InformationFAQs: New Local Plan

What is a local plan? 

Local Plans are used as guidelines when making decisions on planning applications, as a framework that outlines how and where development will take place in an area. It uses policies and maps to identify development opportunities and restrictions, while protecting areas designated for uses like open spaces and recreation. Local Plans aren’t just about where new homes should go, but also the communities we live in, how we can look after the environment around us, how we get around, and making sure we have the access to the facilities and services we need.  

Local Plans are shaped with the help of numerous public consultations, which give local people, businesses and organisations the chance to share their views. EDDC has already held a number of public consultations on the New Local Plan, including one between May – June 2024.  EDDC’s Planning Policy team take every comment into account when drafted the plan, where it is legally and statutorily possible to do so.  

Why must a council have one? 

The Government requires EDDC to have an up-to-date Local Plan, to ensure there are enough homes and jobs to meet people’s needs, as the population continues to grow and change. 

We need extra new homes in East Devon and the number of households in the district is increasing because: 

- We have existing residents that are living in overcrowded and poor quality and often expensive housing; 

- We have young families, in particular, that need a place of their own to move into; 

- We have people, such as the elderly, that have specialist housing needs. And 

- People from other parts of the UK, but especially from surrounding local authority areas, choose to move into East Devon. 

We are a high growth area which reflects the attractiveness of the District as a place to live, and in Cranbrook and the West End where we see many younger people moving into much needed new homes.  

National planning policy and guidance sets out an approach which provides the starting point for assessing how many homes and jobs EDDC must plan for. This takes account of changes in population, like population growth and the need for more better paid, higher quality jobs, as well as the affordability of housing in the area.   

Why do we need a new Local Plan when the current one runs until 2031? 

Local plans should plan for a period of at least 15 years from the point of adoption, but they should be reviewed at least every five years and kept up to date. The current Local Plan was adopted in 2016 and was reviewed in late 2020 when it was concluded that a full plan update was needed.  This was because some of the sites planned for in the adopted Local Plan have not been delivered while Government policy has changed and is not reflected in the adopted plan. Under the legislation we have therefore had to produce a new plan that extends the strategy forward to 2042.  

Why is there such urgency in progressing the Local Plan now? 

The Government have recently published their new policies on planning which includes increasing housing numbers across much of the country to deliver 1.5million new homes, in this parliamentary term. In East Devon this means an increase of more than 200 homes per year, that had not been planned for and would be very difficult to accommodate, given the environmental and infrastructure constraints of the district. There is an opportunity to progress the plan under the previous lower housing numbers, but it requires EDDC to publish a final draft of the plan by the March 12, 2025. It is vital that we meet the timescales to avoid having to meet the increase in the number of houses that we are required to provide. It is also essential to get a new plan in place now in order set the development framework and provide a clear articulation of investment priorities. This will help to access funding opportunities, such as from Homes England.

What are the dangers of the council not having an up-to-date Local Plan? 

In the absence of an up-to-date local plan, EDDC does not have an adequate supply of housing land to satisfy the legal requirements outlined by Government and so decisions on planning applications are having to be made with substantial weight being given to addressing this issue at the expense of other matters.  

At planning appeals, and in the absence of adequate land for new homes and development, Government appointed inspectors will increasingly not consider the local plan and the balanced approach to homes, the environment and communities that it contains. Rather they will place far greater weight on the national agenda/the Government agenda for growth, building and development. 

Planning permissions must be granted for housing developments unless there are very strong reasons for not doing so. As a result, EDDC cannot guarantee the best planning outcomes for its communities. It is therefore important that we progress the Local Plan, bolster the district’s housing land supply and regain control, enabling EDDC to deliver the best possible developments for its communities.  

In the longer term if EDDC do not progress the Local Plan then the Government may intervene and essentially write it for the district itself.  

How have you engaged the residents of East Devon in this plan? 

EDDC has held three main consultations on the new local plan as the work has progressed, receiving thousands of public comments. EDDC has listened to what you have said and the issues you have raised have been debated by your elected councillors through a series of meetings of the Strategic Planning Committee (details on eastdevon.gov.uk[ Browse meetings - Strategic Planning Committee - East Devon]. Parish and town councils were involved in these discussions and members of the public were also able to address the committee. Where it was legally possibly to do so, and where appropriate, EDDC has adjusted its policies to address the concerns raised. EDDC is now at the ‘Regulation 19’ – or publication stage. The Regulation 19 stage is not a repeat of earlier consultations that have helped to shape the Local Plan but a final opportunity for you to say what you think, allowing the Government-appointed Planning Inspector to consider any additional comments before deciding on whether to approve the plan.  

