Representation by Susan Davies
- Date submitted
- 4 November 2023
- Submitted by
- Members of the public/businesses
Rampion 2- Cowfold I strongly object to Rampions proposal of the substation at Oakendene/ Kent St because this decision has not been properly researched or analysed and it will cause an enormous amount of environmental damage, economic hardship, traffic problems and has the potential for flooding the local vicinity and causing pollution in the River Adur. The proposed substation decision. Lack of consultation: On 14.7.2022, a local paper contained a small advert regarding the selection of the Oakendene/Kent site in Cowfold as the new substation site. Many local people hadn’t realised or noticed this small announcement, as it was placed next to some restaurant closure announcements. There appears to have been nothing on social media and the village of Cowfold was none the wiser. Apparently Oakenden was selected for “technical reasons”, however evidence suggests that insufficient analysis had been done at that time, otherwise such a conclusion could not have been reached. Rampion had not completed a full environmental study, nor an economic study, and they didn’t realise that it was a flood plain. Access to the site would be along a section of the A272, which is an accident hot spot, Kent St was assessed as being “unsuitable”, and the surrounding lanes do not have the capacity for additional traffic. The most likely reason that Oakendene had been selected was that there were a few individuals along Wineham Lane who did not want the substation built there. They persuaded Bolney Parish Council to write an excellent letter of objection to the scheme. Rampion state that Cowfold did not object to the proposal at Oakendene. The reason they did not object, is because they knew nothing about it. How could they object to something that they knew nothing about? The very few land owners who did know, had been threatened with compulsory purchase orders and asked to sign a non disclosure agreements. The majority of analysis had been completed at the Wineham Lane site, as Oakendene was supposed to be a “temporary compound”. All the Oakendene studies had been desk top, and as the land had been in the same family for several decades, there was little research that could be found. Rampion had not realised that the site was a flood plain, nor that there were several protected species, hedges, forna on this site, nor that it contained a number of water courses, or that the 7km Cowfold stream ran through it, which feeds the River Adur. They were also unaware of a massive High Voltage cable that runs under the site and should not be built upon. Rampion had been in contact with a number of land owners from Bolney to Cowfold and advised them of compulsory purchase orders and asked them to sign non-disclosure agreements. Apart from a very few people, the local community of Cowfold knew nothing about this scheme, until late October 2022, when Carter Jonas sent out a bundle of documents to certain other land owners, who might be affected. One week before the end of the two year consultation period ended in November 2022, Rampion agreed to a hurried meeting with some Cowfold residents. The turnout was relatively low, because not many people realised that it was happening and Rampion was known for it’s windfarm, so why would that affect Cowfold residents? They had not consulted with them before that time and communication since then has been very poor. Rampion are very dismissive of the opinions of local people and seem to change their narrative to suit. Although we have asked for detailed information about the traffic control measures, the mitigation proposals and the environmental impact, they hadn’t provided any detailed information prior to submitting their application, which has meant that many organisations such as RBPB and Woodlands Trusts simply haven’t got the resources to investigate these matter. Also, relevant and significant data or information is simply not included in the analysis, and significant and crucial facts are not disclosed. Rampion have consistently referred the reader to another chapter or appendix, but neither contains the necessary information. The due diligence has been very poor in certain areas, such as the impact of surface water flooding affecting local houses,; pollution risk- diesel and oil: the number and location of road traffic accidents along the hazardous stretch of A272 alongside Oakendene; traffic data from Cowfold East towards the A272; consistent queuing from Cowfold towards Kent St; air traffic pollution alongside Oakendene affecting residents nearby and the impact on the local community. According to Rampion, all the risks are “negligible”. They are negligible because significant information has been omitted and so much of their analysis is fundamentally flawed and their conclusions incorrect. Lack of Engagement by CPC Cowfold Parish Council appear to have failed to realise the significance of the scheme