Representation by Elizabeth Leanne Marogna
- Date submitted
- 6 November 2023
- Submitted by
- Members of the public/businesses
To whom it may concern, I am writing in with concerns about the impact of the Rampion 2 wind farm if it is accepted. These include but are not limited to: -It is an inefficient use of tons of rare earth minerals in each turbine, especially as the Sussex Bay is a low wind density area. It has been proven that the existing Rampion windfarm generates power on average 34% of the time. This negates the applicant's claim of "producing enough electricity to power all the homes in Sussex, twice over." Records show Rampion has a production claim of 85%, however, it is generating less than 10% of capacity for 41% of the time. This means the claims by the developer are intentionally misleading, and it is a waste of precious resources in an area of low wind and where the RSPB has said it is unsuitable due to heavy bird migration. With these birds, there are insects and bats that migrate across the Channel. Insects are the foundation to our entire world of living things. The impact on insects is lacking in the Environmental Statement. In 2016 a study concluded that 3.5 trillion insects fly over the UK each year. 4 billion fly to and from UK and Europe each year. All pollinators. Some rare migrating butterflies include: Papillio machaon ssp gorganus from continental Europe -rare Pale Clouded Yellow, from N Fr./ cent Eur.-rare Berger’s Clouded Yellow, from Cent.& s. Eur.- rare Clouded Yellow, Annual migrant breeder from N. Africa/ S. Eur. Bath White, from S Eur. -rare Long Tailed Blue, from cont. Eur. -rare Red Admiral, Annual migrant breeder from cent. Eur. Painted Lady, Annual migrant Breeder from N. Africa Camberwell Beauty, migrant from cont Eur. -rare Queen of Spain Fritillary, migrant/ occasional breeder from E & S Eur. -rare Monarch, migrant from USA and possibly from estab. Populations in S. Eur & Micronesia -rare Other species include: Diptera, Flies Marmalade Hoverfly Eupeodes corollae, (hoverfly) Disruption to these species could cause The Butterfly Effect, as loss of one species could damage an entire ecosystem. -Many ecological effects have been scoped out of the Environmental Statement. The Sussex Wildlife Trust, in 2021 wrote: • "Many important habitats and species have been undervalued or scoped out (deemed not to be a concern) too early from assessment. This is especially problematic when ecological surveys haven’t been finished yet." • "Where the likely impacts have been assessed, the categories applied tend to underplay the true impacts. Many are wrongly listed as ‘not significant’ when we believe they will have a significant impact on wildlife." -The Sussex Bay and the South Downs National Park (SDNP) are two highly prized, beautiful places in the UK. By granting this application, we would be denigrating the Natural Assets of the SDNP and the clear view across the serene Sussex Bay. -Current reforms are clear on their vision for future renewable energy projects. The opening statement on the Government document Published 23 February 2023: https://www.gov.uk/government/publications/nationally-significant-infrastructure-projects-nsip-reforms-action-plan/nationally-significant-infrastructure-action-plan-for-reforms-to-the-planning-process#reform-area-3--realising-better-outcomes-for-the-natural-environment "Nationally significant infrastructure will play a critical role in delivering the government’s environmental commitments and supporting our journey to net zero. In bringing forward the infrastructure the country needs, we want to secure the best possible outcomes for the environment so we can live up to our ambition to be the first generation to leave the environment in a better state than we found it. Consideration of environmental impacts needs to be at the heart of early stages of project design, and decision-making, but the current system is too often delivering process rather than helping deliver better environmental outcomes. Our reforms will ensure the NSIP system is better placed to meet our strategic environmental goals and actively address the environmental impacts of development." -If we allow our protected SDNP and Sussex Bay, home of multiple Marine Conservation Zones to be denigrated, it may set a precedent that could see other developers follow suit and sully further Natural Assets. In the drive for Biodiversity Net Gain, it will take more protection and conservation, not disruption and destruction. Ancient hedgerows, untouched forest, breeding sites and habitats - all would be affected and may never recover. -Another concern is for marine life in Sussex Bay. There are many rare and protected species that are in the proposed zone. These include: *Seahorses and shad species are protected under The Wildlife and Countryside Act (1981) (WCA). Under the Variation of Schedule 5 (England) Order 2008, both short?snouted (Hippocampus hippocampus) and long?snouted (H. guttulatus) seahorses and their habitat are fully protected out to the 12 nautical mile limit. This protection means that it is an offence to intentionally or recklessly harm or disturb a seahorse or its habitat. Protection includes a prohibition of killing, injuring or taking, damage or destruction of their places of shelter, or disturbance while such animals are occupying places of shelter. Both short?snouted and long-snouted seahorses are regularly recorded in the English Channel coast, and even at the mouth of the Arun River, (where support vessels would operate from), and both short snouted and spiny seahorses are of conservation importance in UK waters. The Rampion 2 study area is also a potential overwintering area for both seahorse species. *Within the eastern English Channel region there are records of several marine and estuarine species protected under national, European and international legislation. Elasmobranch species that have been included as ‘Priority Species’ on the UK Biodiversity Action Plan (UK BAP) that have the potential to occur within the study area include undulate ray, spurdog, porbeagle shark, shortfin mako, basking shark, tope, and blue shark. *Teleosts (fish, eels) of conservation importance that occur within study area include black bream, sea trout, European eel, smelt, allis shad and twaite shad. Shad are protected from intentional killing, injuring or taking (allis shad) or damage to, destruction of, obstruction of access to any structure or place used for shelter and protection (both allis shad and twaite shad) -There is burgeoning kelp regeneration in the Sussex Bay. With the help of free divers who are, on a daily basis, checking the growth of the kelp and seeing big gains in species diversity and numbers. The sedimentation and changing of seabed from construction and decommissioning is, from the PEIR of Rampion 2: Seabed disturbance during construction: Temporary disturbance to seabed habitat 26,421,466 sq. mtrs Total clearance of seabed for cables 4,500,000 sq mtrs Total clearance for foundations and legs 1,900,000 sq mtrs Estimate weight of the removed material hundreds of metric tons of 'sand and boulders', will be scoured. no mention of the life that resides there. Total introduced hard substrate at seabed level 1,117,400 sq.mtrs Decommissioning 25-30 yrs, disturbance of seabed habitat, 9,916,000 sq mtrs. -Sediment is known to retard growth of kelp, while kelp is a very good sequester of carbon, around 6 times faster than a tree. The seabed is a vast carbon sink - piling will certainly unlock some amount of sequestered carbon. I respect the desire to remove dependence on fossil fuels, however, gas-fired power stations can now be fitted with carbon capture systems. This uses existing infrastructure, improves it, and creates a very clean source of energy. Importantly, without habitat destruction or use of many tons of rare earth minerals per turbine. I thank you very much for your time. Yours sincerely, Elizabeth Marogna