Rampion 2 Wind Farm

ADC01

Construction Compound

Concerns regarding the substantial size of Climping Compound covering 6.13ha and limited details provided on its use. The draft Development Consent Order (DCO) refers to Work No.10 only as a ‘temporary construction compound’, although several assessments refer to concrete plant. 

Concerns that our Environmental Health Department has not previously been consulted on the proposed final location of Climping Compound.

Whilst we appreciate a degree of flexibility is required, further detail of Climping Compound, including on its use and justification for the substantial size, is sought. 

A description (comparable detail to other Work No. descriptions) of its use is sought in the draft DCO or another document where there is a commitment to comply with the description. 

To be discussed

ADC02

Mitigation, monitoring
and compensation

Concerns regarding the lack of commitment and securing mechanism of mitigation, monitoring and compensation. For example, the mitigation set out in the Commitments Register refers to where practicable, where feasible, if necessary. Furthermore, some mitigation/compensation such as the Supply Chain Plan and the Community Benefits Package do not appear to be defined and followed through to a commitment and/or securing mechanism. In addition, the construction communications plan should include Climping Compound.

We will incur additional expenditure relating to the discharging of requirements/associated applications.

Firmer commitment to mitigation/compensation and these to be followed through to a securing mechanism. 

We are of the opinion that compensation ( for example community fund such as that for Rampion 1) is required for significant effects that cannot be addressed by embedded mitigation measures, for example, the significant effects on seascape from the Arun coastline.

Seek to recover costs associated with discharging requirements/applications such as S61 applications.

To be discussed 

ADC03

Alternatives

Insufficient evidence of reasonable alternative locations (taking into account environmental effects) has been given for the temporary construction compound at Climping. The main reasons for the selection of this location next to a residential area and tourist assets have not been given. 

During the initial route option process and for the additional land included within the DCO limits at the landfall at Climping during route modification, it is not evident that Climping Site of Special Scientific Interest (SSSI) or the strategic housing allocation were considered as part of the route selection process. Instead, Chapter 3 ‘Alternatives’ of the ES states that one of the key reasons justifying the preferred route was that ‘statutory ecological designations are largely avoided along the onshore cable route, and none were identified within the onshore cable corridor at this stage’. 

We require further information on the options and appraisal to demonstrate consideration of environmental, social and economic effects have been taken into account in the selection process for the onshore corridor route at landfall location of Climping Compound. 

To be discussed

ADC04

Outline skills and employment strategy

Concerns that limited detail is given within the outline skills and employment strategy and that we are not listed as a consultee.

For us to be listed as a consultee.  

To provide more information on the strategy and benefits for us, including linking to apprenticeships and local education institutes in Arun. Objectives need to include support for local SMEs and opportunities for SMEs to access the supply chain. Measures to also be secured through the Outline Code of Construction Practice.

Likely

ADC05

Community package benefits

We believe that the district will not significantly benefit from the project, rather the area will experience disruption and significant adverse effects, some of which are unlikely to be mitigated. 

Concerns about the mechanism regarding which the community benefits package is secured and the criteria/funds involved as not referenced in the draft DCO.

Further information on a community benefits package. 

Commitment (and securing mechanism) needs to be made to us for this package to compensate and offset adverse effects within the district. 

To be discussed 

ADC06

Jobs

Job creation (construction and operation) has not been assessed at the district level within the administrative area of Arun.  

Employment effects, including job numbers, should be assessed at district level and not just at County level. Employment relates to the skills and employment strategy as the outcomes of the Strategy in terms of developing skills and employment opportunities may influence the spatial distribution of benefits.

Likely

ADC07

Tourism and assets
tourism

We have concerns regarding adverse effects on tourism and tourism assets, including potential displaced tourism from Arun.

Chapter 17 of the Environmental Statement (ES) states that regarding the construction effects of wind farms ‘the research typically focuses on measuring opinions on what the impacts on the visitor economy could be prior to implementation of the scheme. However, ex-post research suggests that even where there have been negative effects, these often occur in the form of displaced tourism with visitors diverting to neighbouring areas instead’. Whilst this may be considered a neutral effect at County level, it suggests areas directly affected by construction such as Arun will experience at least temporary adverse effects, even if Sussex overall has a neutral effect. 