and when alerted, did very little to spread the word or advise the community. A concerned group of residents, distributed leaflets throughout the village in November 2022 and as a consequence over 300 households wrote to the Planning inspectorate confirming that they had not been consulted. Cowfold Parish Council continues to neglect and effectively ignore the views of many concerned residents and has not engaged with our local MP over this matter. Two members of the CPC resigned due to the local backlash. Please let us know if you require written evidence. Rampion’s application- Poor due diligence and missing significant data I have looked through a number of documents and a great deal of relevant data and significant information has simply not been included within the analysis. This would not stand proper scrutiny, since there has not been proper or thorough due diligence. In the traffic section, a great deal of relevant data about level of traffic east of the A272 to A23 is simply missing, as is the RTA data for this hazardous section of road. The same is true of the economics and environmental, pollution and flooding aspects. Economic impact on Cowfold Having looked through Rampion’s documents there is little or no analysis on the local impact this substation will have on Cowfold. The report does mention that a couple of footpaths will be closed. The statement does not go on to explain that many people from outside of the area come to Cowfold to walk their dogs and horses. A number of visitors park their cars and trailers nearby and use the paths and countryside for walking, cycling and horse riding. The actual impact of the proposed substation at Oakendene is significant, and will affect over one hundred Cowfold businesses, not to mention the several thousand vehicle users who drive along the A272 past Oakendene daily. Traffic The A272 is the only main road linking East to West Sussex, it is a major road carrying about 18,500 vehicles per day. The proposed Oakendene site, is situated next to one of the busiest and most hazardous sections of the A272, where existing congestion problems will only get worse. Traffic consistently backs up way past the Oakendene entrance, towards, and frequently past Kent Street. This occurs consistently on a daily basis from around 0630 to 0900 and from 1600 to 1830. If there are any road works or an accident along this stretch of road towards the village, then the traffic is at a standstill and extends beyond Kent street, resulting in chaos for the surrounding lanes. The economic consequences of locating the substation at Oakendene would be significantly more damaging for Cowfold, than Bolney. If Oakendene is chosen, it would negatively affect between 100-130 Cowfold businesses and over 18,000 commuters who use this congested and hazardous section of road. In contrast, using either Wineham Lane North or Wineham Lane South sites, would affect about five Bolney businesses and considerably less commuters. This is because the consistent daily congestion that builds up along the A272 towards Kent St, which is largely attributed to the weight of traffic and the two mini roundabouts within Cowfold village, does not extend to Wineham Lane. When Rampion 1, which is along Wineham Lane, was constructed there was no need for traffic lights at that junction and there were no noticeable traffic problems. “The Environmental Assessment (IEA) guidelines note that additional delays are only likely to be significant, when traffic on the network is already at, or close to capacity”. It is worth noting that traffic approaching Cowfold from the West and East must be close to capacity, considering it consistently suffer from well over a mile of traffic congestion on a consistent basis. It is worth noting that this significant traffic data (from Cowfold East towards the A23), was not included as part of the analysis from Rampion. Locating the substation at Oakendene would not comply with the Horsham District Plan of “supporting rural businesses” and “protecting and enhancing the rural character”. At the first of two meetings with Rampion, they disclosed that they would use over 8,000 HGV’s, though would not disclose the number of LGV nor ancillary vehicles. However in their most recent publications, the information provided in different chapters is not consistent, and it is difficult to know what data is accurate. As Rampion 2 will be a third larger than Rampion 1, we have extrapolated, and estimated 4084 workers, equating to about 325 ancillary workers p/d, resulting in potential movements of 650 for workers, plus 60 for HGV’s, (plus LGV’s) that’s an additional 710p/d of traffic movement across two lanes of busy and fast moving traffic for around six yrs or probably longer. Having looked at the most recent Rampion documents, these numbers are very conservative numbers. There would be multiple negative consequences. The most wide ranging would affect the 18,500 vehicles that use this stretch of the A272 on a daily