In black and white
The evidence
What the expert bodies told the council, what the council's own documents say, and how EXMO20 got into the plan. Every quote links to the original document on the council's website.
What the experts said
These are the government's adviser on nature, two leading conservation charities and the government's heritage adviser, responding to the council's consultations on the plan.
Natural England
The Plan remains unsound until this uncertainty is resolved, the mitigation is secured, and the policy wording is updated accordingly.Natural England on traffic pollution and the Pebblebed Heaths (policy PB04), second Regulation 19 consultation, January 2026 · document (pp.20–23)
We understand that there are currently no practicable options to fully mitigate the impacts of increased emissions at this site resulting from the East Devon Local Plan.Natural England, January 2026 · document
The St John's site (Exmo_20) was rejected as GH/ED/76 (same boundaries) at the Regulation 18 stage of the Local Plan … this is the first time that Natural England has had opportunity to comment on this site.Natural England, letter of 28 March 2025 · document (pp.2–3)
Natural England's January 2026 comments are about the plan as a whole. Devon County Council's traffic forecast puts 2,235 of the 2,536 extra vehicles a day on the B3179, which runs beside the Heaths, down to EXMO20 (FOI reply). In 2025 Natural England asked for a natural buffer along the B3179 rather than objecting to the site outright.
RSPB
The RSPB is very concerned that the St John's allocation in particular will have damaging impacts on the designated heathland SAC/SPARSPB, first Regulation 19 consultation, 2025 · document (pp.33–35)
This allocation and others close to the heaths cannot proceed unless adverse impacts on the integrity of the heaths SPA/SAC can be ruled out.RSPB, second Regulation 19 consultation, 2026 · document
Devon Wildlife Trust
Devon Wildlife Trust considers the inclusion of this site for development is unacceptable and we object in the strongest possible terms.Devon Wildlife Trust, letter of 24 March 2025 · document (p.4)
The entirety of the proposed Exmo_20 allocation lies within a Strategic Nature Area (SNA).Devon Wildlife Trust, 24 March 2025 · document (p.4)
Devon Wildlife Trust would urge East Devon District Council to remove this allocation from the plan to avoid such impacts altogether.Devon Wildlife Trust, letter of 7 January 2026 · document (pp.3–4)
Historic England
Development could result in considerable harm to the setting of this building, which the NPPF identifies as an asset of the highest significanceHistoric England on the grade II* listed Church of St John in the Wilderness, letter of 30 March 2025, marked "Unsound" · document (pp.7–8)
Consequently, in its current form we consider Exmo_20 fails the NPPF tests of soundness as it is unjustified and inconsistent with national policyHistoric England, 30 March 2025 · document
To minimise harm to heritage assets, we suggest that development is restricted to the southern part of the site, and that the quantum of development and proposed range of uses is restricted to that which can be accommodated there.Historic England, letter of 23 January 2026, still marked "Unsound" · document (pp.3–5)
The council's own Habitats Regulations Assessment
there is inherent conflict in that the growth proposed in the Plan would exceed threshold levels and there is, as yet, no means to mitigate or address the risks.Habitats Regulations Assessment for the council, 18 November 2025, p.96 (the same sentence was in the January 2025 version)
As the identified mitigation measures do not fully address the adverse effect to the integrity of the site the HRA process cannot be concluded at this time.Air quality mitigation strategy for the Pebblebed Heaths (ENV-034), 6 November 2025, p.15 · document
For balance: Devon County Council withdrew its minerals objection to EXMO20 in January 2026 after the policy wording was changed. The council says decisions on the plan were made in public after considering all the evidence, and that objectors will be heard at the examination.
What the council's own evidence says
These come from documents written for the council, or by it, as part of the Local Plan.
the key allocation of concernThe council's Habitats Regulations Assessment (November 2025, p.58) on St John's, which it describes as an allocation "that directly abuts the southern parts of the East Devon Heaths SAC/SPA (Withycombe Raleigh Common)" · document
the Local Plan will need to be amended to eliminate this residual adverse effectThe council's air quality mitigation strategy (ENV-034, November 2025), Recommendation 4, on what happens if the mitigation measures are not enough · document
Lack of HRA certainty, particularly for Exmo_20 and other Pebblebed-proximate sitesThe council's own Consultation Statement (October 2026, p.32), listing the main issues people raised · document
while not ideal, the plan could be submitted with some outstanding matters remaining to be resolved.Officers' report to the Strategic Planning Committee, 22 September 2026, para 3.20 · document. Compare Natural England, which recommends the air quality strategy "should be secured and detailed before the Plan is presented for examination".