Chapter 17 also notes that at the local level ‘installation activity along the onshore cable corridor may have a negative impact on walking and cycling routes, coastal paths, holiday parks and other tourism-related assets that are located in close proximity to onshore construction work. The assessment concludes that during the construction phase, there would be major/moderate, and therefore significant effects on a limited number of tourist destinations. These locations are Climping Beach, Climping Camp Site, Climping Caravan Park and Washington Caravan Park. Many of these locations are in Arun and there are also other local assets that are omitted which will experience adverse effects. When this is measured in Sussex the effect is negligible, however, for residents and local businesses in Arun, the effects may be significant and this should be recognised.

Further information is necessary on the effects and mitigation local (Arun District) level, as the list of tourism assets is not considered complete. 

Furthermore, mitigation such as ‘C-33 An Outline COCP will be adopted to minimise temporary disturbance to residential properties, recreational users and existing land users. It will provide details of measures to protect environmental receptors is not considered actual mitigation as it is an attempt to minimise disruption, which is not to say that significant disruption will not occur. Adverse effects on tourism and tourism assets will need to be overcome through community compensation notably via the community benefits package. Specific mitigation should be put in place for Climping Compound regarding nearby tourism assets.

To be discussed.

ADC08

Strategic Allocation
Housing

The cable route transects through a strategic housing allocation (Policy H SP2b, SD4:

Littlehampton – West Bank) identified in ADC’s adopted Local Plan. The allocation is for circa 1,000 residential dwellings that will be key to supporting future regeneration of the town and the Littlehampton Economic Growth Area. 

ADC has significant concerns that the route will sterilise the western part of the allocation and impede the ability to bring forward this site for housing. 

Details are required on what impact the project is likely to have on the strategic housing allocation, including any sterilisation of land, and the effect on housing delivery within Arun.

To be discussed. 

Seascape, landscape and visual   

ADC09

Scale and extent of Wind Turbine Generators 

The spatial extent is greater than Rampion 1 and we continue to have significant concerns regarding the scale relative to the proximity to the coastline and the resulting significant visual effects.

We recognise that the spatial extent has been reduced. However, there will still be significant visual effects on the coastline, for example, from Climping Beach and Littlehampton seafront, which are tourist and recreational destinations. 

We are of the opinion that as no further mitigation is possible, compensation is the only route.  

To be discussed. 

ADC10

Construction Compound

Concerns regarding visual effects of the landfall construction compound (Work No.8) and Climping Compound (Work No.10); the latter is substantial in size.  

We expect the visual effects from viewpoints (to be agreed) to be assessed. 

Seek appropriate landscaping boundary treatments for Climping Compound to be secured and implemented.  

To be discussed. 

ADC11

Permanent Infrastructure
corridor  

Permanent infrastructure corridor width up to 25m (or wider at trenchless crossing locations).

Details are required on the surface treatments within these permanent infrastructure corridors, any requirements for easements in these areas and whether this impacts reinstatement.

To be discussed. 

Terrestrial and marine ecology  

ADC12

Climping SSSI

Significant concerns regarding the cable route passing beneath and near to the Climping SSSI and ecological sensitive areas. Nationally scarce invertebrates have been identified on the sand dunes of Climping beach. We note access would be restricted in the SSSI and no groundbreaking activity. However, there remains the potential for unplanned events and localised degradation of habitat within the SSSI, which is of concern.

To undertake an invertebrate survey of Climping SSSI. 

To provide an assessment of indirect effects to the SSSI.

To be discussed. 

ADC13

Terrestrial biodiversity net gain

Biodiversity net gain has not been assessed at the district level. We would expect biodiversity net gain to be achieved within the administrative area of Arun.

To provide a biodiversity net gain matrix specifically for the area within Arun.

The maintenance programme will need to align and comply with the requirements of the biodiversity net gain for Nationally Significant Infrastructure Projects, which is expected to come into force in 2025.

Regarding Requirement 14 in the draft DCO (Part 3), ADC request that it is amended so that the biodiversity net gain strategy for stages that relate to areas within Arun is also submitted to and approved by us.

Likley

ADC14

Marine biodiversity net gain

To demonstrate marine biodiversity net gain. 

We expect marine benefits to be achieved and contribution to marine restoration projects such as Help the Kelp. 

Consideration should be given to a marine biodiversity net gain assessment.

To be discussed. 

Noise

ADC15

Potentially detrimental effects of Climping Compound on Land to the west of Church Lane, South of Horsemere Green Lane, Climping (planning ref. CM/48/21/RES,

CM/1/17/OUT).

