Stop EXMO20

Strategic Planning Committee

22 September 2026

Air quality and housing numbers.

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

Summary of our findings

EXMO20 was the main subject of public speaking and of the written questions, but there was no item on it. The officer's answers restated that removing the site now would be a significant change that cannot be made under the transitional arrangements, and that the plan still allows modest development to be accessed through Southern Wood. In the debate on item 8, Cllr Jess Bailey asked whether air quality modelling could show the effect of removing sites close to the heaths, 'such as Exmo 20'. Cllr Fernley's question about EXMO20 was ruled outside the progress update.

  • Five public statements all asked for EXMO20 to be removed. They covered the wording of the 400 m heath buffer and the church setting, air quality and electric-vehicle forecasts, Habitats Regulations compliance, housing numbers and walking distances, and the '100 homes' significant-change threshold. One speaker said the group had a petition and that a solicitor's letter would follow.
  • Ed Freeman (Assistant Director) gave written answers to six public questions. He said that removing the 700-home EXMO20 site would 'certainly constitute a significant change', would need a further Reg 19 consultation and would take the plan outside the transitional arrangements. He also said a compliant HRA is legally required at adoption and is recommended at submission.
  • Item 8 (Local Plan progress): the plan was not ready for submission. Three pieces of evidence were still outstanding: an update to the water cycle study (new modelling by Haskoning), the Pebblebed Heaths air quality and HRA work (Ricardo re-ran part of its modelling to match Natural England's thresholds, and ecologists are surveying the roughly 1% of habitat where significant effects cannot be ruled out), and the west end and Marlcombe transport work.
  • The officer said the plan could legally be submitted before the HRA issues are resolved, though he did not want to rely on that. He said whether to submit would be for members to decide. He also said that removing specific sites to bring air quality impacts below the thresholds would be a substantial change that could not be made at this stage.
  • Members asked about air quality mitigation. The officer said that relying on electric-vehicle uptake was 'easier said than done', that highway restrictions can only be imposed for safety reasons, and that habitat management and planting are now the likely mitigation. Members noted the progress update and agreed that work should continue, with one abstention.
  • The aim is still to bring the plan to the November meeting and submit it before the end of 2026, under the transitional arrangements.
  • The meeting was suspended for about 20 minutes (02:46 to 03:06) after the Chair asked members of the public gallery to leave.
  • Item 7: the CIL Working Party recommendations were agreed, with the 'IDP list' restriction removed from the next bidding round (10 for, 1 abstention).
  • Item 9: the Housing Delivery Test result was 84%, so a 20% buffer now applies. The five-year land supply is 3.16 years, and a Housing Delivery Action Plan will come in early 2027. This was agreed unanimously, and the Chair said he would consider writing to the government.

EXMO20 is named 23 times in the transcript of this meeting.

Quotes from this meeting in our case

we should be trying to avoid the impacts on the habitat first of all…Ed Freeman, 22 September 2026, 01:52:31 · play ▶ · 1. Habitats Regulations: harm to the Pebble Bed Heaths not ruled out, and avoidance not tried
…specific sites where if they were removed the impacts would come below the thresholds that Natural England guidance suggests is acceptable…Ed Freeman, 22 September 2026, 03:11:05 · play ▶ · 1. Habitats Regulations: harm to the Pebble Bed Heaths not ruled out, and avoidance not tried
…The removal of any allocation is likely to be a significant change…Ed Freeman, 22 September 2026, 00:49:24 · play ▶ · 6. “Significant change” has no stated basis
A compliant HRA is required at the point of plan adoption. It is not a legal requirement before then…Ed Freeman, 22 September 2026, 00:54:04 · 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.

Officer view that removing EXMO20 would certainly be a significant change

Important Minutes much briefer · Ed Freeman (officer) · 00:49:48 ▶

Said in the meeting“…The removal of any allocation is likely to be a significant change at this point in plan preparation but to remove a site of 700 homes would in officers opinion certainly constitute a significant change and could not be undertaken at this point without a further Reg 19 consultation which cannot be completed in the time available.”
The minutesThe retention of the Exmo_20 allocation had previously been considered by Members, who had decided not to reduce housing numbers due to the risks of delaying the Local Plan and falling outside transitional arrangements.

