Stop EXMO20

Strategic Planning Committee

19 May 2025

First Regulation 19 consultation: next steps.

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

Summary of our findings

EXMO20 was not on the agenda as a decision, but it came up in public speaking (two of the three speakers on the Local Plan item) and briefly in members' questions on the timetable item. The officer declined to discuss its merits that day, and later explained that EXMO20 had been a rejected site at Regulation 18 which the committee chose to allocate. A councillor raised a Woodland Trust letter about long-established woodland and old trees on the site; the Chair said this would be for a planning application and that the promoters' plans did not develop the northern wooded part.

  • Local Plan timetable (item 9): the committee unanimously endorsed reviewing the plan-making timetable, with a second Regulation 19 consultation after the summer (probably from October 2025) covering the new community masterplan, additional evidence and changes to the plan.
  • The officer said the plan must be submitted by about June 2026 (12 June 2026 per the Chair) to stay within the NPPF transitional arrangements and avoid higher housing numbers.
  • Reasons given for the delay included statutory bodies' concerns about missing evidence: the water cycle study (Environment Agency), Level 2 flood risk assessment for late-added sites, and air-quality mitigation for the Pebblebed Heaths (Natural England).
  • Three public speakers addressed the Local Plan item; two (one by written statement) raised EXMO20, covering the HELAA, site selection, the Regulation 18 history and the habitats assessment. The officer deferred EXMO20 to a later Reg 19 feedback report and said he believed the Reg 19 plan was sound, subject to reviewing the responses.
  • In questions, the officer said EXMO20 had been a rejected site at Regulation 18 that the committee chose to allocate; a councillor cited a Woodland Trust letter about old woodland on the site.
  • The five-year housing land supply was reported as 2.97 years; a summary of Reg 19 feedback was offered for the next meeting.
  • CIL bids (item 7): seven bids supported and five rejected (including the Tipton St John school feasibility study), with delegated authority amended to include the Chair; carried 7 to 1.
  • South East Devon habitats mitigation strategy 2025-2030 (item 8): recommended to Cabinet for adoption, 8 to 1; costs per dwelling to rise.
  • Planning and Infrastructure Bill (item 10) noted; members raised concerns about centralisation, the democratic process and a larger Natural England role in habitat mitigation.
  • A public speaker raised rural exception sites and housing needs surveys; the Chair replied that the affordable housing SPD would be revised after plan adoption.

EXMO20 is named 17 times in the transcript of this meeting.

Quotes from this meeting in our case

…it was at that time a rejected site based on officers' assessments…Ed Freeman, 19 May 2025, 02:33:47 · play ▶ · 2. Not “justified”: EXMO20 failed the council’s own assessment and was allocated before the evidence

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.

Environment Agency concern: late-added sites had no Level 2 flood risk assessment

Important Minutes much briefer · Ed Freeman (officer) · 02:15:49 ▶

Said in the meeting“they've also raised some concerns about the strategic flood risk assessment level two as some of the late addition sites hadn't been through the stage two process”
The minutesreceiving a number of concerns raised by statutory bodies in relation to missing evidence.

The officer said late-added sites had not been through the Level 2 SFRA when the Reg 19 plan was consulted on. EXMO20 was added late by members; the minutes give only 'missing evidence'.

Statutory consultees saw the evidence gaps as more significant than officers did

Important Minutes much briefer · Ed Freeman (officer) · 02:16:12 ▶

Said in the meeting“there were some some what we considered minor gaps in the evidence but some of the consultees have considered those to be more significant than perhaps we felt they were um and so um and and that was reflected in say the comments from the environment agency but also Natural England in terms of habitat mitigations issues”
The minutesreceiving a number of concerns raised by statutory bodies in relation to missing evidence.

Records that officers had judged the evidence gaps at Reg 19 to be minor, while the Environment Agency and Natural England considered them more significant. The minutes do not record this difference of view.

Air-quality mitigation strategy for the Pebblebed Heaths commissioned but not yet available

Important Not in the minutes · Ed Freeman (officer) · 02:16:36 ▶

Said in the meeting“it was flagged up in the um the habitat uh assessments about the air quality impacts on the Pebblebed Heaths and the needs for mitigation strategy for that that work has been commissioned but we obviously don't have that yet um and that's obviously raising concerns from Natural England's perspective as well”
The minutesNot recorded in the minutes.