Climping Compound is located adjacent to Land to the west of Church Lane, South of Horsemere Green Lane, Climping. This site has permission for 300 dwellings and therefore has reasonable certainty of coming forward and there is the potential for new residents whilst Climping Compound is in use. No assessment of the noise effects of these future residents nearest to the compound has been undertaken Although classified as ‘temporary’, this compound will be in place for a minimum of 3.5 years with potential for protracted noise detriment. 

Provide modelling and assessment of the noise effects on future receptors introduced by the residential development west of Church Lane and the adjoining Climping Compound. Location of receptor(s) to be agreed with us.

To be discussed. 

ADC16

Noise from Horizontal
Directional Drilling (HDD). Section 61 Applications - The Control of Pollution
Act 1974

Potential for prolonged exposure of sensitive receptors to noisy drilling and ancillary works 24 hours per day over consecutive, often multiple days.

Section 61 applications allow the applicant to apply for prior consent to extend the agreed hours of (noisy) working for specified purposes to be agreed with our environmental health department. This is likely to apply in the case of HDD for 24-hour consecutive, often multiple days.

The applicant to consider temporary relocation of people affected by 24-hour drilling as a method of mitigation where HDD (or other noisy working) is scheduled to proceed for 24 hours per day for longer than 48 consecutive hours.

To be discussed. 

ADC17

Determination  of requirement for Mitigation/ Section 61 consents 

Chapter 21 of the ES states with respect to construction noise effects that determination of the need for Section 61 consent will be determined by the contractor at the detailed design stage, following a review of construction noise assessments if it is determined that there is a ‘significant deviation’ from initial predictions.

Clarification is required on the level of competency of the contractor to review construction noise predictions.

Quantify what is considered a ‘significant deviation’ from predicted construction noise levels. 

To be discussed. 

ADC18

Table 21.23 of Chapter 21 of the ES - Construction Noise ‘Trigger Values’.

These values replicate the values set out in Table E.2 of British Standard (BS) 5228 in particular for the 8am to 6pm time period. Proposed construction hours are stated as 7am to 7pm whereas the shoulder hours (7am to 8am and 6pm to 7pm. Table E.2 suggests a trigger value of 70dB LAeq, T.

Confirm that trigger values are to align with lower trigger value as set out in Table E.2 for the proposed construction periods construction Table E.2.

Review/update construction noise assessment against the revised criterion. 

To be discussed. 

ADC19

Construction noise
predictions/assessment 
outcomes (Tables 21.27 –21.29) 

For some locations that are close to exceeding the 65dB threshold value, the assessment outcome has been increased to reflect potential impact. This has not been done consistently and where there are predicted values that are also close to the threshold value, the outcome has not been increased.  

Review construction noise assessment and increase assessment outcomes where they are within 2dB of threshold/trigger values. This will address the inherent uncertainties that are discussed 21.5.10 – 21.5.11. 

To be discussed. 

ADC20

Climping Compound

There are insufficient details of the noise modelling inputs for the operation of the construction compound.

Provide noise modelling inputs for the construction compound predictions (such as a concrete plant).

To be discussed. 

ADC21

Baseline monitoring data 

Insufficient baseline for noise-sensitive locations in the vicinity of the Climping Compound. Only data for a single location to the southeast of the compound has been presented. This will not accurately characterise existing baseline noise conditions at nearby noise-sensitive receptors, in particular, Climping Village, the caravan park immediately west of the proposed compound, Climping C of E Primary School, Climping Village Hall and play area immediately north of this and glamping at Cuckoo Farm.

Provide additional baseline noise data that is representative of existing sound climate at receptors in the vicinity of Climping Compound.

To be discussed. 

ADC22

Access to cable route west of Benjamin Gray Drive

Potential noise effects of heavy good vehicles (HGV) movements on existing quiet residential roads. No data was provided to support assumptions.

Evidence is required to support assumptions.

To be discussed. 

ADC23

Location of Private Water Supplies

Our environmental health department had not been consulted in this case.

As previously requested, please provide a comprehensive list of private water supplies identified for further investigation due to their proximity to the project.

Likely.

Historic environment 

ADC24

Listed buildings, locally listed buildings and area of characters.

Listed buildings at numbers 45-47 South Terrace, locally listed buildings at 4, 8-95 South Terrace & 16 Granville Road and South Terrace Area of character. 

To provide an assessment for listed buildings at numbers 45-47 South Terrace, locally listed buildings at 48-95 South Terrace & 16 Granville Road and South Terrace Area of character.

To be discussed.