Representation by East Beach Residents Association (EBRA) - Littlehampton (East Beach Residents Association (EBRA) - Littlehampton)
- Date submitted
- 28 October 2023
- Submitted by
- Members of the public/businesses
I have registered on behalf of the East Beach Residents Association. Members have a number of concerns over the Rampion 2 Project. ? It is considered the size of the proposed turbines, much larger than those in the Rampion 1 field, will ruin the seascape both from the seafronts and when viewed from the South Downs. It is a huge change that physically transforms the natural seascape and landscape long enjoyed by many residents and visitors for its historic and host of intrinsic values and well-being effects. ? The government suggests such large turbines should be at least 25 miles offshore, not close inshore as in this case and setting to avoid local harm. ? Building the Wind Farm will cause considerable environmental damage to the Sussex seabed which is only now slow recovering from years of bottom trawling. Kelp farms are beginning to re-establish themselves. All this progress will be put back years. ? There is risk of adverse impacts on migrating birds and the cross-channel migration of flying insets estimated to be 3 trillion annually (thus impacting pollination services and food productivity on both side of the channel). This issue is only coming to light in Geman studies. ? Members consider the economic case for this inshore wind farm is very poor. The present Rampion 1 field has an efficiency rating of some 37-38% on an average annual basis. This is not the windiest coast in our Isles and better regimes are further offshore. ? The cost of the Rampion installation in the region of £3 to 4 billion in current market conditions. Inefficient allocation of money puts upward pressure on electricity tariffs. ? Through our future electricity bills we will all have to pay for this new wind farm. It means we will be paying for a system that is only a little over 1/3 productive, whereas if this money was spent on a wind farm in the North Sea offer an efficiency rating of closer 55%-60% on an annual average or other low emission sources available by 2030 (when Rampion 2 would be commissioned) that offer better value for money. Why should consumers pay for a less efficient system? ? The East Beach Residents Association fully supports the views of Protect Coastal Sussex (PCS) and are happy that they represent our views in future discussions. In this regard we further propose that: Sustainable development may be considered a Principal Issue in the Rampion 2 Windfarm Examination in the context of being a relevant policy lens and organising framework for the Examination to better weigh whether: (1.) The adverse impacts of Rampion 2 outweigh the benefits, and (2.) Rampion 2 would undermine, rather than support the achievement of sustainable development of south coast inshore waters and affected coastal and inland communities. ? The sustainable development framework offers the Examination Authority (ExA) and Interested Parties (IPs) a tangible, less subjective way of understanding, discussing and arriving at judgements about the Application most important to people. ? That is in the context of considering the local impact reports offered by statutory consultees and comment by other Interested Parties in relevant and written representations. ? It enables looking at the balance across the 3-pillars of sustainable development (social, economic, and environment dimensions) from construction, through operation and decommissioning stages, thus considering how Rampion 2 impacts current and future residents and the visitor economy. Specific Policy Relevance Determining whether the adverse impacts outweigh the benefits is cited in Advisory Notes issued by the Planning Inspectorate as a principal role of the Examination Authority and for the Panel to take into account when recommending whether, or not, to consent an application. The overarching principle of sustainable development itself is legally embedded at all levels of UK policy and planning from regional and international conventions and agreements, through national policy statements, down to the neighbourhood plan and local community levels. The National Planning Policy Framework (2023, update) under Part 2 “Achieving Sustainable Development”, states: ? “The purpose of the planning system is to contribute to the achievement of sustainable development” (para 7) ? “So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development.” (paras, 10 and 11), not just any development. The NPPF (2023) also offers a workable definition where, “the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives); namely the social, economic and environmental objectives. Many representations submitted for the Rampion 2 Examination will undoubtedly address adverse impacts, cumulative impacts and issues that can be readily categorised under the three pillars. The National Policy Statements (Energy) (NPS, 2011 - in effect) and (NPS, 2023 - proposed) state that: “The NPS provide the primary basis for Planning Inspectorate (PINS) assessment of an application and its recommendation on whether the Secretary of State (or the delegated Minister) should grant or withhold development consent. (Extract from NPS EN-1, 2011) ? EN-1 (2011) Section 2.2.4 states…. It is important that, in doing this, the planning system ensures that development consent decisions take account of the views of affected communities and respect the principles of sustainable development. And under, “Delivering Government’s wider objectives” ? Section 2.2.27 states“ … The Government’s wider objectives for energy infrastructure include contributing to sustainable development and ensuring that our energy infrastructure is safe. Sustainable development is relevant not just in terms of addressing climate change, but because the way energy infrastructure is deployed affects the well-being of society and the economy…” Practical relevance for efficiency of the Rampion 2 Examination We ask that sustainable development framework and principle, in the context noted above, be considered a Principal Issue in the Rampion 2 Examination (i.e. to help discuss, hear argument and take evidence) to better inform judgements on whether: (1) the combined adverse impacts of Rampion 2 outweigh the benefits; and (2) Rampion 2 would undermine, rather than contribute to the achievement of sustainable development of the south coast inshore and affected coastal and inland communities. Further we ask those specific questions be the subject of topic-specific hearings, however best organised. A suitable venue would be the Millennium Chamber of the Littlehampton Town Hall if the permission of Littlehampton Town Council is requested and given.