Representation by CowfoldvRampion (CowfoldvRampion)
- Date submitted
- 29 October 2023
- Submitted by
- Members of the public/businesses
We have submitted evidence to demonstrate that the local community of Cowfold was not consulted about the proposed substation being located at Oakendene, Cowfold. Furthermore, the decision was made without sufficiently detailed studies, as evidenced by the contents of the PEIR and DCO submission. This significant decision should have been supported with proper research and an understanding of the implications. Instead, it appears to have been selected because there was no local objection, with retrofitting of evidence as to the decision-making process. There was no local opposition because the Cowfold community knew nothing about it. This has led, we believe, to a failure to properly assess the reasonable alternatives as they are obliged to do under EN-1 section 5.4, mitigation hierarchy ‘only when significant harm cannot be avoided should impacts be mitigated’. We would argue that they CAN be avoided by use of an alternative less damaging site. Nor have they fully appreciated the impacts on communities and the environment, to the point where the impacts outweigh the benefits. In NPS EN-3, section 3.8.20, the applicant must show that there are no reasonable alternatives, even in cases of imperative reasons of overriding public interest. With respect to the substation site, we will present evidence to show that there are better alternative sites, and as argued by the Protect Coastal Sussex Alliance, this is true for the project as a whole, not just the substation. Rampion consistently promised, but failed to deliver, detailed surveys or studies on engineering, the environment, a montage or appropriate traffic modelling, despite numerous requests from various organisations. Even now, when more data has been revealed since the DCO submission, there are too many inconsistencies between, and errors and omissions in the documents to allow proper assessment of them in the time available until the Relevant Representation deadline. This will inevitably allow less time for proper and thorough examination and for the determination of correct mitigation measures. Some of these issues are laid out in the Appendix below. We therefore ask you please to exercise your discretion to extend the pre-examination period as much as possible, or even to halt the process altogether, in the interests of allowing people adequate time to meaningfully assess the evidence presented, thus ensuring the best outcome for the project, communities and the environment. • They have failed to understand this location and its traffic movements and the impacts of this on congestion, the Cowfold AQMA and the local economy. It has also resulted in an 11th hour switch to make Kent Street, a tiny single-track lane, with a width restriction of 6’6”, bear a terrible burden of the goods vehicle traffic in an attempt to keep them out of the AQMA in Cowfold. Yet a significant amount of construction traffic will still need to go through the AQMA or affect it. • The Oakendene site is 1 mile east of Cowfold along the A272, a notoriously dangerous accident hot spot, and would be made worse by the increased traffic to the site. • There are 130 businesses in Cowfold which could be negatively affected by the additional traffic congestion, loss of business, delayed deliveries, and diversions using adjacent lanes /minor roads. From a wider perspective, over 18,500 road users would be severely inconvenienced by sitting in unnecessary queues as they approach the village of Cowfold every day. Sitting in traffic for 15 minutes is estimated to cost c. £20m pa in lost productivity, not to mention the additional fuel, and potential loss of trade for local businesses, for around six years. The standing traffic will exacerbate the existing air pollution problems in this AQMA village, further affecting the health and wellbeing of the local community. The necessary route through the village to access cable routes has not been considered with regards to pollution or congestion. This disastrous scenario could be avoided if the substation were located at Wineham Lane North or South site, next to Rampion 1. There are only around five businesses in the Wineham vicinity, and the traffic does not back up to Wineham Lane, making it unlikely to cause as much disruption to road users, as demonstrated during the construction of Rampion1. • Rampion 1 was supposed to take two years, but actually took six years to complete. They estimate the proposed construction will take 4 years so, by the Rampion 1 example, it might cause up to 12 years of disruption this time. • We strongly disagree with the Applicant’s assessment that there will be little or no significant impact