Stop EXMO20

Strategic Planning Committee

11 December 2024

Regulation 19 draft plan approved.

Morning recording ▶ · Afternoon recording ▶ · agenda and papers · official minutes (PDF on the council website)

Summary of our findings

EXMO20 came up several times, although the Chair said the allocation decisions would not be revisited. A public speaker said the SAC/SPA was missing from the papers and maps used for the decision; the Chair accepted it 'perhaps should have been mentioned in those papers'. Cllr Ledger noted that EXMO20 had been allocated by the committee and not on officers' recommendation, and asked whether the additional flood-risk work had been done for it. Cllr Howe raised the Pebblebed Heaths 400 m zone, and Cllr Brian Bailey raised access through Southern Wood and Dinan Way and compared the site unfavourably with Budl_01. The only change agreed was a sentence requiring compliance with policy PB04.

  • The committee approved the Regulation 19 (publication) draft of the Local Plan for consultation. Recommendations 1 and 2 were carried 5 votes to 1 and recommendation 3 unanimously. Officers were given delegated authority to tidy the text, finalise the Policies Map and decide when consultation starts once the new NPPF was published.
  • EXMO20 (Land at St John's, Exmouth) stayed in the plan. The Chair said allocation decisions already taken would not be revisited, apart from the two sites officers had brought back (Budl_01 and Otto_02).
  • The Vice-Chair said the EXMO20 policy did not mention the Pebblebed Heaths or the 400 m zone. Members asked for a sentence saying any allocation must comply with policy PB04.
  • In public speaking, one speaker said the maps used for the EXMO20 decision left off the SAC/SPA designations and that the site boundary had since been redrawn. Another raised EXMO20's scale, access and local services.
  • Councillors raised EXMO20 flood-risk work (the stage 2 SFRA), access routes (Southern Wood / Dinan Way, Archery Club) and a comparison with Budl_01. Officers answered.
  • Budl_01 (Budleigh Salterton) was dropped from the plan, 6–3–2, and Otto_02 (Otterton) was dropped, 8–2–1. Honi_18 (Honiton) is to be included under delegated powers now that access is considered achievable.
  • Officers reported allocations totalling 22,536 homes, against the requirement plus 10% buffer of 22,539 (2024–2042).
  • New stewardship wording for the second new town (WS01) and a new phased-development policy were added. The new town's affordable housing percentage is to be shown as 'XX' until the second Reg 19 stage.
  • Timetable given: stage 1 consultation hoped for January 2025, depending on the new NPPF; stage 2 (new town) in spring 2025; submission in autumn 2025; hearings late 2025 or early 2026.
  • A motion to suspend the constitution so the Newton Poppleford boundary could be revisited failed, 2–6–1. A proposal to extend the Exmouth–Lympstone green wedge failed, 2–4. Several wording fixes were agreed (Tipton school, Ottery 09 map, Broadclyst employment land, policies SE08, SE02 and OL11).

EXMO20 is named 7 times in the transcript of this meeting.

What the Minutes Missed

Minutes are a summary, not a word-for-word record. Below are points from the recording that matter for EXMO20 or the Local Plan, set against what the official minutes say about them. Judge for yourself: each clip opens at the moment it was said.

Chair accepts SAC/SPA was not mentioned in the committee papers

Important Not in the minutes · Cllr Todd Olive (Chair) · Morning 00:42:44 ▶

Said in the meeting“Yeah, no, and I will take that point, and perhaps it should have been mentioned in those papers, But again, members of this committee sit on this committee because we're expected to know…”
The minutesNot recorded in the minutes.

The Chair answered the point that the papers used to allocate EXMO20 left out the SAC/SPA. At 00:42:11 he also said 'perhaps there was no mention in papers'. The minutes give the public point but not this answer.

Housing supply: allocations 3 homes short of requirement plus 10% buffer

Important Minutes much briefer · Ed Freeman (officer, Assistant Director) · Morning 01:34:31 ▶

Said in the meeting“So, effectively, our target plus 10% buffer for the plan 2024 to 2042 was 22,539 homes. With the emission of Budl_01 and Otto 02, we would have allocations amounting to, in addition to the windfall projections and commitments on the table, we'd have a total amounted to 22,536 leaving us three homes shy of the plan requirement plus 10%”
The minutesThe Committee’s attention was drawn to the housing numbers and trajectory graph which helped Members to understand how the Council would get to a five-year housing land supply at the point of the adoption of the Plan.

The minutes give no figures. The plan's total sits at the requirement plus a buffer of about 2,000 homes. At 03:19:19 the officer said housing numbers could be met 'including the 10% buffer' without Budl_01.

