Representation by Lynda Marshall
- Date submitted
- 3 November 2023
- Submitted by
- Members of the public/businesses
It is unsettling how the Rampion 2 Environment Statement (ES) selectively deploys information and evidence to assert that transformation of our natural seascape will have “negligible” adverse impacts on people – residents and visitors. The Applicant says it reached that conclusion after undertaking a comprehensive and detailed desk study, interpretation of the seascape, landscape, and visual impact assessments (SLVIA) following procedural guidance and best practice methods, and by applying professional judgement - all of which it validated by showing comparable experience on other UK wind farms. My overall comment and concern is that, in contrast to the above, the Application actually offers a highly subjective, flawed and misleading assessment of the likely adverse impacts of Rampion 2 on south coast residents and visitors. Given the proposed scale, inshore location and spread along a populous coast, I belive the adverse impacts on residents and visitors should be a principal issue in the Examination, along with how the Applicant fails to take full account of policy-relevant strategic environmental advice on visual buffers to avoid local harm. My comments are in two parts as follows: PART A: FROM MY OWN EXPERIENCE My own experience and feelings with living in full view of the Rampion 1 installation and almost daily seafront walks having social interactions with many people (residents and visitors) are that: - I experienced the constant noise and disturbance of the Rampion 1 construction, as did my neighbours. - The fact that we must now look to the south west to avoid the sight of those Rampion 1 turbines, either spinning or sitting in calm air, looking like a patch of tree stumps or sticks in sea - is a tolerable, though not a welcome sight. - Rampion 2 is a completely different matter. - Many if not most residents in my area have no idea what is actually proposed in this Application and what may come their way soon. - They are shocked and get emotional and upset when they first see actual visual animations (to scale) provided by campaign groups (Protect Coastal Sussex: see the windfarm animations tab). Such highly informative visual animations were not supplied by the Applicant, nor are they available from government at any level. - I don't want to imagine the Rampion 2 turbines, higher than the Shard building in London, towering up to 325m tall, over 1,066 feet, up to 90 of them, so close (if I may say, in our collective faces). - During the day they will impose themselves spinning or still, then flash with navigation strobe lights all night across the entire sea horizon. The only relief would be at times sea mist shrouds them. - There is absolutely no question that Rampion 2 will significantly and adversely change the character of the south coast literally in the eyes of many residents and visitors. - That will seriously affect beneficial use and enjoyment of our natural seascape endowment with all its intrinsic values along a large swathe of the south coast - Like many, I personally see Rampion 2 as an unnecessary, dystopian transformation of our natural heritage that will have many adverse human and economic consequences. - It runs counter to the desire for responsible local environmental stewardship, which is disquieting on so many levels. - Apart from the impacts on people, Rampion 2 will have many significant, complex, adverse impacts on sensitive inshore marine ecosystems and mammals in the Sussex Bay (multiple impacts that are unpredictable). Reality is it risks making these bio-productive inshore waters even more vulnerable to the effects of climate change. - As pointed out by others, Rampion 2 is not sustainable development. It does not meet that test based on balance across social, environmental and economic dimensions. - Nor does this Application explain how it takes into account the government’s own strategic environment advice on visual buffers for large turbines to avoid local harms. PART B: FROM MY DISCUSSIONS WITH OTHERS From my discussions with other residents and community organisations on the Applicant’s PEIR and ES to better understand what is going on, specific comments are: • On the visitor and tourism impact question, the Rampion 2 ES documents offer a highly selective, narrow and limited desk study with mostly dated research from times when turbines were small - to then arrive at a desk-study hypothesis that offshore wind farms do not harm tourism (anywhere). - Equally the ES implies that applies to coastal residents (negligible impact). - As is stated, “The evidence suggests that offshore wind farm developments generate very limited or no lasting negative impacts on tourism and recreational users during both construction and operational phases.) ES ,Ch 17, p81. - That