Representation by Terence Ellis
- Date submitted
- 24 October 2023
- Submitted by
- Members of the public/businesses
The Rampion 2 Application (for a wind farm in the sea off West Sussex) ignores the UK Government’s strategic environmental advice to provide visual buffers for very large turbines. That is a primary mitigation and safeguard against unacceptable adverse seascape and visual effects for huge towers and turbines and controversy dividing local communities. We believe the Rampion 2 Examination Authority (ExA) should consider full respect for the advice in the rolling Offshore Energy Strategic Environment Assessment (OESEA) programme to be a Principal Issue for this Examination. Moreover, this issue is fundamental to the Application. We suggest it should be addressed in the Questions the ExA asks Interested Parties and the subject of a topic-specific hearing. • Rampion 2 will have a transformative effect on coastal communities due to its sheer scale and inshore location, unlike any other offshore wind scheme in the UK. This Application proposes up to 90 large turbines up to 325m tall and wide in profile in arrays, starting only 8 statute miles from shore, and very visible from the shoreline and well into the area of the South Downs National Park. • The giant turbines and blades will spread across a populous Sussex coast where most residents and visitors (though not all, we are told by interested parties) value the natural seascape, our heritage and all the intrinsic values and benefits natural seascapes provide for human health and well-being. • Rampion 2 will have a considerable impact on both local residents and the visitor economy – the very rationale for OESEA advice and safeguards. It certainly risks bitterly dividing communities, not inspiring them. And it will significantly impact the ecologically sensitive coastal waters in many ways. • On the Rampion 2 Application itself, many area residents do not agree with the assumptions, hypothesis and conclusions that were first provided in the PEIR, and are now carried forward to the ES Application documents. • That includes the use of highly selective out-of-date studies on attitudes to windfarms, instead of undertaking actual resident and visitor surveys of the scheme applied for (using before and after images); compounded by offering comparisons with two existing windfarms of a completely different scale and nature to claim that they verify a desk study hypothesis that Rampion 2, like all offshore windfarms in their desk study, has no impacts (negligible) on residents and visitors alike. • This issue of applying OESEA advice to Rampion 2 was raised by local residents in the Community-led and organised public meeting of 24 August 2021 in the Littlehampton Millennium Chamber, which was full to capacity, including local Councillors. The developer’s representatives only agreed to attend the day before the meeting (and then only virtually on a screen). • In that meeting the developer’s representatives were totally dismissive of the OESEA Strategic Advice, as documented in the comprehensive Meeting Report submitted as a formal response to the developer’s statutory consultations. • There was no mention of the OESEA strategic advice in the PEIR at that time, none that we could see. • Now checking the ES Volumes of the Application, it appears OESEA advice barely receives mention. Only as a passing reference in a list of “other relevant guidance and advice” in the ES Volume 2, Chapter 2 Policy and Legislation Context (under other relevant policy); and then gets a mention in boxes (in ES Volume 2, Chapter 15: Seascape, landscape, and visual impact assessment) and even that only to refute the serious concerns about landscape and seascape change and impacts raised directly by the Southdown National Park Authority (SDNPA). • The SDNPA reflects the views and conclusions of many residents who are actually aware of what is being proposed. Policy Relevance • Careful consideration of the OESEA advice in the Rampion 2 Examination is wholly consistent with NPS (2011) EN-3 Part 2: Assessment and technology specific information (offshore wind), as in: Para 2.6.15 “Through the Offshore Energy Strategic Environmental Assessment 2009 (SEA) process ….. the Government concluded that there are no overriding environmental considerations to prevent the achievement of the plan/programme for offshore wind, if mitigation measures are implemented to prevent, reduce and offset significant adverse effects…..” Where it is argued the OESEA visual buffer advice is put there to reduce and offset significant adverse effects (including social, socio-economic and ecological effects). Para 2.6.16 “In addition to new offshore projects, the Government has decided that, in line with Recommendation 6 of the Post Consultation Report (PCR), there is potential for capacity extensions to existing wind farm leases within UK waters. However, this will require careful, site-specific evaluation through the planning process, since significant new information on sensitivities and uses of these areas has become available”. In the Rampion 2 case, this site-specific evaluation with the OESEA is essential both due to its setting; and also to take into account the bid criteria for offshore wind extensions in 2017 was that extensions could be no larger than the existing project (what emerged is a Rampion 2 “extension” scheme of 1,200 MW where the existing Rampion installation is 400 MW). And Para 2.6.17 “Applicants should set out how they have drawn on the Government’s Offshore Energy SEA in making their site selection”. • The OESEA is also relevant in the NPS (2023, proposed) EN-3 under “Factors influencing site selection and design” (Section 3.8.25). We thus believe full respect for the Government’s own strategic environmental advice is a fundamental concern in the Rampion 2 case. That should be a Principal Issue in the Examination as well as the subject of a topic-specific Hearing. The clear indication is the Application regards the OESEA advice as irrelevant. We otherwise hope the Examination Panel gives substantial weight to the importance of upholding the OESEA Advice that offers a “last” essential environmental safeguard for coastal communities, which all offshore windfarm industry actors, foreign or domestic, must fully respect. This is particularly important and urgent given the Government’s stated ambition is to fast-track offshore wind Applications - mainly by limiting local voice from affected coastal communities. Terence Ellis and Deborah Hallford