Councillor compares Budl_01 removal with keeping EXMO20

Important Not in the minutes · Cllr Brian Bailey · Morning 03:27:04 ▶

Said in the meeting“When you compare this to Exxonf 20, Exxonf 20 hasn't got as snowballs compared to this with the access and the level ground and not destroying any particular areas of woodland and things like that. So I can't see how you can be against this but for Exxonf 20. I know it shouldn't be compared but I feel obliged to.”
The minutesNot recorded in the minutes.

A member questioned whether sites were treated consistently: Budl_01 was removed because of its landscape impact, while EXMO20 was kept. This goes to site selection and alternatives. ('Exxonf 20' is a transcription of 'Exmo 20'.)

EXMO20 allocated by committee, not on officers' recommendation; question on additional work

Important Not in the minutes · Cllr Dan Ledger · Morning 03:31:38 ▶

Said in the meeting“can I get assurances the the additional work has been done to all other allocated sites namely EXMO20 because that was previously wasn't proposed as being allocated by officers and we the committee have made that decision”
The minutesNot recorded in the minutes.

A committee member said on the record that officers had not proposed EXMO20 for allocation, and asked whether the evidence work done for officer-recommended sites had been done for it.

Officer answer on flood-risk (SFRA) work for EXMO20

Important Not in the minutes · Ed Freeman (officer, Assistant Director) · Morning 03:32:03 ▶

Said in the meeting“yes so through you chair this is the only one I'm bringing back because of this issue I don't think there were flooding issues specifically with EXMO20 off the top of my head um but if there were that's already been covered in in the sfra work that we've done”
The minutesNot recorded in the minutes.

The answer was given 'off the top of my head'. At 03:39:19 he added that other sites members allocated were done, or are 'now been going through', the SFRA. The minutes do not record either answer.

Vice-Chair on the Pebblebed Heaths 400 m zone and the north of EXMO20

Important Minutes much briefer · Cllr Mike Howe (Vice-Chair) · Morning 03:44:46 ▶

Said in the meeting“…we don't anywhere in this raise the issue of the purple beddies triple si and the 400 meters mitigation zone that we should not ideally be building in I know it's in other policies but surely we should just be highlighting it to any further developer the northern part of this site has its issues to overcome”
The minutesExmo_20 Land at St Johns does not mention the Pebblebed Heaths or the 400m exclusion zone which needs to be included. Officers agreed that a sentence would be added so that any allocation would need to comply.

The minutes record the missing wording, but not the Vice-Chair's view that the 400 m zone should not ideally be built in, or his point that the northern part of the site has issues to overcome.

Councillor's concerns about EXMO20 access routes

Important Not in the minutes · Cllr Brian Bailey · Morning 03:46:35 ▶

Said in the meeting“…The other one is through Southern Wood which is a very quiet well designed cul-de-SAC and at the back of there there's an ancient woodlander track which it's been suggested will be demolished for an entrance there which is highly unsuitable because it will come out of the cul-de-SAC onto a bend which is the Dinan Way.”
The minutesNot recorded in the minutes.

He also said the access by the Archery Club was 'way too far to town' and 'not sustainable' (03:46:17). He was unsure what Highways had said. Access and transport are tests of whether a site can be delivered.

Officer answer: EXMO20 primary access out of town by the Archery Club

Important Not in the minutes · Ed Freeman (officer, Assistant Director) · Morning 03:48:04 ▶

Said in the meeting“So I think we did highlight when members were considering this site that the primary access would need to be out by the Archery Club and that that was out of the town. So that was made clear when members made that allocation.”
The minutesNot recorded in the minutes.

The officer said the main access would be outside the town and that access at the southern (Dinan Way) point would be 'limited' (03:47:45). This bears on transport and sustainability evidence for EXMO20.

Advice that allocations could be revisited at Full Council before submission

Important Not in the minutes · unidentified (probably an officer) · Afternoon 00:00:14 ▶

Said in the meeting“…That won't happen until after the second round of Reg 19 consultation has been completed, which will be beyond six months. so so that might be if the members are minded to revisit this that might be a better time and place to do it”
The minutesNot recorded in the minutes.

Members were told the plan goes to Full Council before submission, the point to revisit decisions outside the six-month rule. A member repeated this at 00:03:22. It is the route by which allocations such as EXMO20 could be reconsidered.

Final vote on the Regulation 19 plan and how many members voted

Important Not in the minutes · Cllr Todd Olive (Chair) · Afternoon 01:30:45 ▶

Said in the meeting“All those in favor, please. That's five. Those against, that's one, and there will be no abstentions then because that's everyone. So that is carried. Recommendation two, all those in favour, please. That's five. Those against, that's one, and no abstentions then. And recommendation three, all those in favour, please. That's unanimously carried.”
The minutesRESOLVED: 1. That the publication draft of the Local Plan as appended to this report ... be approved

The minutes give no vote numbers. Six members voted on approving the Reg 19 plan. Earlier, at 01:23:11, a member said 'there's hardly any committee members left i know we're still core it'.