assertion is made by the Rampion 2 Applicant RWE - despite the fact that RWE’s Awel y Môr offshore wind farm proposal in Wales was scaled back in 2021-2022 based on those very concerns - visual impacts with likely adverse consequences for local residents and their tourism economy. Please see: [REDACTED] • The Rampion 2 Application offers us no robust resident or visitor surveys to conclude there would be a “negligible” impact on people. - For example, it does not use before and after images of the proposed (up to) 325m tall turbines spread across the seascape to ask clear and meaningful questions, as was done in surveys to inform the Navitus Bay WindPark Examination. - That refers to the 970 MW WindPark proposed further west along the Sussex south coast off Dorset by an EdF Energy (France) led consortium that was refused consent in September 2015. - The Rampion 2 Applicant relied on mostly generalised attitude and opinion surveys about the role of renewables and wind farms plus the collection of SLVIA images that are buried deeply in ES volumes on-line. - Similarly that was done for the PEIR in virtual consultations – where the SLVIA images were not accessible to most people, and in fact were hard for most people to understand or process. - Again there were no accessible visual animations for people to grasp what is proposed. - In one generalised survey where the Applicant commissioned the consultancy services firm Populous in 2019 to measure attitudes about Rampion 1, where respondents were asked about visual impacts of that installation (under the question: aspects - the appearance of the windfarm" - 54.9% had a positive view. - Under the question, “Why do you support the Rampion 1 Offshore Wind Farm?" for the sub question, "Like the Appearance?”, the average result was only 9% overall positive, with individual areas like the Brighton Pavillion higher at 16%. That dropped to 5% for the Littlehampton/Bognor areas. - Rampion 2 is a proposed £3-4 billion investment far larger than Rampion 1. Considering its scale and location it is reasonable to say it warrants proper resident and visitor surveys to inform the Examination. • The Rampion ES says that professional judgement was used to assess: a) the sensitivity of residents and visitors as visual impact receptors on the south coast, and b) the magnitude of change they would perceive that Rampion 2 would bring for visual amenity from construction, through operation (20-25 years) and decommissioning stages. - The ES acknowledges that with the statement: “Otherwise, the likely effects of Rampion 2 on the other receptors identified (i.e., jobs, GVA and the visitor economy) is based on professional judgement of the sensitivity of each receptor in addition to the magnitude of change to the receptor brought about by Rampion 2.” Chapter 17: Socio-economic (p98). - Residents in some settlements and visitors (tourism) were classed as “highly sensitive” receptors, but then the ES concluded that any adverse impacts of the physical transformation of the natural seascapes would be negligible. - Thus the professional judgement of the commercial developer and their consultants was essentially that in the eyes of all coastal community residents and visitors - the adverse impacts would be negligible. ? Chapter 17 on socio-economic impacts then argued its desk study hypothesis (offshore wind turbines have no adverse effect on tourism, anywhere) was validated looking at visitor trend statistics for two UK windfarms it selected: - Rampion 1, which is far smaller in scale, sea area, visibility and spread or occupation of the horizon than Rampion 2; and - the Dudgeon Offshore Wind Farm 32 km (20 miles) off the coast of Norfolk in the North Sea. - Dudgeon commissioned in 2017 has turbines of the same scale as Rampion 1 and arrays start further offshore (32 km) as compared to 14km for the proposed Rampion 2 turbine arrays. - Both projects (Rampion 1 and Dudgeon) thus offer misleading comparisons and are not reasonable validations of the false desk-study hypothesis. It is also important to highlight that relevant Rampion 2 ES Volumes also make many contradictory assumptions and assertions about visual amenity that lack credibility: ? Such as, it is suggested that the volume of visitors to the south coast may actually show a net increase overall, due to Rampion 2. People will come to the coast because they will be curious, at least during construction. ? While assessing coastal residents and visitors in West Sussex as “highly sensitive visual receptors” and that, “views from these settlements are often experienced by a relatively large number of people, residing in the settlements”, the ES the concludes the contiguous, linear urbanised coastline between Shoreham-by-Sea to Bognor Regis is a “degraded urban area”, where the character of the area is not defined by natural seascapes and has already