The previous/current part(s) of the consultation process involved/involves: 

  • Issues and Options consultation – January to March 2021 – the stage at which we raised broad issues about the local plan and priorities
  • First consultation on draft plan (Reg. 18) – November 2022 to January 2023 – the suggested basic overarching plan content, for people to comment on
  • Second Reg. 18 consultation – May to June 2024 – specific consultation on some detailed policy matters
  • Public consultation on final draft (Reg. 19) – January to March 2025 – the point at which the council believes it has a sound plan and seeks comment for the consideration of the planning inspector
  • Second Reg 19. consultation / New Town consultation – November 2025 to January 2026 – to consider the changes made to the plan following the first Reg. 19 consultation and matters relating to the new community (Marlcombe) proposals

Next stages:

  • Collate feedback and submit to Planning Inspector 
  • Inspector’s Public Hearings
  • Adoption 

How can you say that you have listened to the community when the plan includes site allocations that the local community strongly oppose? 

Decisions on site allocations have to be made on the planning merits of the development and so the level of objection to a site will not in itself affect whether it is allocated. It is whether the site would cause harm in planning terms that is key.  

In many cases communities have raised concerns about the impacts of development on the capacity of schools, doctors and other infrastructure, however these are common issues experienced by most communities not just in East Devon but across the country. The answer to this is for EDDC to work with infrastructure providers to deliver the infrastructure that is needed and where possible secure funding to support this. These issues do not necessarily mean that a site should not be allocated for development, rather it places an onus from all relevant bodies to find ways that they can deliver the services that they are obliged to and wish to provide. Many new homes will be occupied by people that are local to an area and as such they will already use services so will not place additional pressure on these. 

EDDC has also had to make some very difficult decisions to allocate sites that are far from ideal but are legally required to meet Government housing targets. Although EDDC has challenged the Government’s unrealistic housing targets at every opportunity, there is no real scope to change them under the current top-down system. Not having an up-to-date Local Plan will deliver far worse outcomes than the plan EDDC is promoting.    

How does the plan seek to protect the local environment and ensure that East Devon remains a great place to live? 

The Local Plan is not just about planning for new homes and jobs. There are a range of policies in the plan that seek to address climate change and the associated impacts by improving the standards of new homes and other buildings in the district and ensuring that we retain our flood plains and manage development in areas subject to coastal change. For example, there is a programme in place that will continue to protect and enhance the biodiversity of the Exe Estuary, and the Pebblebed Heaths from negative impacts from developments. It also seeks to protect the identity of nearby communities by retaining green wedges to prevent settlement coalescence. The plan also plays an important role in protecting the countryside including our two national landscapes and protecting natural habitats and biodiversity including the Exe Estuary, East Devon Pebblebed Heaths, Beer Quarry Caves and the River Axe which are specially designated habitats.  

How do we plan for infrastructure if more houses are planned for? 

We know the importance of delivering infrastructure alongside new developments. Alongside the preparation of the Local Plan, the council gathered evidence from a range of organisations and infrastructure providers to understand what is needed to support additional growth while maintaining and enhancing the natural environment, supporting vibrant communities to thrive. This evidence is set out in the Infrastructure Delivery Plan (IDP) in support of the Local Plan. Although we are not directly responsible for delivering much of the needed infrastructure (for developments like GP surgeries, schools etc), we do work closely with providers to try and help ensure needs are meet, when it is required, like by helping to fund the infrastructure with money contributed by developers.  

If approved, the Plan will form part of the statutory development plan for the area that should be followed when making decisions on future planning applications in East Devon. 

What agencies are statutory consultees and how have they been engaged with work on the local plan?

Statutory consultees are bodies that we are required to consult with under plan making regulations – see: https://www.legislation.gov.uk/uksi/2012/767/data.pdf (see specifically “relevant authority” reference).  These are a range of public bodies with specific interests, roles or responsibilities that have direct relevance to the local plan and policy content.

We have directly contacted statutory consultees at each stage of public plan consultation.  We have also made direct contact with such bodies in respect of specific process and technical matters that have arisen or when we have been undertaking (including through employed consultants) specialist studies.  These bodies have also been engaged in Duty to Cooperate work.  Bodies with whom we have had greatest contact include – Devon County Council, Exeter City Council, The Environment Agency, Natural England,  Historic England and National Highways.

