Both sides
Their arguments, our answers
Officers and councillors have given reasons for keeping EXMO20 in the plan. Here are the main ones, in their own recorded words, each set beside the evidence that answers it. Every meeting quote links to the moment in the council's YouTube recording, so you can hear the full context and judge for yourself.
1"The government sets the housing numbers, so we have to find the sites."
What the council says
we are struggling to find suitable sites to meet our housing need which is dictated to us by government and we have to meet those numbersEd Freeman (officer), 3 September 2024, 01:09:25 · play the clip ▶ · about this meeting
to drop numbers further could lead to greater vulnerability to challenges of not adequately planning for appropriate housing provision.Ed Freeman (officer), 22 September 2026, 00:49:01 · play the clip ▶ · about this meeting
Our answer
The government sets a total for the district, not for this site. When EXMO20 was added, the sites officers had recommended, which included only a 150-home southern part of the site rather than the whole 700-home allocation, already met the requirement with some headroom to spare. The requirement has since fallen.
we only have a headroom position of 1.2 or 253 dwellingsEd Freeman (officer), 3 September 2024, on the sites officers recommended, which included only a 150-home southern part of EXMO20, 00:13:35 · play the clip ▶ · about this meeting
equates to a fall of 563 homesEd Freeman (officer), 2 September 2025, 00:33:52 · play the clip ▶ · about this meeting
the LHN represents 40% more than the need implied by the demographic trend aloneThe council's Local Housing Needs Assessment 2025, para 27 · document
Officers advise keeping the 563 homes as extra headroom. That is a judgement, not a legal requirement, and it is the committee's choice to make.
2"Taking EXMO20 out would be a 'significant change'."
What the council says
The removal of any allocation is likely to be a significant changeEd Freeman (officer), 22 September 2026, 00:49:24 · play the clip ▶ · about this meeting
Our answer
We haven't found "significant change" defined in any council document, or any test showing what it would mean for EXMO20. Officers have also told the committee that removing sites is possible.
if we were taking out say a a site of only 10 houses in terms of the housing numbers it doesn't represent a massive problem because we gave ourselves headroomEd Freeman (officer), 8 July 2025, 02:16:43 · play the clip ▶ · about this meeting
that's the kind of scale I think in terms of changes where I think we really have a problem I'm not saying you can't do it I'm just advising you of the consequences potentially of doing itEd Freeman (officer), 2 September 2025, on a change on the scale of EXMO20, 00:46:50 · play the clip ▶ · about this meeting
The replacement figures officers gave members for EXMO20 were based on other Exmouth sites, and we have not seen an assessment of replacements across the district (ground 3).
3"It's only an allocation. The detail is tested at the planning application."
What the council says
all we're doing is allocating sites, it has to go through the planning process … so this is simply an allocationCllr Hayward, 11 September 2024, 00:29:01 · play the clip ▶ · about this meeting
Our answer
Once a site is in an adopted plan, the principle of building there is settled. The questions that decide whether it can work (the Heaths, access, sewage) are the ones being left until later.
once a site is allocated in a plan you're basically accepting it's appropriate for it to come forwardEd Freeman (officer), 8 July 2025, 03:11:12 · play the clip ▶ · about this meeting
ultimately development coming through in that area will have to be subject to Habitat Regulations assessment based on the detailed design and the detailed proposal so those issues will all be considered through that process um laterEd Freeman (officer), 25 November 2025, on the Heaths inside EXMO20's 400 m zone, 00:57:35 · play the clip ▶ · about this meeting
the purpose of preparing a plan is to address all the necessary matters as far as possible, and not defer them to future updates or rely on the Inspector to deal with them, or to 'fix' deficient plans at examination.The Planning Inspectorate's Procedure Guide for Local Plan Examinations, para 1.1 · guidance
4"The harm to the Heaths comes from growth across the district, not from one site."
What the council says
So the impact is not arising from any one site, it's from many, many sitesEd Freeman (officer), 22 September 2026, 03:11:32 · play the clip ▶ · about this meeting
ultimately concludes in terms of the mitigations that are proposed within the plan that it would be acceptable as things stand. … That's an independent conclusion from Footprint Ecology.Ed Freeman (officer), 2 September 2025, on the Habitats Regulations Assessment, 01:23:18 · play the clip ▶ · about this meeting
Our answer
The county council's traffic forecast puts most of the extra traffic on the road beside the Heaths down to EXMO20. Devon County Council forecast 2,536 more vehicles a day on the B3179, "of which 2235 would be due to the Exmo_20 site", assuming its main access is from the B3179 (FOI reply). The latest assessment can't rule out harm, and officers have said that removing particular sites would help.
At the appropriate assessment stage there is not yet sufficient certainty to rule out adverse effects on integrity in relation to … air quality (East Devon Heaths SAC/SPA).Habitats Regulations Assessment for the council (Footprint Ecology), 18 November 2025, summary · document
specific sites where if they were removed the impacts would come below the thresholds that Natural England guidance suggests is acceptableEd Freeman (officer), 22 September 2026, 03:11:05 · play the clip ▶ · about this meeting
we should be trying to avoid the impacts on the habitat first of allEd Freeman (officer), 22 September 2026, 01:52:31 · play the clip ▶ · about this meeting
More on this: traffic pollution next to the site.
