March 2024

As in the message below shared with ADC, we are happy to share the attached input to the Rampion 2 Examination Authority in the form of 3 substantive written representations (WRs) prepared by Sussex community organisations. We are also sharing this input with other bodies including WSCC, SDNPA and area MPs who have been very supportive of our concerns and have objected to Rampion 2. 

The attached PDF named "1-Overview...". has a one-page bullet point summary of each WR. We hope that you will find these informative and can share this appropriately with Councillor and Officer colleagues at your Council.

Sincerely, 

 The Secretary

The Littlehampton Society

Subject:   Rampion 2 Examination Input from Sussex Community Organisations

Further to previous correspondence on this matter over the past few years, we write to inform you of the submission of three written representations (WRs) to the Rampion 2 Examination Authority (ExA) by local community organisations operating under the umbrella of Protect Coastal Sussex (PCS).

These WRs were submitted on 28th February, 2024, for the ExA Deadline 1.  They encapsulate critical local community perspectives supported by evidence on the proposed Rampion 2 development.

We appreciated material in the ADC statutory Local Impact Report and Principal Areas of Disagreement Statement (PADS). 

Attached to this correspondence, you will see the full versions of the three substantive representations, each provided in separate PDF files with accompanying summaries:

WR-1:              Local Impact Assessment (LIA)

WR-2:              Due Diligence on claims about the performance, benefits, and impacts

WR-3:              Consideration of Alternatives in the Rampion 2 Examination

Additionally, a concise overview of key aspects for each WR is offered on one page (one for each WR) in Attachment 1.

Drawing from the evidence presented in these representations, we wish to highlight some overriding considerations that we believe merit careful attention:

1.       Compliance with Obligations: We question whether Rampion 2 is in breach of international treaty obligations and aligned UK national policy and law, particularly considering the European Convention on Landscapes (ECL) as interpreted by the Government’s Offshore Energy SEA (OESEA-4).
2. Assessment of Tradeoffs:  That the adverse effects of Rampion 2 outweigh the national benefits, considering all metrics of benefit as outlined in the relevant National Policy Statements (NPS, Energy).
3. Impact on Sustainable Development:That Rampion 2 poses an unacceptably high risk of undermining rather than advancing the achievement of sustainable development on the Sussex coast and affected inland areas, including designated landscapes.
4. Assessment of Alternatives: Our assessment of alternatives, utilizing NPS policy-relevant indicators, suggests those Alternatives offer greater value than the £3-4 billion capital outlay Rampion 2 would require, without incurring the same high economic, social and environmental opportunity costs.

 

Apart from the potential breach of the European Convention of Landscapes and the new Levelling up and Regeneration Act (2023) that increased the protection of National Parks by making it an active duty for Rampion 2 to further the statutory functions of the South Downs National Park (according to Natural England as we cite, rather than only take note of them), we see no net biodiversity gains either in the marine or terrestrial settings, rather the opposite.  

We refer to various PAD Statements by statutory consultees to support that conclusion.

We also see a significant adverse impact on the south coast tourism sector over time, which we attempt to simply quantify by proxy.  And we offer clear evidence that refutes the Applicant's methods and claims there would be no adverse impact on the tourism economy. 

We trust that the information and evidence presented in our representations will be considered in the Council's ongoing interactions with the Rampion 2 ExA in the coming months, leading up to August 2024 completion of this Examination.

Respectfully,

 

The Secretary

Protect Coastal Sussex (PCS) 

Member of the Rampion 2 Community Project Liaison Group

On behalf of PCS Co-Chairs:

Chris Lee, Aldwick

Melanie Jones, Middleton on Sea

Lawrence Haas, Littlehampton

Meera Smethurst, Cowfold

1- Overview Attachment - One page summaries of 3 PCS Written Representations to the Rampion 2 ExA

Protect Coastal Sussex WR1 Local Impact Assessment_28 Feb 2024_2

PCS WR2- Due Dilligence on Applicants claims on benefits and impacts of Rampion 2 - 28 Feb 2024  Circulation

PCS WR3 - Consideration of Alternatives in the Rampion 2 Examination 28 Feb 2024 Circulation