Representation by Janine Creaye
- Date submitted
- 30 October 2023
- Submitted by
- Members of the public/businesses
I strongly object to the Rampion 2 Windfarm Proposals. The final choice of substation site as Oakendene, is the worst possible option put forward for loss of biodiversity and cannot be offset with ‘net gain’. This is currently an undisturbed section of the River Adur catchment area. It is a patchwork of small fields, flood meadows, dense lichen covered hedges, and mature oak trees. The damage will far outweigh the benefits of choosing this route, which is so unnecessary. The alternative substation site as an expansion to the existing Bolney substation would cause far less ecological damage as it does not involve this mosaic of unfarmed flood meadow round the Cowfold Stream and tributaries The justifications for choosing this option of substation site are inconsistent and no biodiversity data was released in advance of the DCO making it impossible for wildlife organisations and local people to assess evidence accurately. We saw surveys being undertaken just before the DCO submission so they could not possibly have been assessed against the alternatives. Most residents of Cowfold did not know that a substation was planned to be built at Oakendene until the last consultation October/November 2022. This was after the option had been chosen (July 2022). There has been no consultation that includes the choice of substation site. We have not been consulted when the impact on this area is so great. Local people including landowners have not been directly consulted on the biodiversity and people surveying have not been allowed to engage in dialogue with local people. Under threat and inadequately surveyed in the proposal are: 1) Nightingales Red List (22 territories recorded this year directly in the cable construction route) Total of 51 entries into the records. Other protected and declining bird species: skylarks, cuckoos, turtle doves, barn owls, tawny owls, house martins 2) Priority Habitat of Unimproved Lowland Meadows, particularly at Crateman’s Farm. A rare habitat for many insects, mammals and birds. This is not acknowledged in Rampion 2 documents submitted but we have strong evidence to endorse this designation. 3) Ecology of Kent Street and Moatfield/Kings Lanes covering a toad migration, field edge plants (including orchids, wood anemones), glow worm breeding locations, all in the cable construction route. The tributary used for the toad migration is dug up by the cable trench. 4) A Green Lane dating over 150 years with a double row tree boundary, and a well-worn animal track between. This is bisected by cable construction, disconnecting the established wildlife corridor, with the loss of many mature trees and leaving a massive tree gap. 5) Badger territory is extensive in the cable route approaching Oakendene. An active sett is exactly in the middle of the cable route 6) Adders, grass snakes and slow-worms. They are all Uk Priority species in decline and construction vibration and disturbance will destroy a particular well-established population 7) A lake with bats, flying insects, water voles, otters and water birds next to the substation (this is the only option put forward which is next to a large lake 8) Extended route incurred by this substation option loses many more mature oaks, scrub and dense hedgerow than the alternative. 9) Flooding patterns and water quality are essential to the rich ecology here, but would be seriously impacted by construction Surveys of priority red list bird species, have been inadequately undertaken. Rampion has stated that ‘Desk Study’ is considered sufficient for the cable route, yet in such privately owned undisturbed land little recording has already been done to show up in this way. Breeding birds whether nesting at ground level (sky larks) in very dense hedging (nightingales) or in trees are all taken together as ‘breeding birds’ and considered a timing issue only, so appropriate habitat mitigation for their nesting sites is not put forward. Rampion have written that they do not survey for reptiles in the cable route regardless of UK BAP status or threat of extinction (adders). A materials depot and cable construction surround an established breeding site at Cratemans. We have added 7 grass snake and 8 slow-worm sightings to the records this year. Rampion say they do not survey for amphibian migration in the cable route as they are not destroying ponds, but they are cutting through the tributary which is access to the breeding pond and used in migration. They say that minimal hedge loss will mitigate against disruption, which is incorrect as toads use roads and streams in the migration. Rampion will not engage in any conversation about preserving the Green Lane wildlife corridor, or options of minimising the tree loss. 22 trees are in the area marked for removal. Some are mature oaks. Light pollution in the cable route is not being considered in how it impacts glow worm breeding, toad migration, badger feeding, and nightingale breeding - as they are not surveyed. Winter construction and trenchless crossing compounds would all add to the impact, especially if security lighting is used over-night. The flood patterns here are well established. The construction will interfere with this and inevitably people’s properties and access routes will be affected by unexpected flood water, as they were in Rampion 1. Water courses were also polluted by fuel leakage in the construction process for Rampion 1. Rampion 2 has two trenchless crossing depots very close to the Cowfold Stream only in this substation option. The area is flooded through winter and randomly at other times of year including summer. Equipment is known to discharge fuel residue in the water and accidental leakage, as happened before, remains a possibility. This threatens to spread via flood water and as consequence would go on to pollute the River Adur. The psychological impact on local people is missed out in the proposals. The anticipation of noise, vibration, vehicle activity impeding access, where it is so quiet, and the industrialisation of such a rich biodiverse area has meant that the detrimental impact has already begun. Many people from Oakendene Industrial Estate, Cowfold and further across Sussex walk, ride and cycle in this area of the River Adur catchment. This is being greatly underplayed, when footpaths, bridlepaths and lane access will be compromised or shut over the years of construction. The Bolney North option had far less impact on this type of use. The very poor reinstatement of vegetation after rampion 1 is visible and well documented. As a consequence, we have no trust in any promise of reinstatement this time, nor the promise of biodiversity net gain. We have asked how things will be different this time, but have had no answer. As the UK has been found to be one of the ‘world’s most nature-depleted nations’ how can we accept this much loss of undisturbed habitat for the sake of a wind farm which only lasts 25 years, especially when there are much less damaging alternatives? I believe that the irreplaceable habitats and biodiversity of this area need far more serious attention than has been given so far. I will be submitting evidence in the following stage of this process.