Stop EXMO20

Strategic Planning Committee

14 July 2026

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 dominated most of the meeting, although the only decision was the revised timetable (LDS). All public speakers addressed it, and the officer's answers covered the HELAA failure and later access work, the 400m buffer wording, site ownership, land wrongly included in the 3 September 2024 report, and why housing numbers and the transitional arrangements are not being changed. In debate, one committee member and two non-committee councillors questioned or objected to the allocation; others argued the plan must proceed, and one said inclusion in the plan does not mean the site will definitely be developed.

  • Public speaking (five contributions: a statement read out, three speakers in person and a question read out) was all about EXMO20 and the Local Plan: the 400m Pebblebed Heaths buffer, the HELAA result, housing numbers, transitional arrangements, site access and site availability.
  • The Assistant Director (Ed Freeman) read answers into the record: EXMO20 failed the first HELAA mainly on access, and was taken forward after access from the B3179 was explored following the 3 September 2024 meeting; the site is owned by two parties; the 3 September 2024 report included some land in error.
  • He said officers will not update the housing figure for 2024/25 data, that the plan relies on the 80% transitional arrangements, and that moving to the new system would mean higher numbers and an even greater need to allocate EXMO20.
  • Main item: revised Local Development Scheme. Submission slipped from spring 2026; now SPC in September 2026, an extra Full Council in October 2026, submission late October 2026 and adoption in 2028.
  • Evidence still outstanding: air quality at the Pebblebed Heaths (Ricardo), the Habitat Regulations Assessment (Footprint Ecology, waiting for the air quality and water work), the Water Cycle Study (no agreed position yet with the Environment Agency and South West Water), Marlcombe viability and the River Axe nutrient strategy.
  • Members asked about the data behind the air quality modelling, how secure the 400m buffer is, vehicle speeds and sewage capacity; one committee member asked why EXMO20 is still being pursued, and the officer said the plan, including Exmo 20, is the most sustainable way to meet the required numbers.
  • Non-committee councillors spoke: one objected to EXMO20 and asked how it fits the climate emergency, one spoke against the loss of farmland, and one said removing EXMO20 would be a significant change that loses the transitional arrangements. The officer did not add anything.
  • A fourth recommendation was added in the meeting: officers to report back on options for support with water quality issues in planning decisions and keeping the Water Cycle Study up to date. All four recommendations were carried on a show of hands.
  • The committee endorsed a response to Mid Devon's Local Plan scoping consultation (unanimous), with concerns about the Junction 27 proposal.
  • The chair gave a formal warning to members of the public in the gallery under the Constitution's rule on disturbances.

EXMO20 is named 36 times in the transcript of this meeting.

Quotes from this meeting in our case

the allocated site failed the first HELAA assessment.Ed Freeman, 14 July 2026, 00:41:25 · play ▶ · 2. Not “justified”: EXMO20 failed the council’s own assessment and was allocated before the evidence
…following members favorable consideration of the site at that meeting officers further explored the site access arrangements…Ed Freeman, 14 July 2026, 00:21:11 · play ▶ · 2. Not “justified”: EXMO20 failed the council’s own assessment and was allocated before the evidence
…included some land in error…Ed Freeman, 14 July 2026, 00:41:09 · play ▶ · 7. Procedural and consultation flaws

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.

Housing figure: officer says the plan is short of the new standard method and will be challenged at examination

Important Minutes much briefer · Ed Freeman (officer) · 00:27:01 ▶

Said in the meeting“…whilst plan making regulations allow for us to progress the plan under this reduced figure we are short compared to the new standard method figures and are being challenged on this through representations made against the plan and we will have to defend that position at examination therefore changing the housing numbers is not appropriate at this time”
The minutesofficers do not recommend changing the housing numbers explaining that while housing requirements can increase or decrease over time, the Council’s position is that the plan should not be revised each time this happens

The minutes record the decision not to update the figure and the reliance on transitional arrangements, but not the officer's statement that the reduced figure is short of the new method and is being challenged in representations.

No agreed Water Cycle Study position may exist by submission

Important Minutes differ · Ed Freeman (officer) · 00:44:57 ▶

Said in the meeting“…that is ongoing whether we can reach a position where everybody agrees on the position by the time the plan submission is not entirely clear but I don't think that's an essential requirement in terms of submission the plan”
The minutesAn up-to-date Water Cycle Study and agreement with relevant bodies, including the Environment Agency, are required.

The minutes record agreement as required; in the meeting the officer said agreement by submission was uncertain and not essential. Later (01:55:13) he said South West Water disagreed with much of the consultants' modelling.

