Representation by Meera Smethurst
- Date submitted
- 29 October 2023
- Submitted by
- Members of the public/businesses
I object most strongly to the proposals. I do not believe the adverse impacts of Rampion 2 are outweighed by the benefits. Although living in the immediate vicinity of the proposed Oakendene substation site, and potentially directly affected by it, I had no information about it until receiving a recorded delivery Section 42 letter and maps in October 22. The same was true for many others in the immediate vicinity and the RH13 8AZ postcode also, if they received anything at all. You may argue that people don’t remember receiving leaflets and put them in the bin unread, but it is difficult to ignore a large package sent by recorded delivery: we did not get them. There was widespread ignorance of the proposals in Cowfold as a whole until after the whole consultation ended. The lack of consultation with this parish has led to Rampion choosing the substation site based on the ‘path of least resistance’ instead of genuinely seeking to find the most suitable and least damaging and disruptive site, or to reasonably assess and compare the alternative locations. As a result, I believe, it has actually chosen the substation site which is the most damaging to the very environment and ecology we are trying to protect by our switch to green energy. There have been many instances where they have downplayed the impact of the proposals, for instance on • the wildlife at Oakendene and the northern cable route, • the traffic on the A272, • the side roads • the AQMA in Cowfold. • The local economy All of these are major concerns for residents, in the immediate vicinity and also in the wider village community. The unnecessary, unmitigable destruction of veteran trees and additional hedges, many classed as Important, by the choice of this site, the destruction of nightingale and reptile breeding grounds between the A281 and Oakendene and the disruption of wildlife corridors in the area should be worrying to all. The potentially severe negative economic impact of delays on the A272 will damage or destroy the Oakendene industrial estate, a major local source of employment and may also affect the economy of the wider county • the visual impact of the substation, both from the A272 but also the AONB just a few hundred yards away have been significantly downplayed. Rampion’s photomontage of this has been misleading, being taken from the east, not directly from the north, nor taking into account the number of mature trees and hedgerows which will need to be removed to create the access road. The AONB viewpoint assessments also downplay the true impacts. • The poor reinstatement record of Rampion 1 is also very concerning. • Road safety: At a personal level, and speaking also for others along the A272 nearby, we are very worried about safety and access to our homes during the years of construction work. The A272 is extremely dangerous from the industrial estate to the east of Kent Street with poor visibility from and to side roads, and a dip in the road which no amount of visibility splay will help to improve. There will be complex movements of HGVs in and out of the two Oakendene sites and Kent Street, adding to the dangers. I do not believe that Rampion have properly understood the way traffic flows at this point and have identified ‘no need for a detailed junction assessment’(Doc ref 6.2.23). The access to Wineham Lane is not affected in the same way where it comes off the A272 being farther away from the mini roundabouts. Nobody raised traffic on the A272 as an issue in the Rampion 1 Relevant Representations. Indeed, they highlighted the fact that Wineham Lane had been built to take the Substation construction traffic. • The core working hours are far too long, and then there is an additional one hour either side to allow return of HGVs, and the potential to extent the hours due to ‘highway delays’. • Kent Street: Rampion seem to have discounted the Wineham Lane route and site, partly on the grounds of Wineham Lane being a single-track road, but seem happy to use the most unsuitable, considerably smaller Kent Street for both construction and operational access and have not properly understood the impact of standing traffic or the effect on the AQMA. This is despite highlighting Kent Street in the early parts of the consultation as ‘unsuitable for HGVs’. This is a much larger project than Rampion 1, yet no holding bay to manage the flow of HGVs has been considered, even though it was considered necessary for Rampion 1. There is a high voltage cable supplying much of the Horsham area which runs under the site. What will happen if UKPN need urgent access? Has UKPN been consulted about the construction of the proposed access road? • Alternatives: I do not believe Rampion have adequately considered the alternative substation sites, as they are obliged to do, because it is now clear from the DCO documents that much of the environmental assessment supposedly taken into account in the decision-making process, was only done after the decision was made. They have also played down the impact on Oakendene Manor, businesses in Cowfold, and the public rights of way and ecology. Indeed, they do not seem to have recognised until after submission that a PRoW actually runs right through the substation site. There will be a brutal impact on the Grade 2 listed Oakendene Manor and ecology (both effects far worse than at the Wineham Lane sites), and on the landscape and public rights of way • Property depreciation: Many of the owners of property in the immediate vicinity of the substation at Oakendene are elderly and realistically most of the homes will need to be put on the market before completion of the project. This will have a severe impact on their value. It will also have health and social care impacts should it prevent them from moving to residential care in the latter part of their lives. Many people in the village of Cowfold are also worried about the value of their homes as the traffic issues will adversely affect this. • Not enough time to allow adequate assessment: It is clear that there is a lack of attention to detail in the DCO submission documents, where there are many examples of inaccuracies and omissions, even looking only at the information related to the onshore substation area. I have highlighted a number of them to WSCC and Horsham DC, such as the lack of clarity about exactly where vehicles will travel on Kent Street, definition of LGVs and the extent of traffic through Cowfold. What at first sight appears to be a smart presentation, actually contains many instances of very poor-quality data. The evidence presented clearly cannot be taken at face value and requires careful scrutiny. Add to this Rampion‘s determination not to share EIA information, beyond what was available in the PEIR reports, before submission. WSCC and Horsham DC have already expressed their frustration about this. And on 3rd October I received the following from SWT:” We are currently working our way through the documentation presented for the entirety of the 38.8km onshore cable route, plus the proposed new onshore substation and all marine elements. Given the sheer scope of the proposal, and the team’s involvement in the concurrent Gatwick DCO process, it will not be possible for us to make detailed comment on every aspect of Rampion 2 within the required timescale.” And from Sussex Ornithological Society:” I am afraid that, following the sad passing earlier this year of our Conservation Officer, Richard Cowser, the society has had to somewhat reduce its engagement in planning work as he has proved to be irreplaceable. Our Officers have decided that we will not be able to engage directly in the Rampion DCO process by registering as an interested party ourselves. However, we will be supporting Sussex Wildlife Trust in their work on the project, and we are more than happy to help groups such as yourselves in any way we can.” In addition, the NPS is currently under revision and we find ourselves preparing our relevant representations referring to the old NPS, yet it may be examined under the new one, or the Secretary of State can override it under the new one. This can only lead to confusion and the potential arguments for legal challenge at a later date. Under the Planning Act 2008, section 108 allows for suspension in these circumstances. I therefore urge you 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. I would also like to suggest that, given the lack of engagement so far with this community, and that it will be the only place where lasting infrastructure remains above ground onshore, that at least one examination meeting is held in Cowfold please, to discuss the consequences of the substation location and its impact on the community and local environment.