Stop EXMO20

Strategic Planning Committee

4 February 2025

East Devon District Council meeting on the Local Plan.

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

Summary of our findings

EXMO20 was the main subject of public speaking: all six speakers addressed it. It came up again in the Local Plan item, where the officer said that B3179 access had always been expected and that Devon County Council wording had been added on road and junction capacity and mitigation. The officer also said air pollution on the heaths needed a mitigation strategy before submission. The Chair and officer said the allocation itself was not being reconsidered. Two committee members commented on EXMO20 (one giving the reason it was chosen, one opposing it), and the Regulation 19 plan including EXMO20 was approved 10–1–1.

  • The committee approved the Regulation 19 (publication) version of the Local Plan, which includes EXMO20, and agreed a six-week consultation from the week of 10 February 2025. The vote was 10 for, 1 against (Cllr Jess Bailey) and 1 abstention (Cllr Helen Parr).
  • Six people spoke about EXMO20 before the item: four members of the public (one representing Budleigh Salterton Town Council) and two ward members (one by written statement). They raised B3179 access and road safety, the Pebblebed Heaths SSSI/SAC, air quality and the Habitats Regulations Assessment, the involvement of Budleigh Salterton, and the late allocation.
  • Before the Local Plan item, the Chair said the committee was only looking at changes since the December 2024 version and could not reverse earlier decisions unless the Constitution were suspended. The officer said the allocations were not being reconsidered.
  • The officer said the HRA had been updated but was not final. A new air-pollution issue affecting the Pebblebed Heaths still needed a full mitigation strategy before submission, and Natural England would be consulted through the Regulation 19 process.
  • Evidence that members had not seen or that was not ready: the Infrastructure Delivery Plan, the final HRA, the water cycle study, the Greater Exeter Transport Study and probably the latest Sustainability Appraisal. One member objected to consulting without them. Others preferred to keep to the timetable and use the second Regulation 19 round if changes were needed.
  • Two committee members spoke about EXMO20 in the debate. Cllr Davey gave the members' reason for choosing it (a better location than Hulham Road sites). Cllr Brian Bailey said he was totally against it and said the site has no active travel.
  • Under the new December 2024 NPPF, the housing requirement became 950 homes a year (80% of 1,188), with 9.8% headroom and a stepped trajectory (850 then 1,070 a year). Five-year housing land supply fell to 2.97 years, and a six-year supply will be needed from 1 July 2026.
  • The committee noted the NPPF changes and agreed to write to government about the six-year housing land supply requirement.
  • The committee also agreed to object to Exeter City Council's Regulation 19 plan over employment land and the Topsham infrastructure framework, endorsed the self-build monitoring report, and recommended the new Local Development Scheme to Council.

EXMO20 is named 16 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: earlier allocation decisions could not be reversed at this meeting

Important Not in the minutes · Cllr Todd Olive (Chair) · 00:55:16 ▶

Said in the meeting“where I will take the opportunity before Mr Freeman speaks to remind members that we are looking at what has changed since the December version that we saw, because we have, of course, already approved the December version, which means unless members would like to suspend the Constitution, we can't go back and reverse those decisions at this time.”
The minutesNot recorded in the minutes.

This limited the scope of the debate. Members were told that site allocations, including EXMO20, could not be revisited at the meeting that approved the Regulation 19 plan. The officer repeated this at 01:05:01.

HRA: air pollution on the Pebblebed Heaths still needs a full mitigation strategy

Important Minutes much briefer · Ed Freeman (officer) · 01:02:25 ▶

Said in the meeting“Habitat Regulations work and further specialists on this air pollution issue so we are satisfied that it can be mitigated but we obviously need to develop a full mitigation strategy as part of further work to inform the plan for that to be submitted for examination…”
The minutesMembers noted that work was still ongoing in relation to air pollution and the Pebblebed Heaths.

The officer also said this air-pollution issue 'wasn't previously identified' (01:01:45). He confirmed that no mitigation strategy existed yet and that one was needed before submission. The minutes record only that work was ongoing.