Why continue to produce an East Devon Local Plan when Local Government Reorganisation is coming?

The Local Plan, after adoption, will remain in place and operational, for the area it covers (currently the administrative area of the existing East Devon District Council) even after Local Government Reorganisation takes place.  It is quite common for new unitary local authorities to inherit already adopted, and in some cases adopt, local plans that were produced by a predecessor authority.  Whilst a new unitary authority will be required to produce a future local plan or plans this could take some time to occur and in the absence of an adopted local plan for the current East Devon area there would be an absence of a formal development plan. The consequence of that would be that there would be no up to date strategy for where development should take place and no up to date policies to assess planning applications against. It would also mean that we would be unable to demonstrate an adequate supply of land to meet housing needs which is a government requirement. The absence of this means that we have to give substantial weight to this when considering applications for housing and often means that the balance is in their favour even if they do not comply with our plans for growth. It is therefore very much in the interests of East Devon, its residents and the environment that we have an up-to-date Local Plan.

How have concerns raised during consultations been considered and where is the evidence to show that comments have been fully considered and the plan amended?

The Council has undertaken consultation in accordance with the Statement of Community Involvement. Concerns raised during consultations on the East Devon Local Plan have been considered iteratively and transparently throughout the plan making process, with clear documentary evidence showing how representations influenced plan content, supporting evidence, and Sustainability Appraisal findings. A full Consultation Statement covering the whole plan making process will be submitted with the Local Plan, and will be available on the Council website once it has been approved by Members.

Comments received at each stage of consultation have been summarised and reported for consideration by Members at the Strategic Planning Committee, with the comments in full being available to view on the Council website. This has taken place in the following stages:

  1. Issues and Options consultation (January–March 2021)

The Issues and Options consultation informed the earliest stage of Local Plan preparation, exploring alternative strategic approaches. It was supported by a Call for Sites and consultation on the Sustainability Appraisal scoping report, ensuring that environmental, social and economic issues were identified early. Concerns raised at this stage shaped the spatial strategy, evidence base and the scope of subsequent assessments. Representations are published here

  1. Draft Local Plan consultation – Regulation 18 (November 2022–January 2023)

The Council consulted on a full draft Local Plan, Policies Map, Sustainability Appraisal and supporting evidence. All comments were reviewed and published. Following the consultation, the Plan was amended to reflect representations received and in light of updated and newly commissioned evidence. Comments and feedback reports are available here

  1. Further Draft Local Plan consultation – Regulation 18 (May–June 2024)

In response to feedback on the earlier Draft Local Plan, a further Regulation 18 consultation was undertaken on eight specific topic areas, including housing allocations, neighbourhood housing requirements, green wedges and the Sustainability Appraisal. This targeted consultation demonstrates how earlier concerns were revisited and informed revised proposals. Consultation material and responses are available here

  1. Ongoing plan amendments and committee consideration (2023–2025)

Between consultation stages, the Council made further changes to the Plan to address consultation comments, Sustainability Appraisal recommendations, new evidence and changes in national planning policy. Numerous Strategic Planning Committee meetings considered emerging plan content, with opportunities for verbal and written representations. Updated plan versions, evidence base documents and consultation reports were produced during this period.

  1. Regulation 19 pre-submission consultations (2025–2026)

Two Regulation 19 consultations invited representations on the Plan’s legal compliance and soundness. All representations were published and summarised in officer consultation reports. Changes between Regulation 19 versions are clearly identified, including through tracked-changes versions of the Plan.
First Regulation 19 consultation responses and feedback report
Second Regulation 19 consultation The feedback report is not yet available on the planning policy webpages but was appended to an SPC report here 1a. Appendix 1 Reg 19 Stage 2 feedback report.pdf

  1. Evidence showing how comments informed plan amendments

The Consultation Statement is supported by schedules and chapter-based audit trail documents which explain how Regulation 18 comments informed the Regulation 19 Plan. These documents identify where policies were amended, deleted or added and explain the reasons for those changes, providing a clear audit trail of how consultation influenced the Plan’s evolution.
Audit trail documents are available at:
Evidence and Examination Library - Other Evidence (OTE) - East Devon

How is the council complying with its obligations under the Habitat Regulations?

