Representation by Sussex Wildlife Trust (Sussex Wildlife Trust)
- Date submitted
- 3 November 2023
- Submitted by
- Members of the public/businesses
Sussex Wildlife Trust is registering as an Interested Party to raise comments on the progression of the Development Consent Order application for the Rampion 2 Offshore Windfarm. Since climate change is one of the most serious threats to biodiversity, we support efforts to reduce carbon emissions by producing renewable energy. However, we also recognise that all forms of energy generation will have environmental costs. It's therefore vital that renewable energy projects are planned and delivered to avoid harming wildlife and deliver an overall net gain for biodiversity to support nature’s recovery. Rochdale Envelope • The extensive use of the Rochdale Envelope has made it challenging to pass meaningful comment as a stakeholder, due to the high level of uncertainty regarding the proposed development, the techniques to install, and by association the types of mitigation that could be used. We are therefore uncertain of the environmental impacts of the project, and that the developer is committed to sufficiently mitigate these impacts. • We query whether this application could be considered incomplete due to the very high level of uncertainty for a project of this scale. Commitments Register • The Commitments Register lacks detail and includes frequent caveats i.e. commitments to be delivered ‘where practical’ or ‘where possible’. This reduces confidence that commitments will be adhered to. • We seek clarity as to how the developer will be held to account on the commitments made at this stage in the process, and how they will be monitored and enforced during construction. • It is also unclear from the Register which are commitments, and which are essential requirements. Offshore • We believe the proposal should commit to the type of foundations being used for the wind turbine generators. There is a high level of variation of impacts on the sea bed between the proposed foundation types. • We would like to see high level of commitment to micro-siting of all elements of construction to minimise environmental impact, particularly to irreplaceable habitats. • More specifically, we would like to see commitment to micro-siting for HDD exit pits at landfall location due to the high potential for habitat disturbance using this technique. • We would like to see a commitment to noise abatement technology as this is now being used as standard practice for projects of a similar nature across Europe. • Details on cable laying methodologies used during the installation of Rampion 1 should be referred to; the overall geology of the area is similar and there should be visible lessons learned from the post-consent surveys. • We have concerns over the ‘Future Baselines’ section 9.6.36-38 in ES Chapter 2 Volume 9. The wording of these paragraphs is meaningless regarding commitments from the developer, and specifically with regards to the recovery of the historical kelp beds. We suggest if the developer cannot make meaningful commitments, such as adaptive management of the construction, then this should be removed. Onshore Construction methods • The high degree of flexibility that has been built into the application results in a lack of specific detail, making it difficult to assess or comment on specific ecological impacts e.g. stage-specific LEMPs not yet produced, ground conditions not yet assessed. • The criteria for deciding whether HDD is viable at each proposed crossing point are unclear e.g. commitment C-5 states HDD will be used ‘where this represents the best environment solution and is financially and technically feasible’ and C-17 states open cut techniques will be used ‘where trenchless techniques are…not practical’. • We query whether the ‘realistic worst-case scenario’ presented in the Environmental Statement allows for changes to construction methods e.g. if a planned HDD crossing is altered to a trenched crossing. Climate resilience of construction techniques in the coastal zone • The beach at Climping is highly mobile and already experiencing heavy erosion. Conditions may therefore be significantly altered by 2026 and continue to change during the construction process. We query whether this has been fully taken into account when assessing construction methods and to ensure minimal ecological impacts at this sensitive protected site. Biodiversity Net Gain (BNG) • The commitment to delivering at least 10% BNG is welcome (C-104) but the applicant’s Biodiversity Gain Information lacks detail and certainty as to whether and how this will be achieved. • Clarity is required on BNG delivery to ensure it is separate from and additional to the essential requirements under the mitigation hierarchy. Habitat restoration • Clarity is required on the type and total area of habitat to be permanently lost and the subsequent mitigation and compensation for this loss. • We would like to see on-site habitat restoration delivering enhancements (compared to the baseline) at every opportunity. • Clarity is required on how lessons learned from Rampion1 will be fully incorporated to improve effectiveness of habitat restoration e.g. improved monitoring of reinstated hedgerows to avoid delays to remedial action. • We query whether there is sufficient evidence to support the effectiveness of hedgerow translocation as a restoration method, based on local conditions. Future capacity • We ask whether it is possible for the applicant to consider future needs at this stage e.g. to build in additional capacity now, so as to avoid the need for further cabling and works in future and therefore minimise disturbance and impacts on the natural environment.