Councillor John Stephens (Cabinet Member for Strategic Planning and Transport (Deputising for the Leader)) introduced the report and discussed:

 

a)     Councillor Stephens was attending in place of the Leader of the Council, who was unwell. The Board sent its best wishes to the Leader for a speedy recovery;

 

b)    The proposal responded to the Government’s statutory invitation to bring forward local government reorganisation proposals for the whole of the existing Devon area. The Council was required to submit its proposal by 28 November 2025, with Scrutiny’s comments feeding into Cabinet and City Council consideration on 24 November 2025;

 

c)     This was a period of significant uncertainty and concern for many dedicated local government employees across Devon. Their professionalism and commitment to public service during such a challenging time were deeply respected;

 

d)    The current two?tier system operated by neighbouring authorities created confusion, duplication and artificial barriers. The Government had given the area a rare opportunity to reduce this fragmentation and improve joined?up public services for residents;

 

e)     Plymouth, Exeter and Torbay had worked together to propose four unitary authorities across the Devon area:

 

                     i.         an expanded Plymouth;

                   ii.         a new and expanded Exeter;

                  iii.         an expanded Torbay;

                  iv.         a new Devon Coast and Countryside authority;

 

f)      For Plymouth, the proposal sought a modest boundary extension to include 13 South Hams parishes which already formed part of Plymouth’s functional economic area (places where people worked or learned in Plymouth and regularly used facilities that only a city could provide);

 

g)     The proposed extension would add approximately 30,000 residents to Plymouth’s existing population of approximately 270,000, bringing the new authority to approximately 300,000 residents;

 

h)    The proposal was not an “empire building” exercise or “land grab”, but an attempt to correct outdated boundaries which currently cut through growing communities and prevented proper strategic planning for housing, transport and infrastructure;

 

i)      The existing Joint Local Plan with South Hams demonstrated that these areas already operated as a single functional area and the proposal would make the governance arrangements match the lived reality;

 

j)      The benefits of the proposed structure went beyond council efficiency and were central to unlocking wider public service reform across health, employment and community safety;

 

k)     Major programmes, such as the Connect to Work plan and the development of integrated neighbourhood teams for health, could not be delivered by any single agency, but instead required the ability to convene partners such as the NHS, police and skills providers to tackle complex challenges together;

 

l)      Under the current two?tier structure, there was often no single body capable of exercising that systems leadership effectively across the whole place. The four?unitary model would create authorities with sufficient strategic scale to be credible convening partners, but still local enough to understand and deliver what communities actually needed;

 

m)   The Council was taking a genuinely developmental approach to community engagement and neighbourhood governance, proposing to establish neighbourhood networks from vesting day, but recognising that empowerment would look different in different places;

 

n)    The Council was committed to working with communities to co?design neighbourhood arrangements rather than imposing a rigid model. The Government was expected to bring forward detailed regulations about neighbourhood governance, powers and duties, which Plymouth would work with flexibly to support locally appropriate solutions whilst maintaining consistent standards across the expanded area;

 

o)    The approach would mean continuous dialogue with communities, not just occasional consultation, and would aim to give people real influence over decisions that affected them;

 

p)    The proposal treated Plymouth as a continuing authority, thereby minimising transition costs and risks compared to creating a wholly new council;

 

q)    The alternative to the proposed reorganisation risked a path of “managed decline” in which Plymouth, if locked within its existing boundaries, would struggle to grow, plan strategically or fund the services residents deserved. This would not only affect existing residents, workers and students in the city, but also those living in the 13 parishes Plymouth proposed to serve as the governing authority;

 

r)     The proposal rested on three key arguments:

 

                 i.         That decisions should be taken closer to communities rather than in distant council chambers, and that the model would protect the culture and identity of all communities in an expanded Plymouth through strong local decision?making;

 

                ii.         That the two?tier system had “failed Devonians”, cost too much, and left many core services in significant difficulty with serious impacts on residents;

 

               iii.         That Plymouth needed room to grow, to capitalise on Freeport and Langage opportunities, and to secure the full benefits of “Team Plymouth” and the defence dividend;

 

s)     Councillor Stephens noted his thanks to Council staff who had contributed to the submission, including those who had volunteered to facilitate engagement sessions with the 13 South Hams parishes, six localities across Plymouth, and a wide range of stakeholders and interest groups.

