Increasingly people are deeply concerned about climate change and the preservation of our environment and planet for future generations. A noticeable shift in attitudes towards sustainability and recycling, especially among the younger generation has emerged. Investors are demanding more environmentally conscious investments, leading to billions of pounds being poured into ESG funds (Environmental, Social, Governance).

Greenwashing In May 2021 The Economist published an article revealing rampant “greenwashing” and called for more disclosure and transparency from companies. This practice misleads consumers seeking environmentally responsible choices and undermines the credibility of authentic eco-friendly products and services. Companies can employ diversionary tactics, drawing attention away from their detrimental environmental practices. Their failure to offer transparent information or data about the environmental impact further complicates consumers’ ability to verify their claims.

While the investment industry is eager to support green initiative and has committed substantial funds, it acknowledges the prevalence of greenwashing. Efforts are underway to ensure that investments meet stringent criteria, aiming for genuine environmental friendliness.

ESG

ESG (Environmental, Social, Governance) investing traces its roots back to 2004. However, in practice, ESG information’s utility in investment processes remains somewhat constrained due to ambiguous data, inconsistent standards, and short term investment horizons. Firms can easily boost their ESG score, by transferring “dirty” assets to a new owner, who maintain the status quo.

Despite the proliferation of sustainability-rating schemes, they suffer from a number of inconsistencies leading to confusion. To counter such disparities and foster genuine investments, IMCA has devised new criteria for green bonds.

Green Bonds

In response to the growing awareness of greenwashing and its potential repercussions, the ICMA (International Capital Markets Association) introduced the Green Bond Principles. This voluntary process aims to instill integrity and transparency in the green bond market, intending to establish a cohesive benchmark and eradicate greenwashing practices.

EU Taxonomy

The EU Taxonomy Regulation effective since July 12, 2020, serves as a green classification scheme, evaluating environmental performance in certain economic activities. It identifies environmentally sustainable activities and outlines methodologies for calculating sustainability turnover. This regulation plays a crucial role in steering the financial system towards a low carbon economy, in line with the Paris Agreement.

The six EU environmental objectives are:

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy

5 Pollution prevention and control

6 Protection and restoration of biodiversity and ecosystems

Certification as environmentally sustainable, under Taxonomy requires a substantial contribution to at least one of the specified objectives, whilst avoiding significant detrimental impact on the other five.

EU Taxonomy hopes to end the practice of greenwashing and have a coherent benchmark. 

The screening criteria is as follows:

i Make a substantial contribution to one or more environmental objectives

ii Do No Significant Harm (DNSH) to any other environmental objective, such as protecting bio diversity

iii Comply with minimum safeguards

iv Technical screen criteria

Do No Significant Harm.

The DNSH principle is outlined in Article 2(17) of the SFDR (Sustainable Finance Disclosure Regulation), requires that financial products making sustainable investments ensure that neither the environment nor the social objectives are significantly harmed.

The DNSH principal specifically aims to ensure that actions supporting one environmental goal do not detrimentally affect other objectives, such as biodiversity. This principle serves as a fundamental factor in categorizing economic activities and financial products as sustainable

One critical framework that aligns with this principle is the CBD (Convention of Biological diversity), which emphasises the conservation and sustainable utilisation of biological diversity, encompassing generic diversity, species diversity and habitat diversity. The CBD asserts that any project should prioritise biodiversity as wither the primary or secondary objective.

https://www.icmagroup.org/News/news-in-brief/the-principles-announce-updated-guidance-for-transition-finance-and-climate-themed-bonds-and-the-integration-of-sovereign-issuer-considerations-in-the-recommendations-and-tools-for-sustainability-linked-bonds/

Rampion have confirmed that they will comply with EU Taxonomy and the principles of DNSH.

RWE Green Financing Framework 2023

On p30 of RWE’s funding strategy, they confirm Alignment with the ICMA Green Bond Principals and LMA Green Loan Principles 2023 and state they are fully aligned with the EU Taxonomy.

