Proposed Submission Core Strategy

Ended on the 11 November 2011
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Part 4 - Core Policies



13.1 Managing the way people and organisations interact with natural resources to ensure their long-term availability is central to ‘sustainable development’. This chapter deals with the conservation of natural resources and how they will be efficient and effective utilised and managed. In particular, it considers how energy generating resources may contribute to the reduction in carbon emissions.

13.2 Specific sections relate to:

  1. Moving towards a low carbon future;
  2. Water Management.

13.3 Environmental conservation, in respect of flood risk, biodiversity and landscape, is more fully addressed in Chapter 17: Environment, while encouraging more sustainable travel patterns is addressed in Chapter 18: Transport.


13.4 The Strategic Objective in relation to sustainable resource management, as set out in Chapter 6 is:

‘To mitigate and adapt to climate change impacts, and to use natural resources efficiently’

13.5 This can be elaborated upon by the following objectives:

Sustainable Resource Management Objectives

  1. To reduce carbon emissions and move towards a low carbon future

  2. To maintain an adequate, safe water supply, use water resources efficiently, and avoid their pollution

Towards a Low Carbon Future

13.6 The UK is committed to a target to reduce carbon emissions by 34% by 2020, and by 80% by 2050, relative to 1990 levels32. It is also committed to supply 15% of its energy from renewable sources by 202033.

13.7 National Planning Policy Statements34 35 set out the contribution that planning can play at both national, regional and local levels in moving towards a low carbon future. They highlight the need to both reduce emissions and to adapt to the unavoidable effects of climate change when planning new development.

13.8 The main areas for local policy consideration in the more recent revised and consolidated draft PPS 36 include:

  • Identification of opportunities for decentralised energy;
  • Allocating sites central to the energy strategy and setting site-specific energy requirements;
  • Planning development to avoid significant vulnerability to climate change impacts and otherwise effectively managing risks;
  • Recognition of the role of green infrastructure in adaptation;
  • Support for achieving progressive energy targets via Building Regulations;
  • Consideration of impacts on travel demand, and increasing travel by sustainable modes.

13.9 The UK Climate Impacts Programme provides climate change projections looking forward some 70 years. Its ‘medium emissions’ scenarios indicate that all areas of the UK warm, especially in the summer months and in southern England. While annual precipitation will remain similar, it will increase in winter and decrease in summer, especially in the south of England. Relative humidity also decreases in southern areas in summer.

13.10 Locally, the Rother Local Strategic Partnership (LSP) has identified carbon reduction as one of its three priorities for action. It is currently formulating an ‘action plan’ embracing encouraging behaviour change, energy efficiency and a low carbon economy.

13.11 Sources of carbon emissions in Rother district are illustrated below.

Figure 13: Breakdown of Rother Carbon Emissions

Figure 13

13.12 The Council’s ‘Low Carbon and Renewable Potential Study’ (July 2010) identifies that Rother has a carbon footprint of 623,000 tonnes; it also highlights that even a rigorous new build energy efficiency policy would only have a very limited impact on this. Hence, policy should consider how emissions can be reduced from existing buildings and from travel patterns.

13.13 The Study identifies good opportunities for low carbon and renewable technologies, particularly wind, biomass and solar energies. There is a substantial biomass resource associated with both farmland and woodland cover, while wind speeds are most favourable to energy generation around Bexhill, west of Hastings and Rye, as well as along the High Weald ridges.

13.14 It recommends that smaller schemes of up to 3 turbines, of the order of 1.5 - 2MW capacity, would be most appropriate. The large mixed use development to the north-east of Bexhill is regarded as offering potential for energy generation above current national standards, while the prospect of other larger sites should also be assessed, in accordance with South East Plan policies NRM11-12.

(1) 13.15 A local requirement to secure a proportion of energy in new developments from decentralised sources is regarded as unnecessary given ongoing changes through Building Regulations. However, it will still be important to support the deliverability of these new requirements in terms of the form and viability of development.