basis, just over 9,000 each way. Several studies conducted by INRIX, CBI have demonstrated that traffic congestion is very costly in terms of lost productivity. If the substation is located at Oakendene, in Cowfold, this is estimated to be approximately £20m pa* in terms of lost productivity, as drivers sit in traffic queues. This takes no account of the increased fuel costs of sitting idle in traffic jams. For local businesses, the prolonged congestion (which could beyond 6 yrs), is likely to be enormously damaging for the long-term prospects of their businesses. Studies have shown that people try and avoid an area of congestion, so any businesses where customers are expected to visit, could be vulnerable to losing trade. Other businesses which rely on deliveries of raw materials or stocks, could also be prone to delivery delays, as some delivery drivers will not want to waste time sitting in queues, as they are paid per delivery. It is highly likely that deliveries will be delayed, transportation costs will rise, profits will fall or prices have to increase, thereby making Cowfold businesses less competitive. Customers may decide to use other more convenient and competitive firms, which have easier access. A number of businesses, predominantly in hospitality, have also mentioned that retaining employees will also be a challenge, as getting to work becomes more time consuming and stressful. They may have to attract new staff by offering higher wages, which will hit margins and negatively impact profits. Further studies have shown that as “A” roads get busy and congested, drivers find alternative routes and these will include the narrow single tracks of Picts Lane, Bulls Lane, Long House Lane and possibly Spronkets Lane. These lanes are normally quiet lanes used by the residents and rural businesses to move their livestock and horses. The future of these businesses may be in jeopardy, if theses lanes are used as cut throughs and diversions. The estimated construction time for the substation is approximately three years. However with Rampion 1, the estimated construction time was 2 years and it actually took over six years, (72 months). It is highly likely that the construction time for rampion 2, will be nearer six years, if not longer, with testing and commissioning. Disruption for this length of time can prove absolutely devastating for even the strongest of businesses, let alone those facing a cost of living crisis and rising interest rates. Once the substation is built and operational, the power will have to be stored somewhere. It will be necessary to accommodate several battery facilities which will also have transformers and which will cover several acres of land in relatively close proximity to the substation. We are aware of several proposed battery facility applications being considered around Rampion 1 in Bolney. One application that has already been submitted is for a “Battery energy storage facility with associated infrastructure for transformer and operations room etc” NC/22/0021 & NC/21/0017. This will alter the landscape and future land use and is likely to impact house prices. HDC has raised the safety impact. Research is currently underway concerning the explosive aspects of these lithium batteries and the potential impact on health. There are also other applications underway for massive solar panel facilities, which will alter the rural landscape for ever. The stationary traffic will increase the air pollution even further in Cowfold, however quantifying the unintended costs of air pollution for the NHS in this AQMA area is difficult. Air pollution will be significantly raised along the A272, running parallel to Oakendene, where there is currently no measuring equipment, but a number of local residents will be affected. Also, whilst analysing Rampion 1, we discovered a number of breaches of conditions and diesel spillages. Who will pay for monitoring Rampion 2? Will it be WSCC and if so, from which budget? Environmental Health? Two and a half miles outside Cowfold village, along the A272 is Wineham Lane, which was used for the access to Rampion 1, and did not require traffic lights during its construction. This is a two lane road, which was constructed in the 1960’s for the installation of the National Grid substation. It has a visibility splay and is on a straight stretch of road, which does not suffer from congestion or suffer from such a high number of road traffic accidents. Locating the substation here, next to Rampion 1, would affect about five local businesses as opposed to over 130 businesses in Cowfold, Neither would the 18,500 drivers need to sit in unnecessary extended traffic queues for up to six years, because there would be no need for traffic management at this junction and hence, far less disruption for those using the A272. However, there is no doubt that those five businesses and residents living in the vicinity of Wineham Lane and Bob Lane will suffer enormous and dreadful inconvenience, disruption