This is the officer's stated reason why EXMO20 cannot be removed now. The minutes refer only to members' earlier decision, not to the officer's opinion about a 700-home site or the need for a further Reg 19 consultation.

HRA timing: legally required at adoption, recommended at submission

Important Minutes much briefer · Ed Freeman (officer) · 00:54:11 ▶

Said in the meeting“…compliant HRA is required at the point of plan adoption. It is not a legal requirement before then albeit it is clearly good practice and recommended in planning inspectorate guidance to have this at the point of submission.”
The minutesA compliant Habitat Regulations Assessment would be required before plan adoption, and work was continuing to address outstanding issues before submission.

The minutes do not record the officer's statement that Planning Inspectorate guidance recommends having a compliant HRA at submission.

Plan could be submitted before the HRA issues are resolved

Important Minutes much briefer · Ed Freeman (officer) · 02:41:35 ▶

Said in the meeting“…the legal requirement is to have a sound HRA at the point of plan adoption it's very much best practice and in the guidance to have it at the point you submit the plan but it's not an absolute requirement so we could submit the plan in advance of resolving those issues”
The minutesthe key issue related to the Pebblebed Heaths, as a legally compliant Habitat Regulations Assessment would be required before the Local Plan could be adopted.

The officer said that submitting the plan before the Pebblebed Heaths HRA issues were resolved was an option. The minutes do not record this.

Whether to submit without an acceptable HRA is for members to decide

Important Not in the minutes · Ed Freeman (officer) · 02:43:39 ▶

Said in the meeting“…I say ultimately that's for for you as members to decide whether or not we submit the plan um based on wherever we get to by the deadline um so there will be a choice to be made but I hope it's a choice you won't have to make”
The minutesNot recorded in the minutes.

The officer said members may have to choose whether to submit the plan without an acceptable HRA by the deadline. The minutes do not record this.

Removing specific sites to cut air quality impacts would be a substantial change

Important Minutes much briefer · Ed Freeman (officer) · 03:12:20 ▶

Said in the meeting“…if they were removed the impacts would come below the thresholds that Natural England guidance suggests is acceptable such that there isn't a significant effect um so that is something that we could look at but to do so would probably involve uh well would involve a substantial change to the plan that we can't do at this point”
The minutesWhile the impact of removing sites or reducing housing numbers could theoretically be assessed, the Assistant Director – Planning Strategy and Development Services advised that the current focus was on understanding impacts as a whole and identifying appropriate mitigation measures.

The question named EXMO20 as one of the sites closest to the heaths. The minutes do not name EXMO20, and they do not record the officer's statements that 'some do impact more than others' and that removing sites would be a substantial change.

Southern Wood access to EXMO20

Not in the minutes · Ed Freeman (officer) · 00:52:33 ▶

Said in the meeting“…I'm not clear why you are saying that access through southern wood is not now proposed however the draft Local Plan continues to allow for modest levels of development to be accessed this way”
The minutesNot recorded in the minutes.

Access to EXMO20 decides how much of the site's traffic crosses the Pebblebed Heaths. The minutes summarise the answers without this point.

Limits on traffic measures to protect the heaths

Not in the minutes · Ed Freeman (officer) · 02:13:00 ▶

Said in the meeting“…the acts that they work to mean you have to do them for highway safety purposes uh not to mitigate impacts on a protected habitat so there's not a great deal we can do in terms of those sorts of things”
The minutesNot recorded in the minutes.

The officer said traffic restrictions cannot legally be used to protect the heaths, which limits one route to air quality mitigation. Neither Cllr Davey's question nor this answer is recorded.

Whether Marlcombe is in the baseline or the future-growth modelling

Minutes differ · Ed Freeman (officer) · 02:15:55 ▶

Said in the meeting“well Cranbrook expansion areas in terms of existing planned growth and then malcombe's part of the modeling of the future growth that is what's in the assessment now yeah”
The minutesHe confirmed that both the Cranbrook expansion areas and the Marlcombe development had been included within the baseline assessment and had therefore been taken into account within the modelling.

The officer put Marlcombe in the modelled future (Local Plan) growth, not in the baseline. The minutes say both Marlcombe and Cranbrook are in the baseline.

