How to respond

Owl is sceptical about the use of box ticking surveys and questionnaires. They seem designed to meet procedural requirements easily processed by computer, rather than gather genuine feedback. 

The issues surrounding the elimination of the tier of local government closest to residents with consequential dilution of elected representation are profound.

Ironically, the government claims it is removing a tier of local government, district councils, while, at the same time, planning to add another on top, the strategic mayoral authority. This form of devolution does not bring local decision making closer to people.

Owl will, therefore, be sending in a narrative response and not be completing the “survey”.

See this companion post describing the proposals.

The Consultation 

Nitty gritty (Taken from the gov.uk website)

This consultation will last for 7 weeks from 5 February 2026 to 23:59 on 26 March 2026. 

Enquiries:

For any enquiries about the consultation please contact:

lgrconsultationresponse@communities.gov.uk

How to respond:

You may respond by completing the online survey.

If you are responding in writing, please make it clear which proposal you are responding to. You can email your response to the questions in this consultation to lgrconsultationresponse@communities.gov.uk

Alternatively written responses should be sent to:

LGR Consultation
Fry Building 2NE
Ministry of Housing, Communities and Local Government
2 Marsham Street
London
SW1P 4DF

When replying please include your name and indicate in which council area your home or organisation address is located:

• Devon County Council
• Plymouth City Council
• Torbay Council
• outside the affected area

We would also like you to confirm whether you are replying as a named consultee, submitting an official response on behalf of an organisation that is not on the list of named consultees, or replying as an individual.

Using the online survey

Ticking the Boxes

What to expect if you use the online survey

The same set of questions are asked of each of the five proposals. You do not have to respond to all five but it is unclear how a nil response will be treated.

Each question requires you to select, on a six point scale, on how strongly you agree or disagree with the question, viz: strongly agree, somewhat agree, neither agree nor disagree, somewhat disagree, strongly disagree, don’t know.

The questions ask do you agree/disagree:

• Q1 that the proposal suggests councils that are based on sensible geographies and economic areas?
• Q2 that the proposed councils will be able to deliver the outcomes they describe in the proposal?
• Q3 that the proposed councils are the right size to be efficient, improve capacity and withstand financial shocks? 
• Q4 that the proposed councils will deliver high quality, sustainable public services?
• Q5 that the proposal has been informed by local views and will meet local needs?
• Q6 that establishing the councils in this proposal will support devolution arrangements?
• Q7 that the proposal enables stronger community engagement and gives the opportunity for neighbourhood empowerment?

These questions are followed by a free text box to explain the answers you have provided to questions 1-7, referring to the question numbers as part of your answer. You may also use the box to provide any other comments you have on the proposal.

Proposals 3 to 5 involve boundary changes so each has an additional question followed by a free text box.

The additional question is: to what extent do you agree or disagree that the proposal sets out a strong public services and financial sustainability justification for boundary change?

Owl gets to the heart of each proposal

Five proposals have been submitted to the government and are subject to consultation. Here is Owl’s summary of each.

(A companion post explains how to take part in the consultation.)

No 1 Devon County Council proposal

Arguably the simplest, Plymouth and Torbay are left alone and a third “Devon Unitary” created to include all existing districts and Exeter city. 

Points to note

• No of Unitaries – 3
• Population disparity. Devon Unitary would have a population of c. 850,000, Plymouth 275,000 and Torbay 140,000. Set against a government guideline  of 500,000, even Plymouth falls short of this; and Torbay falls well short indicating it may not be an efficient size for a unitary authority.
• Geography. It would seem administratively convenient to centre the Devon administration on County Hall in Exeter. But there is no disguising the remoteness of the unitary council based in Exeter from Tavistock, Ilfracombe, Tiverton, Axminster and Kingsbridge, compared with residents of Plymouth and Torbay whose council is central.

Nos 2 & 3 District council proposals

These two proposals are very similar, one is simply a minor tweak on the other. South Hams, Teignbridge and West Devon have broken away from the earlier consensus amongst district councils. The difference revolves around whether or not to make a modest increase in the size of Plymouth. The proposed expansion involves switching parts of four parishes, currently in South Hams but on the edge of Plymouth, to include them in what is called the “Plymouth Policy Area”. The purpose is to stop Plymouth expanding across the Dartmoor National Park boundary, maintaining clarity and coherence in planning authority responsibilities. See dotted line on map below:

This division amongst district councils illustrates just how divisive LGR has become. It would appear that only around 6,000 residents would be affected but it is obviously important to them.