has changed by Rampion 1. ? The ES argues, “the visual amenity experienced by the viewers is already influenced by the presence of the existing Rampion 1 WTGs. This clear and prominent existing wind farm influence in sea views moderates susceptibility to change as WTGs are characteristic elements in the sea views and further WTGs will be viewed in the context of this wind farm developed skyline”. ? In effect saying more turbines will do no harm. To the contrary, many would agree that most local residents and visitors to Littlehampton are not overlooking a degraded urban landscape, rather we overlook and /or enjoy a natural open seascape in our daily lives as we move about, socialise, work and play. That same is true for many communities and their visitors along the coast. ? The Rampion ES Application documents failed to mention the Navitus Bay WindPark Application along the south coast that was refused consent in 2015, and thus Interested Parties collectively will not benefit from the lessons it provides. - The Rampion 2 ES dismissed the Navitus Bay Examination findings with the statement, “No empirical, ex-post evidence for existing wind farms off the Sussex coast could be found.” (ES Vol 2, Ch 17, pg 63) - The ES thus focused on marshalling argument and information to support its assertion that Rampion 2 will have no more adverse visual amenity impacts than the Rampion 1 installation, and if any they would be negligible. - Rampion 2 is more comparable to the 960 MW Navitus Bay proposal, which suggests that lessons can and should be drawn from that Navitus Bay Examination and decision. Dismissive of OESEA visual buffer advice: • This is a major concern raised by an number of statutory consultees as reported in the ES and also by community organisations during consultations. • Why would the UK Government even offer strategic advice on visual buffers for offshore wind farms based on the size of the proposed turbine and the setting in its rolling Offshore Energy Strategic Environment Assessment (OESA) programme - if indeed the Applicant’s desk study hypothesis and assertions were credible? i.e.. that all evidence shows that all offshore wind farms have negligible impacts on people (residents and visitors). • Here it is noted that Rampion 2 ES repeatedly dismisses the OESEA advice as being only, “a high level ‘buffer’ study … it is a strategic tool and is not guidance or a roadmap for placing of wind farms…” (ES, Volume 2, Chapter 15: Seascape, landscape, and visual impact assessment. Pages 52, 53 and further on). - That was the Applicant’s primary and repeated response when statutory consultees raised concerns about the lack of conformance to the OESEA buffer advice, including local authorities and the South Downs National Park Authority (SDNPA). - In fact the OESEA (BEIS) commissioned research and analysis, “Review and Update of Seascape and Visual Buffer study for Offshore Wind farms”, 2020, as in the link below is clear that: a) Offshore wind turbines do have significant impacts on people, when in visible close proximity to coastal communities and designated landscapes, and b) The suggested buffer distances that the OESEA offers are precisely to be taken into account on wind farm proposals such as Rampion 2. https://assets.publishing.service.gov.uk/media/5ef9a3abd3bf7f769a4e7742/White_Consultants_2020_Seascape_and_visual_buffer_study_for_offshore_wind_farms.pdf - The OESEA research (2020, above link) goes on to state its purpose is to support: “Analysis of wind farms coming forward in respect of their seascape and visual impact assessments (SVIAs), focussing on visual impact of a proposed development alone and cumulatively with other wind farms.” - And in respect to the DCO processes where buffers have the legal status of advice to be considered in the Examination as to how it is taken into account (as in NPS EN-3), the OESEA research (2020) says while they (buffers) , “…. do not necessarily suggest no–go areas for development. These areas would need to be subject to careful further assessment and consideration should development be proposed within them (the buffer zones).” On the interpretation of evidence the Applicant’s ES offers - and only to illustrate: ? Arun District Council, for example, “recognises that the views to the sea are one of the prime attractions for residents and visitors to the district. They state that the potential impact on the economy and tourism is unknown and believe more information and assessment is required”. (ES Vol 2 Chapter 17, Socioeconomics, p32). ? The Applicant’s response to ADC, again as repeated many times in the ES was: “The ES assessment provides a comprehensive and detailed review of the available evidence on the impact of offshore wind farms on tourism. Although this identified some gaps in the literature, the weight of available evidence suggests there will be no