Have your say on Rampion 2
By Jess Price
Only nine more days to have your say on plans to expand the Rampion Offshore Windfarm off the Sussex coast.
The Sussex Wildlife Trust recognises the threats posed by climate change and supports action to tackle the joint climate and ecological crises. However, the construction and operation of such a large infrastructure project inevitably poses risks to wildlife, so we are working to understand what these risks might be and whether we think these risks can be avoided or minimised.
The process of getting consent for the expansion of the Rampion Windfarm is a lengthy one, and this particular consultation focuses on the work that RWE (the developer, and operator of Rampion 1) has done so far to assess the impacts on the environment and local communities. This is a really important opportunity for everyone to give their views about the Rampion 2 proposals and influence the final plans, due to be submitted to the Planning Inspectorate in 2022.
The proposals have major impact, both at sea and across the land, as the cable route is directed to the electricity substation at Bolney. Our response to the current consultation will cover these overarching concerns:
- 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.
- Much more detail is needed on how RWE will minimise the environmental impacts and compensate for any damage caused. This should include monitoring and aftercare, with associated funding identified and secured for this. We want to see this set out in detail before the application proceeds any further, taking into account the lessons learned from past successes and failures of the Rampion 1 project. For example, we would like to see a Marine Mammals Monitoring Plan prior to consent, with RWE ensuring adequate funding to allow these surveys to take place.
On land, we are particularly concerned about the amount of hedgerow and woodland likely to be impacted, and the lack of information provided on mitigation, compensation and restoration to maintain, restore and enhance the ecological connectivity of the landscape. We are also concerned that vulnerable birds such as Nightingale and Turtle Dove have not been specifically considered. Nor have migrating non-seabirds that cross the impacted area each year.
Some of the habitat mitigation and restoration undertaken for Rampion 1 wasn’t completely successful. Information on successes and failures needs to be provided, so that we can be realistic about the environmental impacts of Rampion 2 and how long these will last. For example, it’s clear that there are still gaps in hedgerows created by the Rampion 1 cable route, as well as changes to soil structure.
At sea, we are concerned that not all appropriate data sources have been included in some of the desk-based baseline studies. Again, we are concerned that impacts on specific species have been underplayed, including seahorses, Herring and Black Sea Bream. It’s important that developments like Rampion 2 should not compromise the Sussex IFCA’s ability to maintain and promote sustainable fisheries and protection of the marine environment.
We know that many of you are really supportive of the Sussex Kelp Restoration Project and currently we do not think it has been given due consideration - especially given the high volume of responses raising concern for how this will interact with the development during the informal consultation earlier this year. This definitely needs to be addressed. Overall, we need much more information on the total long-term habitat loss of each habitat type, the length of loss and how this might change under different array/route options.
Rampion 2 is a Nationally Significant Infrastructure Project, so there is currently no national policy requirement for the project to deliver net gains to biodiversity i.e. leave wildlife in a better state then it was before the development. However, Sussex Wildlife Trust is pushing for net gains to be delivered here as an example of best practice, and what is urgently needed given the ecological emergency we are all facing.
We have summarised our main concerns here but our full response will go into much more detail. The Wildlife Trust’s National Marine Energy team are working collaboratively with us so that we can make appropriate representation on a local and national level, applying our local knowledge as well as more universal expertise on offshore wind in UK waters.
We would really encourage you to get involved in the consultation and have your say before the deadline of Thursday 16 September. We hope that our observations here are helpful for your own responses.