Representation by Henry Smethurst
- Date submitted
- 5 November 2023
- Submitted by
- Members of the public/businesses
I object to the Rampion 2 windfarm and its effects on Oakendene and Cowfold. My main concerns are: Traffic and Pollution: Traffic in Cowfold is a big concern for the residents of not only the A272 and the quiet country lanes around the substation site, but for the whole village and the far wider community who use this road on a daily basis. I do not agree with Rampion’s methodology for assessing the impact, and believe they have significantly downplayed the impacts on congestion, pollution and accident rates. They have not properly understood the way the mini roundabouts in Cowfold alter the flow of traffic, or why looking at only percentage increases in traffic numbers is too simplistic an approach. Local knowledge testimony, and scientific evidence both demonstrate the more likely, far more disruptive, true effect of the proposed vehicle movements. The traffic movements will affect the AQMA in Cowfold to a far greater extent than they suggest. The impact on the tiny lanes of Kent Street and Moatfield lane will create an unacceptable level of misery for the residents for the duration of the construction, and also for those on Picts Lane and Bulls Lane to the north. The economic effects of the traffic have also been underestimated. No Traffic Impact Assessment has been carried out for Kent Street. This is not reasonable, given the extent to which it will be used, and the fact that the impact assessment on other lanes such as Wineham Lane was used to exclude the Wineham Lane substation sites from consideration. Rampion have failed to adequately consider or have played down, both the health and social impacts of the traffic, and the alternatives. Wineham Lane was widened in the 1960s for the construction of the main substation site. No concerns were raised in the relevant representations for Rampion 1 regarding traffic on A272 at the Wineham Lane turning. Noise, air pollution, quality of life and access to health care will also be affected. Economy: Rampion have significantly downplayed, or indeed hardly considered the economic impact of the construction traffic on the economy of Cowfold and wider community. Neither have they weighed this in the balance when choosing the site. Rather, they have focussed on the largely tourist economy of the South Downs and Coastal areas. There are 130 businesses in Cowfold which could be negatively affected by the additional congestion, loss of business, delayed deliveries, and diversions using adjacent lanes. From a wider perspective, over 18,500 road users would be severely inconvenienced by sitting in unnecessary queues as they approach the village of Cowfold every day. The loss of productivity, delays in receiving supplies and loss of business as people are put off from visiting as a result of the traffic congestion, could be catastrophic. The Oakendene industrial estate is a significant provider of rural employment in this area, yet it faces extinction as a result of the traffic delays and construction compounds required to be navigated in order to access it. I believe that the economic impacts, which will result from the choice of this substation site, would be far more serious than at the alternative locations. Ecology: The ecological, economic and social impacts of the proposals have been significantly downplayed or ignored by the Applicant. NPS EN-3 section 3.8.16: “where development affecting irreplaceable habitats requires the benefits (including need) to clearly outweigh the harm.” The area of the northern end of the cable route approach and exit form Oakendene are just such irreplaceable habitats and the risks do not justify the benefits, as reasonable alternative locations exist. EN-1 section 5.4.2 recognises the importance of the government’s policy for biodiversity as set out in the Environmental Improvement Plan, Biodiversity 2020 and the National Pollinator strategy whose aim is to halt biodiversity loss, support healthy well-functioning ecosystems and to establish coherent ecological networks, more resilient and adaptable to climate change effects. Rampion’s proposals are in direct conflict with these aims by the choice of substation location, and, in line with the mitigation hierarchy, (section 5.4.42), cannot be justified as less-damaging options exist. Instead of making the wildlife more adaptable to climate change, they in fact reduce their resilience to change by causing irreparable damage to species, habitats and connectivity. Although the area is undesignated, its habitats and species are of such significance, as we watch the biodiversity decline elsewhere across the nation, that they should be protected, and that alternative, less damaging cable route and substation sites exist which could provide the necessary infrastructure without significant delay. Landscape, visual and heritage: Rampion have consistently underestimated the landscape and visual impacts of the substation and the damage to heritage sites including Grade 2 listed buildings, including the context in which they sit within the landscape. They have not paid proper attention to the heritage aspects of the landscape itself, nor of the part that it plays in the ecological importance of the area. They have consistently failed to include many of the nearest properties when assessing visual impacts, noise, lighting or any other impacts and therefore their claims do not give an accurate picture of the truth. The Design and Access Statement (doc ref 5.8) now recognises the existence of a PRoW (no 1786) through the site and the grim impact there will be on this much-loved PRoW from Taintfield wood and around the lake. Also, the heritage impact on Oakendene Manor. They also now recognise the extent of the flooding on this site. None of this was taken into consideration when looking at the ‘engineering constraints’ which informed their choice of substation location. Reasonable Alternatives: Rampion have not properly considered the alternatives. As part of the development falls within the SDNP, Rampion must consider the alternatives (NPS EN-1, section 5.10.31). Further, the Secretary of State should be guided by whether there is a realistic prospect of the alternative delivering the same infrastructure capacity, including energy security, climate change and other environmental benefits, in the same timescale (section 4.2.22). There are suitable alternative substation sites which can be used in the same time frame or potentially less (there being 5km less cable route and no floodplain to negotiate.) and which are far less damaging ecologically and to communities. There is also good evidence that they did not consider this before choosing the site. They admit that they have only a marginal preference for the Oakendene site. I believe that when the additional factors are weighed in the balance, the balance is no longer in favour of using Oakendene Finally, there is widespread concern about the cumulative impacts of this, the Kent Street battery storage farm proposals and Cobwood solar farm. Also, the proposals have materially changed from those consulted on: • The plans for Kent Street have gone from recognising that it is ‘ a single track lane unsuitable for HGVs’ during the informal consultation and the first round consultation , to now expecting it to bear the significant burden of avoiding the AQMA in Cowfold • Extended use of the western compound • The complicated traffic movements now proposed • The numbers of HGVs and LGVs now to be involved has increased several -fold. • AQMA- it is now apparent that there will, even with the use of Kent Street, be considerable construction traffic going through Cowfold, yet from FOI requests to the Parish Council it is clear that they believed they had been given assurances before the first consultation, that NO site traffic would pass through the village. This may explain their apparent decision not to oppose the proposals. I would like to see these topics taken forward as part of a Principal Issue in the Examination. I would also ask you to hold a topic-specific hearing at the Village Hall in Cowfold to properly examine the consequences of the proposed substation and its impact on Cowfold, its community, businesses and environment. I hope that the Examining Authority will allow local knowledge testimony at the hearings. I also ask that the Examining Authority conduct a site visit to Oakendene and Cowfold to properly understand these issues.