The Habitat Regulations are a legally prescribed set of regulations that require a local  plan to be subject to assessment of potential impact in cases where proposals within the plan (or emerging plan) could  result in adverse impacts that could undermine the integrity of  any site that falls in the highest tier of designated wildlife sites – these specifically include Special Areas of Conservation and Special Protection Areas (as an example the Pebblebed Heaths come under both designations).  Where adverse impacts may arise there is a requirement for mitigation to be delivered that will result in net negative impacts not occurring, or exceptionally it can be possible to provide replacement habitats as compensation.  The Council has already employed specialist consultants to review the plan in respect of the Habitat Regulation – see specifically csd-006-rev-b-se-devon-local-plan-hra-reg-19-v2.pdf, noting that earlier assessment work has helped refine plan content.  At the time of drafting this response there is, however, also ongoing work in respect of setting out proposals for mitigation in respect of the potential for adverse impacts on:

  • The River Axe - Special Area of Conservation – in respect of net additional nutrients entering the river on account of increased overnight residential accommodation being built (essentially this means new housing).
  • The Pebblebed Heaths - Special Area of Conservation and Special Protection Area – in respect of net additional pollutants (specifically because of increased impacts of net nutrient loading) on account of increased vehicles that will travel across the heaths because of new planned development.

How does the plan comply with the requirement to further the purposes of the National Landscapes?

Since December 2024 local planning authorities have had a legal duty to ‘seek to further’ the statutory purposes of National Landscapes (this replaced the duty to ‘have regard to’). The ‘purposes’ referred to are ‘conserving and enhancing natural beauty’. National guidance on this duty makes it clear that, when developing local plans, the planning authority should consider whether the purposes of the Protected Landscape can be furthered through measures embedded in the design of plans and proposals, where reasonably practical and operationally feasible. A paper has been prepared to show how the local plan has sought to meet the duty.

How have neighbourhood plans been taken into account in preparing the Local Plan?

The preparation of the new Local Plan takes account of latest national planning policy and related legislation and the latest evidence, much of which is more recent than most of our Neighbourhood Plans – and our current Local Plan under which they were prepared and examined.

Many of our neighbourhood plans did not make provision for development, which is understandable and reflects typical local community views in many settlements in the district.  However, a certain level of development needs to be accommodated in all of our more sustainable locations to meet Government requirements

The new Local Plan will not automatically or necessarily supersede existing neighbourhood plans and their policies, but when adopted it will carry greater weight where it is the more recent development plan document to be adopted, when then is conflict between the two, as this is how the planning system works.  In many cases, such as in relation to biodiversity requirements, the new Local Plan furthers neighbourhood plan objectives and goes further than existing neighbourhood plans policies where they are dated.

In drafting new Local Plan policies, endeavours have been made to take account of existing and emerging Neighbourhood Plan policy and to avoid unnecessary conflict or replacement, for example, by including green wedges identified in neighbourhood plans within the Local plan policy, and leaving site allocations to neighbourhood plans where plans were already well advanced or ‘made’ (adopted).

It is good practice to review neighbourhood plans when new strategic policy is in place, and we are continuing to support communities who wish to consider a review and update of their plans.

New or updated neighbourhood plans will need to generally conform to national policy and the strategic policies of the new Local Plan when adopted, but there are plenty of opportunities referred to in it where neighbourhood plans can add value and local specificity in policy terms, such as, but not limited to, heritage and conservation, design, provision for new development to meet local needs, identification of valued local views and local green spaces for protection.

Why do we need to build so many new homes in East Devon?

The population of England has increased over the years and in East Devon has increased at a proportionately higher rate. For East Devon the increase is accounted for by people living in other parts of the UK choosing to move into the district.  As a district council we have no powers to control people moving into East Devon.

Alongside people moving to East Devon there has been a general trend of decreasing average household sizes, with more people living alone and more households forming, for example people leaving parental homes.  Essentially, we need more homes just to accommodate the same number of people. 

Population increases create the need for additional houses to provide homes for people to live in.  If new homes are not built there would be more homelessness or inadequate/insufficient housing for our population or more people needing to leave to find homes.  The current Government (in common with previous Governments) set out a clear position that we must build more homes and that increasing the supply of homes will improve the affordability of housing. The Council is required to respond and produce a Local Plan that complies with government policy.

Are we planning for the right types of homes to be built?

The Local Plan provides for a wide range of new homes to be built reflecting the fact that there are a range of differing people with different needs, expectations and aspirations to occupy those homes.  Most new homes built in England, and this applies in East Devon, are built by private businesses and are sold on the open market.  Prices are determined by market forces, though noting that on most medium and larger sites (and many smaller ones) developers will actively choose to build a range of properties of differing sizes. 