significant adverse effects on tourism in the study area. (Chapter, 17, p32) ? The ES thus draws primarily on its selective, narrow desk-study that fails to acknowledge and reflect the OESEA research and evidence (as cited above (2020 embodied in OESEA4), which indeed was comprehensive, detailed and international. This should be taken into account in the Examination. Other related concerns with the Application include: • The ES notes in Para 17.10.20, “ Under the maximum design scenario, it is assumed that Rampion 2 will consist of 65 WTGs of up to 325m in height (or up to 90 WTGs of up to 210m in height if smaller capacity WTGs are used). Chapter 17 Volume 2, page 131. - Yet the Application submitted is for up to 90 WTGs up to 325m in height. - It underlines the very serious questions as to what visual impact was actually assessed in the ES, as is noted in the Planning Inspectorates Section 51 Advice Letter issued to the Applicant 10 Sept 2023. - It suggests this is an important issue to resolve and call for remedial steps before the Examination is opened, also recognizing there is no prescribed duration of the pre-Examination stage. - I can be argued this is grounds for the Examination Authority to recommend suspension of the Examination (to the Secretary of State) until the matter is resolved. • For the Navitus Bay Examination, both in its pre-application objections and in its subsequent Local Impact Assessment report the Bournemouth Borough Council (BBC) established that the impact on tourism and the visitor economy would be a principal effect. - The Applicant argued there was no robust empirical evidence that windfarms had socio-economic effects at local or regional levels - as the Rampion 2 Applicant now argues. Navitus Bay Wind Park Local Impact Report Bournemouth Borough Council (BBC) PINS Reference Number: EN010024 - In its statutory LIR, the BBC argued that the Navitus Bay Applicant failed to properly quantify the net impacts on tourism and explains why the developer would need to provide annual mitigation or compensation of just over £100 million p.a. or £2.5 billion over the life of the project to offset the expected loss of trade, as well as further compensation for investment loss in the area. Bournemouth (BBC) argued this rose to £6.3 billion over the lifetime of the project over all affected districts. - That estimate was based on a detailed visitor survey where respondents were shown before and after images of the turbines to scale and asked detailed questions on how it would change their decision to visit in future. That survey was conducted by Visit England. It established that while some visits would be unaffected, a significant proportion would be, especially including the longer stays. - The Secretary of State Decision Letter when explaining why consent was refused on Navitus Bay implied that the likely adverse impact and loss to the tourism economy may be somewhere between the Applicant’s estimate and the estimate arrived at processing the detailed visitor survey information conducted by Visit England. - It noted the Examination found that the Applicant erred in some assessments by lessening negative impacts on tourism-related jobs, and that there would be “significant residual harm to tourism” in some local areas. Please See: https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/EN010024/EN010024-000055-SecretaryofStateDecisionLetterandStatementofReasons.pdf - If the Navitus Bay (BBC) findings were simply mapped (by ratio) onto demographics affected by Rampion 2 scheme, there would be a reduction of some £44M per year for Arun and almost £200M per year for West Sussex is possible, and grows over time. • Thus it is suggested relevant lessons from Navitus Bay Examination be considered in the Rampion 2 Examination Like many residents in Littlehampton directly impacted by Rampion 2 who have attempted to understand what is in the ES Volumes, and critically, to assess the credibility of the key assumptions and the nature of the professional judgements employed, I strongly disagree with the Applicant’s assertions that: • The impact of the construction operation and maintenance of Rampion 2 on coastal residents (settlements) is Negligible (as in ES, Volume 2, Chapter 15), and • The impact of the construction, operation and maintenance of Rampion 2 on the volume and value of the tourism economy in Sussex Negligible (as in ES, Volume2 , Chapter 17). Like many, I would be perplexed if the Government’s OESEA guidance on visual buffers is not fully respected, given the scale and location. It would be fair and reasonable to fully apply that advice and overwhelmingly in the public interest. It is massively important from the position of responsible local environmental stewardship. It warrants close scrutiny by the Examination Panel as a Principal Issue and weighs substantially against recommending consent.