Rother Local Plan 2025-2042 Regulation 19 (pre-submission) version September 2026

Ends on 24th November 2026 (43 days remaining)

Chapter 5: Green to the Core

Policy GTC1: Net Zero Development Comment

Status

Strategic

Priorities

Green to the Core

Strategic Objectives

1, 2

Operational Energy

  1. All new development proposals must prioritise a ‘fabric first’ approach[110] and be designed and orientated to minimise energy demand for heating, lighting and cooling, in accordance with Policy LWL6.
  2. Opportunities to provide solar PV and energy storage must be incorporated where feasible, and opportunities to connect to district heat networks and decentralised electricity networks should be considered where these are available.
  3. Compliance with the applicable requirements of this policy will be required to be demonstrated through the submission of proportionate information with the planning application. Major development proposals must be supported by an Energy Statement.
  4. All new dwellings will be expected to achieve the following:
    1. For new builds, a 60% improvement over the dwelling Target Emissions Rate (TER), calculated using SAP 10.2.
    2. For conversions to residential development, a Building Research Establishment Environmental Assessment Method (BREEAM) ‘Excellent’ standard as a minimum.
    3. Where it is demonstrated through the information submitted with the application that the 60% TER improvement required by criterion 4(a) is not technically feasible, the development must achieve the maximum feasible improvement over TER. The submitted information must clearly identify the technical constraints and the measures considered to maximise performance.
  5. Compliance with the residential operational-energy requirement must be demonstrated through the relevant SAP calculations submitted with the application and verified through an as-built assessment prior to occupation. The requirements relating to BREEAM should be demonstrated through the relevant certification process.
  6. Non-residential development (including building conversions) should achieve:
    1. A LETI TEUI Target for Operational Energy of:
      1. For office buildings (Class E(g)(i)) - 55 kWh/m2/year (GIA);
      2. For light industrial buildings (Class E(g)(ii) and (iii)) - 65 kWh/m2/year (GIA); and
      3. For general industrial and warehousing buildings (Class B2, B8 and associated Sui Generis), a feasibility statement to evidence a practicable TEUI Target; and
    2. A BREEAM ‘Excellent’ standard as a minimum.
  7. If BREEAM is updated or replaced during the plan period, the equivalent replacement requirements will be applied.

Embodied Carbon

  1. All new development proposals must meet the following embodied carbon standards, with compliance demonstrated in accordance with criterion (3) above:
    1. All residential development must achieve a LETI C rating for embodied carbon emissions, equating to 600 kgCO2/m2 upfront embodied carbon and 970 kgCO2/m2 total embodied carbon. From 1 January 2030, a LETI A rating must be achieved, equating to 300 kgCO2/m2 upfront embodied carbon and 450 kgCO2/m2 total embodied carbon.
    2. All office development should achieve a LETI C rating for office development, equating to 600 kgCO2/m2 upfront embodied carbon and 970 kgCO2/m2 total embodied carbon.

From 1 January 2030, a LETI A rating must be achieved, equating to 350 kgCO2/m2 upfront embodied carbon and 530 kgCO2/m2 total embodied carbon.

Key evidence and/or guidance:
 

5.1The UK Climate Change Act commits the UK Government by law to ensuring that the UK’s greenhouse gas emissions for the year 2050 are at least 100% lower than the 1990 baseline (net zero). Dwellings are a significant contributor to greenhouse gas emissions, responsible for 16% of the UK’s total emissions in 2020, and unlike other sectors such as business and transport, residential homes saw emission levels rise between 2017 and 2020[111].

5.2Building Regulations establish minimum standards for the energy and carbon performance of new homes. The Council considers that higher standards are necessary to support the transition to net zero and reduce the operational carbon emissions associated with new development. This will also reduce energy bills for occupiers, at a time of significant volatility in energy prices. A “fabric-first” approach, which minimises energy demand before considering low-carbon heat and renewable energy generation, is an important part of achieving this. Policy LWL6 sets out how orientation, microclimate, compact built form and opportunities for low-carbon and renewable energy should be integrated with site layout, landscape, local character and other placemaking objectives.

5.3For residential development, this policy expresses the mandatory operational energy requirement as a percentage improvement over the Building Regulations Target Emissions Rate (TER), calculated using the specified approved methodology. The Council’s Energy Efficiency Standards Study (2026) recommends a 60% improvement over TER for new dwellings. The study finds this level of improvement is likely to deliver operational energy performance broadly aligned with the UK Net Zero Carbon Buildings Standard EUI limits for new buildings. The UK NZCBS EUI limits provide a useful performance benchmark but do not constitute a separate mandatory residential compliance requirement under this policy. Compliance with the residential operational energy requirement will be demonstrated through the relevant approved energy calculations submitted with the planning application and, where appropriate, verified through an as-built assessment.

