Stop EXMO20

Strategic Planning Committee

8 July 2025

Consultation feedback report.

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

Summary of our findings

Exmo_20 was the main subject of the meeting. Most public speakers addressed it, and in debate several committee members, including some who had supported it, called for it to be reviewed; Cllr Ledger said officers had advised against including it. The committee voted to ask officers for a report on Exmo_20 alongside six other sites with above-average objections, with the officer warning about the transitional arrangements and housing numbers.

  • The committee received feedback on the first Regulation 19 consultation: 3,510 individuals or organisations commented, with about 1,100 responses on Exmo_20 (biodiversity, flood risk, infrastructure and procedure).
  • Twelve people had registered to speak, most about Exmo_20 (HELAA and site-selection history, HRA, access via the B3179, the Pebblebed Heaths, distance from services); others spoke on the Whimple sites and the Sidmouth Cliff Road CCMA.
  • Several councillors asked for Exmo_20 to be reviewed. The Chair said it would not be sound to review Exmo_20 alone and that other sites with above-average objections should also be looked at.
  • Officer advice: new Planning Practice Guidance on two-stage Regulation 19 consultations means significant changes could lose the transitional arrangements and raise the housing figure by about 25%; he advised against deciding on sites at this meeting.
  • Outstanding evidence (water cycle study, Level 2 SFRA, Pebblebed Heaths air quality assessment and mitigation, transport study, housing needs update, statements of common ground) was expected for a second Regulation 19 consultation in October–November 2025.
  • On Cllr Ledger's amendment (seconded by Cllr Brian Bailey), the committee endorsed the timetable and asked for a report on the water cycle study, CCMAs, duty to co-operate, wind energy areas and sites Lymp_01, Whim_08a, Whim_11, Feni_08, Otry_20, Exmo_17 and Exmo_20 (and any others officers suggest). The recording shows 9 for, 0 against, 2 abstentions.
  • The officer said that report would also cover the implications of removing sites, including housing numbers and alternative sites.
  • The committee recommended the revised Local Development Scheme to Cabinet (unanimous).
  • Urgent item: £100,000 awarded in principle from CIL to Exmouth Rugby Club's revised project, reduced to £67,000 if the club can reclaim VAT.

EXMO20 is named 72 times in the transcript of this meeting.

Quotes from this meeting in our case

…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 headroom…Ed Freeman, 8 July 2025, 02:16:43 · play ▶ · 6. “Significant change” has no stated basis
…we knew we didn't have the water cycle study we knew that the HRA required some some further workEd Freeman, 8 July 2025, 01:47:06 · play ▶ · 7. Procedural and consultation flaws
…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 ▶ · 8. Councillors’ own admissions
…not to say I like EXMO20 in any shape or form it shouldn't have been there…Cllr Howe, 8 July 2025, 03:19:57 · play ▶ · 8. Councillors’ own admissions

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.

Officer: new National Landscape duty not reflected in the plan

Important Minutes much briefer · Ed Freeman (officer) · 01:30:04 ▶

Said in the meeting“…we've moved from this duty to have regard to the national landscape to a duty to further the purposes of the national landscape which isn't reflected in the plan and so it's not a surprise that that's been raised by various parties including Natural England so we need to respond to that”
The minutesConcerns about site allocations within a national landscape.

The officer accepts that the Regulation 19 plan does not reflect the current duty towards National Landscapes, raised by Natural England. The minutes record only 'concerns'.

Pebblebed Heaths air quality assessment and mitigation still in progress

Important Minutes much briefer · Ed Freeman (officer) · 01:35:06 ▶

Said in the meeting“…other things to mention in terms of pebble bed he says the air quality assessment and mitigation strategy that works progressing well with the consultants and again confident that we will have an approach to that that addresses the concerns that have been raised in time for the consultation the second regulation 19 consultation”
The minutesThe Assistant Director – Planning Strategy and Development Manager advised that he was confident that the outstanding evidence documents would be completed in time to support the Local Plan consultation

The minutes do not name the Pebblebed Heaths air quality assessment and mitigation strategy as outstanding. This evidence is directly relevant to a site next to the heaths SAC/SPA.

