Representation by Paul Lightburn
- Date submitted
- 30 October 2023
- Submitted by
- Members of the public/businesses
I refer to the “Draft Development Consent Order (DCO) EN010117” and the supplementary “Notice of Acceptance of a DCO” which refers specifically to Plot Number 32/13, related to the Rampion 2 Wind Farm and substation project. I object to the application on 3 counts. 1. Failure to consult properly. 2. Failure to fully evaluate other less damaging and less costly alternatives. 3. Failure to consider and evaluate fully the adverse environmental impacts Additionally, there are specific local reasons why this current application should be refused. 1. The supplementary “Notice of Acceptance of a DCO” includes the threat to acquire rights over which I have existing rights including unfettered right of access between my home and the highway. 2. The cable route plans fail to recognise my existing right of access along the lane to my home, which the plan states will be closed while construction work takes place. In support of my objection, I draw the following to the Planning Inspectorate’s attention. The supplementary “Notice of Acceptance of a DCO”, which was pinned to a gate post refers specifically to Plot Number 32/13, identifies what the applicant refers to as ‘land of which ownership is currently unknown.’ The applicant’s consultation process for this notice was non complaint. None of the resident of King’s/ Moatfield Lanes were consulted or informed about the “Plot Number 32/13 Notice” as required by the Planning Act 2008. The ownership status of this piece of roadway is disputable. There has been no direct contact with any of the landowners or owners of any third-party rights to discuss ownership or explain what is proposed and explain how the applicant intends to change our existing rights or how they might be affected by any, change to, or the creation of new rights. There can be no compelling operational reason why this very small piece of roadway adjacent to the highway needs to be compulsory acquired or for our pre-existing rights of access and easements for utilities to be changed. This creates a potential ‘ransom strip’, the purpose of which, in terms of access rights, is, as stated by Rampion, only required for post construction operational access. The applicant does not need to acquire ownership to secure rights of access over this strip at the entrance to King’s Lane. All legitimate users can enjoy full access and no other utility company has had any difficulties accessing their equipment on land adjoining King’s Lane and Moatfield Lane. Plan EN010117-000161-2.5 – “Rampion 2 Access, Rights of Way and Street Plans.pdf" sheet 32 categorises King’s Lane as a “bridleway and public footpath”. This is incorrect, it is a 24 hour/7 days a week access road, privately owned and subject to legacy access rights granted to all properties on the lane in their title deeds by the title deed holders of the roadway. The plan, referenced above, shows that King’s Lane will be closed in 2 places at Points 48a – 48b and 50a – 50b. The applicant has made no provision for a diversion or alternative means of access to allow householders, as is their right, to have continuous access to the public highway during construction works. On the wider issues, particularly environmental, the applicant’s failure to consider and mitigate fully the significant adverse environmental impacts, caused by the proposed routing of the on-shore cables and the location of the new, unnecessary substation, proposed for Oakendene near Cowfold. Other options with far fewer adverse environmental impacts appear not to have been fully considered and evaluated and given sufficient consideration during the design, development and optioneering phases. Expert organisations including Natural England have submitted evidence in support of the environmental damage that will result if this proposal is not refused Options, such extending the existing high voltage substation at Bolney, rather than building an unnecessary new substation on the edge of a village, were not fully evaluated. There should be no need to create another substation site when the existing nearby site at Bolney has capacity. This option could make use of the existing infrastructure site rather than creating another substation, which would require far less underground cabling across roads, fields, ancient woodland and hedge rows to the south and south east of Cowfold village. Nor has the congestion caused by additional traffic on the already heavily congested and polluted A272 and adjoining single track lanes during the construction and operation of the unnecessary additional substation, been fully evaluated and mitigated. Another option with far fewer adverse environmental impacts - following the existing Rampion 1 cable route, does not appear in any publicly available papers, suggesting it was not given thought at the design feasibility stage. My objection is made on principal and is independent of any opinions I may have of the wider Rampion 2 project. As such it falls within Article 8 of the Human Rights Act 1998 and European Convention of Human Rights and all provision in compulsory purchase law. The current proposal should be rejected and the developers asked to rethink their options and improve their consultation and stakeholder engagement process. I request the right that my representative or I have the right to speak at any hearing during the examination stages of the process.