Representation by Worthing British Sub Aqua Club 1323 (Worthing British Sub Aqua Club 1323)
- Date submitted
- 31 October 2023
- Submitted by
- Members of the public/businesses
This response represents the views of members of Worthing BSAC dive club #1323, also members of Guildford BSAC who regularly dive this area. This is our contribution of feedback to the proposals submitted regarding the Rampion 2 development. I have previously been involved with the Sea Users’ PLG for Rampion 1, and our club members have already experienced the disruption caused to our prime diving sites during the construction phase. I refer to the Preliminary Environmental Information Report (PEIR), “As noted in the baseline section (Section 7.6), the majority of dive sites used in the area fall outside the boundaries of the Proposed Development (see Figure 7.8, Volume 3) and therefore actual dive activities (at wreck or feature locations) are unlikely to be impacted. As can be seen in Figure 7.8, Volume 3, the areas either side of the export cable are popular diving areas however within the PEIR Assessment Boundary of Rampion 2 itself there is little diving activity.” This is patently incorrect regarding prime dive sites considered in your consultation. Please note that the SeaSearch data (Figure 7.8, Volume 3) refers to information regarding marine life of interest to the diving community. As such, although this represents excellent data, such as potential effects on the Black Bream nesting sites and the wider MCZs, it does not consider the many wreck sites that are also of particular interest to our dive club and are considered prime dive sites by the wider diving community nationally. From PEIR volume 4 Chapter 17 – ‘5.2.1 Seventy-five wrecks identified in the data provided by UKHO and NRHE are located within the marine archaeology study area. Of the 75 wrecks, 49 are classed as LIVE. In addition, there are 31 foul and seabed obstructions and 85 recorded losses.’ Having examined the proposed boundary, together with details of the 42+ wrecks identified by the PEIR within the designated area that we regularly dive, there are three main areas of concern that will significantly affect our members of the local and national diving community, all during the construction phase, as follows: 1. The necessary exclusion zone during construction, during which the majority of the prime wreck diving sites will be unavailable. 2. Suspended Sediment Concentration (SSC) and the unavoidable impact on dive sites, not only during, but also after construction, and also potential effects on nearby wreck sites outside the exclusion zone. 3. Underwater noise propagation during construction and its potential impact on divers, even for some considerable distance outside the exclusion zone – as was experienced during the Rampion 1 construction phase. It is point 1 above that is of prime concern, as the exclusion zone effectively removes the majority of wreck dive sites of interest to our members, even if designated of “low archaeological significance”. We most certainly do not agree with your conclusions from PEIR. “Considering these findings, together with the notifications for planned works that will be issued (C-46, C-85, Table 7-12) and the implementation of the VMP (C-51, Table 7-12), it is considered that any risks of collision or disruption to dive vessels and activities will be minimised.” “7.9.16 Overall, the impact is considered to be short to medium-term (throughout the construction phase), of local extent, intermittent and reversible and there will be no impact arising on the long-term viability of any of these activities. Therefore, the magnitude of the impact from construction activity vessel movements is assessed as being low for diving and negligible for other water sports.” The impact is likely to be considerable for the on-going viability of our club, launching as we do from our mooring in Littlehampton marina. The committee is seriously concerned that during the construction phase, with it’s necessary exclusion zone, which is likely to last for several years, the club will be unable to offer its members any wreck diving in the vicinity of our established base. As such, unless some viable alternative can be found, the diving club, established for over forty years, will struggle to offer our members the ability to continue diving in the local area. With this in mind, we are looking to relocate our mooring on the river Arun, but are currently constrained by the additional costs this will necessarily entail. We would submit that a contribution towards funding these measures would not be unreasonable in the circumstances, similar to the awards made to the fishing community and other water users for Rampion 1. Bruce Lampard MSc Safeguarding and Welfare officer Worthing BSAC dive club #1323