13.16 Travel-related emissions can be minimised by locating development in places with ready access by means other than the car to shops and services that meet day-to-day needs. The Government also encourages planning for charging points for electric and hybrid vehicles. The town centres and Ravenside Retail Park appear the prime areas for this.

(6) Policy SRM1: Towards a low carbon future

The strategy to mitigate and adapt to the impacts of climate change is to:

  1. Require proposed developments of more than 100 dwellings or 1,000m2 of non-residential floorspace to provide a comprehensive energy strategy, including an assessment of the potential for solar, biomass and wind generated energy, and of combined heat and power, and consider extending this requirement to smaller schemes, subject to further assessment via a subsequent DPD and/or SPD;

  2. Ensure that all developments meet prevailing energy efficiency standards, and encourage them to meet higher standards and pursue low carbon or renewable energy generation, where practicable, by fully recognising related costs in assessing viability and developer contributions;

  3. Support stand-alone renewable and low carbon energy generation schemes that:

    1. do not have a significant adverse impact on local amenities or landscape character, particularly those utilising solar, biomass and wind energy technologies, and

    2. in respect of locations in or adjacent to the High Weald AONB and other sensitive landscapes, are generally small in scale;

  4. Achieve high levels of energy performance on the strategic mixed use developments to the north east of Bexhill, including by Combined Heat and Power (CHP) and/or wind energy generation;

  5. Reduce the carbon emissions from existing buildings by encouraging application of prevailing standards to whole buildings when extending them, supporting adaptations to be energy efficient, promoting take-up of Government energy efficiency schemes and supporting community-based energy infrastructure initiatives;

  6. Adaption in accordance with the East Sussex LCLIP, including through building in resilience to anticipated climatic changes, including through green infrastructure;

  7. Promoting more sustainable travel patterns in accordance with transport policy TR2, and through widespread fast broadband coverage.

Water Management

13.17 Ensuring that robust and resilient water supply and waste water infrastructure is in place is essential to the well-being of residents and businesses. There are challenges in meeting demand from housing growth, safeguarding water sources from the threat of pollution, reducing usage, as well as meeting the challenge brought on from the impacts of climate change.

13.18 The approach towards water resources and infrastructure in general is based on making the most of the capacity of existing infrastructure, encouraging behavioural change where this will enable more efficient use of the existing infrastructure, remedying any major deficiencies in existing infrastructure and providing new infrastructure that is needed to serve new development. The Environment Agency has produced a report on the current state and future pressure on water resources. Pressures are greatest in south east and eastern England because they are the driest parts of England and Wales, coupled with the highest population density and household water use.

(1) 13.19 Within the area covered by South East River Basin Management Plan, (drawn up under the Water Framework Directive 37) there are nine catchments and Rother traverses two catchments: the Cuckmere and Pevensey Levels catchment and the Rother catchment.

13.20 The south east river basin district has some of the highest levels of personal water use in the country; 72% of the public water supply comes from groundwater sources in its catchment, so it is essential to safeguard supplies from pollution.

13.21 Rother is supplied by both surface water and groundwater sources. The surface water sources within Rother comprise the three reservoirs - Bewl Water, Darwell Reservoir and Powdermill Reservoir.

13.22 Bewl Reservoir is situated at the northern edge of the district and straddles the adjacent authorities of Tunbridge Wells and Wealden. The reservoir is an important regional resource, but is also a significant recreational amenity, drawing upon a wide catchment area.

(1) 13.23 Both South East Water Management Plan (Dec 2010) and the Southern Water Management Plan (Oct 2009) identifies Bewl reservoir as a strategic option for enlargement to form part of a regional solution to water supply-demand balance. While noting that it will not necessarily come forward if subsequent modelling indicates it is not required, it would be prudent for the Council to safeguard it, to facilitate long term strategic planning and development.

13.24 Two water companies cover Rother district; Southern Water deals with wastewater collection and disposal, but the water supply service in Rother is split between Southern Water and South East Water.

