Representation by Jeremy Smethurst
- Date submitted
- 29 October 2023
- Submitted by
- Members of the public/businesses
I strongly object to the Rampion 2 proposals for the Oakendene substation. As a resident affected by the project, I did not know anything about it until I received a Section 42 letter in October 2022. There was an almost complete lack of information in Cowfold and the location was referred to as Bolney or Wineham and never Oakendene until the decision had been made. I also feel that the alternative site at Wineham would be a hugely better choice of substation site based on my comments below. The cable route direct to Wineham would be more direct and therefore damage far less distance of beautiful Sussex countryside. General: • In the Consultation Report (doc ref 5.1) section 5.3.13, Rampion justify the lack of Section 42 letters to much of Cowfold in the first round of consultation by saying, everyone who should have been sent a Section 42 letter got at least one during the whole consultation. For Cowfold, this cannot be acceptable as key decisions were made in the first round ie choice of the substation site. Effectively therefore Cowfold Residents were neither consulted nor indeed even aware of the potential proposal for Oakendene. This resulted in Rampion’s failure to properly consider the impact of their choice of substation site (with the benefit of local knowledge) or to look properly at the alternative locations. • Size was included as one of the reasons for choosing Oakendene. Yet all three sites originally considered were all big enough by some margin. This was just a ‘nice to have’ rather than an acceptable reason for choice. They have also failed to give convincing reasons based on any engineering or other impacts for their choice of Substation location. • This proposal will have an enormous detrimental impact on local communities in terms of: their daily lives, both during and after the construction, the local economy and on the wildlife and landscapes we are meant to be trying to make more resilient to climate change. Therefore, at this location, I strongly believe that the adverse impacts outweigh the benefits. • The core working hours are far too long; 7am to 7pm - 5 days/week with 8am to 1pm on Saturday, plus an hour either side will give no respite from the traffic or the noise. • I believe they have played down the implications for the effects on human health and wellbeing, the effects on the daily lives of a large number of people, the visual effect on the landscape, and the destruction of precious, though undesignated, wildlife habitats between Oakendene and the A281. Ecology: I am seriously concerned about the lack of proper consideration given to the wildlife at Oakendene and the northern cable route, and that environmental issues at Cowfold have effectively been sidelined: • During the first consultation there was little data for this area available so wildlife charities could not comment much. In the second round, the focus was on the cable route, particularly the SDNP, so again insufficient attention was given to Oakendene. • WSCC and Horsham DC have complained about the lack of data sharing by Rampion prior to Acceptance, and now are concerned they have insufficient time to assess the information, as are the various wildlife trusts. This is made worse by the concurrent Gatwick Runway proposals and other concurrent planning issues in Sussex. • It would appear from the submitted documents that there are too many omissions, inaccuracies and caveats in the studies they have done, to allow proper assessment of the evidence. Too many say the land in question was ‘inaccessible or only partially accessible’ to allow proper comparisons of populations or species. • Much of the data for Oakendene and Cowfold appears to have been collected after the choice of substation site was made and therefore the decision cannot have taken this into account. • Why choose a site for the substation right next to a beautiful large lake, in an area with so many Important Hedgerows in such close proximity, and so many red list species and endangered habitats? Indeed, in the DCO documents, for several species, Oakendene is the only location where they have been found. This surely indicates the ancient and biodiverse nature of this landscape? • When Britain’s wildlife is in crisis, why choose a site which will destroy a dense area of nightingale breeding sites and meadowland? Why have they said only 7 veteran trees are to be found across the whole proposed development? My experience of this area is that there are a huge number of valuable trees in the northern cable route and the substation site alone which will be removed under Rampion’s proposals. • There is a high voltage cable running under the A272 and across the northern part of the Oakendene site. It is not clear if Rampion2 have confirmed with UKPN the exact location and that any proposals for roads, hardstanding, planting, bunding, excavation etc are acceptable to UKPN? The oil-based coolant for the cable has leaked in the past contaminating the stream and lake. Now there will be three such cables close to or crossing the water, increasing the risk. Traffic: • Traffic is a serious concern for not only those in the immediate