The habitats assessment had flagged air-quality impacts on the Pebblebed Heaths SAC/SPA, next to EXMO20; the mitigation strategy was not yet available and Natural England had concerns. The minutes do not mention air quality or the heaths here.

Missing the submission deadline would mean housing numbers over 25% higher

Important Minutes much briefer · officer (probably Ed Freeman) · 02:31:38 ▶

Said in the meeting“Well it will have to be at or around the start of June because the 18 months of the NPPF being published just before Christmas is an absolute critical date if we don't hit that then we can't comply with the transitional arrangements and we'd have to increase our housing numbers by over 25%.”
The minutesall the work would need to be completed by the start of June as this would be within the required 18 months of being published. The Chair confirmed the deadline would be 12 June 2026

The minutes record the deadline but not the stated consequence: missing it would raise the housing requirement by over 25%. This frames the timetable, and the room for changing sites, in terms of housing numbers.

Officer explains EXMO20 was a rejected site at Regulation 18 and was allocated by the committee

Important Not in the minutes · officer (probably Ed Freeman) · 02:33:58 ▶

Said in the meeting“while we did consult on that site at regulation 18 stage it was at that time a rejected site based on officers' assessments and you recall that it was the committee that determined that you wanted to include it as an allocation in the plan”
The minutesNot recorded in the minutes.

Confirms in public that EXMO20 was rejected on officers' assessment at Regulation 18 and was made an allocation by the committee. He added that many people did not treat it as an allocation at Reg 18.

Councillor cites Woodland Trust letter on old woodland and 400-year-old trees on the site

Important Not in the minutes · Cllr Brian Bailey · 02:34:41 ▶

Said in the meeting“I have a copy of a letter here from the Woodland Trust and they've done some research into this and they are suggesting that that area we're talking about is 200 years old it's been um a woodland area and there are also several trees on that site that are over 400 years old”
The minutesNot recorded in the minutes.

A committee member raised a specific environmental concern about the EXMO20 area (long-established woodland and veteran trees) citing the Woodland Trust. The minutes do not mention it.

Officer declines to address the EXMO20 points raised by public speakers

Minutes differ · Ed Freeman (officer) · 00:44:34 ▶

Said in the meeting“Well, I'm not going to respond to points about the merits or otherwise of EXMO20, because that's not for today.”
The minutesIn response the Assistant Director Planning Strategy and Development Management firstly addressed the comments made about Exmo_20 and advised that a feedback report on the Regulation 19 Consultation would be brought to Committee in due course

The minutes say the officer 'addressed the comments made about Exmo_20'; on the recording he said he would not respond to them at this meeting and deferred them to a later feedback report.

Habitat mitigation cost per dwelling was given at the meeting

Minutes differ · Ed Freeman (officer) · 02:12:44 ▶

Said in the meeting“so yeah the costs per dwelling range from £852 for the accessory only to £977 for accessory in DoorDish Warren but that's the SAM measures only that's the on-site costs that's not the SANGs costs as well”
The minutesAlthough the exact costings per dwelling could not be provided at the meeting Members were advised that the cost would increase fairly significantly.

The minutes say per-dwelling costs could not be given; the officer did read out figures from the strategy (on-site measures only, excluding SANG costs). Mitigation cost per home bears on viability of sites near the heaths.

Councillor says there were no exhibitions or public meetings for the consultation

Not in the minutes · Cllr Roy Collins · 02:26:56 ▶

Said in the meeting“you've not had any exhibitions in any towns or public meetings where a lot of people, they feel unable to write letters and things or do emails and that. I think they would have appreciated the opportunity to come here and speak. You had quite a lot of meetings that you cancelled, which that denied the public the chance.”
The minutesNot recorded in the minutes.

A councillor raised how the Regulation 19 consultation was run (no in-person events, cancelled meetings), which goes to consultation adequacy. No officer reply is heard and the minutes do not record the point.