Chair rules that site allocation decisions will not be revisited

Not in the minutes · Cllr Todd Olive (Chair) · Morning 03:16:52 ▶

Said in the meeting“Just to remind members, the allocation decisions have been taken. We're not going to be revisiting those other than the two that officers have flagged legal concerns regarding.”
The minutesNot recorded in the minutes.

This set the scope of the debate: the EXMO20 allocation was not reopened after the public points on it (SAC/SPA papers, redrawn boundary). At 01:54:14 the Chair said he did not think the committee could constitutionally revisit allocations.

Planning Solicitor's advice on suspending the constitution

Minutes much briefer · Damian Hunter (officer, Planning Solicitor) · Afternoon 00:22:20 ▶

Said in the meeting“so it is possible for you to do that but again democratic services manager agrees with me that it's quite dubious behavior to do so uh in relation to a decision that you've taken less than one month ago”
The minutesthe Planning Solicitor advised that it would be possible to suspend the Constitution but questioned whether such a suspension would be proportionate taking account of the purposes of the Constitution set out in Article 1.

Legal advice given in public. The minutes record it as questioning proportionality, without the words 'quite dubious behavior' or the point about a decision taken less than a month before. Vote 2–6–1 (00:27:26); the minutes give no count.

Who attended

From the council's own attendance record for this meeting. Members of the public who spoke are not named here.

Chair and vice-chair (2)

  • Councillor Mike Howe – Vice-Chair
  • Councillor Todd Olive – Chair

Committee members present (10)

  • Councillor Brian Bailey
  • Councillor Jessica Bailey
  • Councillor Kevin Blakey
  • Councillor Colin Brown
  • Councillor Bethany Collins
  • Councillor Paula Fernley
  • Councillor Ben Ingham
  • Councillor Geoff Jung
  • Councillor Dan Ledger
  • Councillor Yehudi Levine

Committee members who sent apologies (3)

  • Councillor Olly Davey
  • Councillor Paul Hayward
  • Councillor Helen Parr

Other councillors attending (4)

  • Councillor Christopher Burhop
  • Councillor Roy Collins
  • Councillor Peter Faithfull
  • Councillor Eleanor Rylance

Officers (4)

  • Wendy Harris
  • Matthew Dickins
  • Ed Freeman
  • Damian Hunter

Notes on the recording

  • The afternoon transcript (MdcEAvzze7A) starts in the middle of the Newton Poppleford boundary debate. The afternoon public speaking is not in the transcript, so those minutes cannot be checked against the recording. This includes a public speaker on the Pebblebed Heaths SAC/SPA and policies PB01, PB03 and PB04, and Cllr Burhop. The transcript also stops at 01:31:53, although the stated length is 02:07:23, and there is a gap from 00:08:19 to 00:20:56 (a recess).
  • Morning gaps: the recording starts at 00:01:44. There is a technical break from 00:56:18 to 01:09:35 and a comfort break from 03:04:27 to 03:16:52.
  • Attendance: at 00:06:01 the Chair read apologies from Cllrs Davey, Hayward and Ledger. Cllrs Ledger and Levine are later said to have 'joined us slightly late' (01:41:52). The minutes list Cllr Parr, not Ledger, as giving apologies; Cllr Parr is not mentioned in the transcript.
  • Public speakers, by topic only. One speaker (00:41:35) said Natural England had not commented on EXMO20 because its consultation came before the site was preferred, and asked for the allocation to be paused. The minutes do not record this part. Another speaker (from 00:10:36) named EXMO20 and said it was allocated against officer advice; the minutes summarise this as a site 'in the Ting Tong area' without naming Exmo_20.
  • Vote counts the minutes leave out: Budl_01 6–3–2 (03:29:54); Otto_02 8–2–1 (03:40:12); suspending the rules of procedure 2–6–1 (afternoon 00:27:26); green wedge extension 2–4 (afternoon 01:24:16).
  • The minutes say Cllr Jess Bailey 'proposed a motion to rescind the previous resolution' alongside the suspension. On the recording, only the motion to suspend was put to the vote. The Chair said that as a result a motion to redraw the boundary could not be made (afternoon 00:27:49).
  • The machine transcript misspells EXMO20 as 'Exxonf 20', 'xmas 20', 'expert 20' and 'xmo 20'. 'purple beddies triple si' is probably 'Pebblebed Heaths SSSI', 'Dean and Way' / 'Dinan Way' is Dinan Way, and 'Buddle 01' is Budl_01.
  • The minutes place the OL11 (agricultural land) comment under Chapter 12. On the recording it was raised after the Chair announced Chapter 13 (afternoon 01:26:22). No member commented on the Chapter 13 (biodiversity / PB) policies, which matches the minutes.
  • On the stage 2 SFRA, the officer said other sites members had allocated against officer advice 'have either already been through' it 'or have subsequently now been going through that process' (03:39:19). This suggests some of that work was still in progress when the plan was approved.