Policies of the council promote developments with a mixture of property sizes.  But policies also go much further in respect of requiring different property types, to include:

  • Affordable housing - in our new local plan, and as part of any open market housing scheme that exceeds 6 or 10 new dwellings (location dependent), we require inclusion of a proportion of affordable housing.  Percentage levels vary by location from 25% up to an aspiration for 40% of the new town of Marlcombe.  The thresholds are at the lowest level, and percentages are at the highest level that we believe can reasonably be achieved given Government policy and financial viability considerations. More and better affordable housing is desperately needed by people who cannot afford open market prices and most affordable housing is, and can only realistically be secured, through it being a proportion of an open market scheme.  In simple terms we need new open market housing to be built to also be able to have most of the new affordable housing that is needed built.
  • Housing for older people – the population of East Devon is comparatively old and ageing.  Whilst we as a Council are promoting jobs, housing and wider opportunities for younger people in East Devon there is a reality that we are all getting older and in East Devon the trend in increasing numbers of older people is stark.  Accordingly, we have policies in our new plan that seek provision of dedicated housing for older people.
  • Accessible and adaptable housing – some people, can have mobility restrictions and therefore it is right that through our Local Plan we actively promote and require developments that meet and exceed accessibility standards.  Also, we require homes to be adaptable so that should occupants have mobility restrictions in future years the homes they live in will be readily adaptable to be accessible in the future.
  • Self-build housing – we are aware that some people are keen to be self-builders and therefore we have policies to support such developments.  Self-build homes can often be of high quality and cost less for occupants than other housing choices.

How are numbers of homes to be built defined?

The Government has a standard method, that is applied across the whole of England, that establishes the minimum number of homes that each area should accommodate.  This standard method takes the existing number of homes that already exist in an area and adds a proportionate increase to these.    It also adds in an extra amount that considers the affordability of houses in that area.  This is based on a formula that takes in to account existing house prices and wage levels in the area. 

The Government stress that numbers generated under the standard method should be regarded as a minimum and there may be good and appropriate reasons to exceed these numbers.  Our current Government, and preceding Governments, see more and better house building as essential to support peoples housing needs and to also help grow and stimulate the economy and provide jobs. 

We would highlight that it is possible, but extremely challenging, to set out a case to plan for less than standard method numbers.  The Council has considered this option, but assessment has shown that it would not be possible to justify lower numbers (however see specific number comments below).  Furthermore, any considerations around planning for less would need to consider the positive benefits that new housing helps deliver and support.

What is the standard method housing requirement for East Devon?

At the time of the first consultation on the local plan, in early 2025, on what is termed the Regulation 19 Local Plan we were working to the standard method that generated a housing requirement for an average of 1,188 new homes per year to be built in East Devon.  The standard method number can, however, vary over time and in recent years has fallen.   This has been because of a rise in wage levels in East Devon which has improved overall affordability.

Given a standard method number of 1,188 homes a year, why are we actually planning for less?

In the 1st Regulation 19 draft Plan regulation-19-plan.pdf we set out policy, that also considers some houses that have already been built or have planning permission, that would see delivery of up to 22,614 new homes.   This is over a 22-year plan period stretching from 1st April 2020 to 31st March 2042.  Over 22 years, with a standard method number of 1,188 new homes per year the plan requirement would be 26,136 new homes.  Against this standard method output there is therefore a projected under-delivery. However, and very importantly, we are working to Government policy, in the form of the National Planning Policy Framework, dated December 2024 - National Planning Policy Framework, that states (para 234) that where a plan has reached Regulation 19 of the plan making regulations on or before 12 March 2025 the plan can proceed if it meets at least 80% of housing need.  Taking the 26,136 figure and applying 80% to this generates a figure of 20,908.

In planning for 22,614 new homes over the life span of the local plan, we are exceeding the figure of 20,908 by 1,705 new homes.  But it is important to recognise that the 22,614 figure is an upper total and it is highly unlikely that all of these homes will be built.  For example, it assumes that all the homes allocated on sites for development in the Plan will be built out by 2042.   This is unrealistic and as such our Plan currently has a ‘headroom surplus of 12.8%’ (a headroom of between 10 – 20% is usual in Local Plans).

Given that standard method numbers have been falling, why not apply the lower figures now?