Officer: gaps in evidence (SFRA, water cycle study, HRA) were known

Important Minutes much briefer · Ed Freeman (officer) · 01:47:06 ▶

Said in the meeting“…we knew that there was some work that still needed to be done in terms of Stage 2 SFRA, for example. we knew there were some sites that hadn't been through that process because they were added in quite late we knew we didn't have the water cycle study we knew that the HRA required some some further work”
The minutesIn response he advised that some comments were a surprise and gave an example that the Environment Agency had objected to the lack of a Water Cycle Study when it was not a requirement.

The minutes record the 'surprise' part of the answer but not the statement that the missing SFRA, water cycle study and further HRA work were known when the plan went to consultation.

Officer: committee can make substantive changes; consequence is about 25% more homes

Important Minutes much briefer · Ed Freeman (officer) · 02:18:31 ▶

Said in the meeting“…I'm not saying you can't do it obviously you can um it's in your gift to to make those changes and if those changes lead to us falling out the transitional arrangements we would have to deal with the consequences of that but the consequences are that the housing numbers would go up by about 25 percent”
The minutesThe Assistant Director – Planning Strategy and Development Manager clarified that it would depend on the size of the site and whether this would have a consequence on the headroom of housing numbers.

The minutes record the 25% risk in general terms (under paragraph 4.2), but not this answer: that changing sites is within the committee's power. He added 'i don't know where those additional sites would come from' (02:18:55).

Councillor's account of how Exmo_20 entered the plan

Important Not in the minutes · Cllr Olly Davey · 02:38:05 ▶

Said in the meeting“My recollection is that EXMO20 wasn't put forward by officers and it was councillors who persuaded them to look at it again because we felt it was an alternative to the sites to the west of Hullam Road, the northwest of Hullam Road, which did seem to us incredibly unsustainable.”
The minutesNot recorded in the minutes. (The minutes record only: 'There was a need to consider the high level of objections received for Exmo_20 and a suggestion was made to review Exmo_20.')

Gives a member's account of the site's origin (not proposed by officers; chosen by councillors as an alternative to Hulham Road sites). Relevant to site selection and alternatives.

Proximity of Exmo_20 to the National Landscape and Pebblebed Heaths

Important Not in the minutes · Cllr Olly Davey · 02:39:26 ▶

Said in the meeting“There's also, and I think very importantly, the proximity to the national landscape and particularly the Pebblebed Heaths. And I notice the very first point in the issues and actions is to review allocations within or adjacent to a national landscape.”
The minutesNot recorded in the minutes. (Only 'a suggestion was made to review Exmo_20' is recorded.)

The stated reason for review links Exmo_20 to the officers' own action to review allocations within or next to a National Landscape, and to the protected heaths.

Committee member says officers had advised against including Exmo_20

Important Not in the minutes · Cllr Dan Ledger · 02:51:19 ▶

Said in the meeting“…yes this isn't an ideal site and it shouldn't have been included at the time. The officers themselves said it shouldn't be included. We as members have made that decision to push forward and we have to be accountable to the members of the public”
The minutesNot recorded in the minutes. (The minutes record only his point that 'this was going to be East Devon District Council’s last Local Plan'. Under public speaking they record the officer's general remark that 'on occasions the Committee’s views had differed from officers recommendations'.)

A committee member states in public that officers advised against including Exmo_20 and that members chose to include it. This bears on how the allocation decision was reached.

Exmouth's strategic role and constraints

Minutes differ · Ed Freeman (officer) · 02:08:02 ▶

Said in the meeting“…I think when we went through the site assessments we were um trying to identify opportunities wherever possible to accommodate growth in eczema for by far our biggest town and um and but it is quite constrained as as you've already heard in terms of the sites we have chosen never mind the ones we haven't”
The minutesalthough Exmouth is the biggest town in East Devon it has environmental and other constraints that would not allow any further development.

The minutes say constraints 'would not allow any further development'; the officer said Exmouth is 'quite constrained', including the sites already chosen. Relevant to whether Exmouth alternatives exist.

Statutory consultees' responses are mostly soundness objections

Not in the minutes · Ed Freeman (officer) · 02:11:07 ▶

Said in the meeting“to be honest in most cases there are objections about soundness of the plan that's how we asked people to phrase their their responses um but that doesn't mean that they can't be overcome they're not saying necessarily that they're insurmountable”
The minutesNot recorded in the minutes.

Confirms that most statutory consultee responses were formal objections on soundness rather than general concerns. Cllr Jess Bailey said this was not clear in the report.