and noise, and so should be compensated directly by Rampion. Road Traffic Accidents – Please refer to Appendix 1 The information provided by Rampion in relation to RTA is very selective and does not represent a true and accurate picture. We have obtained RTA data from HDC covering the past 10 yrs and found that the number of accidents along the proposed site at Oakendene/Kent Str was double that of those relating to Wineham Lane. Kent Street was 3 serious and 17 slight collisions, whilst Wineham Lane had 3 serious and 6 slight collisions. It is worth noting that many accidents are not reported, since police are not involved when roads do not need to be closed, or accidents called. According to HDC, there is 1 reported to every 3.34 unreported injury. Whilst 1:15.36 unreported for injury and damage, so these quoted numbers are significantly lower than actual collisions. The A272 running parallel to the Oakendene site, is not straight and dips down, and suffers from consistent congestion, which could account for the high level of RTA’s. There are no such problems when approaching the Wineham Lane junction, which is a straight and flat section of road. There have been a significant number of accidents along Picts Lane, where drivers who are unfamiliar with the lanes and are driving too fast and are not aware of all the obscured bends. Highways introduced pedestrian traffic lights east of Wineham Lane, a few years ago which appears to have reduced the number of accidents. Traffic- data We have scrutinized the documents published by Rampion and noted that many pertinent questions raised by National Highways, WSCC and HDC, have not been addressed. They often redirect the reader to other chapters, or appendices, that fail to provide relevant answers. Rampion possibly assumed that this would be a “tick box” exercise, and that the data would not be checked. Rampion failed to provide the relevant traffic information relating to the A272, East of Cowfold towards the A23, there is no traffic modelling, no up to date road traffic accidents (RTA), or any mention of the impact that their proposal will have on the surrounding lanes. As a consequence of omitting such significant information, their conclusion is that the proposed substation at Oakendene, will have “negligible” consequences, which is certainly not the case. Last week, on Friday afternoon (20/10/23), there was another accident on the A272, which effectively blocked one lane for 48hrs. As a result of this incident temporary traffic lights were installed and drivers took alternative routes to avoid the long queues. They used Picts Lane and Kent St, as a cut throughs, which resulted in absolute chaos, causing another accident and cars ending up in ditches. A report of this, together with photographs will be in the County Times and Sussex newspapers this week. The newspapers appear very receptive to these local stories, so we have agreed to keep them up to date with developments. This incident lasted a mere 48hrs, causing chaos in the lanes, resulting in some very angry exchanges between drivers. Rampion’s proposal is expected to take five or more years. Please bear in mind that Rampion 2 is substantially bigger than Rampion 1 and Rampion 1’s substation should have taken 18 months, but instead took 72 months. This is not a short term problem. In addition to the unaddressed questions, it is concerning to discover a number of omissions of significant factors in their document 6.2.23- 004866046-01. 1. It is disconcerting that the main road connecting East to West Sussex, the A272, which carries about 18,000 vehicles daily, from the A23 to Cowfold village, seems to have been excluded from Rampion’s analysis. This stretch of road, from the A23, to the proposed substation site at Oakendene in Cowfold, is stated to be Rampion’s primary route, yet no relevant data appears to have been provided. Notably, there is data from West, South and North, but not from the East of Cowfold, the main proposed route. . 2. Rampion has neglected to incorporate recent pertinent Road Traffic Accidents Data for this hazardous stretch of road, known to be an accident hot spot, with one of the worst records in the region. In addition to normal traffic, this stretch of road will have to cope with thousands of Rampion’s HGV’s and LGV’s entering and exiting daily from two closely connected sites. By excluding this relevant data, Rampion have inaccurately concluded a "negligible” impact of their proposal. Interestingly, they have included data from other road sections, covering periods of lockdown, which are not representative and provides a misleading picture. The number of reported RTA’s relating to the Oakendene site is double that of those at Windeham Lane. Simply drive along this section of the A272 near Oakendene and you will see several gaps in the hedges where vehicles have crashed through. Please note, that the number of accidents are significantly under reported, as not all accidents are reported to the police, and so won’t be included in the official RTA data. According to HDC the ratio is 1:3.34 unreported injury and 1:15.36 for unreported injury and damage. There are many accidents that occur on the surrounding lanes, which are not reported to the police, and so are not in the official numbers. Picts Lane suffered two accidents this past weekend alone, one involving a horse box and another a van. These were due to the diversion on the A272, neither were reported to the police. I’m not sure if any accidents occurred along Kent St this past weekend, but they also suffered complete chaos. There was a head on collisson involving two cars yesterday, along Spronkets Lane (a cut through leading to Picts Lane), that was also not reported to police. 