5.4Non-residential TEUI targets are set for light industrial and office buildings. To achieve these targets, it is likely that rooftop and/or on-site ground solar PV systems will need to be installed.

5.5For new industrial buildings, including warehouses, the target is flexible and will be considered on a case-by-case basis. A feasibility statement should demonstrate that the best energy efficiency outcomes have been achieved to serve the proposal, by maximising opportunities for on-site solar PV systems and optimising building fabric performance, heating and ventilation.

5.6Embodied carbon (the carbon associated with both building materials and the construction and maintenance of a building throughout its whole lifecycle) is a significant contributor to carbon emissions and is likely to amount to as much as 50% of total emissions over a building’s lifetime as operational emissions reduce. Rother’s Climate Change Study (2023) advises that, based on the joint Embodied Carbon Target Alignment guidance from LETI, RIBA and other industry organisations, current average building design achieves an E rating on the LETI carbon rating system, equating to 950 kgCO2 /m2 upfront embodied carbon and 1400 kgCO2 /m2 total embodied carbon. While the policy aim should be to achieve the LETI A rating for both residential and non-residential buildings, Arup’s carbon specialists advise that the construction industry is not yet capable of meeting this. Therefore, a staggered approach is proposed to transition towards meeting the LETI A rating target from 2030.

5.7In relation to waste, the ESCC Waste and Minerals Local Plan requires proposals to minimise the quantities of aggregates used in construction and prioritise the use of recycled and secondary aggregate over virgin aggregate. It supports the promotion of sustainable aggregate use policies within Local Plans.

5.8Development should also have regard to Policy HER1 (Conservation of the Historic Environment) which sets out how the historic built environment must be considered and protected by new development. More specifically, Historic England have produced guidance ‘Adapting Historic Buildings for Energy and Carbon Efficiency’ Advice Note 18, providing advice to homeowners and local planning authorities on requirements for decarbonising and improving the energy efficiency of historic buildings.

National policy context

5.9National policy allows local planning authorities to seek residential energy performance standards above Building Regulations where these are supported by a well-reasoned and robustly costed rationale, including consideration of development viability, housing supply and affordability.

5.10Where an additional residential energy performance requirement is set, national policy requires the standard to be expressed as a percentage improvement over the dwelling Target Emissions Rate (TER), calculated using a specified approved methodology.

5.11The Council’s technical and viability evidence supports seeking a residential energy performance standard above Building Regulations. This policy therefore requires new residential development to achieve a 100% improvement over TER.

Policy GTC2: Net Zero Retrofitting Comment

Status

Strategic

Priorities

Green to the Core

Strategic Objectives

1, 4
  1. Development proposals which result in considerable improvements to the energy efficiency and reduction of carbon emissions of existing buildings will be supported.
  1. Development affecting statutorily and non-statutorily protected historic buildings, or within Conservation Areas, should be guided by Historic England advice on climate change and historic building adaptation.
  2. Alterations and extensions to existing buildings which comprise major development must:
    1. Provide an Energy Statement which aligns with the six principles for best practice in LETI’s Climate Emergency Retrofit Guide.
    2. Meet BREEAM Domestic Refurbishment Excellent standard, as a minimum, when delivering 10 dwellings or more.
    3. Demonstrate that due consideration has been given to the carbon efficiency of the whole building.

Key evidence and/or guidance:

5.12It is widely accepted that retrofitting of existing buildings is essential if net zero targets are to be achieved. A substantial amount of annual CO2 emissions come from existing homes - homes that are likely to be in use in 2050. If these are retrofitted well, this can offer a host of environmental, social and economic benefits.

5.13Retrofit is not only about reducing carbon emissions. A best practice retrofit should reduce fuel bills, reduce fuel poverty and also improve health and wellbeing.

5.14LETI’s Climate Emergency Retrofit Guide underpins the Local Plan retrofit policy, setting out what good retrofit looks like for existing homes, and targets energy consumption reductions of 60-80% for the average home.

5.15LETI best practice for retrofit is led by the following principles, which must be addressed in a submitted Retrofit Plan for major development, setting out building information, key works, and a plan for monitoring and consumption:

  1. Reduce energy consumption.
  2. Prioritise occupant and building health.
  3. Have a whole building Retrofit Plan.
  4. Measure the performance.
  5. Think big!
  6. Consider impact on embodied carbon.