on biodiversity in the Oakendene and northern cable route area and will address this concern in detail in the written representation. In addition, for some of the impacts, they have classed as moderate or not significant things they had given greater significance to in Rampion 1 The proposed development interrupts or compromises existing wildlife corridors here, and more widely affects planned biodiversity connectivity corridors such as the Weald to Wave. • The State of Nature report highlights the plight of the UK’s wildlife. It cannot be sensible to destroy what we will demonstrate in the written representation to be a highly sensitive, yet undesignated area of particular significance and importance, around the substation location, containing flood meadows, a high density of nightingale breeding sites, 8 of the 14 Important Hedgerows across the entire Proposed Development, reptile habitats and many red list species. In several instances this is the only place where some of these endangered species are to be found. • The fact that it is proposed on an area which floods, contains a huge range of biodiversity and acts as a massive carbon store, makes achieving biodiversity net gain challenging. Based on Rampion 1’s poor track record regarding re-planting, (as highlighted by SWT, SDNP and Bolney PC), numerous breaches of the DCO requirements, which caused pollution and contamination, and now regular flooding from Rampion 1 in an area which did not flood before (Bolney PC report), there is a real danger of long-term damage and polluting the watercourses which feed the River Adur. • It is an incomprehensible choice of location, given the damage that it will cause economically, environmentally and socially. • We will be submitting further evidence to show that the Applicant has seriously downplayed the impacts on this community, traffic, local businesses and unique habitats and red listed species. We will argue that the visual impacts are far more significant than stated by Rampion, and they have not listened to/taken into account key evidence from local residents. Nor have they properly considered the alternative locations for the substation. We also believe that so many aspects of the proposals have changed so significantly from those of the original consultation as to warrant a reopening of the consultation • We associate ourselves with the submissions made by PCS alliance, and would like the opportunity to participate in the pre-examination hearing and the issue specific hearings. We kindly request a site visit to Oakendene and an issue specific hearing at Cowfold Village Hall to look at the impacts of this choice of substation site on Cowfold, its residents, economy and environment Appendix: Document Omissions, errors and conflicting statements: PINS have highlighted, in advice notes to Rampion, a number of discrepancies and omissions in the DCO submission, which they felt needed to be resolved before beginning the registration process. In looking at just a few of the documents submitted by Rampion, and concentrating only on subjects directly related to Cowfold, we have found a number of other anomalies and inaccuracies which also need to be dealt with before proceeding to the Examination stage. We believe this lack of attention to detail is likely to be indicative of failings throughout the documents and as such they are not fit for purpose. • Light goods vehicles: The term LGV is referred to throughout the documents as Light Goods Vehicles and mention is made of private cars, minibuses and white vans. However, it would seem from table 4-4 from Doc Ref 7.6 that this may in fact indicate vehicles under 7.5T. The first item under HGVs refers to vehicles over 7.5T. Smaller trucks are not expressly listed at all and therefore the implication is that trucks UNDER 7.5T are to be considered LGVs. Indeed, this would be consistent with the official change in definition of LGV in 1992 to Large Goods Vehicle. This difference has huge implications for the residents of Kent Street and for those living in the vicinity of the haul road as a result of the proposals for LGVs to bypass the AQMA in Cowfold. An email from Chris Tomlinson on 11th October clarifies the definition of LGV, “The definition as set out in the Environmental Statement is applicable to all our assessments and tables; LGV refers to Light Goods Vehicles that are less than 3.5t. HGVs are goods vehicles heavier than 3.5t.”