3. The increased risk of accidents when drivers become frustrated, as outlined in the RSK Environment Ltd report of 2012 (Chap 29-22), is likely to cause more accidents and additional congestion and backlogs. 4 There is no analysis or sufficient comment about the effect of the increased traffic through Cowfold village, posing a danger to young pedestrians. With a significant rise in HGV’s and LGV’s, especially during the two year “peak period”, families with young children walking from the housing estate along the very narrow path through the village to the primary school, will be particularly vulnerable. Although this danger was raised by the Parish Council years ago and a report published, apparently, there is little that can be done due to the proximity of the pavement and cottages. 5 Another area of confusion arises from data provided by Rampion. The number of HGV’s and LGV’s appears inconsistent from one document to the next, though the data within the application is significantly higher than what was originally disclosed by Rampion. This lack of clarity and miss-information, is presenting a skewed and misleading picture and leading to inaccurate conclusions. 6 There appears to be no analysis or traffic modelling for the impact of the increased congestion, on the surrounding lanes used as cut throughs. Highways England have stated “the over reliance on “A” roads in the regions means congestion is quick to develop, with no built in resilience, and in turn, pushing road users into single carriageways.” This is precisely what occurs in Cowfold, causing chaos and havoc to surrounding areas when there are roadworks or an accident. This weekend (20/10/23), there was another accident on the A272, between Picts Lane and Spronkets Lane. The vehicle could not be moved for 48 hrs, which meant that Highways installed temporary traffic lights along the A272. It is no exaggeration to say that it caused absolute chaos on Picts Lane and Kent Street. There were cars trying to go in both directions on these single track lanea, cars got stuck in the ditches, there was a horse box that rolled over, a van was involved in an accident and there was much abuse from very angry drivers and residents. This was just one weekend of utter chaos, not several years. One of the neighbours took video footage of the extended queues and grid lock along Picts Lane, while other neighbours took photos along Kent St. The verges became a quagmire and a complete mess. Please let me know if you would like these photos and videos. 7 According to a Parliamentary Publication, the Select Committee on Transport’s seventh report, stated that “traffic diversions could have a significant effect on road safety as traffic moves to less appropriate routes for high vehicle flows”, which can have a very significant negative effect on less suitable surrounding lanes. If the substation is located at Oakendene, and traffic backs up towards Kent Street, then drivers will find alternative routes such as the single track lanes of Picts Lane, Bulls Lane, and possibly Long House Lane. There are a number of residents who use these lanes on a regular basis to move their horses to fresh pasture and turn them out. Aglands farm is a prime example of a farm being used for a variety of different purposes by a number of different people, including for the local shoots and ploughing competitions. These single track lanes are in areas of outstanding natural beauty, and have very few passing places and are not suited to heavy volumes of traffic. Picts Lane has two narrow bridges which effectively act as width restrictors. They experience grid lock if there are accidents or roadworks along the A272 towards the village of Cowfold, because drivers access the lane from both the A281 and A272. 8 There is no analysis of the existing queues that form consistently each day, during the two main rush hours, from Cowfold East, along the A272, past Oakendene towards Kent Street. The village of Cowfold is already at saturation point, when it comes to existing volumes of traffic, this can be seen by the extended and consistent queuing that occurs on a daily basis. If a traffic management scheme is introduced along this section of the road, parallel the Oakendene site, it will compound the existing congestion problems and create utter chaos for road users and local residents alike. 