Standard method numbers have fallen in recent years.  However, we are applying specific provision in plan making as set out in the December 2024 National Planning Policy Framework, that allow us to plan for 80% of need.  Because for housing number matters, we are working to the December 2024 of the National Planning Policy Framework it is appropriate to meet the housing need numbers, with the at least 80% qualifier, that were applicable at the time of its publication.  To deviate from this position would make the Plan vulnerable to challenge on not meeting the underlying numbers, and Government policy, that allow for providing at least 80% of the strategic housing requirement.

In addition to the above there are wider matters that we need to be aware of when it comes to the numerical side of housing provision.  The Government is promoting an increase in housing delivery and we as a local planning authority (in common with all planning authorities) are part of implementing the Government agenda and its policies.   

Furthermore, as set out in response to earlier questions, there are positive benefits that are associated with house building, and it is correct and proper that we seek to realise these.  In providing for an around 10% extra buffer in housing provision, we allow for  a degree of choice and variety in the sites that can come forward – recalculating against a current lower standard method number provides for an increased buffer and as such adds a stronger ‘safety net’.  But we should also be aware that whilst standard method numbers have come down, they could well go up in the future.  The potential for rising numbers, should we attempt to make plan amendments, could therefore provide a real threat to the Plan progressing, as would the issue of overall compliance with Government policy.

Another benefit of including a buffer within our housing provision is ensuring that we have adequate supply in the long term. The government require us to maintain a 5-year housing land supply. If we don’t then the consequence is that we must give much greater weight to the benefits of addressing the resulting under supply when we consider planning applications for housing even if they don’t comply with our local plan. This can often lead to sites that were rejected through the plan making process having to be granted permission at the application stage, sometimes years later, to maintain supply. By building in a buffer at the plan making stage, we can ensure that there is flexibility within our supply and reduce the chances of sites that have not been fully considered and consulted on through the local plan process having to be granted permission later.

In addition to the above we would also highlight that in planning to 2042 we are not fully in line with the National Planning Policy Framework that advises of plans needing to look forward 15 years from the point of adoption.  Plan adoption is now likely to be in 2028 and looking forward 15 years from 2028 takes us to 2043.  The Local Plan does make provision for some development in 2043 and beyond, specifically for Marlcombe.   But this is just one element of future longer-term provision (the rest is not yet planned) so having some flexibility through higher housing numbers goes some way  to addressing challenges that we will not be appropriately planning for development needs that stretch 15 years forward from the point of adoption.

Overall, it is important that we maintain the buffer that we have built into our housing numbers even though this has increased slightly due to recent changes in affordability. It does not present an opportunity to revisit housing allocations in the plan not least because this would involve significant changes to the plan which could not be accommodated within our timeline for production of the local plan. The consequences of revisiting site allocations at this late stage is that we would fall out of the transitional arrangements in the legislation which are allowing us to keep our housing numbers down compared with those that would be required under the new government requirements. The housing numbers in this Local Plan are thousands of homes lower than they would be if we applied the governments new standard method figures.

If building new homes is a good thing, with positive benefits for society, why not plan to build more?

We acknowledge the positive benefits that new house building can provide, and we set these out in the Local Plan.  However, we need to be aware of and consider other wider considerations in our Local Plan and overall proposals for development in East Devon.

East Devon is a district with a very high-quality environment.  Close to 60% of East Devon falls within designated National Landscape areas (formerly called Areas of Outstanding Natural Beauty), we have a World Heritage site coastline, wildlife areas of international importance and built heritage assets with many listed buildings and Conservation Areas which are also of great importance and are sensitive to the impacts of development.  Added to these we have many additional areas of more local significance that people value and cherish.  In planning for new housing, and indeed any form of development, we strive to secure a balance between the new building that is needed, and serves needs in society, whilst also protecting and enhancing our natural and built heritage assets.

We note that some people consider that we are planning to build too much, and specifically consider some sites allocated in the plan are inappropriate for development, though nearly every site allocated in the plan came in for some level of objection through consultation. But, by the same token we have also had very robust objection from those promoting development, and especially housing development, that we are under-providing and we should be allocating more sites for development.

Planning to meet just 80% of standard method housing needs has come in for strong objection through consultation from developers and site promoters. Some respondents from the development industry set out that this is contrary to the expectations of Government and that we should actively seek to plan for higher development levels.  To plan for 80% is seen as relying on a technicality of guidance and not actually providing for what is needed and what would be good for East Devon, noting the benefits that new housing development can deliver.  Amongst other matters there are also objections that we should be planning for more development on account of some other areas outside of East Devon not being able, or having not planned to meet their own needs appropriately.