5.16Proposals affecting heritage assets must have regard to Historic England’s Advice Note 18 ‘Adapting Historic Buildings for Energy and Carbon Efficiency’.

Policy GTC3: Construction Materials and Waste Comment

Status

Strategic

Priorities

Green to the Core

Strategic Objectives

1, 2, 11
  1. Development proposals that reuse previously developed land and buildings, consistent with maintaining and enhancing local character and distinctiveness, will be supported subject to other Local Plan policies.
  1. Major development proposals involving demolition and/or refurbishment will be required to demonstrate through the planning application how opportunities to reuse and recycle materials that arise through demolition and refurbishment have been maximised, including through the reuse of excavated soil and hardcore within the site. All major development proposals involving demolition will be required to undertake a pre-demolition audit, to determine products and materials for re-use.
  2. Major development must demonstrate how buildings have been designed, where practicable, to facilitate future adaptation, disassembly and the reuse or recovery of components and materials.

Key evidence and/or guidance:

5.17The Local Plan seeks to ensure that the sustainability of development includes the construction stage. Requirements relating to the construction processes of major developments, such as a pre-demolition audit and “design for disassembly”, ensure that every stage of the development process from design to demolition has been considered in terms of embodied and operational carbon and waste.

5.18A pre-demolition audit provides advice about the products and materials that can be re-used or re-cycled prior to demolition or refurbishment, to ensure best practice in resource efficiency is adopted by the contractor. The process enables the construction industry to manage waste sustainably and at a high value, with outcomes based upon accurate data. Policy LWL5 addresses how material reuse, adaptability, design for disassembly and circular economy principles should inform the design of development, including material choice, local distinctiveness and whole-life design.

5.19The ‘design for disassembly’ concept aims to preserve resources and address concerns regarding power consumption. The key principle is that the buildings are made specifically for material recovery and value retention. Buildings designed according to the principle of design for disassembly are enduring and constructed in a way that envisions they will never be demolished but layered in such a way that ensures that they can be one day taken apart for re-use.

5.20This policy complements policies of the East Sussex, South Downs and Brighton & Hove Waste and Minerals Local Plan, including Policy WMP3a (Promoting Waste Prevention, Re-use) which seeks to maximise waste prevention and re-use, including through encouraging developments that involve the preparation of materials for re-use, and Policy RM0 (Sustainable Use of Aggregates)[112] which supports proposals that minimise the quantities of aggregates used and prioritise the use of recycled and secondary aggregates, and requires applicants to demonstrate the sustainable use of aggregates as part of their wider consideration of resources used when designing their developments.

Policy GTC4: Water Efficiency Comment

Status

Non-strategic

Priorities

Green to the Core

Strategic Objectives

1, 3
  1. All new development proposals should minimise their impact on water resources. Proposals should seek opportunities to integrate rainwater and/or grey-water storage and recycling measures, green roofs and walls, and other water efficiency measures.
  1. All new dwellings are required to be designed to achieve a water consumption rate of no more than 100 litres per person per day.

Key evidence and/or guidance:

  • Water Resource Management Plans
  • Environment Agency/Department for Environment, Food and Rural Affairs data (identifying Rother as a seriously water stressed area)

5.21National planning policy requires development plans to take a proactive approach to mitigating and adapting to climate change, taking into account impacts including extreme weather, drought and flood risk, and implementing measures including setting local water efficiency standards for new development where these are justified. Local plans may apply the Building Regulations optional requirement of 110 litres per person per day where justified, or exceptionally a more stringent local standard in areas of serious water stress.

5.22Rother is within a serious water stressed area as determined by the Environment Agency[113]. Therefore, a more stringent requirement than the Building Regulations optional requirement can be justified. Water usage for new dwellings of 100 litres per person per day has been subject to viability testing through the Local Plan Viability Assessment (2026) and found to be acceptable in these terms. This requirement would be secured via a planning condition of the development being approved.

5.23Both South East Water and Southern Water have company-wide Water Resource Management Plans. These set out how the water companies will secure water supplies into the future. These plans have fed into the region-wide Water Resources South East (WRSE) regional plan which has brought together all the water companies in the region. WRSE confirms that the whole of the South East is designated as seriously water stressed by the Environment Agency. The water supply in the region is under increased strain from an increasing population; climate change, particularly changes to rainfall patterns and droughts; and the need to balance increasing demand for water while protecting and improving the environment.