 

Tracey Lee (Chief Executive) added:

 

t)     This work was about shaping the structure of local government for the next 50 years, and it was difficult to imagine a more important decision in terms of how councils were organised;

 

u)    The way councils were organised mattered because of the leadership they provided to communities and the way in which public services were delivered on the ground;

 

v)     Concerns that if councils over-expanded there were risks of losing grip, pace and quality of delivery, whereas if they were too small there would be challenges with viability. The four?unitary model sought to establish an appropriate balance;

 

w)   The proposed approach meant four councils within the Devon system. While this would result in one more Director of Children’s Services and Director of Adult Services than at present, it would also significantly reduce the overall number of councils and therefore other statutory senior posts across the area;

 

x)    The proposal had been developed in partnership with Exeter and Torbay. The proposition was exactly the same as Exeter’s submission and closely aligned with Torbay’s, with the only difference being that Torbay proposed to remain on its existing boundary. This alignment demonstrated a clear sense of unity among the urban areas of Devon regarding the preferred way forward;

 

y)     Changes to local government boundaries would need to be aligned with evolving place?based arrangements in health and other services rather than treated in isolation;

 

z)     In her view, the Council was coming to the end of “phase one” of the process (developing the proposal) but there would be many further phases ahead if Government decided to proceed, and that it was therefore vital to submit the best possible proposal, aligned with partners’ submissions.

 

Ross Jago (Head of Devolution and Local Government Reorganisation) added:

 

aa)  The Council first received formal notification that Local Government Reorganisation (LGR) was likely in December 2024, when Government released its white paper, and that this had been followed by a statutory invitation requiring proposals for the whole Devon area;

 

bb)The Government had been very clear that the abolition of the two?tier system was its stated policy intention, and therefore, change was guaranteed for Devon;

 

cc)  Plymouth had developed an interim plan which was agreed by Council in March 2025, and had undertaken significant stakeholder engagement including a parish conference and targeted engagement across South Hams and the city, alongside work with all Devon councils via a shared data room and regular officer meetings;

 

dd)  The Government’s criteria for assessment included:

 

                   i.        proposals covering the whole of Devon;

 

                  ii.        authorities of the “right size”. Guidance indicated an ideal population around 500,000, but with flexibility to consider local alternatives;

 

                iii.        prioritisation of high?quality, sustainable public services;

 

                iv.        evidence of joint working;

 

                  v.        support for future devolution arrangements;

 

               vi.         strengthened community engagement and local accountability;

 

ee)  In practice, reaching 500,000 residents in an authority built around Plymouth would have required a very extensive and, in his view, unrealistic boundary extension. Plymouth therefore argued that around 300,000 residents was the “right size” for a resilient, viable unitary authority, comparable to several metropolitan authorities in Greater Manchester and London;

 

ff)    Devon was a complex mosaic of different communities with varying levels of deprivation, connectivity and need. The four?unitary model was deliberately designed to reflect those differences;

 

gg)  The Government had required Plymouth to bring forward a “base case” proposal based strictly on whole district boundaries under the Local Government and Public Involvement in Health Act 2007, while also allowing for more complex modifications where there were compelling reasons;

 

hh)The legally compliant base case effectively replicated the current structure (Plymouth and Torbay as unitary authorities, Exeter as a district within a larger Devon), leaving Plymouth and Torbay with smaller populations and weaker tax bases, and creating a very large county?wide authority for the rest of Devon;

 

ii)     Other options proposed in Devon included a single large unitary, and a “1?4?5” model promoted by districts, both of which left Plymouth stranded on its current boundary and created significant imbalances in tax base and population;

 

jj)     The modified four?unitary model recommended by officers proposed:

 

                 i.         an expanded Plymouth (current city plus 13 South Hams parishes);

 

                ii.         an expanded Exeter (Exeter plus surrounding parishes across parts of Teignbridge, East Devon and Mid Devon);

 

              iii.         an expanded Torbay (on its existing boundary but with an expanded functional role);

 

              iv.         a new Devon Coast and Countryside authority tailored to rural and coastal communities;

 

kk)  This model delivered four resilient and viable unitaries with more balanced populations and tax bases, coherent functional economic areas, and clearer urban–rural distinctions to support tailored service delivery;

 

ll)          The proposal emphasised neighbourhood networks as the core of local governance, but deliberately avoided being overly prescriptive about their final form until Government regulations on powers and duties were published and further co?design with communities could take place;

 

mm)    Stakeholder engagement had included 19 public events, an online survey with approximately 11,000 website visitors, and 17 stakeholder meetings with public sector bodies and local institutions, alongside targeted parish and locality engagement. A comprehensive engagement report was included in the pack;

 

nn)       Feedback from South Hams parishes had highlighted concerns around rural identity, planning, infrastructure and potential domination by the city, while feedback from Plymouth had focused on growth, inclusion, and improved service outcomes, though with many common issues such as affordable housing, homelessness and access to schools;

 

oo)      There was broad recognition among partners that the removal of the two?tier system could be beneficial for the delivery of services, even where bodies were understandably cautious about endorsing particular boundary configurations at this stage.