We are working on the basis that at the public examination of the Local Plan those objecting to the plan on the grounds of not planning for enough housing will present very robust arguments.  Though of course those saying we are planning for too much development will also be able to present their case. The independent Inspector or Inspectors conducting the examination will draw their conclusions, but they will need to do so fully considering Government policy as a key consideration.

How were broad locations for development chosen?

To determine broad locations for the distribution of new housing the Local Plan sets out what we call a spatial strategy, and before arriving at end conclusions various options were considered.   Major constraints in East Devon formed a key part in determining the spatial strategy but we also examined the services and facilities that settlements offer with an objective of concentrating and directing a large part of the new housing development to settlements with the greatest range of existing services. 

Of special note, however, is that we also saw the appropriateness of planning for the second new town of Marlcombe.  Marlcombe is in a location where development will have lesser adverse impact than other parts of East Devon whilst also being close to the city of Exeter and the many services and facilities that are in or close to the city.  In locational terms it also takes advantage of, and offers scope to enhance, major infrastructure.

Other than for the new town of Marlcombe the main towns of East Devon were identified as the key focal point for a large part of future housing growth.  The towns have the greatest range of existing services and facilities and through development at towns there is the greatest scope to secure new homes in locations where the best access to services and facilities, minimising travel distances, will be achieved for future residents.

Of all the towns in East Devon, Exmouth has the greatest number and range of facilities and as such is identified as strategically the most logical town to accommodate the highest future growth levels.  Exmouth (discounting the new town of Marlcombe) does, appropriately, have the highest level of new housing numbers on site allocations in the local plan.  However, when these numbers are expressed as a percentage growth of the town, compared to existing dwellings, the scale of growth is relatively modest and falls below the percentage growth levels that some other towns will accommodate.

Outside of the main towns new housing development is, for the most part, smaller scale, and focussed in most cases around meeting local needs.

How were sites selected for suitability for development?

To inform local plan making we provided the opportunity for people and landowners to send details to us of land areas that they wished to see developed. This was through an exercise called the Housing and Employment Land Availability Assessment (HELAA).  The sites submitted were assessed against their ability to accommodate new development (to include for example matters such as would it be possible to gain a highway access) and also their suitability given the broad spatial strategy we had developed.  The HELAA is designed to inform decision-making on-site allocations but is not definitive. Those sites that aligned with the spatial strategy, i.e. were in the right broad types of location, and technically could reasonably be developed, were assessed further and this assessment work was carried forward over time as local plan making progressed.

The site-specific assessment looked at broad suitability and sensitivity matters with a specific focus on landscape, built heritage and ecological considerations and sensitivities.  The site assessment reports were considered through various committee meetings at the Council. These were held in public session where Councillors heard first hand from the community with their views on the sites as well considering representations made in writing.  Through these discussions members drew conclusions on those sites that would be appropriate for allocation for development in the Local Plan.

How did the allocation of Exmo_20 come about?

The site now known as Exmo_20 was originally considered as two separate sites as part of the first Reg 18 consultation on the plan at the end of 2022/early 2023. The bulk of the site was shown as Exmo_20a and was not a favoured site for allocation whereas the smaller southernmost part of the site by Meadowview Road was identified as Exmo_20b and shown as a second-choice site. At that time the various constraints to the larger site particularly the limited capacity of the access by Southern Wood meant that the larger site was not achievable.

Through discussion at the Council’s Strategic Planning Committee Councillors asked officers to look again at the site. They considered that a more comprehensive development of the area would make it viable for the development to deliver social and community facilities as well as space for jobs alongside homes meaning it would put less pressure on existing facilities and make for a more sustainable development. Following further investigation, it was found that many of the issues that had raised concern through the HELAA could be addressed and so the site was taken forward and consulted on as a single allocation as part of the first Reg 19 consultation. This raised over 1,100 responses raising concerns about the proposed allocation. Some of these related to the process that had been followed noting that the site had not passed the HELAA process and so under the Council’s own methodology for assessing sites should not have been taken forward. The Council is however entitled to consider sites further even where they have not passed the HELAA stage and given the scale of this proposal and its potential benefits as identified by Councillors it was appropriate for it to be given further consideration.  

The concerns raised by residents through the various consultations have been considered in detail by both officers and elected members and are addressed below. A report on the issues raised and a detailed analysis of how these could be addressed was considered by the Council’s Strategic Planning Committee who ultimately decided to maintain the proposed allocation of Exmo_20 but only after making amendments to the proposed allocation policy in response to the concerns raised. These changes prescribe in detail the basis upon which the site could acceptably come forward for development. This revised wording was then consulted on as part of the second Reg 19 consultation.