5.24To help address these challenges, the policy goes further than simply requiring higher standards than Building Regulations for new dwellings, by also giving weight to development proposals of all scales and types which take opportunities to reduce water consumption. This could be through measures such as rainwater storage and recycling (including underground tanks and “dual pipes” to allow rainwater to be recycled in the home), the installation of water efficient appliances, and allowing space within site layouts for water storage and treatment.[114] The extent to which a proposal can demonstrate being water efficient will be a factor weighing in its favour (and subject to design, heritage and safety considerations).

Policy GTC5: Heat Networks Comment

Status

Non-strategic

Priorities

Green to the Core

Strategic Objectives

1
  1. Development proposals for decentralised low-carbon energy infrastructure, including district heat networks, will be supported where compatible with other policies in the Local Plan.
  1. Where an existing or committed heat network is capable of serving a development, development proposals should be designed to enable connection to the network and will be expected to connect where technically and financially feasible.

Key evidence and/or guidance:
 

5.25National planning policy encourages Local Plans to take advantage of opportunities to draw low carbon energy from decentralised networks (such as district heat networks), where these are available, and to co-locate energy and heat generators and users, especially to take advantage of suppliers of surplus heat and energy.

5.26For residential developments, the Rother Climate Change Study - Net Zero Carbon Evidence Base Report (2023) identifies that the most favourable opportunities for establishing new district heat networks are in Bexhill-on-Sea because of existing building heat density and the presence of large, non-residential buildings with sufficient heat demand to act as anchor loads. The most favourable opportunities for large non-residential developments are in Bexhill-on-Sea and Rye Harbour. Where an existing or committed heat network is capable of serving a development, connection should be considered in accordance with Policy GTC5. Development proposals should therefore refer to the Rother Climate Change Study, or successor evidence base documents, for the latest information on decentralised or other heat network opportunities.

5.27A community heat network has been delivered at The Gateway development in North East Bexhill. The development is served by a centralised heat network providing heating and hot water to homes, demonstrating how low-carbon heat infrastructure can be incorporated into larger residential developments within the district. The network is specific to The Gateway development and should not be assumed to have capacity to serve development outside the site unless this is confirmed by the network operator.

5.28Where heat-network or other decentralised-energy infrastructure is proposed, it should be coordinated with the site masterplan and built form from the outset. Necessary plant, pipe routes, connection points and provision for future connection should be integrated so that they do not undermine the quality of buildings, streets, landscape, green and blue infrastructure or public realm, having regard to Policy LWL6.

Policy GTC6: Renewable and Low Carbon Energy Comment

Status

Strategic

Priorities

Green to the Core

Strategic Objectives

1, 3, 11
  1. Development proposals for renewable and low carbon energy generation will be supported where:
    1. They will not result in unacceptable adverse impacts on landscape character including the High Weald National Landscape; trees, woodland and hedgerows; higher quality agricultural land[115]; or heritage assets;
    2. They will avoid unacceptable visual impact from the effect of glint and glare and shadow flicker on the landscape, on neighbouring uses and aircraft safety;
  2. Weight will be given to proposals for community-led renewable and low energy generation initiatives, including those proposed through Neighbourhood Planning.
  3. In addition, the following criteria will be used to assess specific generation types:
Solar
  1. Proposals for roof-mounted solar energy supply infrastructure will be supported, subject to other policies and Policy HER1 (Heritage Management) in particular.
  2. Stand-alone ground mounted installations will be supported, subject to other policies, on previously developed land.
  3. Proposals for ground-mounted installations on greenfield land will be considered in line with other Local Plan and national planning policies, particularly those relating to landscape impact and the effect on the best and most versatile agricultural land. Greenfield sites within, or affecting the setting of, the High Weald National Landscape are unlikely to be suitable locations for commercial scale[116] ground-mounted solar farms.

Energy Storage

  1. Proposals for energy storage will be supported subject to other policies, where it is co-located with an existing or proposed renewable energy development or can be shown to alleviate grid constraints and demonstrate fire and leak containment safety.
  1. Land at Pebsham Landfill Site, Freshfields, is suitable in principle for a stand-alone ground mounted solar installation for a temporary period[117], subject to other Plan policies.

Key evidence and/or guidance:

5.29Planning policy has a fundamental role to play in the implementation of successful and long-term sustainable energy solutions, and this can be delivered with the support of other agencies and stakeholders.