 

Paul Barnard (Service Director for Strategic Planning and Infrastructure) added:

 

pp)In addition to the Government’s six criteria, Plymouth had developed a set of “Plymouth principles” in March 2025 to guide its thinking, which had been endorsed unanimously by Full Council with one abstention. The principles included the need for:

 

                     i.         a financially viable boundary change with appropriate population size;

 

                   ii.         preservation of the character and identity of existing Plymouth neighbourhoods and communities in the extended area;

 

                  iii.          respect for existing unitary and county boundaries;

 

                  iv.         minimising organisational impacts on Dartmoor National Park;

 

                   v.         using parishes as the basic building blocks for any boundary extension rather than relying solely on whole district lines;

 

                  vi.         supporting Plymouth’s long?standing growth agenda, including the Joint Local Plan with South Hams and West Devon, and the step?change expected from Team Plymouth initiatives, the dockyard, the proposed “town in the city” concept for the city centre and new housing growth;

 

qq)The proposed extension into 13 South Hams parishes reflected these principles by aligning with the functional economic area and existing planning arrangements.

 

Oliver Woodhams (Head of Finance) added:

 

rr)   Officers had compared projected financial sizes of the proposed authorities with existing single?tier councils across the country, using graphical analysis contained in the financial appendix;

 

ss)   Officers had built a complex financial model using data from 2025/26 budgets and most recent statements of accounts, projecting forward three to four years into a future structure of councils which did not yet exist. As a result,  there was a high degree of uncertainty in projections;

 

tt)   The model incorporated prudent assumptions about savings including moving from 11 councils to 4, estimates of transition costs, and the harmonisation of council tax bases, and used national expert advice on income projections (including Revenue Support Grant and business rates);

 

uu)Under the modified four?unitary model, all four proposed authorities showed a modest surplus of income over expenditure in the medium term, whereas under the base case some smaller authorities, notably Exeter, and to a lesser extent Plymouth, faced more acute viability challenges, with modelled costs exceeding projected income;

 

vv)        Modelling suggested potential annual savings of around £6 million across the system in steady state, with transition costs of approximately £14.9 million (over several years), to be funded from one?off resources and repaid over three to four years through efficiencies;

 

ww)    Income predictions, particularly national funding streams and business rates, were inherently uncertain, but officers had adopted a prudent and cautious approach, avoiding some of the more ambitious assumptions used elsewhere in the country. This included not building in unproven savings in high?cost areas such as adult social care;

 

xx)Officers had deliberately not included some speculative savings in the viability analysis, focusing instead on those that could be reasonably evidenced at this stage. External experts had been commissioned to validate key aspects of the modelling.

 

Elinor Firth (Head of Public and Partner Relations) added:

 

yy)  The Council had undertaken an intensive programme of engagement as part of the ‘Big Community Consultation’, including well attended in?person events in both Plymouth and the South Hams, online surveys, web content and targeted sessions with stakeholders;

 

zz)        While many residents in the South Hams had initially attended meetings expecting a predetermined decision, feedback indicated that residents felt genuinely listened to, with officers presenting a blank?page approach rather than telling communities what would happen;

 

aaa)     Some attendees remained opposed to the proposal but nonetheless felt the process itself had been fair and respectful, and that their views had been properly heard;

 

bbb)    Although demographic data for event attendees were limited, officers had observed a broader age mix, including younger people, than might traditionally be seen at parish?based events;

 

ccc)     The next phase of consultation would be the Government?led statutory consultation on whichever proposals Ministers considered viable;

 

ddd)    Officers had already launched detailed web pages explaining Plymouth’s proposal in accessible language and intended to continue updating those pages, using questions and concerns emerging from communities to shape further content.

 

In response to questions, the Board discussed:

 

eee)    Concerns that councils were being asked to plan for the next 50 years while key policies, including the shape of Integrated Care Boards, SEND reforms, social care funding and elements of the devolution framework, were still changing or unknown;

 

fff)        Risks that the Government could ultimately choose a different model or design its own solution;

 

ggg)     Officers confirmed there were indicative national timelines and that areas ahead of Devon (for example Surrey and several priority areas) broadly appeared to be progressing within those timescales. There would inevitably be learning and adjustments as the national programme unfolded;

 

hhh)    Members recognised the inherent risk and ambiguity of planning in such a fluid environment, but accepted that local government was already managing multiple reforms and that LGR represented another, significant, but not unfamiliar, challenge;

 

iii)         Officers confirmed that they had carefully studied recent LGRs (including in Somerset and Wiltshire), that Plymouth had staff with direct experience from those areas, and that the Local Government Association and a former chief executive with LGR experience were supporting the work to avoid repeating known pitfalls, particularly in IT integration, HR and organisational design;

 

jjj)         Concerns about the cost of developing the proposal, with questions about how much LGR had cost Plymouth to date and the level of Government funding for this preparatory work. Officers confirmed that Plymouth had received approximately £40,000 from a Government fund shared equally between the 21 LGR areas, and that total Council expenditure on external support (excluding internal staff time) was estimated at under £100,000, with a conscious decision not to rely on large consultancy firms;