(1) 13.25 Water companies maintain statutory Water Resource Management Plans, which effectively set out their agreed investment plans for meeting their obligations to supply water. They adopt a twin-track approach of water supply and demand management of water consumption. The latter looks at demand management initiatives like universal metering, tackling leakages, rainwater harvesting and the promotion of water efficiency initiatives. These are complemented by investment in technology and infrastructure.

13.26 In Southern Water’s Final Water Resources Management Plan Oct 2009 (page 10-70), the company has reaffirmed its commitment to the development of a regional solution:

‘As a result of the preferred options identified from the WRSE 38) modelling work, we have included the following options in our company preferred regional strategy, over and above the company only least-cost solution and includes raising Bewl Water at the earliest start date of 2022.’

‘The actual start date required for the regional solution will be refined following the results of the further regional modelling work. However, this approach demonstrates our continued commitment to the development of a regional solution’.

13.27 It follows that the Core Strategy should safeguard such expansion, at the same time highlighting the planning issues that would need to be addressed, including access, amenity and promoting recreational use.

13.28 Groundwater sources can be found across the district at Ticehurst, Brede, west of Battle and south west of Rye. A number of these groundwater sources have recorded high levels of nitrate concentrations as result of pollutants from urban and agricultural activities39). The threat from pollution is significant and could also potentially impact on the sensitive ecology of the adjacent wetland, lakes and streams.

13.29 Foul sewerage should be by connection to the public mains system. Only exceptionally will other provision be allowed, where it is not feasible to connect. The rate of run-off from developments needs to be carefully controlled to avoid any adverse impacts on watercourses and increasing the risk of flooding downstream. It must not prejudice the integrity of floodplains or flood defences.

(6) Policy SRM2: Water Management

Effective management of water resources will be supported by:

  1. Ensuring that the relevant water companies are aware of and have capacity to meet demands for water, wastewater and sewerage arising from new development;

  2. Ensuring that new development does not have an adverse effect on the water quality and potential yield of water resources, with particular reference to groundwater ‘source protection zones’;

  3. The promotion of sustainable drainage systems to control the quantity and rate of run-off as well as to improve water quality wherever practicable, and specifically for all development that creates impermeable surfaces within the hydrological catchment of the Pevensey Levels;

  4. Safeguarding land for the possible raising of Bewl Water reservoir, and contributing to the development of plans that also secure Bewl Water as a recreational, economic and social amenity for the local community. (NB The safeguarded area will be defined through the Site Allocations process in conjunction with Wealden and Tunbridge Wells Councils); and

  5. The promotion of water efficiency through the use of rainwater and grey water storage and recycling.

Other matters

Air quality

(1) 13.30 There are no specific localities within the district currently identified as having poor air quality. Nonetheless, the Council will support the respective Highway Authorities in their initiatives to reduce the environmental impacts of traffic and congestion, while Policy SRM1 above highlights opportunities to support the use of cleaner transport fuels. Also, air quality is put forward as a general development consideration in chapter 7. Hence, no specific air quality policy is put forward.

Waste reduction

(1) 13.31 Waste planning can contribute to carbon reduction, including through minimising construction and demolition waste and by generating energy from waste. The latter may be at both the community and farm scale. All such matters are the responsibility of East Sussex County Council and will be addressed though the Waste and Minerals Core Strategy that it is preparing with Brighton & Hove City Council.

32 Climate Change Act, 2008 33 EU Directive 2009/28/EC 34 PPS1 Supplement ‘Planning and Climate Change’, Dec.2007 35 PPS22 ‘Renewable Energy’ 36 Consultation on a PPS: ‘Planning for a Low Carbon Future in a Changing Climate’, March 2010. (NB: This is not being progressed as Government move to a simplified national planning framework.) 37 The European Water Framework Directive came into force in December 2000 and became part of UK law in December 2003. The Water Directive is designed to improve and integrate the way water bodies are managed throughout Europe 38 The WRSE group is made up of seven water companies1 that supply customers in the South East, led by the Environment Agency, with the engagement of Ofwat, the Consumer Council for Water, Natural England, SEEDA, and the South East Partnership Board 39 Environment Agency - River Basin Management Plan, South East River Basin District – Rother Catchment - December 2009
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