. However, as yet, no amendment to Table 4-4 has been made. • Circular routes in Section 3: In the Outline construction Management Plan (Outline CTMP), Table 6-2, figure 7.6.13c and figure 7.6.6c appear to contradict each other. In table 6-2 there is a clear intention to use Kent Street, via access from the north, and to continue through to the haul road and to Wineham lane. 7.6.13c shows a route from Wineham Lane to an isolated spot in the south part of Kent Street, not apparently connected to the cable route and no obvious through route down Kent Street is shown at all from the North. And 7.6.6c shows all kinds of movements to the west of Cowfold in and out of the AQMA • Duplication of Table 6-2: The second half of this table appears to be a duplication of the first 2 pages. It is not clear whether this is simply a duplication and needs to be removed, or whether in fact further, necessary, information has been omitted as a result of the duplication. In addition, not all access points seem to be accounted for. • Use of the term single track lane: There are references in the various DCO documents to ‘single track lanes such as Wineham Lane and Kent Street’. Whilst technically, it might be true to call Wineham Lane a single-track Lane as it has no white line down the centre, it is in fact of similar width to the A272, a major road, and does not require passing places for the traffic to pass in both directions. Kent Street however is truly a narrow single track lane, quite unsuitable for HGV use. It is misleading to equate the two • Hedges: Regarding the hedge map, (Outline CoCP, Doc ref 7.2 figure 7.2.1k) a large part of H520 is apparently to be retained or notched. Only section H520 b is to be removed. How can this be compatible with the need to create a bell mouth and visibility splay large enough to comply with the regulations for the 60mph A272? Indeed, conflictingly, Trees map 7, taken from the Arboricultural Impact Assessment (DR 6.4.22.16) clearly shows that large parts of it WILL in fact be removed. Also confusingly, the hedge numbering appears to be different between these two maps. • AQMA Cowfold: Consultation Report (DR 5.1.3) p240: “In addition, Chapter 23: Transport, Volume 2 of the ES (Document Reference: 6.2.23) presents the methodology and calculation of construction traffic, confirming that no traffic will be routed through the Cowfold AQMA” But: outline CoCP DR 7.2 C-158 and Commitments register (DR 7.22) both say that the area will be avoided ‘where possible’ and indeed the maps mentioned above appear to show extensive use of the roads through Cowfold • Poor quality maps: DR 5.1.1-maps on pp 296-326 meaningless symbols instead of words or letters • Smaller compounds: The smaller compounds, for example the one at Cratemans Farm on the haul road between the A281 and Kent Street, are not shown on any maps. This gives a misleading impression of the true impacts of the proposals. • Bellmouth at Oakendene (A63): Page A62 of the Outline Construction Traffic Management Plan (Doc Ref 7.6) shows the need for a new temporary construction bellmouth. Yet this access will be for both construction and operation it says. Is this just an error? Is there in fact an alternative proposal to access the site from Kent Street for operational purposes? Is the intention to reduce the bellmouth once construction is completed? How can we comment sensibly on something so potentially important visually when it is so unclear? A verbal statement about this from Vicky Portwain at a meeting on 4th October was to the effect that that the bellmouth was to be reduced after construction to reduce impact. Yet from the Design and Access statement (Doc Ref 5.8) 4.1.1 “A new access (A-63) is required for the onshore substation at Oakendene for both the construction and operation and maintenance phases. This is shown on the plan in Appendix A Oakendene onshore substation - Indicative Layout and Elevation. The access will be designed to provide access for Abnormal Indivisible Loads (AIL) and this function will be retained during the operation and maintenance phase in order to allow for any AILs required.” • Core working hours exceptions: The list of exceptions to the core working hours is far more extensive in the Outline CTMP ( Doc ref 7.6) than in 6.4.23.2 p39 , 6.2.23 or 7.2 and includes highways delays as an acceptable reason to extend the core working hours. This is not mentioned in the other documents, nor is the intention to allow an extra hour either side to allow workers to reach, and return from, the areas they are working in. This lack of clarity allows Rampion to adjust what is agreed to suit themselves unless it is addressed. Indeed, even the proposed core hours are unacceptable to residents. An email from Chris Tomlinson on 29th October indicates that they will make the necessary changes to any omissions and errors “prior to the Preliminary Meeting at the start of the DCO examination.” This is far from the wishes of the Planning Inspectorate to make all alterations before opening the registration and is far too late for people to make informed comments about the new documents.