9 There is no analysis on the impact on the surrounding villages that will be affected, as traffic diverts to avoid the queues along the A272. 10 I believe that there was traffic analysis conducted along Kent St, this past weekend. The results will be heavily distorted, as a result of the A272 accident, so please bear this in mind. The A272 was blocked from late afternoon on 20.10.2023 until late afternoon on 22.10.2023. 11 A neighbour reminded me over the weekend, that the cyclists, horse riders and walkers frequently use these lanes. They will no longer be able to do so, since it will become too dangerous to use them, as motorists do not slow down on these narrow lanes. 12 Please also bear in mind that Oakendene is a flood plain, and if the substation is built there, that this could have repercussions on the highways, as the water is displaced by 6 ha of concrete. No such problems exist on the Wineham Lane site. It is not on a flood plain, it has two lanes and has a visibility splay, unlike Kent St., which was deemed “unsuitable” in the original analysis by Wood Group. If this proposal goes ahead and is located at Oakendene, the congestion will persist for several years, and angry drivers and residents will express their frustration towards the authorities who granted permission, for this ill conceived and avoidable proposal. Interestingly, the impact on traffic congestion and RTA's, will not be as significant, if the site was located down Wineham Lane. This location is three miles away from Cowfold village, situated on a straight stretch of road and queues do not extend that far. The RTA’s are also half those reported at Oakenene. Nobody raised the A272 traffic as an issue for Rampion 1. At a meeting in Cowfold with Rampion in summer 2023, local residents were eager to point out the existing problems with queuing traffic along the A272 East of the village. The village simply can’t cope with existing volumes, as the traffic often extends way past Oakendene towards Kent St. Locals also pointed out how dangerous it would be for HGV’s and LGV’s to turn into and out of the site. If the substation is built at Oakendene, this situation will be significantly worse for a sustained number of years. This concern was simply ignored by Rampion, who said " it was Highways problem. " All this potential disruption and chaos could be avoided if the proposed sub station were located on the other suggested site, along Wineham Lane either to the South or to the North, in close proximity to Rampion 1. These alternative locations have no flood planes, or water courses, no direct access to the stream that feeds the River Adur. Wineham Lane is located some three miles outside the village of Cowfold, where the stretch of road is long and straight, and traffic seldom backs up to that junction. In the 1960’s when building the NG sub station, National Grid installed a visibility splay and two lanes along Wineham Lane for the HGV’s, which would be far more suitable option. The questions posed by the authorities have been relevant and astute, but answers have not been provided, and much of the information provided by Rampion is incomplete and hence misleading, resulting in inaccurate conclusions. Could you please investigate these outstanding questions and further examine this matter, ensuring that NPPF Paragraphs 111 and 113, and the GEART rules are applied? Thus far we have been disappointed by Rampion’s lack of engagement and refusal/inability to listen to the concerns raised by the local community. Flood Risk and Pollution Risk Last week on 20/10/2023, there was an open meeting with our MP Andrew Griffiths, organised by the editor of Sussex World. There was a great deal of public frustration and anger at the way our local waterways is being polluted. There was also anger at the proposed Rampion substation and battery facilities, that will alter the way we use our land and ruin our beautiful countryside. This is a topic which the local press will continue to follow. We have just walked along to the Oakendene site and it is already flooded, the lake has burst its banks and the whole area is water logged. We will be sending photos under separate cover. The same happens every year, where will all this surface water be directed once 6ha of substation is built over it? We are concerned about the following factors which have not been fully investigated, since all the facts have not been disclosed: 1 The flood risk, of surface water flooding affecting houses nearby. This factor doesn’t appear to have been addressed by Rampion 2 The flood risk for the communities downstream due to building on a flood plain 3 The potential pollution of the River Adur through diesel spillages. There was a diesel spillage during Rampion 1, which was reported to the Environmental Agency, when Rampion refused to address the problem. Such a spillage would be significantly more detrimental