5.30Roof-top solar is strongly supported. Stand-alone ground mounted solar installation opportunities are limited within the district however the policy supports suitable schemes in appropriate locations. The High Weald National Landscape (HWNL) Unit has published a Position Statement on Solar Farms and the HWNL which should be referred to in considering relevant proposals.

5.31The opportunity for the development of wind turbines within the district, is extremely limited and is not appropriate in, or within the setting of, the High Weald National Landscape. The Local Plan Climate Change Study corroborated the findings of RDC’s Renewable Energy Background Paper (2016), with Catsfield and Crowhurst found to be the parishes with the most favourable spatial conditions for wind turbines, subject to further investigations regarding wind speed data. However, given the landscape sensitivities of these parishes (being either within or close to the HWNL) and the lack of any third-party promotion of land for wind turbines, this has not been explored further at this stage. Any planning application which does come forward would be assessed against this policy together with other local and national planning policies.

5.32Historic England has produced guidance ‘Adapting Historic Buildings for Energy and Carbon Efficiency’ Advice Note 18, providing advice to homeowners and local planning authorities on requirements for decarbonising and improving the energy efficiency of historic buildings.

Pebsham Landfill Site

5.33Pebsham landfill is a 34-hectare site that closed in 2014, owned by Hastings Borough Council but on a long lease to East Sussex County Council. The site benefits from a National Grid connection to export electricity generated via landfill gas. At the close of the landfill site, this was generating at full capacity, however gas volumes (and electricity generation) are now in decline, allowing potential capacity for additional energy input from solar power. The site is within a Strategic Gap and the Combe Valley Countryside Park, however it is uniquely placed in the district and indeed the county, in terms of it being a recently closed landfill site, currently unsuitable for other uses or public access, and offers an opportunity for temporary use as a solar farm to generate a significant amount of renewable energy.

5.34The site is largely elevated and exposed in relation to the surrounding land and topographically could be suitable to accommodate a solar farm. However, its proximity to sensitive receptors including the Combe Valley Countryside Park, local residents and businesses means that the design and layout would need careful consideration to ensure no adverse effects in terms of glint and glare from the solar panels. Other visual impacts from the panels, including in longer countryside views, are likely to be able to be mitigated through a careful layout, avoiding panels on the more elevated parts of the site, but a landscape and visual impact assessment would need to inform the detailed proposal. The site is also close to protected habitats including the Combe Haven SSSI, and consideration of likely impacts would be needed to inform the site layout and necessary BNG measures. Appropriate drainage measures would also be required, having regard to the sloping topography, nearby watercourses and sensitive habitats.

5.35It is understood that there is an approved restoration plan for the landfill site (secured by the Waste Planning Authority), including areas of woodland and scrub planting. The long-term plan for the site is to allow public access on paths that would link to rights of way in the wider countryside, leading to a viewpoint at the highest point of the landfill. It is understood, however, that the landfill site will not become safe for public access for many years. In any event, further information would be required at planning application stage to clarify how the proposal would impact on the agreed plans for restoration and future use.

[110] See, for example, National House Building Council: Chapter 1 - Fabric First - NHBC

[111] 2020 UK final greenhouse gas emissions statistics: one page summary (publishing.service.gov.uk)

[112] East Sussex, South Downs and Brighton & Hove Waste and Minerals Local Plan Revised Policies (October 2024)

[113] Water stressed areas – 2021 classification, published by Environment Agency and Department for Environment, Food and Rural Affairs (July 2021)

[114] Best practice guidance should be referred to, for example ‘Water Efficiency and Reuse in Housing: Design Guide for a Changing Climate’ (Good Homes Alliance, 2025).

[115] As defined in the NPPF, best and most versatile agricultural land: Land in grades 1, 2 and 3a of the Agricultural Land Classification (ALC). ALC is graded from 1-5 and based on yield, range and versatility of use, and need for input.

[116] The High Weald National Landscape Position Statement on Solar Farms and the HWNL (2025) suggests that small-scale freestanding ground-mounted solar arrays (i.e. up to 0.05ha (500sqm)/50kw) to serve individual buildings, such as schools, hotels, community buildings such as village halls, and agricultural properties etc., alongside domestic use, may be acceptable in the High Weald NL, as their lesser ground coverage is often more able to be accommodated into the small-scale landscape without industrialising its character or scenic natural beauty.

[117] It is understood that the expected lifespan of a solar farm is 25-40 years. The site is not suitable for permanent use, beyond this period, due to its inclusion as part of the Combe Valley Countryside Park.

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