 

kkk)        Concerns that LGR could divert focus from day?to?day service pressures if not managed carefully. Officers emphasised that LGR was being treated as an opportunity for public service reform, referencing parallel work on new neighbourhood working arrangements, integration with health, SEND reforms, and the Council’s future operating model, stressing that Plymouth would remain an ambitious, improvement?focused authority whatever the outcome of the Government decision;

 

lll)            Queries around the transparency and robustness of financial assumptions, particularly the projected £6m annual savings and £14.9m transition costs. Members requested clearer evidence-based information, identifying which assumptions were price?sensitive, which were volume?sensitive and which were driven by specific efficiencies. Officers reiterated that the Financial Appendix already provided a detailed breakdown of the modelling and underlying data, but accepted that further explanation of key assumptions,  especially around savings, income forecasts and transition costs, could be added to support public and member understanding;

 

mmm)   Concerns about the scale and composition of the Devon Coast and Countryside authority and the risk that larger authorities might dominate future devolution negotiations, leaving Plymouth as a “minor partner” if it remained on its current boundary. Officers repeated their view that the base?case model and some alternative proposals created significant imbalances in population and tax base, whereas the modified four?unitary model offered a better balance of voice between urban and rural areas and a stronger position for Plymouth within any future mayoral or combined authority framework;

 

nnn)       Questions were raised regarding potential gaps in consultation, particularly in relation to younger people and under?represented groups in parishes. Officers acknowledged limitations in the demographic data from engagement events but noted that younger people had been more present than expected, and that the focus between now and Government consultation would be on clear, accessible communications and targeted outreach, rather than attempting to re-run the same consultation process;

 

ooo)       Concerns from some members and residents that communities such as Ivybridge or rural parishes might perceive a mismatch between their identity and inclusion in a city council area. Officers noted that previous boundary changes, notably the incorporation of Plympton and Plymstock, had prompted similar concerns, but those areas now felt firmly part of the city while retaining distinct identities. The proposed neighbourhood network model, combined with future electoral boundary reviews by the Local Government Boundary Commission, would be key to protecting local identity and ensuring fair representation;

 

ppp)       Feedback from some residents in South Hams that while they valued their rural character, their daily lives and service use (e.g. work, education, leisure and health services) were closely tied to Plymouth, particularly around transport links, and that these real patterns of movement and service use underpinned the functional economic area case;

 

qqq)       Questions were raised about whether Devon councils had considered collectively refusing to participate in LGR, and what the implications might have been. Officers confirmed this had been considered but that there had been a real existential risk for Plymouth that other proposals could envisage the abolition or absorption of the city within a larger Devon unitary if Plymouth did not put forward its own case;

 

rrr)         Members explored the risk of a “mega Devon” option imposed by Ministers, effectively abolishing Plymouth as an authority, and sought reassurance that the proposal made a strong political and technical case against this scenario. Officers advised that while Ministers had powers to determine structures and had, in previous LGR rounds, asked the Boundary Commission to develop alternative options, the current national context, tight timelines and the explicit requirement for locally developed proposals made it unlikely that Government would design a wholly new un-consulted option, although this could not be ruled out entirely;

 

sss)          Concerns regarding council tax harmonisation, local housing allowance and other financial mechanisms across expanded boundaries, with questions about how these would be managed in practice and over what timescale. Officers explained harmonisation of council tax was a legal requirement when councils merged and that, for modelling purposes, they had assumed harmonisation to an average rate in the first year of the new authorities, noting that actual decisions would be a matter for future administrations at the time of implementation;

 

ttt)          In respect of Local Housing Allowance (LHA) rates, officers had assumed no change in the immediate term and had apportioned current costs using population?based drivers, recognising that any future harmonisation or change would be a relatively small factor compared to the overall scale of LGR finances;

 

uuu)       Officers agreed communications needed to stress the shared benefits, including improved bus services, integrated planning and climate?conscious travel options, and confirmed that Plymouth would continue proactive communications in addition to the formal Government consultation.

 

The Board agreed:

 

1. To note the content of the Plymouth City Council Draft Local Government Reorganisation Proposal for Devon;

 

2.     To recommend that the ‘Plymouth principles’ for local government reorganisation set out in the options appraisal be broadened to apply to the whole of Devon;

 

3.     Action: To request that Plymouth’s LGR Communications Plan is reported back to the Scrutiny Management Board prior to the Government’s statutory consultation period, expected to be in 2026.

 

4.     Action: To request that the financial modelling included in the proposal be updated to include enhanced detail of assumptions made in relation to the savings, costs and transition expenses in order to provide further transparency on the methodology used for the local government reorganisation proposal.