at Oakendene, as it is surrounded by watercourses, and has the Cowfold stream, which feeds the River Adur. 4 The potential pollution of the surrounding watercourses, and the River Adur, as a result of the frequent use of weedkiller on the site. 5 We understand that all underground cables have an oil sleeve to cool them, and that they leak not infrequently. We understand that a boom was needed in the past, in order to clear a leak from the Oakendene lake. If permission is granted at Oakendene, there will be three underground cables, which could potentially leak into the surrounding water coarse and contaminate the River Adur. 6. Significant information has been omitted from Rampion’s reports, including the Environmental Agency flood maps and risks of surface water flooding of local houses. 7. P151. A Water neutrality commitment 26.7.10 has been requested by HDC & WSCC. However, Rampion has a very poor track record for keeping promises or commitments. Please refer to the poor experiences during Rampion 1: breaching weekend and evening non- work commitments, poor replanting, extensive damage to land, diesel spillage, poor communication with neighbours resulting in traffic congestion and extended road closures, generators running 24/7, construction period was supposed to take 18 months and took over 6yrs, problems with tunnelling and laying cables, resulting in numerous broken promises to local residents, 8. When the National Grid built their substation at Wineham Lane, they had to raise the ground by 15 feet to avoid flooding. Please can you investigate the ground level for this proposed 12m high structure and how they intend to prevent the flood planin from flooding. Where will all the displaced water go? 9 How will Rampion’s proposals affect communities downstream? Either they will be flooded or there may not be sufficient water. Which option is more likely? And who will be responsible if they have miscalculated? 10 According to C-75 “Construction and permanent developments in floodplains will be avoided where ever possible”. It is avoidable in this instance, as the substation could be located in Wineham Lane, near Rampion 1. 11 According to C-117 on p124 “Works on areas identified as floodplain, will be programmed to avoid the period between October and February inclusive”. How would this be possible at Oakendene without extending the build for another few years? 12 26.10.7. "The drainage from the impermeable onshore substation footprint and the presence of a below ground grid have the potential to disrupt infiltration and displace shallow groundwater”. Have these factors been examined and addressed in detail? 13 2.2.15 Discharge via infiltration to the ground. " No soil testing has been undertaken at the onshore substation site.” Surely this should have been one of the first things to have been done, considering the land has been untouched for four decades. 14 According to Cranfield University 2023, Soilscape "soil mapping, indicates that the onshore substation site is underlain by slowly permeable seasonally wet soils with impeded drainage”. This type of soil and flood plain is not recommended for the location of substations. 15 2.2.16 "Given the presence of clay and the poorly drained soils, discharge of surface water to the ground is not considered feasible. “ 16 The pollution hazards indices for the substation are not provided in table 26.2 of the CIRIA SuDS manual. This important factor cannot be ignored, due to what happened at Rampion 1. Who is going to obtain this data and analyse the results? Other areas of concern, relating to the inadequate /misleading information provided by Rampion: 1 This document, 6.2.26, was supposed to examine the flooding aspect of this site, but has not included maps showing surface water flooding for Oakendene/Kent St. These fields are floodplains and flooding has caused damage to nearby houses, which are already on the Environmental Register for surface water flooding. These points have not been covered or examined in this report. 2 There has been no analysis of the displacement of surface water associated with piling construction techniques. 3 The weed killers which will be used regularly for the substation site will permeate into the water courses and go into the River Adur. There has been no mention of this in this report. 4 The impact on the Cowfold stream has been downplayed and the River Adur not mentioned in conjunction with it. However, the Cowfold stream is on the Oakendene site and is 7km long and feeds the River Adur. The consequences for the River Adur, of building the substation have not been examined at all. The site could either flood and flood the Adur, or planting trees around the existing site could use up the water, which may cause water shortages down river affecting the ecology and existing habitat. The consequences are unknown and have not been examined in detail. 