the LHN represents 40% more than the need implied by the demographic trend aloneThe council's Local Housing Needs Assessment 2025, para 27. It gives a "demographically projected need of 12,878 dwellings" against the plan's 20,909 · document
The impact assessment primarily relies on 'visual connectivity' and does not represent a robust assessment of the potential impact on the significance the church derives from its setting, critically failing to consider impact on tranquillity. This is a major concern.Historic England on the council's heritage assessment for EXMO20, letter of 23 January 2026 · document
The council's view
To be fair to the council, here is how it explains its position:
All decisions on the Local Plan have been made in public sessions of our Strategic Planning Committee which has considered the Local Plan and its supporting evidence at over 60 public meetings including public speaking.The Vice Chair, responding for the council at full Council, 15 April 2026 · minutes
Ultimately the plan will be examined in public by a government appointed inspector and those who maintain an objection to the plan will have an opportunity to be heard.The same response
The council also points to a shortage of housing land. In September 2026 its land supply was recorded as 3.16 years, against the five years national policy expects, and it narrowly failed the Government's Housing Delivery Test (84% against a requirement of 85%). The September 2026 minutes record an officer explaining that members had "decided not to reduce housing numbers due to the risks of delaying the Local Plan and falling outside transitional arrangements". We think the evidence above shows those risks are better met by getting the plan right. Read both sides and judge for yourself.
The council's own documents
How EXMO20 was assessed, set side by side:
| Document | What it says about EXMO20 |
|---|---|
| Site Selection Methodology, May 2022 | Only sites assessed as "suitable, available and achievable" in the HELAA go forward to site selection. Sites within 400 m of the Pebblebed Heaths should be sifted out. |
| HELAA (housing land assessment), 2022 | Listed in the appendix headed "Available but not suitable or achievable". Its site profile marks it "Probably unachievable", citing access, the Pebblebed Heaths and minerals. |
| Officers' Exmouth site selection report for the committee, August 2024 | Should EXMO20 (700 homes) be allocated? "No (but see separate reference to Exmo_20b)", a 150-home southern part. document (p.11) |
| Strategic Planning Committee, 3 September 2024 | Members vote to allocate the whole site. The meeting |
| Site selection report, February 2025 | The answer becomes "Yes. On balance Strategic Planning Committee determined it to be an appropriate site to allocate for development." |
| Sustainability Appraisal, February 2025 | Says EXMO20 was "assessed as suitable, available and achievable" in the HELAA (p.329). |
| Sustainability Appraisal, November 2025 | Corrected: EXMO20 is a reasonable alternative "despite being unachievable in the HELAA" (p.387). For areas within 400 m of the Heaths, "mitigation would not be seen as possible" (p.399). The neighbouring site Exmo_04 was cut back to avoid the 400 m zone. EXMO20 was not. |
| Draft plan policy for EXMO20, November 2025 | Development that would cause "unacceptable impacts" is not permitted within 400 m of the Heaths. "The only exception to this constraint will be provision of an access road … to the B3179" (p.87). |
| Committee minutes, 14 July 2026 | "Exmo_20 had initially failed the HELAA assessment due to concerns about site access." minutes |
The council's environmental decision (July 2026)
Before applying for planning permission, the developer, 3West, asked the council for a "screening opinion": a decision on whether the scheme needs a full Environmental Impact Assessment. Devon Wildlife Trust records that the developer's request said the scheme was not EIA development. The council disagreed.
the Council's opinion is that the proposed development is likely to have significant effects on the environment and therefore constitutes EIA Development. Accordingly, any subsequent planning application must be accompanied by an Environmental Statement.East Devon District Council, screening opinion 26/0005/EIA, 10 July 2026 · planning record ("EIA letter")
The site occupies a particularly sensitive environmental location on the northern edge of Exmouth. It lies immediately adjacent to and within the setting of the East Devon National Landscape and in close proximity to the East Devon Pebblebed Heaths Special Area of Conservation (SAC), Special Protection Area (SPA) and Site of Special Scientific Interest (SSSI).The same letter
Evidence before the Council indicates that the SAC is already subject to exceedances of critical loads for nitrogen deposition and critical levels for ammonia.The same letter, on air quality and the Pebblebed Heaths
The proposal would urbanise approximately 85 hectares of currently undeveloped countryside and introduce a substantial new population into an environmentally sensitive location.The same letter, conclusion
DWT strongly objects to proposals for development of this scale within this location.Devon Wildlife Trust, comment on 26/0005/EIA, 23 June 2026. It notes the site lies "within approximately 10m" of the Pebblebed Heaths designations · planning record
What the developer's own plans show
3West published a framework plan and a constraints plan for the site after its July 2026 webinar (developer's website). The framework plan marks the 400 m buffer around the Pebblebed Heaths with a dashed line. Inside that line it shows:
- the main vehicle access road from the B3179;
- sports pitches, with "Social and Community facilities, Sports pitches with changing rooms and associated parking";
- an area of about 2 hectares labelled "Care, health, community, retail and employment";
- public open space or SANG (green space for recreation, intended to draw visitors away from the Heaths).