Chair on the original Exmo_20 vote and the officer's view

Not in the minutes · Cllr Todd Olive (Chair) · 02:41:36 ▶

Said in the meeting“…given that I didn't vote for it in the goddamn first place. And a number of members of this committee did, who are now saying that they want to talk about taking it out. I think [member of the public] probably sitting to my left quietly thinking, I told you so, in relation to that site specifically.”
The minutesNot recorded in the minutes. (The minutes record the Chair's growth figures for Exmouth and that 'it would not be a sound decision to only review Exmo_20'.)

The Chair's remarks indicate that the earlier allocation of Exmo_20 went against the officer's view, consistent with Cllr Ledger's statement.

Vice-Chair's concern that the motion risks higher housing numbers

Not in the minutes · Cllr Mike Howe (Vice-Chair) · 03:18:54 ▶

Said in the meeting“…getting worried about this conversation and partly this motion which is driving us further and work further away from having a regulation 19 consultation and driving us to more houses on a yearly basis an extra 200 homes per year we are gonna have to find if we are not careful about what we're doing”
The minutesNot recorded in the minutes.

A stated reason against the amendment, given in debate. In the same contribution he said of Exmo_20 'it shouldn't have been there' (03:20:05). Two members abstained.

Vote on the amended recommendation

Not in the minutes · Cllr Todd Olive (Chair) · 03:23:59 ▶

Said in the meeting“…that's nine in favor for the benefit of the tape we turn the mics off just so uh members watching folks watching at home could see the hands raised um those abstaining please oh sorry against first please for the benefit of the tape there's uh no hands in the air uh and those abstaining two two abstentions”
The minutesRESOLVED: 1. That Strategic Planning Committee endorse the proposed new local plan making timetable and work plan, including studies to be completed.

The minutes give the resolution but not the vote (9 for, 0 against, 2 abstentions in the recording). This is the decision to bring back a report on Exmo_20 and other sites.

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 Olly Davey
  • Councillor Paula Fernley
  • Councillor Paul Hayward
  • Councillor Geoff Jung
  • Councillor Dan Ledger
  • Councillor Yehudi Levine

Committee members who sent apologies (3)

  • Councillor Del Haggerty
  • Councillor Ben Ingham
  • Councillor Helen Parr

Other councillors attending (6)

  • Councillor Aurora Bailey
  • Councillor Ian Barlow
  • Councillor Christopher Burhop
  • Councillor Roy Collins
  • Councillor Peter Faithfull
  • Councillor Nick Hookway

Officers (3)

  • Wendy Harris
  • Ed Freeman
  • Damian Hunter

Notes on the recording

  • Recording starts at 00:09:07. Breaks at 01:10:37–01:24:36 and 02:56:33–03:02:45; no other gaps noticed.
  • Agenda numbering differs: on the video the Local Plan report is item 7, the LDS item 8 and the Rugby Club item 9; the minutes number them 6, 7 and 8. Minute 4 refers to 'minute 276', which looks like a slip. The agenda says previous minutes of '15 May', the minute says '19 May' (the Chair says 19 May on the video).
  • The saved minutes file has the full text only for item 6; the item 3 (public speaking) text is cut off after the third speaker. The items were rechecked against the full printed minutes: item 3 records the officer's answers on procedure and AI use, and that 'on occasions the Committee’s views had differed from officers recommendations', so item-3 points were not listed here.
  • Machine-transcript errors: 'eczema', 'Exxon 20', 'Expo 20', 'xmas' for Exmouth/Exmo 20; 'motorcycle study' for water cycle study; 'pebble bed he says' for Pebblebed Heaths; 'Councillor Young' for Cllr Jung; 'Mr. Truman' for Mr Freeman; 'Hullam/Harlem Road' for Hulham Road.
  • Who abstained is not clear: after 'two abstentions' the transcript reads 'councillor how on my right does exist', which is garbled.
  • Not in the minutes: at 02:49:28 the Chair said he had asked AI to summarise the consultation report and that 31 of the 72 sites had a response asking for removal (nearly 3,000 homes). The officer also said comments were summarised using AI (00:48:38).
  • Officer's answer to Cllr Blakey (03:11:12): problem sites cannot be held back as 'last resort' or reserve sites ('the short answer is no not really'). Not in the minutes.