Water cycle study: data still incomplete; promise to bring it to members before the second Reg 19

Minutes much briefer · Ed Freeman (officer) · 02:29:59 ▶

Said in the meeting“you know members agree the new timetable then there'll be an absolute final date of needing to bring that to members before that second round of Reg 19 consultation but really we want it well before then to give members an opportunity to to review that and debate that”
The minutesSouth West Water had taken six months to provide data to the study which has led to further work being needed as some data was missing in relation to the waste water infrastructure.

The officer committed to bring the water cycle study to members before the second Reg 19 consultation, calling it 'particularly controversial' and 'particularly important'. The minutes record the delay but not this commitment.

Councillor agrees with Exmouth residents that the Reg 19 consultation was not adequate

Not in the minutes · Cllr Brian Bailey · 02:32:40 ▶

Said in the meeting“Many of the residents of Exmouth, especially those that are relatively close to the Pebblehead East, have, to quote Mr Barlow, a substantial number, whatever that may be, a considerable amount have complained that they didn't think that the first round of consultation was adequate, to quote them. I have a tendency to agree.”
The minutesNot recorded in the minutes.

A committee member stated in public that he tended to agree the consultation was inadequate for residents near the heaths, which is the EXMO20 area. The minutes do not record this.

Chair says woodland is a planning-application matter and refers to the promoters' plans

Not in the minutes · Cllr Todd Olive (Chair) · 02:35:12 ▶

Said in the meeting“I'm sure issues like that would be picked up if and when it came to a planning application And I know that the plans that we've seen from the promoters of the site actually don't involve developing out the very northern bits, which are the wooded bits.”
The minutesNot recorded in the minutes.

The Chair said the woodland issue would be for a later planning application, and referred to plans from the site's promoters that did not develop the northern wooded part. The minutes do not record this exchange.

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 – Apologies
  • Councillor Todd Olive – Chair

Committee members present (9)

  • Councillor Brian Bailey
  • Councillor Jessica Bailey
  • Councillor Kevin Blakey
  • Councillor Colin Brown
  • Councillor Paul Hayward
  • Councillor Ben Ingham
  • Councillor Geoff Jung
  • Councillor Yehudi Levine
  • Councillor Helen Parr

Committee members who sent apologies (3)

  • Councillor Olly Davey
  • Councillor Paula Fernley
  • Del Haggerty

Committee members absent (1)

  • Councillor Dan Ledger

Other councillors attending (5)

  • Councillor Bethany Collins
  • Councillor Ian Barlow
  • Councillor Roy Collins
  • Councillor Peter Faithfull
  • Councillor Eleanor Rylance

Officers (5)

  • Ed Freeman
  • Damian Hunter
  • Wendy Harris
  • Paul Osborne
  • Melissa Wall

Notes on the recording

  • The transcript starts at 00:15:18 (nothing transcribed before the meeting opens) and has a gap for the comfort break from about 01:53:01 to 02:05:27.
  • Between about 00:44:47 and 00:49:04 there was noise from the public gallery: the Chair asked for quiet three times and said he would adjourn the meeting if it continued. An unidentified speaker's remarks at 00:47:18 ('We live here too.') are only partly audible. The minutes do not record this.
  • Vote counts are not in the minutes: CIL bids 7 for, 1 against (01:52:34); habitats mitigation strategy 8 for, 1 against (02:14:08); Local Plan timetable unanimous (02:37:03); Planning and Infrastructure Bill noted unanimously (02:55:15). When moving the timetable recommendation at 02:36:39 the Chair said 'I don't think we really have a huge amount of choice, to be honest.'
  • The minutes' summary of the third public speaker on the Local Plan omits some topics raised (00:42:00 to 00:44:02): the Reg 19 habitats assessment, access to the EXMO20 site and nitrogen on the protected heaths, and the point that Regulation 18 consulted only on preferred and second-choice sites.
  • Also not in the minutes: the officer said a five-year land supply is needed at adoption and that applications on sites proposed for allocation in the Reg 19 plan would go to planning committee to bolster supply (02:25:35); further transport modelling with Devon County Council and National Highways was not complete (02:18:35); and the officer said many respondents did not understand that a Reg 19 consultation asks about soundness (02:24:30).
  • The minutes resolution for item 9 reads 'additional evidence ad changes' (typo for 'and'). In the transcript, Cllr Geoff Jung appears as 'Young'/'Jung' and Cllr Ingham as 'Inham'/'Hingham'.