The housing areas are drawn just outside the line. The plan's key says "Circa 750 homes @33 dph", where the draft Local Plan says "around 700".
Set that beside what the council's own documents say about the same 400 m zone:
The 400m buffer from the Pebblebed Heaths SPA/SAC coincides with the higher, more prominent parts of Exmo_20, meaning built development will not be permitted in this areaSustainability Appraisal for the council, November 2025, p.392
new homes and other development that would result in unacceptable impacts will not be permitted within 400 metres of the Pebblebed Heaths.Draft Local Plan policy for EXMO20, November 2025, p.87. The policy makes an exception for the access road to the B3179.
Concern was expressed about development within the proposed buffer zone. The project team explained that the buffer zone was designed to prevent residential development so some carefully considered commercial/community uses were being explored.The developer's own summary of its meeting with town and parish councils, 1 June 2026 · developer's website
The developer's documents describe early proposals. No planning application has been submitted yet. Its July 2026 slides say it intends to "submit an outline planning application later this year".
Then and now: the 2021 vision
Before EXMO20 was in the Local Plan, the site's promoters published a vision document, "St John's Woodland Village – A place to belong" (2021). The council publishes it as the Exmo_20 vision statement. Here is what it said, set beside what has been said since.
| 2021 vision document | Since then | |
|---|---|---|
| Homes | "719 Homes", "1800 Population" | Draft Local Plan: "around 700". Developer's 2026 framework plan: "Circa 750 homes". |
| The 400 m rule | Quoted the adopted Local Plan: "new dwellings will not be allowed on or within 400 metres of the SPA" | Draft policy for EXMO20 (2025): "new homes and other development that would result in unacceptable impacts will not be permitted within 400 metres". The RSPB says the word "unacceptable" is "unclear, rather than 'adverse' which follows specific tests". |
| Can it be seen? | "Virtually all of the site is well-screened from views from the surrounding area" | The council's 2026 EIA decision: "The site is visible from surrounding roads, elevated viewpoints, publicly accessible countryside and parts of the East Devon National Landscape." |
| Visitors to the Heaths | The development would ensure "that the sensitive Pebblebed Heath habitats are not exposed to increased visitor pressure" | The council's 2026 EIA decision: the proposal "would introduce a substantial increase in population within the zone of influence of these internationally important sites and has the potential to increase recreational pressure". |
| Land not suitable for building | "Not suitable for development: Total 43.3 ha", including "17.0 - ecological buffer" | The 2026 scheme covers about 85 hectares. The developer's framework plan puts the access road, sports pitches and a care, health, community, retail and employment area inside the 400 m buffer. |
| Why here? | Described St John's as "one of the only options for delivering sustainable growth in Exmouth" | The council's own officers recommended "No" to allocating the whole site in August 2024. |
Objections in numbers
Both of the council's feedback reports call the policy containing EXMO20 "the most commented-on policy by a considerable margin". The first report adds that responses were summarised using Microsoft Copilot. (second feedback report)
Timeline
| 2022 | The whole site is consulted on as a "rejected" site. Only a smaller southern part (Exmo_20b) is a "second choice". |
| Aug 2024 | Officers' report recommends not allocating the whole site. |
| 3 Sep 2024 | Strategic Planning Committee members vote to allocate EXMO20 (about 700 homes). |
| 11 Dec 2024 | The committee approves the draft plan for consultation. |
| 13 Feb – 31 Mar 2025 | First Regulation 19 consultation: about 1,110 responses on EXMO20. |
| 2 Sep 2025 | The committee votes 9–1–2 to keep EXMO20. |
| 28 Nov 2025 – 26 Jan 2026 | Second Regulation 19 consultation: 1,672 responses on EXMO20. |
| Apr 2026 | The June 2026 submission deadline is replaced by "the end of the calendar year". |
| 29 May – 10 Jul 2026 | The developer, 3West, asks the council whether a full Environmental Impact Assessment is needed. The council decides it is "EIA Development" and that any application must include an Environmental Statement (ref. 26/0005/EIA). |
| Jul 2026 | 3West publishes a framework plan for "circa 750 homes", with the access road, sports pitches and a care, health, community, retail and employment area inside the 400 m buffer. |
| 22 Sep 2026 | Officers report they are "not in a position to recommend submission". Air quality and water evidence is still being finished. |
| 24 Sep 2026 | David Reed MP holds a public meeting on EXMO20 in Exmouth. |
| 1 Dec 2026 | Next Strategic Planning Committee. |
| 9 Dec 2026 | Full Council. Only full Council can decide to submit the plan, and it must be submitted in 2026 to go ahead under the current rules. |
Some important evidence hasn't been published yet: see the questions we're asking. For press coverage, see in the news.
Quotes are copied from the published documents; page numbers refer to the PDF. Names of private individuals in the council's documents are deliberately left out.