Representation by Edward Stratton Woodward (Edward Stratton Woodward)
- Date submitted
- 29 October 2023
- Submitted by
- Members of the public/businesses
I object to the proposed Rampion 2 development. Concerns I wish to register are that many people in my community who are actually aware of what is proposed in the Application documents disagree with the explicit and implied benefit-risk tradeoffs and assertions. These concerns relate to provisions in National Policy Statements. Significant claims about performance, benefits and adverse impacts that lack evidence and credibility made during pre-application consultations have been carried forward to the Application. Thus due diligence to help identify substantive claims which lack credibility is both important and materially relevant in the Rampion 2 Examination to better inform the Panel recommendations. That is very much in the public interest. Unfortunately, there is a systematic pattern of understating the adverse impacts while exaggerating the benefits of this proposed Rampion 2 development. ? There certainly was no scrutiny of the claims about the performance and benefits by competent authorities during pre-Application consultations, unless behind the scenes. ? Claims were made in formal public consultations, in media articles and in the Applicant’s briefings to councils at all levels with no fear of them being tested, of accountability or consequences. ? We accept this is not unusual. That same pattern of developer overstatement-understatement is clearly revealed in the Examination Panel recommendations and Secretary of State Decision Letters on the two other south coast windfarm proposals, namely: the far smaller Rampion 1 scheme consented in 2014, and the Navitus Bay WindPark scheme on the other side of the Isle of Wight refused consent in 2015. The Navitus Bay proposal was much closer in scale and adverse impacts to this Rampion 2 proposal. ? Among the concerns about overstating benefits while understating adverse impacts, unchallenged – is the chilling effect on residents and institutions in regard to their appetite to engage and their important role in the DCO process, as envisaged in legislation and Planning Inspectorate Advice Notes. ? That chilling effect served not only to limit informed consultation feedback in the developer-led front-end of the process that was already compromised by the fact that statutory consultations (on the offshore component) were conducted entirely in a restrictive virtual-only mode; but it also served to effectively deter many in our communities from registering as an Interested Party. ? In conversation locally, for many people it was either a case of too much information to take in and process, or it prompted thinking that to simplify matters - if Rampion 2 reduces our electricity bills as the developer states, plus if is so beneficial to the environment and does no harm otherwise, as we are told – then why object or even bother to engage in this process. ? Hence it is argued that explicit due diligence on the significant claims that lack proper evidence and credibility is important and NPS policy relevant. To illustrate: ? Due diligence would include consideration of evidence on clams such as Rampion 1 and 2 combined would provide all the power needs of Sussex across all sectors of the economy (industry, commerce, schools, hospitals, homes, public services, etc) as the Applicant stated in the pre-Application consultations. ? That claim specifically was made in Applicant briefings (mostly remote and virtual) to statutory consultees and the developer-led community Project Liaison Groups, whose members represented and reported back to Parish and Town, as well as in website information, and articles in local media – all uncontested. ? That benefit claim suddenly changed in the Applicant’s Press Release when Rampion 2 was accepted for Examination to say Rampion 1 and 2 combined would provide, “enough to power all households in Sussex – twice over”. The earlier claim (all sectors) abandoned after having served to shape public attitudes to deter objections via the chilling effect – as it may be reasonably argued. ? Moreover, the claim remains wholly misleading without acknowledging the intermittency and variability of power output from the proposed development, which is case and setting specific. There is no mention that the actual power output from Rampion 2, or from Rampion 1 and 2 combined would vary from little to no output for days at time and for long periods. ? And that such the benefits are weather dependent and vary considerably day-to-day, season-to-season and year-to-year. Nor was there any indication of what that implies across all the benefit metrics that are cited in the NPS as relevant. ? Rampion 1 has a life capacity factor or load factor around 37-38%, as would Rampion 2 (or slightly more being far taller and larger but still in the same lower density wind regime in the Sussex Bay inshore) – thus it is well below the average for annual generation of wind turbines installed properly offshore in beneficial UK wind regimes which also respect strategic environmental advice on distances they need to be from designated landscapes to avoid local harm. ? Those factors all need to be taken into account to apply the important and relevant Examination calculations on whether the adverse impacts of Rampion 2 outweigh the benefits, as required in all case-specific DCO Examinations (for example, to respect NPS (2011) EN-1 Overarching, Section 1.1.2; as well as NPS (2023, proposed) EN-1, Section 1.1.4.). In the Rampion 2 Examination it is suggested: ? Due diligence warrants a place in a topic-specific hearing schedule within the Examination to help understand, discuss and judge benefit-risk tradeoffs, including making the important policy-relevant calculation on whether “adverse impacts outweigh benefits”. ? Certainly the statutory Local Impact Reports (LIRs) and Interested Party representations will help inform the adverse impact side of that calculation. There needs to be a similar effort (necessary and sufficient) to at least breakdown and calibrate the benefits. ? Given the synergy (and examination efficiency) in looking at the benefit-side of the essential policy calculations it is suggested that a due diligence hearing on benefit clams be held in conjunction with the Examination Panel inviting and taking evidence on the consideration of Reasonable Alternatives. ? The latter (the consideration of Alternatives) is policy requirement for the Rampion 2 Examination in respect to NPS (2011) EN-1 provisions in Section 4.4 (Alternatives), in conjunction with NPS (2011) EN-1, Section 5.9.10 stipulations on developments proposed within nationally designated landscapes such as Rampion 2 is within and impacting the South Downs National Park. A detailed Written Representation on the Due Diligence issues prepared in association with PCS and affiliated independent community organisations who are applying to register separately as Interested Parties will be shared with the ExA and other IPs during the Examination. This approach respects the Government’s Examination Guidance (MHCLD, 2015) that encourages groups with similar interests to work together to help make a more efficient Examination. At this stage, I very much hope the Examination Panel can give these considerations substantial weight as Principal Issues in the Examination.