Representation by Luke Michael Davies
- Date submitted
- 30 October 2023
- Submitted by
- Members of the public/businesses
I object vehemently to the proposed substation at Oakendene/Kent Steet in Cowfold. The information submitted by Rampion, ignores and omits significant information/data which gives an inaccurate and misleading conclusion. The impact is significant for both the local community of Cowfold, and also for those communities living downstream along the River Arun. Last week, there was an open meeting with our MP Andrew Griffiths, organised by the editor of Sussex World. There was a great deal of public frustration and anger at the way our local waterways are being polluted. This is a topic which the local press will continue to examine. We are writing to you to express our deep concern regarding the proposed substation site at Oakendene/Kent Str, along the A272, for the following main reasons: 1 The flood risk, of surface water flooding affecting houses nearby. This factor doesn’t appear to have been addressed by Rampion 2 The flood risk for the communities downstream due to building on a flood plain 3 The potential pollution of the River Adur through diesel spillages, as experienced during Rampion 1 4 The potential pollution of the surrounding watercourses, via the Cowfold stream which feeds the River Adur, due to all the weedkiller that will be frequently used on-site. 5 We understand that all underground cables have an oil sleeve to cool them, and that they leak not infrequently. We understand that a boom was needed in the past, in order to clear a leak from Oakendene lake. If permission is granted at Oakendene, there will be three underground cables, which could potentially leak into the surrounding water course and contaminate the River Adur. 6. Significant information has been omitted from Rampion’s reports, including the Environmental Agency flood maps and risks of surface water flooding of local houses. 7. P151. A Water neutrality commitment 26.7.10 has been requested by HDC & WSCC. However, Rampion has a very poor track record for keeping promises or commitments. Please refer to the poor experiences during Rampion 1. as listed in the Bolney PC scoping response 2020: breaching weekend and evening non- work commitments, poor replanting, extensive damage to land, diesel spillage, poor communication with neighbours resulting in traffic congestion and extended road closures, generators running 24/7, construction period was supposed to take 18 months and took over 6yrs, problems with tunnelling and laying cables, resulting in numerous broken promises to local residents, 8. When the National Grid built their substation at Wineham Lane, they apparently had to raise the ground by 15 feet to avoid flooding. Please can you investigate the ground level for this proposed 12m high structure and how they intend to prevent the flood plane from flooding. Where will all the displaced water go? 9 How will Rampion’s proposals affect communities downstream? Either they will be flooded or there may not be sufficient water. Which option is more likely? And who will be responsible if they have miscalculated? 10 According to C-75 “Construction and permanent developments in flood planes will be avoided where ever possible”.It is avoidable in this instance, as the substation could be located in Wineham Lane, near Rampion 1. 11 According to C-117 on p124 “Works on areas identified as floodplain, will be programmed to avoid the period between October and February inclusive”. How would this be possible at Oakendene without extending the build for another few years? 12 26.10.7. "The drainage from the impermeable onshore substation footprint and the presence of a below ground grid have the potential to disrupt infiltration and displace shallow groundwater”. Have these factors been examined and addressed in detail? 13 2.2.15 Discharge via infiltration to the ground. " No soil testing has been undertaken at the onshore substation site.” Surely this should have been one of the first things to have been done, considering the land has been untouched for four decades. 14 According to Cranfield University 2023, Soilscape "soil mapping, indicates that the onshore substation site is underlain by slowly permeable seasonally wet soils with impeded drainage”. This type of soil and flood plain is not recommended for the location of substations. 15 2.2.16 "Given the presence of clay and the poorly drained soils, discharge of surface water to the ground is not considered feasible. “ 16 The pollution hazards indices for the substation are not provided in table 26.2 of the CIRIA SuDS manual. This important factor cannot be ignored, due to what happened at Rampion 1. Who is going to obtain this data and analyse the results? There were certain points raised in Rampion’s documents, which should have precluded the Oakendene flood plain as an option, with extracts below: 1 The Oakendene site is acknowledged as a “ floodplain on p31, with the eastern branch subject to long periods of inundation during the winter months.” 2 5.3.13 "The proposed Oakendene site is intersected by several surface water flow paths as indicated in the ROFSW flood extents, with approx 0.8 of the onshore substation footprint area at high risk of surface water flooding”. It goes on to state that the southern boundary would be prone to flooding. There are also a series of wells mapped in this area, along with Kent Street which is situated 50m & 260m from the DCO order limits. 