Natural England to be consulted on heaths issues through Regulation 19

Important Not in the minutes · Ed Freeman (officer) · 01:03:03 ▶

Said in the meeting“…we will be consulting with Natural England on those issues and obviously working with them as the plan progresses through the examination process as well so as I say that's all an iterative process that works forward so we don't have the final answers we don't need to on some of those issues at this point…”
The minutesNot recorded in the minutes.

A public speaker said Natural England had not been properly consulted. The minutes record that claim but not the officer's answer: consultation would happen through Regulation 19, after the plan was approved, and final answers were not needed yet.

Water cycle study not available and not seen as essential

Important Minutes much briefer · Ed Freeman (officer) · 01:18:31 ▶

Said in the meeting“…so we don't have the water cycle study so that won't be going out to consultation at this stage but I think as we said in the report I don't consider that necessarily essential for the Local Plan that has obviously wider connotations than just that”
The minutesMembers also noted there were outstanding evidence documents which included: … Water Cycle Study.

The minutes list the water cycle study as outstanding. They do not record that it would not be published for this consultation, or the officer's view that it was not essential to the plan (repeated at 01:24:31 and 01:25:03).

Updated HRA is not final; work to continue beyond Regulation 19

Important Minutes much briefer · officer (probably Ed Freeman) · 01:24:01 ▶

Said in the meeting“…so we have an updated HRA again as I say it won't be a final one because as I say there's further work ongoing and there will be even beyond the regulation 19 consultation…”
The minutesThe Assistant Director – Planning Strategy and Development Management acknowledged that not all the final versions of the evidence documents had been seen and reassured Members that these documents did not contain any surprises

The plan, including EXMO20 next to the Pebblebed Heaths SAC/SPA, went to Regulation 19 with an HRA that the officer said was not final. The minutes record only that members had not seen all final versions.

Members had probably not seen the latest Sustainability Appraisal

Important Not in the minutes · officer (probably Ed Freeman) · 01:28:05 ▶

Said in the meeting“…sustainability appraisal again the sustainability appraisal is an iterative process so that's been carried out alongside so I've lost track of which iteration you've seen probably not the latest but again there won't be any surprises in there”
The minutesNot recorded in the minutes.

The Sustainability Appraisal is the statutory assessment of sites and reasonable alternatives. The officer said members approving the plan had probably not seen the latest version. The minutes do not mention the Sustainability Appraisal.

Cllr Davey: why members chose EXMO20

Important Not in the minutes · Cllr Olly Davey · 01:40:56 ▶

Said in the meeting“…just like to say about EXMO20 I think one of the reasons we asked officers to look at it again was because we considered it was a better location than some of the developments along hullam road that we really did not like and I think it was actually chosen as an alternative…”
The minutesNot recorded in the minutes.

A committee member's stated reason for the EXMO20 allocation: it was chosen as an alternative to Hulham Road sites. This is relevant to site selection and alternatives. He added that he was not at the meeting where it was approved.

Cllr Brian Bailey: opposed to EXMO20

Important Not in the minutes · Cllr Brian Bailey · 01:46:43 ▶

Said in the meeting“I'm totally against Exxon 20. When it did come up, it was seen as a least worst option, I think, was the quote from Councillor Howe when it came up. And the more we look into it, the worst choice. sometimes, personally, I think most of the committee that voted for it would probably wish that they hadn't.…”
The minutesNot recorded in the minutes.

A committee member said he opposed EXMO20 and described it as having been seen as the 'least worst option'. The minutes do not record any member's comments on EXMO20.

Public speaker: soundness should be tested before Regulation 19, and the HRA could not rule out adverse effects

Minutes differ · a public speaker · 00:18:42 ▶

Said in the meetingA member of the public raised this point. We don't quote or name members of the public, so play the clip to hear it.
The minutesthis should be rigorously assessed before the Local Plan is submitted for examination.

On the recording the speaker said soundness should be assessed before publication at Regulation 19, and that the HRA could not rule out adverse effects on site integrity (00:19:18). The minutes put the test at submission and record his HRA water and air quality concerns, but not that point.

EXMO20 access from the B3179 and Devon County Council's wording

Minutes differ · Ed Freeman (officer) · 01:04:15 ▶

Said in the meeting“…I think our reports have always highlighted that access would need to be from the B3179 and that there were issues in terms of access to the south uh on the eczema side so that was already known…”
The minutesHowever, the primary access was always to be from the B3179 and Members were made aware of this when deciding to allocate the site.

