Stop EXMO20

Strategic Planning Committee

30 September 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 not an agenda item and was not debated or voted on. It came up in public speaking (three speakers) and in the officer's answers. The officer said developers could apply ahead of the plan, admitted the earlier slide had shown too large a site, and promised a corrected plan, probably in November. In the Marlcombe item, the officer rejected the public suggestion to drop sites such as EXMO20 and move their numbers to Marlcombe. He also said the air quality assessment for the Pebblebed Heaths was still outstanding.

  • Three of the four public speakers raised EXMO20: the HRA and the lack of a mitigation strategy, inconsistent site maps, the HELAA availability finding, statutory consultees' responses, developer documents that do not match the draft plan, and a call to move EXMO20's numbers to Marlcombe.
  • Answering a public speaker, the Assistant Director (Ed Freeman) said the 3,000+ Regulation 19 comments would get no individual replies, and that developers could apply for something different at EXMO20 that could be considered and potentially approved before the plan is adopted.
  • Answering Cllr Howe, the officer said the slide at the 2 September meeting showed a slightly larger EXMO20 site than the one proposed, and a corrected plan would come back, probably to the November meeting.
  • Answering Cllr Hayward, the officer said he knew of no authority that had successfully adopted a plan at a figure well below the standard method, and set out the risks of not doing so.
  • The second Regulation 19 consultation was expected in November rather than October. The officer said they were still waiting for the water cycle study and the air quality assessment for the Pebblebed Heaths (the transcript reads 'pelvis'), with a meeting on 4 November to agree the consultation materials.
  • Marlcombe new town: the revised vision (amended to 'at least 10,000' homes), revised Policy WS01, the masterplan vision, the transport vision and the SOBC executive summary were agreed for the second Regulation 19 consultation (6 for, 1 against, 2 abstentions). The infrastructure delivery plan was discussed but not voted on.
  • The officer said deleting sites and putting higher numbers on Marlcombe would not work within the plan period because of lead-in times and conservative build-out rates.
  • The changes to Coastal Change Management Area boundaries and Policy AR03 were endorsed unanimously.
  • The response to Dorset Council's Local Plan options consultation, and delegated authority for a Statement of Common Ground, were agreed unanimously.
  • The minutes of 2 September 2025 were approved, with Cllr Jung added to the apologies.

EXMO20 is named 12 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.

Developers can apply for EXMO20 before the plan is adopted

Important Minutes much briefer · Ed Freeman (officer) · 00:21:52 ▶

Said in the meeting“…what we think is acceptable for EXMO20 they can make an application for something else if they want to doesn't mean it's going to be acceptable to us um but they are entitled to um and that can be considered ahead of the Local Plan and could potentially be approved ahead of the Local Plan”
The minutesDevelopers were entitled to promote additional development, so there was no need for developers’ plans to align with the plans in relation to EXMO 20 before the draft Local Plan was adopted.

The minutes record the public speaker's question about approval before adoption, but not the officer's answer: an application differing from the plan could be considered and potentially approved before the plan is adopted.

Slide at the previous meeting showed a larger EXMO20 site; corrected plan promised

Important Minutes much briefer · Ed Freeman (officer) · 00:28:31 ▶

Said in the meeting“…yes so there was an error on the powerpoint slide at the last meeting which showed a slightly larger site than is actually proposed for allocation in the plan we will obviously be bringing a further version of the plan to you probably the next meeting in november”
The minutesIt was clarified that a further version of the EXMO 20 plan would be brought to a future meeting of the Strategic Planning Committee to be considered and agreed.

The minutes do not record the councillor's question, or that the officer confirmed the slide at the 2 September 2025 meeting showed a larger site than the one proposed for allocation.

Pebblebed Heaths air quality assessment and water cycle study still awaited

Important Minutes much briefer · Ed Freeman (officer) · 00:56:07 ▶

Said in the meeting“…rig 19 consultation I think the timeline I brought forward was um to launch that in october I think realistically it's probably more likely to be november now we're still waiting on a couple of key documents particularly the water cycle study and um the assessment of air quality issues on the pelvis…”
The minutesIt was noted that Regulation 19 consultation was likely to commence in November 2025 for a six-week period.

The minutes give the November date but not the reason: the water cycle study and the air quality assessment for the Pebblebed Heaths (probably 'pelvis' in the transcript) were not finished. Both matter for the HRA and for EXMO20.

Officer rejects moving numbers from other sites to Marlcombe

Important Minutes much briefer · Ed Freeman (officer) · 01:14:55 ▶

Said in the meeting“…in that plan period um so I don't think the solution that was suggested earlier of of you know deleting sites in the plan and just putting higher numbers that Marlcombe actually works in in reality um as much as that might be a convenient solution”
The minutesThere were a number of challenges with housing numbers. The build rates were set as they were, with conservative numbers as it was very hard to predict when delivery might start and the speed at which it would take place.

This is the officer's answer to the public suggestion to drop sites such as EXMO20 and use Marlcombe instead, a point about reasonable alternatives. The minutes record the build rates but not this conclusion.

Risks of planning for fewer homes than the standard method

Not in the minutes · Ed Freeman (officer) · 00:26:25 ▶

Said in the meeting“…I'm not aware of any local authority that has successfully taken forward a plan at a significantly lower figure than the standard method set by government um and the consequences of not promoting a plan that achieves that is that we don't have a Local Plan…”
The minutesNot recorded in the minutes.

This is officer advice on the housing requirement that drives the need for sites such as EXMO20. He added that the government could otherwise produce a plan for East Devon. Cllr Hayward asked for this answer 'for the public record'.

