Representation by Brighton & Hove City Council (Brighton & Hove City Council)
- Date submitted
- 3 November 2023
- Submitted by
- Members of the public/businesses
The following provides the Relevant Representation of Brighton & Hove City Council (BHCC) in response to the application by Rampion Extension Development (RED) Limited for a Development Consent Order relating to the Rampion 2 Offshore Wind Farm, extending the existing Rampion 1 Wind Farm. This sets out our main conclusions in relation to the environmental, social and economic impact of the proposal on Brighton & Hove. Principle of the Development BHCC acknowledges the benefit of the scheme in terms of providing renewable energy to address the UK’s impact on climate change. This accords with the national target of net zero carbon by 2050, but also the Council’s own target of becoming carbon neutral by 2030. While the energy would go into the national grid rather than directly to local use within Sussex, we acknowledge the overall benefit the scheme would deliver and are supportive of the increased provision of green energy. Seascape and Visual Impact We note and support the conclusion that the impact of the scheme on the Brighton and Hove seafront would be ‘major/moderate’, particularly noting the high sensitivity to change. We are pleased that this impact has reduced since the preliminary (PEIR) assessment through revisions to the layout. However, we would highlight our concerns over the remaining impact, particularly noting the seafront is visited by millions of visitors each year, and enjoyed year-round by locals. It is at the core of the City and its character. The capacity for the character of the view to be ‘changed by seafront and beach activity’ is noted in the SLVIA (p257), and we would certainly characterise this as a positive change. The beachfront activity is part of what attracts people to live and visit the city, and increases the potential for the visual impact to be experienced more widely. Periods of reduced activity are also potentially subject to greater visual impact as those using the seafront expect more tranquil, less busy views. For this reason we raise concerns over the impact of the scheme on the Brighton and Hove seafront. We also note the ‘major’ impact on Rottingdean highlighted in relation to viewpoint 7. Although this viewpoint is within the South Downs National Park, it is just 75m north and 100m west of the Brighton & Hove City boundary so the impact would be similar to that on areas within our jurisdiction (noting that they are outside of our jurisdiction only in relation to planning matters). The impact on this part of our coastline is also of concern, given the lack of mitigation set out in the submission. Impact on Heritage Features We query the conclusion that the impact of the offshore works on all heritage features along the coastline, including within Brighton & Hove would be ‘not significant’, regardless of the magnitude of change and their sensitivity to it. For Brighton & Hove, we do not agree that the impact on the numerous heritage features along our coastline would be ‘not significant’. We acknowledge the distance to the turbines, but would highlight the views shown in the SLVIA (viewpoints 7 and 8) which make it clear that the impact is greater than ‘not significant’. The existing turbines have already visibly changed the setting of these historic features, and as is apparent in these viewpoints, the increased number and height would increase this impact. Socio-Economic Impact As we did at the PEIR stage, we note the lack of socio-economic benefit the scheme would deliver to Brighton & Hove, despite the city bearing the long-term brunt of the visual impact on our coastline and its heritage features. We query the applicant’s justification for not using ex-ante (post-development) windfarm survey data which they state is because responses are ‘subject to bias’ depending on people’s feelings about windfarms. This justification could relate to any development. It is not, therefore, considered sound reasoning for not undertaking, or excluding survey data from people living and visiting Brighton & Hove – i.e. people experiencing Rampion 1. We welcome the Outline Skills and Employment Strategy and RED’s recent engagement on this in a meeting with officers. However, it lacks any commitment to financial contributions to education or employment within Brighton & Hove. For our purposes it cannot therefore be considered mitigation and we can only conclude that the proposal would have no economic benefit for the city. Conclusion BHCC notes the national benefits of the scheme in terms of the provision of renewable energy and the positive impact this will have on climate change. However, BHCC raises concerns over the visual impact of the scheme on our coastline, particularly its sensitive heritage features, and the lack of any economic or other benefits for the city, or contribution towards mitigating the visual impacts of the scheme, such as through financing schemes to improve/upgrade heritage features and the public realm along the city’s coastline. On the basis of the above, BHCC raises a holding objection to the proposal.