Representation by Middleton on Sea Coastal Alliance (Middleton on Sea Coastal Alliance)
- Date submitted
- 5 November 2023
- Submitted by
- Members of the public/businesses
Middleton on Sea Coastal Alliance (MOSCA) A community organisation Interested Party Registration Comment Comment Registered by Melanie Jones – 5 November 2023 I have Registered on behalf of Middleton on Sea Coastal Alliance (MOSCA). We have a significant Visual Adequacy Consultation and right to information concern over the Rampion 2 Project: There has been a basic, and vital, deficiency of real-life animation or static representations depicting Rampion 2, made available to residents, businesses and the wider public to offer an accurate ‘real life’ indication of what the array could look like from particularly the coast. This has been requested by the Parish Council, by MOSCA and residents from the start of the first Consultation process. Building applications by law must provide drawings and back up illustrations for, particularly, large projects. After lengthy delays these requests and reminders for visual aids have been ignored then disregarded without proper explanation. This procedure has been disingenuous and not least disrespectful to those who should have been fully consulted and could have to live with the construction now and in the future. We therefore, request the Examination Panel notes the significant importance of the lack of any authentic visual information or aids to residents and the wider community during both Consultations and to fully respect that residents’ rights have not been fully represented to enable them to have an accurate view of the array planned for the horizon of the Sussex Bay and therefore to have been able to fully engage with an ‘open information’ project. We also request: 1. The ExA should invite the Applicant to provide adequate static representations and visual animations. 2. Failing that, the ExA should be open to consideration of animations to scale already available and demonstrably credible. (See link below to PCS requested to be included with this comment) 3. Further that these animations should be considered in combination with written and oral evidence on the applicability of the OESA strategic advice on visual buffers the opportunity for IP discussion in a topic-specific hearing where the full application of the OESEA advice to Rampion 2 is a Principal Issue. 4. Examine why the Applicant has not taken into account the visual buffer guidance for installing turbines of this scale in the government’s OESEA advice on visual buffers, as required in the National Policy Statements (EN-3). That should take evidence on why the OESEA should be interpreted and fully applied in the Rampion case. 5. The ExA should invite and allow local views in that topic specific hearing to examine why the Applicant has not considered the visual buffer guidance for installing turbines of this scale in the government’s OESEA advice on visual buffers, as required in the National Policy Statements (EN-3). That should take evidence on why the OESEA should be interpreted and fully applied in the Rampion case. The Rampion 1 Array sight line from Middleton on Sea, is currently visible to the left of Littlehampton. We understand there would be a minor ‘shipping gap’ or corridor to ease access for Littlehampton Harbour between the existing Rampion 1 turbine array and the start of the far larger Rampion 2 array of about 2.2km as it spreads westward to Selsey. Unfortunately, the benefit of this gap as a visual break will only be enjoyed along a small length of coastline cantered around Goring by Sea. Two thirds of the proposed new turbines would be placed to the west of the gap, the remainder would be to the east – to the south of the existing Rampion 1 Array. From nearly all viewpoints along the coast, and particularly from the Bognor Regis/Selsey end of the bay it would not be possible to discern there is a gap as the two areas of new turbines and the original Rampion 1 Array would merge into a chaotic cluster extending across most of the field of view. Consequently, the turbine grouping will impact the sea horizon view in daylight – at a stand or spinning – together with the use of flashing red navigation lights particularly at night – there will be no part of the horizon that is not adversely affected by the grouping. This is a major visual life change for the natural seascape and character of landscape and coastal communities and views from the South Downs National Park for generations to come and would change exponentially the cultural and mental health benefits of coastal life and visiting the area. There is nothing natural in this construction of ‘utility machinery’ and it has and is concerning that the Developer has, effectively hidden the proposal in illustrative terms, from public view. With no ‘official’ project visual animation available from the Developer to illustrate the proposed array nor real life indication of the 325m height and bulk of the turbines – it appears that Rampion 2 will significantly and adversely ‘fence in’ the entirety of the sea horizon* As the disturbing exchange of letters between the Planning Inspectorate and the Applicant on Section 51 Advice so clearly indicates There has been no clarity on Turbine height or number which makes the understanding all the more difficult – either up to 116 turbines (WTGs) up to 240m tall or up to 75 turbines (WTGs) up to 325m tall. Or 90 wind turbines up to 325m tall. The latter two being 2 ½ times taller, more visible and far more intrusive and transformative. The latter larger turbines should be at least 25 miles offshore, not close inshore as in this case we understand is normal Government policy. The Planning Act (2008) says the adverse impacts offshore wind proposals will be evaluated on the basis of the worst case. As in Pins Advisory Note 9: https://infrastructure.planninginspectorate.gov.uk/legislation-and-advice/advice-notes/advice-note-nine-rochdale-envelope/ Other concerns relating to the proposal are also visual but have environment and mental health consequences for this area: § Building the overall size of the proposed Rampion 2 will cause considerable environmental damage to the Sussex seabed which is only now slowly recovering from years of bottom trawling. Kelp farms are beginning to re-establish themselves. All this progress will be put back years. § Adverse impacts on migrating birds and the cross-channel migration of flying insects estimated to be 3+ trillion a year (a major impact on pollination services on both side of the channel); It will, both in the construction and future operation create a disturbing number of carcasses and injured creatures washing up along a coastline not least an uninterrupted view of what has to be called an industrial view – which has fairly recently, been incorporated into part of the Natural England Coastal Path supposedly to encourage healthy living and exercise and enjoyment of natural surroundings. It is a fact that natural surroundings and a long sight view of horizons has major benefits to positive mental health. Rampion 2 would undermine, rather than support the achievement of sustainable development of south coast inshore waters and affected coastal and inland communities and the adverse effects of Rampion 2 outweighs the benefits. Looking closely at a balance across the 3-pillars of sustainable development (social, environment and economic) from construction, through operation and decommissioning stages, thus considering how Rampion 2 impacts current and future residents and the visitor economy. Separately, the economic argument for Rampion 2 does not stand up. The present Rampion 1 field has an efficiency rating of just 37-38% on an average annual basis. This coastline is not a logical wind catchment area. We will be adding further important data and information during the Examination period when allowed. *Please see these two links which we feel are pertinent to add to this Representation, with PINS permission. The first being a BBC South report and the second factual animations that have been produced, by Protect Coastal Sussex (PCS) in lieu of the unavailable requested animation from Rampion 2 [REDACTED] [REDACTED]