Habitat Regulations Assessment still waiting for air quality and water evidence

Important Minutes much briefer · Ed Freeman (officer) · 00:45:18 ▶

Said in the meeting“…all of this obviously feeds into Habitat Regulations assessment work as I mentioned so once we have all of that work footprint ecology will be updating their Habitat Regulations assessment work and hopefully we'll be in a position where we can have an acceptable Habitat Regulations assessment to accompany the plan”
The minutesMembers received progress updates on outstanding evidence work, including the Marlcombe Viability Testing, Playing Pitch and Open Space Strategy, Air Quality Impacts at the Pebblebed Heaths, Habitat Regulations Assessment, Water Cycle Study

Records that, about three months before planned submission, the HRA for a plan allocating sites near the Pebblebed Heaths SAC/SPA still depended on unfinished air quality and water work.

Natural England query on employment uses within the 400m zone

Minutes much briefer · Ed Freeman (officer) · 00:20:03 ▶

Said in the meeting“…It is noted that in their consultation response to the first regulation 19 consultation the Natural England sought clarity about where employment uses would be located. However this is a level of detail that does not need to be determined at this stage.”
The minutesno further detail or clarification is considered necessary at this stage

The minutes record the conclusion but not that the officer referred to Natural England's request for clarity on uses within the 400m zone next to the SAC/SPA.

New plan-making system would raise the need for EXMO20 (minutes say 'potentially' and 'sites like')

Minutes differ · Ed Freeman (officer) · 00:32:12 ▶

Said in the meeting“I mean, I think it's important to note that if we were to adopt the new plan-making system, we'd also have to adopt the new standard method and the higher housing numbers. So you'd have to provide thousands of additional homes over what's in this plan, which would create an even greater need to allocate EXMO20.”
The minutesif the Council switched to the new system this would result in higher housing requirements and potentially an even greater need for sites like Exmo_20

The officer referred to EXMO20 directly and without qualification; the minutes add 'potentially' and widen it to 'sites like Exmo_20'.

Source of the electric vehicle data in the air quality modelling

Not in the minutes · Ed Freeman (officer) · 00:55:08 ▶

Said in the meeting“I'd have to check in terms of the source of the data on either usage um I'm assured that it comes from a reliable source and can be relied upon in terms of this work um it may even be government data um I have to check obviously it's a prediction…”
The minutesNot recorded in the minutes.

The refined Pebblebed Heaths air quality modelling relies on higher electric vehicle uptake; the officer could not confirm the data source in the meeting. This evidence feeds the HRA.

Committee member questions why EXMO20 is still pursued

Minutes much briefer · Cllr Brian Bailey · 01:07:54 ▶

Said in the meeting“and I fail to see, with the evidence before me, regarding the HELAA, the air quality and the water cycle, that why with such lack of consistent and positive reports on Exxon's 20 in particular, why are we pursuing it? Because it appears to me that we're up against a brick wall.”
The minutesSeveral Members acknowledged the concerns raised by Exmouth Ward Members regarding Exmo_20 while emphasising the Committee’s responsibility to consider the wider needs of East Devon as a whole.

The minutes refer to Exmouth members' concerns only in general terms. They do not record this committee member's points on the HELAA, air quality and water evidence, or on local infrastructure (GP access, sewage overflows).

Officer: transitional arrangements used to keep numbers down; some environmental impacts will remain

Minutes much briefer · Ed Freeman (officer) · 01:14:21 ▶

Said in the meeting“…keep the growth levels down to the minimum we can justify by going through these transition arrangements and produce the plan that tries to meet those growth requirements in the most sustainable way possible that's not to say that there won't still be some environmental impacts…”
The minutesExmo_20 has been proposed for allocation as part of the Council’s statutory responsibility to plan for housing growth. Officers advised that the Local Plan represents the most sustainable and appropriate approach

The minutes give the conclusion; the officer's reasoning (choice of transitional arrangements, accepted environmental impacts, evidence still being produced) is not recorded.

Councillor's climate emergency question on EXMO20 not answered

Minutes much briefer · Cllr Melanie Martin · 01:23:51 ▶

Said in the meeting“…I have a question. EDDC called a climate emergency in 2019 and is now proposing a development that is harmful to wildlife, trees and nature. How does the EXMO20 development align with the council's climate change action plan?”
The minutesCouncillor Melanie Martin confirmed her objection to the allocation of Exmo_20 within the Local Plan citing concerns about impacts on wildlife and habitats.

The minutes record her objection but not her question about EXMO20 and the council's climate policy. When invited to respond at about 01:32:03, the officer added nothing, so no answer was given in the meeting.