The Green financing criteria are aligned with the:

1 Substantial Contribution Criteria and

2 Do Not Significant Harm (DNSH) and

3 Minimum Safeguards

The proposed substation at Oakendene/Kent St

The residents of Cowfold have voiced concerns regarding the decision of Rampion 2 to construct their substation at Oakendene, situated on undisturbed floodplains, known for their abundant biodiversity and numerous protected species. Residents question why an alternative site just a mile away along Wineham Lane, which avoids floodplains and poses less environmental impact hasn’t been chosen. Moreover, this alternative wouldn’t pose as much economic and social damage.

Publicly available representations on the Planning Inspectorate website highlight repeated environmental concerns expressed by residents and environmentalists across Cowfold, spanning the South Downs to t the coast. Primary among these concerns is the perceived downplaying or neglect of environmental issues, along with omission of significant and pertinent data. Doubts have also arisen about whether the alternatives were adequately assessed before deciding to build on floodplains.

While the initial land acquisition cost might be lower for undisturbed plains, the long-term costs could soar due to the expenses associated with implementing intricate engineering solutions and ongoing maintenance. These un-touched areas require careful consideration for their unique environmental aspects including the preservation of delicate ecosystems, diverse biodiversity and maintaining water neutrality. Preservation efforts must extend to protecting endangered species and their ecosystems.

Constructing on floodplains might necessitate raising the structure above the base flood levels or employing stilts, piers, deeper piling or raised foundations to mitigate flood risk. Incorporating flood protection measures, robust drainage systems and complex Sustainable Drainage Systems (SuDS) becomes imperative. Consequently, ongoing operational costs are likely to escalate due to regular inspections and maintenance of flood protection measures and drainage systems. Given that the Cowfold stream passes through these plains and feeds into the River Adur, diligent monitoring and control of water pollution are crucial, as downstream communities could be adversely affected. Nearby properties may face heightened flood risks, potentially leading to increased flood insurance premiums.

The Environmental Argument, from a local perspective.

The Oakendene site is nestled within the untouched expanse of the River Adur catchment area, paints a vivid picture of biodiversity. It encompasses a mosaic of small fields, flood meadows teaming with life, dense lichen-covered hedges and stands of majestic mature oak trees. The decision to establish the substation here is poised to inflict substantial harm, eclipsing perceived benefits. The choice appears unnecessary when considering the wealth of ecological richness present.

In stark contrast, the alternative site along Wineham Lane stands distinct for its absence of this delicate ecosystem. Its selection for the substation would result in significantly less ecological damage, particularly as it avoids disrupting the intricate patchwork of unfarmed flood meadows surrounding the Cowfold Stream and its tributaries.

The reasoning behind selecting this particular substation site lacks consistency and transparency. Crucially, no biodiversity data was made available prior to the Developemtn Consent Order (DCO), rendering it impossible for wildlife organisations and local residents to accurately evaluate the evidence. Moreover surveys were conducted just before the DCO submission, precluding any meaningful assessment against the available alternatives. This sequence of events raises concerns about the credibility and thoroughness of the decision-making process, especially regarding the site’s impact on biodiversity and local ecosystems.

Under threat and inadequately surveyed in the proposal are:

1) Nightingales Red List (22 territories recorded this year directly in the cable construction route) Total of 51 entries into the records. Other protected and declining bird species: skylarks, cuckoos, turtle doves, barn owls, tawny owls, house martins

2) Priority Habitat of Unimproved Lowland Meadows, particularly at Crateman’s Farm. A rare habitat for many insects, mammals and birds. This is not acknowledged in Rampion 2 documents submitted but we have strong evidence to endorse this designation.

3) Ecology of Kent Street and Moatfield/Kings Lanes covering a toad migration, field edge plants (including orchids, wood anemones), glow worm breeding locations, all in the cable construction route. The tributary used for the toad migration is dug up by the cable trench.

