, Brixham, 21B049

Land at Greenway Road, Brixham, 21B049a

Land at Long Road and Stoke Road, Paignton, 24P001

Land North of Totnes Road, Paignton, 21P010

Land South of Totnes Road, Collaton St Mary, Paignton, 21P015

Station Lane and Great Western Car Park, Paignton, 21P028

Land at Long Meadow, Collaton St Mary, Paignton, 21P062

Land North of Totnes Road, Paignton, 21P078

Chilcote Close Car Park, St Marychurch, Torquay, 21T008

50/54 Swan Street, Torquay, 21T014

Land adjacent to Broadley Drive, Livermead, 21T050

Land off Teignmouth Road, Maidencombe, Torquay, 21T065

Central Cinema, 29 Abbey Rd, Torquay, 21T071

Union Square Shopping Centre, Torquay, 21T075

Seascape Hotel, 8-10 Tor Church Rd, Torquay, 21T077

Seabury Hotel, 11 Manor Road, Torquay, 21T080

R/O Edinburgh Villas, off McKay Avenue & Newton Road, Torquay, 21T095

Land at Teignmouth Road, Maidencombe, Torquay, 21T110

Land at Port Talland Farm, Torquay, 21T111

Former Living Coasts, Beacon Hill, Torquay, 21T119

Land at Hamelin Way and Moles Lane (Edginswell), 21T122

Shedden Hall Hotel, Shedden Hill, Torquay, 21T124

Stantor Barton, Torquay, 21T137

Castle Circus House and adj buildings, Union Street, Torquay, 21T140

Torquay Golf Club, Torquay, 21T147

Land North of Steep Hill, Maidencombe, Torquay, 21T157

Oxen/Freshwater Cove, Brixham, 22B002

Adj Tithe Barn Cottage, Watcombe Beach Road Torquay, 22T010

Go Kart/Park & Ride Site, Dartmouth Road, Churston, 23BCG001

Land SW of Nutbush Lane and west of Armada Park, 23T002

Steps Cross Playing Field, Moor Lane, Watcombe, Torquay, 23T005

Former Palace Hotel, Babbacombe Road, 23T008

Land at Long Road and Stoke Road, Paignton, 24P001

Oldway Mansion, Paignton, 24P004

12-14 Victoria Street, Paignton, 24P005

Barton Pines, Blagdon Road, 24P006

Former Halifax, 30 Torquay Road, Paignton, 24P010

Green list

Town Centre Car Park, Brixham, 21B006

Paint Station, Brixham, 21B007

Torbay Industrial Estate Part 1, Brixham,21B053

Torbay Industrial Estate Part 2, Brixham, 21B054

Corner of Hyde Rd and Torbay Rd, Paignton, 21P026

Victoria Square Multi Story Car Park, Paignton, 21P027

Site Opposite Paignton Train Station, Victoria Street, Paignton, 21P048

Summerhill Hotel, 2 Braeside Rd, Paignton, 21P055

Former Kia Garage, Totnes Road, Paignton, 21P088

Shelley Court Hotel, 29 Croft Road, Torquay, 21T003

Torquay Town Hall Car Park, Torquay 21T032a

Land R/O Market Street, Torquay, 21T034

Site opposite Market, Market St Torquay, 21T037

Roebuck House, Abbey Road, Torquay, 21T038

Pimlico, Torquay, 21T041

Adjacent to Abbey Hall, Rock Road, Torquay, 21T043

Fleet Walk shopping centre, Torquay, 21T047

Argos ‘Block’, Union Street, Torquay, 21T052

Dainton Storage Yard (Torre Station), Torquay, 21T053

Bancourt Hotel, Avenue Road, Torquay, 21T054

Former Magistrates Court, Union Street, Torquay, 21T070

Debenhams, 10-14 The Strand, Torquay, 21T081

Imperial Hotel, Park Hill Road, Torquay, 21T093

Lower Union Lane Office Block, Torquay, 21T123

Former New Look, 70-82 Union Street, Torquay, 21T141

Waste Land R/O Castle Circus House, Torquay, 21T146

Torbay Hospital, Torquay, 22T002

Maycliffe Hotel, St Lukes Road, Torquay, 24T002

Chelston Telephone Exchange, Torquay, 24T005

48-50 The Terrace, Torquay, 24T008

Hotel Virginia, Falkland Road, Torquay, 24T010