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

Committee members present (9)

  • Councillor Brian Bailey
  • Councillor Jessica Bailey
  • Councillor Kevin Blakey
  • Councillor Colin Brown
  • Councillor Olly Davey
  • Councillor Peter Faithfull
  • Councillor Charlotte Fitzgerald
  • Councillor Paul Hayward
  • Councillor Geoff Jung

Committee members who sent apologies (3)

  • Councillor Paula Fernley
  • Councillor Ben Ingham
  • Councillor Yehudi Levine

Committee members absent (1)

  • Councillor Dan Ledger

Other councillors attending (3)

  • Councillor Paul Arnott
  • Councillor Roy Collins
  • Councillor Melanie Martin

Officers (3)

  • Wendy Harris
  • James Docherty
  • Ed Freeman

Notes on the recording

  • Minutes source: checked against the council's printed minutes PDF (8 pages, from the 'Printed minutes PDF' link). The full printed minutes properly record three points from the first draft of this file, which have been removed: the site ownership and 3 September 2024 boundary error answer, Cllr Arnott's view on removing EXMO20, and the fourth recommendation with its proposer, seconder and resolution.
  • Cllr Arnott asked officers to say if his understanding was wrong (01:29:50–01:29:56): that removing EXMO20 would be a significant change and lose the transitional arrangements. When the chair invited the officer to add anything after the three non-committee speakers (about 01:32:03), he did not. The minutes record Cllr Arnott's view as his own and do not mention an officer response.
  • Votes: the printed minutes list four resolutions for item 6, proposed by Cllr Olive and seconded by Cllr Hayward, but give no vote figures. In the recording the vote was a show of hands declared 'clearly carried' (02:14:26), with no count announced. Resolution 4 in the minutes says 'keeping the Water Cycle up to date' (the word 'Study' is missing), whereas the proposal text just above it says 'Water Cycle Study'.
  • Agenda numbering differs: in the recording the chair calls public speaking item 4, the Local Plan update item 7 and the Mid Devon item 8 (apologies were taken as item 2). In the minutes these are items 3, 6 and 7.
  • Public speaking in the transcript of HsS41KBmdRA: the chair announces five speakers (one statement to be read out and four present). The read-out statement starts at 00:13:04; the second speaker is called at about 00:21:43–00:21:51 and speaks from 00:22:20; the third starts at about 00:28:11; the fourth is called at 00:34:32 and speaks from 00:35:07; the fifth contribution (a question read out) is at 00:39:49. The officer's answers follow each one. So this transcript includes the public speaking, at times close to those campaigners give for the second video (13:00, 21:50, 28:15, 34:50). All five contributions and the officer's answers are also summarised in the printed minutes. Only HsS41KBmdRA was transcribed; 92yrfhEUnNo was not available, so the two videos could not be compared.
  • Near 01:29:15 the transcript runs on without a break (lines at 01:29:10, 01:29:12, 01:29:16 and 01:29:24) during a non-committee councillor's speech. The transcript header gives a length of 02:33:53 and says it was transcribed on 09 Nov 2026, so it reflects the version online at that date. The transcript alone cannot show whether an earlier upload differed.
  • Gaps in the transcript: nothing between 00:02:01 (chair's welcome) and 00:07:57 (health and safety announcement), about 6 minutes; the chair then starts 'the meeting proper' at 00:08:27. A 50-second gap at 00:38:31–00:39:21 (chair: 'We're just checking a constitutional point'). The announced break runs 02:14:31–02:24:05. Other gaps of 20–35 seconds come from long merged lines or interruptions, for example 00:33:06–00:34:27 during an exchange between the chair and a public speaker. The minutes give the meeting times as 10.05 am to 12.30 pm.
  • In the minutes but not in the transcript: Councillor Brian Bailey's declaration of an 'Other Registerable Interest, Exmouth Town Councillor' is not spoken in the recording (at 00:09:41 he makes no specific declaration). The minutes record the Chair declaring lobbying on Exmo_20 for all members; in the recording individual members declare lobbying and at 00:11:05 a speaker suggests all members have been lobbied, which the democratic services officer agrees to note. Otherwise, everything in the printed minutes appears in the transcript, with small wording differences. For example, the minutes say the site 'could be delivered' where the officer said 'could be achieved', and 'a site boundary error' where he said the report 'included some land in error'.
  • Not in the printed minutes: the chair's formal warning to members of the public in the gallery under Part 4, Clause 19.1 of the Constitution (00:41:39), and an exchange between the chair and a public speaker at about 00:32:39–00:34:27. The content of that exchange is not repeated here.
  • The machine transcript mis-hears several names: 'Exxon's 20', 'eczema' and 'Expo 20' for Exmouth/Exmo 20, 'Malcolm/Malcom' for Marlcombe, 'Young/Jung' for Councillor Jung, and 'heal our/HELAR/Heller' for HELAA. Quotes keep the transcript spelling.
  • Earlier verified findings in the evidence report already cover several of these passages (00:20:03, 00:20:50, 00:27:06, 00:32:12, 00:41:09, 00:41:25, 00:45:18, 01:07:54, 01:13:45, 01:54:01).