The minutes give this as a firm statement and add that members knew when they allocated the site. On the recording the officer said 'i think our reports have always highlighted'. The minutes also leave out the 'review of local road and junction capacity' (01:04:48).

Vice-Chair: known issues, including the HRA, could be fixed in the second Regulation 19 round

Minutes much briefer · Cllr Mike Howe (Vice-Chair) · 01:35:51 ▶

Said in the meeting“if we find issues we know there are issues but if we find issues that are unsurmountable because the HRA or anything else we can adjust and go through again in the second Reg 19 consultation”
The minutesSupport was expressed to keep to the original timescales and to publish the first phase of the Consultation on 10 February.

The minutes do not record the reason given for not waiting for the evidence: known issues, including the HRA, could be dealt with later. Nor do they record the officer's reply (01:36:21) that the second Regulation 19 consultation could be widened.

Cllr Brian Bailey: EXMO20 has no active travel and adds car journeys

Not in the minutes · Cllr Brian Bailey · 01:47:32 ▶

Said in the meeting“we're doing things that normally are under a less pressurised system we wouldn't even consider to do in XF20 for example we haven't got any active travel we've got pollution because we're running miles in the wrong direction to get to where we want to be in the first place”
The minutesNot recorded in the minutes.

A committee member raised sustainability concerns about EXMO20 (no active travel, car pollution) and linked the choice to time pressure. He also said the plan was 'seven eights prepared' (01:46:12).

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 Bethany Collins
  • Councillor Olly Davey
  • Councillor Paula Fernley
  • Councillor Paul Hayward
  • Councillor Geoff Jung
  • Councillor Yehudi Levine
  • Councillor Helen Parr

Committee members who sent apologies (2)

  • Councillor Colin Brown
  • Councillor Ben Ingham

Committee members absent (1)

  • Councillor Dan Ledger

Other councillors attending (5)

  • Councillor Aurora Bailey
  • Councillor Ian Barlow
  • Councillor Roy Collins
  • Councillor Peter Faithfull
  • Councillor Melanie Martin

Officers (4)

  • Ed Freeman
  • Damian Hunter
  • Wendy Harris
  • Debbie Meakin

Notes on the recording

  • The transcript starts at 00:06:37 (nothing before the Chair opens the meeting). There is a break from 02:06:09 to 02:22:32. The meeting ends at 02:40:12.
  • The saved minutes file had only an extract of item 255 (NPPF changes). The full printed minutes record the motion for a letter to government on the six-year housing land supply (proposed by Cllr Jung, seconded by Cllr Fernley) and a resolution to draft it, but no vote count. On the recording, the Chair counts 'Ten' for (00:54:48) and then an abstention from Cllr Brian Bailey (00:55:07); Cllr Hayward later says he voted against (01:30:58).
  • The Local Plan vote in the minutes (10 for, Cllr Jess Bailey against, Cllr Parr abstaining) matches the counts on the recording (02:05:44: ten, one, one). The recording does not say who voted against or who abstained.
  • The minutes name the public speakers. The website should not, under the campaign's rules.
  • The public-speaker item has an empty quote because the brief allows quoting only officers and councillors.
  • The machine transcript misspells EXMO20 in several ways: 'Exmouth 20', 'ECMAS 20', 'Exxon 20', 'XF20', 'TXMO 20', 'Expo 2.0', 'autri 20', 'x plus 20'. Budleigh appears as 'Budley' or 'Buddley', and Exmouth as 'eczema' (01:04:21). Quotes keep the transcript spelling.
  • Further omissions, left out of the list as less central: the officer said the Infrastructure Delivery Plan was 'quite a key document' that was not ready for the meeting (01:05:18, 01:05:58). The minutes say only that it would come to committee after consultation. The officer also said the stepped trajectory gives 'a robust 6.59 year housing land supply upon adoption', only 0.59 years above the requirement (00:59:58).
  • At 01:15:58 to 01:16:29 the Chair warned a member of the public about interrupting and said he would adjourn if it continued. This is not in the minutes (procedural only).