3 According to the Environment Agency’s Catchment Flood Management Plan for the River Adur (Environmental Agency 2009a)3.5.6, the strategy for the upper Adur(including both eastern and western branches), was to investigate removal of Environmental Agency owned and maintained defence structures, with the aim of providing additional storage of water on the floodplain to reduce risk to downstream areas by restoring rivers and floodplains to a naturally functioning state.” The development of the Oakendene floodplain will be in direct contrast to this plan and ultimately lead to avoidable flooding and pollution of the River Adur, via the 7km Cowfold Stream. 4 According to 5.3.5 "The mapping (Figure 26.2.5a-e, Annex B indicates regions at high risk in the northeast portion of the proposed DCO Order Limits, where the underlying geology is dominated by the Weald Clay (from chainage 24km onwards, as discussed in Section 3.6). The majority of surface water flood risk intersecting the proposed DCO Order Limits is associated with crossings of minor watercourses and tributaries of the River Adur and Cowfold Stream. Away from these watercourses, the risk is generally low.” Our question is, why locate the massive 6ha substation on this floodplain, when a more suitable site is available, next to Rampion 1, along Wineham Lane? 5 According to 5.3.15 the development "could lead to an increase in peak runoff rates and volumes and a consequent increase in flood risk for downstream receptors”. 6 2.1.4- According to British Geological Survey mapping , the soil underlaying this site is Wealden Clay. The entire onshore substation site has been considered entirely impermeable. Any surface water run off will go into the surrounding watercourses. The Cowfold stream is nearly 7km long and feeds into the River Adur. 7 2.1.5. The Environmental Agency has a data base of Risk of Flooding from Surface water and neighbouring properties are on that list. This information has not been included in Rampion’s report. In document 004866049-01, which examines flood maps and surface water flooding, there is a big chapter on surface water flood risk from p103. Oakendene/Kent St are NOT included in this analysis, even though this area floods and is on the Environmental Agencies Register. 8 2.2.15 According to Soilscapes soil mapping (Cranfield university 2023)” the onshore substation site is underlain by slowly permeable seasonally wet soils with impeded drainage” 9 2.2.16 Given the presence of clay and the poorly drained soils, discharge of surface water to the ground is not considered feasible. 10 SuDS treatment 2.4.14. it is anticipated that pollution control measures would serve to limit pollution potential of the onshore substation site, but some degree of pollutants would likely still be captured by surface water run-off and require capture and or treatment before discharge. How exactly is this to be done? and who will be monitoring it? 11 The changes of land use from flood plane to substation base have not been examined, but should have been included in p106, alongside other areas. Other areas of concern, relating to the inadequate documentation/misleading information provided by Rampion: 1 This document, 6.2.26, was supposed to examine the flooding aspect of this site, but has not included maps showing surface water flooding for Oakendene/Kent St. These fields are floodplains and flooding has caused damage to nearby houses, which are already on the Environmental Register for surface water flooding. These points have not been covered or examined in this report. 2 There has been no analysis of the displacement of surface water associated with piling construction techniques. 3 The weed killers which will be used regularly for the substation site will permeate into the water courses and go into the River Adur. There has been no mention of this in this report. 4 The impact on the Cowfold stream has been downplayed and the River Adur not mentioned in conjunction with it. However, the Cowfold stream is on the Oakendene site and is 7km long and feeds the River Adur. The consequences for the River Adur, of building the substation have not been examined at all. The site could either flood and flood the Adur, or planting trees around the existing site could use up the water, which may cause water shortages down river affecting the ecology and existing habitat. The consequences are unknown and have not been examined in detail. 5 Pollution is mentioned in passing 2.4.14, but final decisions will only be made at the DCO stage, by which time it will be too late to change this course of action, and the negative consequences could affect a number of villages down stream. 6 Water neutrality has been promised, however Rampion 1 also made promises about re-planting, and pollution control, but they have largely failed to materialise. Rampion have done little to address this ongoing failing/breach. 7 During the construction of Rampian 1, there was also supposed to be minimal pollution, however there was a diesel spillage, which Rampion ignored, until local residents contacted the Environmental Agency. Such a spillage would be even more damaging at Oakendene/Kent Street given all the water courses, wells and the Cowfold stream. 8 2.2.15 Discharge via infiltration to the ground. No soil testing has been undertaken at the onshore substation site. The British Geological Survey mapping (BSG2023), indicates that the substation is underlain by Wealden Clay. According to Cranfield University 2023, Soilscape "soil mapping, indicates that the onshore substion site is underlain by slowly permeable seasonally wet soils with impeded drainage” Please could you examine these areas of concerns. By way of an alternative, Rampion’s documentation concludes that there are no flood plains or water courses at the alternative Wineham Lane sites.