Affordable housing at Marlcombe depends on government grant

Minutes much briefer · Ed Freeman (officer) · 00:59:23 ▶

Said in the meeting“…our aspiration remains to deliver 40% affordable housing as is set out in the policy but we acknowledge that we will need grant funding from government to achieve that fundamentally without that it would be a significantly lower proportion…”
The minutesGovernment funding would be key on delivering aspirations. It was unclear at present as to the level of funding but Marlcombe had new homes programme support.

This is officer advice on the viability of the plan's largest allocation: without grant, affordable housing would be significantly below the 40% in the policy. The minutes do not record that consequence.

Marlcombe 'not a magic bullet' for avoiding development elsewhere

Minutes much briefer · Cllr Olly Davey (probably) · 01:40:20 ▶

Said in the meeting“But even if we were to build it out at a higher density, that housing would not arrive in time for us not to still need to allocate the number of houses we need to do within this Local Plan. And this is the point. Marlcombe is not a kind of magic bullet for avoiding development elsewhere.”
The minutesHousing need, land use across the nation and density of development at Marlcombe were all debated.

This is a stated reason why higher density at Marlcombe was not treated as an alternative to other allocations. The minutes record only that density was 'debated'.

Marlcombe could take more homes (councillor's reason for not supporting)

Minutes much briefer · Cllr Ben Ingham · 01:42:15 ▶

Said in the meeting“…or any party that was in power I think would have been far happier with a 15,000 delivery rather than 10,000 within a controlled structure of supply which involved that coherent infrastructure which we hope to do here because I think 700 delivery is weak I think we could have done a thousand…”
The minutesHousing need, land use across the nation and density of development at Marlcombe were all debated.

A committee member gave his view that Marlcombe could deliver more homes and faster. This bears on whether other allocations are needed. The minutes do not record his view or that he did not support the vision.

Not all listed infrastructure will be deliverable

Minutes much briefer · Chris Knott (council's external consultant) · 01:50:55 ▶

Said in the meeting“…things are factored into our costs our viability fairly soon we're gonna have to make some choices so not all of these things will be deliverable not all of the transport probably will be delivered at least not in the early years so there's a balancing process here that we need to go through”
The minutesIt was suggested that the prioritisation of items be removed from the infrastructure delivery plan, however they were regarded as helpful when allocating finite funding.

This is advice to the committee that some infrastructure, including transport, will probably not be delivered, at least not early. Infrastructure deliverability is a soundness test. The minutes record only the debate about priority labels.

Vote on the Marlcombe recommendations

Minutes much briefer · Cllr Todd Olive (chair) · 01:59:03 ▶

Said in the meeting“…can I ask please all members in favor okay that's six in favor those against please I count one and those abstaining please I count two in which case then those recommendations are clearly carried”
The minutesRESOLVED: that members of Strategic Planning Committee: 1. Agreed that the revised vision statement for Marlcombe be included in the second Regulation 19 version of the Local Plan for consultation.

The minutes do not give the vote (6 for, 1 against, 2 abstentions), or that recommendation 4 (the infrastructure delivery plan) was not put to a vote, on the solicitor's advice relayed at 01:56:50.

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 (7)

  • Councillor Kevin Blakey
  • Councillor Olly Davey
  • Councillor Paul Hayward
  • Councillor Ben Ingham
  • Councillor Geoff Jung
  • Councillor Dan Ledger
  • Councillor Helen Parr

Committee members who sent apologies (3)

  • Councillor Colin Brown
  • Councillor Paula Fernley
  • Councillor Yehudi Levine

Other councillors attending (4)

  • Councillor Paul Arnott
  • Councillor Ian Barlow
  • Councillor Roy Collins
  • Councillor Peter Faithfull

Officers (3)

  • Ed Freeman
  • Damian Hunter
  • Andrew Melhuish

Listed (attendance not confirmed) (4)

  • Wendy Harris – Secretary
  • Councillor Brian Bailey – Committee Member
  • Councillor Jessica Bailey – Committee Member
  • Councillor Del Haggerty – Committee Member

Notes on the recording

  • The recording begins at 00:02:27. It has a gap from 01:59:50 to 02:09:52 during the announced break.
  • The machine transcript misspells several names: Marlcombe appears as 'Malcolm', 'Malcom', 'Malcombe' and 'Markham'; Cllr Jung as 'Councillor Young'; Cllr Howe as 'Councillor Howell'; HELAA as 'HELAR'. 'pelvis' (00:56:24) is probably 'Pebbles', meaning the Pebblebed Heaths.
  • The minutes' summary of public speaking leaves out some topics the speakers raised: the HELAA availability finding (00:07:19), the EXMO20 boundary taking in a residence and its possible effect on residents (00:07:13), the responses of statutory consultees and wildlife bodies (00:08:50, 00:10:28), what the plan says about the northern part of the site and the settlement boundary (00:09:16), and that the developer's documents use a map called out of date (00:15:04). The first speaker also made remarks about named individuals; these are left out here.
  • Not in the minutes: the chair's statement at 00:29:31 defending the Assistant Director's professional competence against criticism from public speakers, and his response at 00:19:57 to a guest councillor's remarks.
  • The minutes link 'a further version of the EXMO 20 plan' to the reply to the public speaker. In the recording it was the answer to Cllr Howe's separate question about which EXMO20 map applies (00:27:49 to 00:28:31).
  • Attendance page: Cllrs Brian Bailey, Jessica Bailey and Del Haggerty are shown as 'Expected', not Present or Apologies. They were not called in the roll call (00:03:44). Cllr Jung did not answer when called at 00:04:15, but spoke at 00:05:09.
  • Coastal Change Management Areas: the transcript records the vote as 'carried unanimously' (02:20:32), proposed by Cllr Jung and seconded (transcribed as 'Councillor Lau'). The minutes give the resolution without these details.