vicinity, but for the whole village and anyone who uses the A272 regularly. This is in striking contrast to the situation at Wineham Lane, where nobody raised traffic on the A272 in the Rampion 1 relevant representations. Indeed, there were no Relevant Representations from Bolney village at all, just from Wineham Lane. Far fewer people were really impacted and hardly any to the extent that is occurring widely as a result of the traffic in this case. • There is much more congestion as one approaches Cowfold, this project is much larger than Rampion 1 and the movements of vehicles in and out of Kent Street, Oakendene and the western compound will be much more complex than just entering and leaving Wineham Lane, yet no holding area to control the traffic has been deemed necessary, whereas it was for Rampion 1. I do not believe Rampion have carried out appropriate studies on traffic flow and pollution. Nor have they considered the accident rates at this particular part of the A272 which are frequent. • Kent Street has a width restriction of 6’6” and is totally unsuitable for heavy traffic yet is being used to access the cable route and to avoid the AQMA in Cowfold. Throughout the autumn and winter the verges are wet and are destroyed. • On Fri 20 -Sun 22 Oct 2023 there was a good example of what happens when the road is either blocked or very slow moving, which is not at all unusual. Due to a blockage, eastbound traffic was using either Picts Lane or Kent Street at the crossroads just east of Oakendene. Huge trucks were also using these roads which are both totally unsuitable. As the verges were very wet due to recent bad weather vehicles became bogged in and unable to move if they pulled off the single track carriageways. I have attached some photographs of the chaos that was caused. • The true extent of the use of the AQMA in Cowfold by Rampion traffic is very vague and difficult to assess. Terms such as: ‘avoid where possible‘, are not helpful. It also appears that Light Goods Vehicles ‘may include vehicles up to 7.5T’: which is not very light. But it is clear that there will be a significant increase in volume of construction traffic through Cowfold both on the A281 and the A272 roads through the village. Battery storage farm: • A planning application has also been made to Horsham District Council for a battery storage farm next to the substation site at Oakendene. (HDC Planning Ref EIA/23/0006). It is not included in their assessment of cumulative effects. Although any involvement by Rampion has been denied by Vicki Portwain and Lucy Tebbutt, there MUST surely be collaboration between these projects as the location lies right over the top of the cable route and the application suggests that it will use the same trench to be connected: “The Site, excluding the underground cable route to the Point of Connection, comprises land totalling approximately three hectares (see Location Plan at Appendix 1) set within well-established hedgerow and tree planting. The Site will be connected via an underground cable route to the Point of Connection at Bolney National Grid Substation, located approximately 1km to the south-east of the Site.” Although alone, a battery storage farm application would normally be a matter for local planning, the cumulative impact must be considered and the plan should therefore be seen as part of the DCO application, and as it does NOT currently form part of it, the DCO application should be re-submitted. Flooding: The whole area of Oakendene (not just the Cowfold stream, and the lake) is regularly flooded in times of heavy rain; as can indeed be seen from the Flooding maps that Rampion provide. This makes it very difficult for any wheeled vehicles to go off hardstanding or roads. • There is a culvert running under the A272 which then drains into a ditch running north to south through the proposed substation site, if this is blocked by the development, which is likely as the main Rampion entrance to the site is very close to it, this will most likely cause further flooding to properties already at risk on the north side of the road. • The proposed site is very close to the Cowfold stream which is regularly flooded in periods of heavy rain. If most of the site is to be hardstanding, the ability of the ground to absorb any excess water will be significantly reduced, which is likely to affect the water levels downstream and the River Adur. Until the submission of the DCO, Rampion has denied that there is any problem with flooding at Oakendene. However their proposed site plan now includes flood protection measures on three sides. This will also surely affect the flow of water into Cowfold Stream, (a tributary of the River Adur), and may affect the existing underground cable. • As a consequence of the flooding, it is important to understand the effective ‘Ground Level’ for the substation site. If this were to be raised from the existing level, it would have substantial effect on the visual impact. Indeed, from the ‘consultation’ Information Event in Cowfold, I was told that the ground level for the construction could even be lowered to reduce the visual impact. This is now clearly nonsense. • There is no mention of flooding problems at the potential alternative site at Wineham.