It is acknowledged that there remains significant opposition among the community to allocation of Exmo_20, but it is considered to be the most acceptable way of meeting the housing numbers. The remaining objections will be considered through the examination of the plan by a government appointed inspector in 2027.

Why is Site Exmo_20 allocated?

Site Exmo_20 lies on the eastern side of Exmouth.  It is a large site with capacity for around 700 new homes that is able to incorporate  large areas of open space .  Being at Exmouth, Exmo_20 fits in with the broad spatial strategy for the Local Plan, noting the strategic development role identified for the town.  If it were not allocated and not ‘replaced’ by other sites, the scale of growth planned for the town would fall significantly short of the strategic significance attached to it as a location for development.

Exmo_20 is an opportunity to comprehensively plan for a new neighbourhood that can deliver benefits in terms of the infrastructure and facilities it can deliver compared with a number of smaller piecemeal developments. The allocation requires the provision of social and community facilities as well as at least 2 hectares of employment land creating a sustainable community where homes, jobs and facilities are delivered alongside one another and residents can walk and cycle between them.

In terms of suitability for development Exmo_20 benefits from being very well screened by existing mature blocks of planted trees so views into the site from immediate and wider surroundings are limited, though there are some long-distance viewpoints into and of the site.  However, being a large site, it offers scope to carefully plan development and secure additional screening in a way that will minimise adverse impacts. 

Abutting Exmo_20 is the St John in the Wilderness church, which is an important heritage asset and community resource.  The sensitivity of this asset and other listed buildings was taken into account in the site assessment and this led to clear policy statements about the need to minimise scope for any adverse impacts.  The very clear policy expectation and requirement will be for built development to be accommodated in parts of the site that are separated from and away from the church. 

Biodiversity considerations are also an important consideration at this site.  Whilst the existing fields at the site that will accommodate development are typically of some but comparatively limited biodiversity importance, some woodland areas that abut the site are of greater value, as are hedgerows in the site.  Through site development particular attention will need to be attached to ensuring biodiversity assets are retained and protected where at all possible (some hedgerow loss being the greatest concern).  However, there is, through Biodiversity Net Gain, and given the large spacious nature of the site, real potential to secure positive wildlife benefits.  Such improvements would be a real positive given how important access to the countryside and wildlife is for human wellbeing. 

Beyond site Exmo_20 lie the Pebblebed Heaths.  This is an internationally important wildlife site and it is receiving particular care and attention as we consider future developments around Exmouth (including Exmo_20) and also in other locations in southerly, central and some easterly parts of the district. This is particularly so given adverse impacts extra vehicles, arising from development may have on roads that cross the Pebblebed Heaths.

Why do you continue to plan for more homes when the sewage infrastructure cannot cope?

Wastewater infrastructure in East Devon is the responsibility of South West Water overseen by Ofwat and the Environment Agency. The Council has no control over the water industry, but it does have a responsibility to work with South West Water to understand the impacts of proposed development on their network and ensure that new homes only come forward when there is adequate capacity to provide them with clean drinking water and to process wastewater from them.

There are some acute issues now, particularly in relation to sewage treatment works in parts of the district. However, the development in the Local Plan would be built over the next 15 years during which time it is envisaged that there will be various improvements to the water infrastructure. We are working with South West Water to co-ordinate improvements to their network with planned development   to ensure that wherever possible capacity is available when needed. Where capacity is not already available but is planned then we will place conditions on planning permission preventing development coming forward until there is capacity. Where there is no capacity and no plans to provide it in good time then planning permission will be refused. 

How are you going to assess whether there is capacity in the wastewater network?

The Council has commissioned a study called the Water Cycle Study which can be found at: ccf-001-the-east-devon-water-cycle-study.pdf. Among other things, it considers whether there is capacity to provide the required water treatment facilities and drinking water to the proposed new homes and the potential impacts on our waterways and coastline. We are working with the Environment Agency to refine this work which will give us an understanding of the position at a point in time. The position is however constantly changing as developments are built and South West Water make improvements. Through on-going work with South West Water and the Environment Agency we will assess the impacts of developments through planning applications using the most up to date information available to us at the time to ensure that our decisions do not have a detrimental impact on the water environment.

When this content has been updated

Last updated 8 July 2026