5"No homes will be built within 400 metres of the Heaths."
What the council says
the wording of the policy as drafted is new homes and other development that would result in unacceptable impacts will not be permitted within 400 metersEd Freeman (officer), 25 November 2025, 02:06:21 · play the clip ▶ · about this meeting
Our answer
The draft policy covers “new homes and other development that would result in unacceptable impacts”, but officers read it as applying mainly to homes, and have said other uses and the main access road can go inside the zone. The developer's framework plan puts the access road, sports pitches and a care, health, community, retail and employment area there (see the plan).
Those issues wouldn't arise with community uses or commercial uses and so I don't see a planning basis upon which to restrict those uses within that zone.Ed Freeman (officer), 25 November 2025, 00:15:32 · play the clip ▶ · about this meeting
it's obviously not ideal to have the access there but it's not something that you can't have within the 400 meter buffer zoneEd Freeman (officer), 3 March 2026, on the access road, 00:54:52 · play the clip ▶ · about this meeting
The policy also currently refers to 'unacceptable' impacts on the Pebblebed Heaths, which is unclear, rather than 'adverse' which follows specific testsRSPB, second Regulation 19 consultation · document
6"The access problem that failed the site assessment has been solved."
What the council says
Alternative access arrangements including from the B3179 in addition to St John's Road were later explored and meant that the site could be achieved.Ed Freeman (officer), 14 July 2026, 00:21:04 · play the clip ▶ · about this meeting
Our answer
The road's route still hadn't been fixed a year after the site was kept, and it can only reach the site through the 400 m zone. Historic England has warned about the road itself.
we don't know where the access road would come in from from the B3179Ed Freeman (officer), 2 September 2025, 01:46:35 · play the clip ▶ · about this meeting
if you take that 400 meter zone out of the allocation then there's no access to that siteEd Freeman (officer), 25 November 2025, 00:56:50 · play the clip ▶ · about this meeting
we are concerned by the proposal to bring a long access road from the B3179 to the north. This could itself result in significant harm to the setting, while opening up the area to future pressure for development and associated harm.Historic England, letter of 30 March 2025 · document
7"No homes will be built until there's sewage and water capacity."
What the council says
new homes will not come forward unless there is adequate wastewater infrastructure and potable water to support them.Ed Freeman (officer), 3 March 2026, 01:12:11 · play the clip ▶ · about this meeting
So deficiencies in the water cycle study don't necessarily mean that the Local Plan is unsound. … We don't have to agree with the Environment Agency fundamentally.Ed Freeman (officer), 5 May 2026, on the Environment Agency's comments, 01:24:57 · play the clip ▶ · about this meeting
Our answer
A plan has to show its sites can be delivered. The evidence on water is still being redone, and the Environment Agency, the government body responsible, says it doesn't yet show that.
does not currently provide sufficient evidence to demonstrate that all aspects of the proposed growth strategy can be delivered sustainably.Environment Agency, on the Local Plan's Water Cycle Study, reply to David Reed MP, November 2026 · letter
they were quite clear that they just don't have the dataEd Freeman (officer), 3 March 2026, on South West Water and sewage capacity, 01:55:13 · play the clip ▶ · about this meeting
More on this: water and sewage.
8"The NHS helped plan the infrastructure."
What the council says
they were involved in the production of the infrastructure delivery plan that accompanies the plan so we should have captured all of their needs in terms of health care infrastructureEd Freeman (officer), 5 May 2026, on the NHS's comments, 01:26:22 · play the clip ▶ · about this meeting
Our answer
The local NHS trust has since told the MP that the growth would add to demand on its services, and that it will be asking the developer to contribute.
Our modelling indicates that this level of development could result in around 3,186 additional residents, which would increase demand on local NHS services.Royal Devon University Healthcare NHS Foundation Trust, reply to David Reed MP, November 2026, on about 1,455 new homes in Exmouth including EXMO20 · letter
More on this: health services.
10"Members have considered EXMO20 many times and chose to keep it."
What the council says
Having heard the concerns of residents and given them full consideration members on each occasion have decided to continue to allocate the site.Ed Freeman (officer), 22 September 2026, 00:50:31 · play the clip ▶ · about this meeting
Our answer
The officers' own report recommended "No" to allocating the whole site in August 2024 (see the documents). When members added it, officers said more work was needed first, and at least one member has since said it shouldn't have been included.
some further work would need to be done before we could put it in as a concrete fixed allocationsEd Freeman (officer), 3 September 2024, 00:12:58 · play the clip ▶ · about this meeting
it shouldn't have been included at the time. The officers themselves said it shouldn't be included.Cllr Ledger, 8 July 2025, 02:51:03 · play the clip ▶ · about this meeting
Quotes come from machine transcripts of the council's own recordings. We've corrected misheard names and terms and kept every other word as transcribed. "…" marks words left out of a longer remark. Please play each clip to hear the full context. Ed Freeman is the council's Assistant Director, Planning Strategy and Development Services. This page sets out the evidence; it isn't legal advice. For the council's general statement of its position, see the council's view.
9"Every comment has been read and considered."
What the council says
Our answer
Committee members decided on summaries made with AI. Officers have described how those summaries were checked, and have corrected mistakes in them.