5 Pollution is mentioned in passing 2.4.14, but final decisions will only be made at the DCO stage, by which time it will be too late to change this course of action, and the negative consequences could affect a number of villages down stream. 6 Water neutrality has been promised, however Rampion 1 also made promises about re-planting, and pollution control, but they have largely failed to materialise. Rampion have done little to address this ongoing failing/breach. 7 2.2.15 Discharge via infiltration to the ground. No soil testing has been undertaken at the onshore substation site. The British Geological Survey mapping (BSG2023), indicates that that the substation is underlain by Wealden Clay. According to Cranfield University 2023, Soilscape "soil mapping, indicates that the onshore substion site is underlain by slowly permeable seasonally wet soils with impeded drainage”. Why had testing not been completed? Please could you examine these areas of concern, and ask Rampion other pertinent questions, so that West Sussex doesn’t share the same fate as other communities who have flooded or caused enormous damage to their waterways. By way of an alternative, Rampion’s documentation concludes that there are no flood plains or water courses at the alternative Wineham Lane site. Environmental Damage. Over the past year, we have pleaded with Rampion to disclose their environmental data, as have the RSPB, Woodlands Trust, and other organisations, in order to give sufficient time to assess their proposed mitigation measures. They refused to disclose this information until they submitted their application. As you know this is a sizeable document with a massive amount of data and now those environmental groups are overwhelmed by the information and other applications at Gatwick and cannot do justice to all the areas affected. This appears to have been a deliberate ploy by Rampion. Rampion have completed no analysis on the extensive Oakenene lake, nor the impact on the wintering birds and wildlife that depend on the lake. It’s heart breaking to think that several decades of undisturbed bio diversity and carbon capture will potentially be lost. There are many red list and protected species, such as the great crested newt, badgers, nesting nightingales and water voles, otters and many more that will be affected by this massive destructive construction. Several ancient oaks will be lost to make way for the visibility splays, for the steal and concrete construction. It is utterly devastating that the landscape will be altered forever, for a scheme that will last a mere 30yrs. Our neighbour, Janine Creaye has completed a great deal of analysis on the environment, so please can you read her report. Alternatives In comparison, the sites at Wineham Lane do not appear to have these extensive lakes and watercourses, or extra ordinary hedges with bio diversity which has been undisturbed for several decades and are home to hundreds of nesting nightingales, turtle doves and many more. Sadly Wineham Lane has already been disrupted, what a shame to extend this disruption to yet another area. *An average 15 minute wait will cost £20m in lost productivity, and that doesn’t take account of the increased fuel consumption.( Assuming an average 15 min delay to each journey. 18,000 vehicles @£15ph divided by 4 =£70k pd in lost productivity. Assume 5 day week and ½ day at weekends =£420k pw, equals £20m pa). Appendix 1 Email 31.10.2023 Hello Susan, Further to our phone conversation this morning, please find attached a pdf plan showing the collision locations. Where there were clusters of collisions, I have pulled out the symbols so that the reference numbers can be seen; those that I have moved will have a locator indicator (line) to show where the collision was plotted. The reference numbers will tie up with the reference numbers in the reports I previously sent, you may need to zoom in to see them. The plan has been created for an A3 print output. In answer to your phone question about how many collisions occur in relation to those reported to the police, I have an old note that says there are an estimated 1 reported injury collision for every 3.34 unreported injury collisions and there are an estimated 1 reported injury collision for every 15.36 unreported injury and damage only collisions. These rates are probably 5+ years old now but I have little reason to suspect they have changed much. However, as I warned, this will be an estimation based on national data, so shouldn’t be applied to the data I have provided and assumed that that is the actual number of collisions that are occurring. I suspect the ratio for this section of the A272 is likely to be lower than the 15.36 national estimate. In answer to your written questions, there were 2 Serious collisions and 15 Slight collisions west of Kent Street Lane. If you include the Kent Street Lane junction, then there is 1 more Serious and 2 more Slight collision. At Wineham Lane there were 3 Serious and 6 Slight collisions. Regards David Newman Senior Technician, AIP, County Road Safety Group, Highways, Transport and Planning