Similar issues crop up in proposals 4 and 5.

The government really has stirred up a hornets’ nest.

Both proposals are derived from the very first 5:4:1 district proposals in which the geographic county is split into three unitary councils.

• Exeter and Northern Devon Unitary. [East Devon, Exeter, Mid Devon, North Devon, and Torridge].
• Torbay and Southern Devon Unitary. [ South Hams, Teignbridge, Torbay  and West Devon ]
• ​Plymouth unchanged in Proposal 2, or expanded, with consequential reductions in the South Hams in  Proposal 3

Points to note

• No of Unitaries – 3
• Population. These proposals create a more even balance of populations in each unitary: Exeter & northern Devon c 550,000; Torbay and Southern Devon c. 420,000; Plymouth remains at the lower end of the target population of c 275,000/280,000.
• Geography. Likely administrative centers to be Plymouth, Torbay and Exeter which still leaves parts of West, North and East Devon somewhat remote.

No 4 Exeter City Council and Plymouth City Council proposal

This is arguably the most radical proposal creating 4 unitaries, involving a lot of boundary changes. Three of these imply significant expansion of areas adjacent to Plymouth, Torbay and Exeter. These three areas would become compact “urban” unitaries with the rest of Devon lumped into a surrounding horseshoe of “Coast and Countryside”.

• Exeter: plus 15 parishes from within Teignbridge District Council, 28 parishes from within East Devon District Council and 6 parishes from within Mid-Devon District Council.
• Plymouth: plus 13 parishes from South Hams
• Torbay: plus 22 parishes from within Teignbridge District Council and South Hams District Council.
• Devon Coast and Countryside: The rest of Devon! 

See the Proposal 4 map:

Points to note

• No of Unitaries – 4
• Population division. This proposal quite clearly creates a division between Town and Country. The populations of the three urban unitaries range from c. 305,000 for expanded Plymouth, 260,000 for expanded Exeter to 232,000 for expanded Torbay. All fall short of the 500,000 target. The rural periphery, on the other hand, is far larger with a population of c. 455,000
• Geography. Fine for the urban unitaries centred on Plymouth, Torbay and Exeter. A nightmare for the rest.

No 5 Torbay’s proposal to be left alone

This insular proposal takes Exeter’s and Plymouth’s proposal (4 above) but says “no thank you” to the idea of adding 22 parishes to Torbay. Torbay proposes these parishes should be lobbed into the “Coast and Countryside” rump, making it an even greater nightmare to administer. 

Points to note

• No of Unitaries – 4
• Population division. This proposal returns Torbay to a population of c.140,000 which is really too small for an efficient unitary, smaller than East Devon. The “Coast and Countryside” rump is increased by about 100,000.
• Geography Even more of a nightmare for managing “Coast and Countryside” than in proposal 4 above.

You can find all the detailed cases made for each of these five proposals at: www.devonlgr.co.uk. 

The Government “Mission Statement”

So it’s all about growth. It does nothing to address impending bankruptcy and the ballooning costs of social care and provision for children with special educational needs. More importantly the centralisation it seeks, reducing your access to councillors and making councils more remote, is the antithesis of what most people think devolution means. – Owl

“Our ambition is to simplify local government, ending the two-tier system and establishing new single-tier unitary councils that are responsible for all local government services in an area. Our vision is clear: stronger local councils in charge of all local services, equipped to drive economic growth, improve local public services, and lead and empower their communities.

Strong local government will help grow the economy and drive up living standards – the government’s number one mission. With one council in charge, we will see quicker decisions to grow our towns and cities and connect people to opportunity. Reorganisation will speed up house building, get vital infrastructure projects moving, and attract new investment – with more people able to buy their own homes and access high-quality local jobs.

New unitary councils must support wider devolution structures. Our ambition is that all of England can access devolved powers by establishing Strategic Authorities – groups of councils working together over areas that people recognise and live and work in – to make the key decisions over strategic scale and to drive economic growth. Strategic Authorities use their powers over housing, planning, transport, energy, skills, employment support and more to deliver growth and opportunity to communities across the country. In the Devon, Plymouth and Torbay area, the Devon and Torbay Combined County Authority is already established, this does not include Plymouth. “