Request to publish the evidence early for members and the public

Not in the minutes · Cllr Dan Ledger (request); Cllr Todd Olive, Chair (reply) · 02:29:15 ▶

Said in the meeting“…can we just have a commitment to that can it also be put on our website as well early enough so that members of the public can accurately scrutinize it as well mr Freeman says yes”
The minutesNot recorded in the minutes.

A commitment was given to send the new air quality, HRA and water evidence to members early and to publish it for the public before the plan comes back. The minutes do not record it.

Electric-vehicle uptake as mitigation 'easier said than done'

Minutes much briefer · Ed Freeman (officer) · 02:38:59 ▶

Said in the meeting“…we thought initially the mitigation would simply be you know increasing uptake of electric vehicles knowing that it's the pollutants that are rising from that but as as the report shows and and as members are picked up on that's that's very much easier said than done”
The minutesThe findings would then be used to inform the development of appropriate mitigation measures, which could include habitat management and additional planting, before a final mitigation strategy is agreed.

The officer said the original approach to air quality mitigation, relying on electric-vehicle uptake, was harder than expected. The minutes record only the new options.

Air quality modelling did not include unallocated sites

Minutes much briefer · Ed Freeman (officer) · 03:14:04 ▶

Said in the meeting“…no because the modeling was the sites that we're allocating in the plan not the sites that we chose not to allocate um so we'd have to do further modeling specifically in terms of that site to understand its impacts but ultimately the onus as things stand is on the applicant to to address that issue”
The minutes…whether a significant planning application on an unallocated site within the area had been taken into account in the modelling assumptions.

The minutes record the question but not the answer: the plan's air quality modelling does not cover large unallocated applications such as the Clyst village scheme. Cumulative impacts on the heaths depend on this.

Vote on the Local Plan progress update

Minutes much briefer · Cllr Todd Olive (Chair) · 03:19:12 ▶

Said in the meeting“…all those in favor please those against and those abstaining one okay thank you members that is carried”
The minutesRESOLVED: That the ongoing work be noted and officers continue to progress further to provide a sound evidence base for submission of the Plan.

The minutes give no vote figures. The recording shows one abstention, but the numbers for and against were not read out.

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

Committee members present (9)

  • Councillor Brian Bailey
  • Councillor Jessica Bailey
  • Councillor Colin Brown
  • Councillor Kevin Blakey
  • Councillor Olly Davey
  • Councillor Peter Faithfull
  • Councillor Paula Fernley
  • Councillor Ben Ingham
  • Councillor Dan Ledger

Committee members who sent apologies (4)

  • Councillor Charlotte Fitzgerald
  • Councillor Paul Hayward
  • Councillor Geoff Jung
  • Councillor Yehudi Levine

Other councillors attending (2)

  • Councillor Ian Barlow
  • Councillor Roy Collins

Officers (3)

  • Ed Freeman
  • Damian Hunter
  • Wendy Harris

Notes on the recording

  • The recording starts at 00:17:02. The meeting was suspended from 02:46:11 to 03:06:41 after the Chair asked members of the public gallery to leave. The minutes do not mention the suspension.
  • The agenda is numbered differently in the recording (items 1 to 9) and in the minutes (minutes 8 to 15). Item 8 in the recording is minute 14, and item 9 is minute 15.
  • The Chair said a late public question not related to EXMO20 would be answered 'via the minutes'. The full printed minutes contain no such answer.
  • The item 14 minutes include points not heard in the recording: 'developer funding mitigation measures likely to form part of the overall solution', capacity problems at named junctions, and 'Developer contributions'. These probably come from the written report.
  • The minute on the 'restoring heathland' question leaves out that the officer described replacing or restoring habitat as a last resort under a 'derogation test' (01:52:51).
  • This is a machine transcript and is garbled in places (for example 'pebble bird higgs', 'Malcom/Malcombe' for Marlcombe, 'Exmo 20/Eximo 20'). Speakers are named only where the Chair names them.
  • Cllr Fernley's question (02:24:38), 'how many equivalent areas of Exmo 20' would be needed if the plan failed, was ruled outside the progress update and left for the officer to research. The minutes do not record it.