4) A Green Lane dating over 150 years with a double row tree boundary, and a well-worn animal track between. This is bisected by cable construction, disconnecting the established wildlife corridor, with the loss of many mature trees and leaving a massive tree gap.

5) Badger territory is extensive in the cable route approaching Oakendene. An active sett is exactly in the middle of the cable route

6) Adders, grass snakes and slow-worms. They are all UK Priority species in decline and construction vibration and disturbance will destroy a particular well-established population

7) A lake with bats, flying insects, water voles, otters and water birds next to the substation (this is the only option put forward which is next to a large lake

8) Extended route incurred by this substation option loses many more mature oaks, scrub and dense hedgerow than the alternative.

9) Flooding patterns and water quality are essential to the rich ecology here, but would be seriously impacted by construction

Surveys of priority red list bird species have been inadequately undertaken. Rampion has stated that ‘Desk Study’ is considered sufficient for the cable route, yet in such privately owned undisturbed land little recording has already been done to show up in this way.

Breeding birds whether nesting at ground level (sky larks) in very dense hedging (nightingales) or in trees are all taken together as ‘breeding birds’ and considered a timing issue only, so appropriate habitat mitigation for their nesting sites is not put forward.

Rampion have written that they do not survey for reptiles in the cable route regardless of UK BAP status or threat of extinction (adders). A materials depot and cable construction surround an established breeding site at Cratemans. We have added 7 grass snake and 8 slow-worm sightings to the records this year.

Rampion say they do not survey for amphibian migration in the cable route as they are not destroying ponds, but they are cutting through the tributary which is access to the breeding pond and used in migration. They say that minimal hedge loss will mitigate against disruption, which is incorrect as toads use roads and streams in the migration.

Rampion will not engage in any conversation about preserving the Green Lane wildlife corridor, or options of minimising the tree loss. 22 trees are in the area marked for removal and some are mature oaks.

Light pollution in the cable route is not being considered in how it impacts glow worm breeding, toad migration, badger feeding, and nightingale breeding - as they are not surveyed. Winter construction and trenchless crossing compounds would all add to the impact, especially if security lighting is used over-night.

Flooding

The flood patterns here are well established. The construction will interfere with this and inevitably people’s properties and access routes will be affected by unexpected flood water, as they were in Rampion 1. Water courses were also polluted by fuel leakage in the construction process for Rampion 1. Rampion 2 has two trenchless crossing depots very close to the Cowfold Stream only in this substation option. The area is flooded through winter and randomly at other times of year including summer. Equipment is known to discharge fuel residue in the water and accidental leakage, as happened before, remains a possibility. This threatens to spread via flood water and as consequence would go on to pollute the River Adur.

The local community

The psychological impact on local people is missed out in the proposals. The anticipation of noise, vibration, vehicle activity impeding access, where it is so quiet, and the industrialisation of such a rich biodiverse area has meant that the detrimental impact has already begun.

Many people from Oakendene Industrial Estate, Cowfold and further across Sussex walk, ride and cycle in this area of the River Adur catchment. This is being greatly underplayed, when footpaths, bridlepaths and lane access will be compromised or shut over the years of construction. The Wineham Lane North option had far less impact on this type of use.

Poor Re-instatement

The very poor reinstatement of vegetation after rampion 1 is visible and well documented. As a consequence, we have no trust in any promise of reinstatement this time, nor the promise of biodiversity net gain. We have asked how things will be different this time, but have had no answer.

As UK has been found to be one of the ‘world’s most nature-depleted nations’ how can we accept this much loss of undisturbed habitat for the sake of a wind farm which only lasts 25 years, especially when there are much less damaging alternatives?

These irreplaceable habitats and biodiversity in this area demand significantly more serious attention and thorough consideration. Their preservation and protection should be paramount, warranting meticulous care and thoughtful evaluation in any decision-making process.