Guest blog – Walshaw Turbine 21 by Nick MacKinnon – Mark Avery

Nick MacKinnon is a freelance teacher of Maths, English and Medieval History, and lives above Haworth, in the last inhabited house before Top Withens = Wuthering Heights. In 1992 he founded the successful Campaign to Save Radio 4 Long Wave while in plaster following a rock-climbing accident on Skye. His poem ‘The metric system’ won the 2013 Forward Prize. His topical verse and satire appears in the Spectator, and his puzzles and problems in the Sunday Times and American Mathematical Monthly. Email: nipmackinnon@gmail.com 

Turbine 21 Pennine Way  SD 97664 34327 ///messed.depend.sourcing

1 June 2025 We are almost at the end of the “non-statutory public consultation” for Calderdale Energy Park, and it has been a sham. What we are being consulted on isn’t a proposal and cannot be the subject of a legitimate Public Consultation. Instead, we were allowed to see CWF Ltd’s dirty laundry in the design of layout 210225-41t, which is not a wind farm but “the snapshot of a process.” So chaotic were the preparations that when I told them the peat map was wrong, posh Tom and amiable Kevin of Cavendish Consulting probably spent the night putting stickers into all the glossy brochures, as though doing their Italia 90 Panini albums. “I’ll swap you two Ally McCoists and a Gianluca Vialli for one Paul Gascoigne.”

In order that CWF Ltd cannot claim that what just happened was a Public Consultation, the Walshaw Turbines Research Group, who are the various people who take part in these blogs, have sent a legal letter to CWF Ltd requiring that the Public Consultation is postponed until it can be held under the Gunning Principles. You can read the letter here, and the evidence base, a lawyered-up version of the blog on the phantom T42. Thank you to our lawyers and their network of legal contacts for thousands of pounds worth of pro bono work and advice.

I went to the Trawden Public Exhibition and finally met some real talent in the opposition. Whatever CWF Ltd are paying Donald Mackay, it isn’t enough. He is from Lewis and has the devastating Highland accent that I am told I have lost, but Donald’s is the purest kind, weaned on Gaelic.

“Machair” is the turf that grows on storm-smashed shells on the true Atlantic coasts of Ireland and the Hebrides. It has corncrakes, orchid carpets and the great yellow bumblebee. If machair could speak, it would sound like Donald Mackay. His Hebridean gaze turns from trawling the western horizon to welcome the sabbath-breaking heathen into his home. A kettle is at simmer on the peat range. There are the sternest luxuries: oatcakes and quarter-peel marmalade.

Donald Mackay’s talent is to tell the truth if it can be told.

I have been asking CWF Ltd about the weakness of the onsite aggregates for 390 days since the blog on Bedlam Knoll. There is a famous Asimov story called “The Last Question” which takes longer to answer than mine, but not much. I asked my question in the blogs, which are read closely at CWF Ltd. I asked my question directly and was told that the project team was “unable to answer it with the information available”, straight out of Asimov. Robbie Moore M.P. asked the question on House of Commons notepaper and was given the brush off. I asked the question in Oxenhope and got Alison Sidgwick’s bluster that wind farm consultants of her seniority cannot be expected to consult geology maps. Finally, Lydia typed in the question at the Webinar on 21 May, and Donald Mackay answered it (43:44) like this, which means he thinks it the costless truth.

“As you can imagine, a project of this scale requires a large quantity of aggregate to be brought onto the site for topping off the roads and for the aggregate requirement for making concrete which will probably be batched on site. The material … the naturally occurring material we have isn’t the best quality for construction, so we will need to strengthen the roads by bringing in aggregate from outside the site. Given the location of the site, it’s fair to assume that the aggregates will come from a number of different sources that will depend on geography and onsite requirements. To be able to manage that kind of quantity of traffic the aggregate sources will be looked at as part of that overall transport assessment. We haven’t identified specific quarries at the moment, but as part of the design process once we have identified the quantities that are required, we will look at it in a lot more detail as part of that traffic assessment.”

At Trawden, I said to Donald Mackay,

“As we both know, the local stone doesn’t make roadstone or concrete.”

He said, cheerfully,

“And nobody round here will sell it to you for those purposes! There’s no compromising on aggregate. If you use something cheap it always costs. Gritstone aggregates are just for bulk fill”.

“What would “topping off” involve?”

“It will be what I call a hardstone.”

“Limestone or granite?” (Trick question)

“Granite is harder. Limestone will erode with time. We need these tracks to last thirty years.”

“The limestone quarries are much closer of course, but the Estate are not allowed to use it on tracks, and they don’t, (Restoration plan 8.1.6 ) because bicarbonate is a sphagnum poison. You won’t be allowed limestone in the SAC.”

(The head gamekeeper passed me on his quadbike while I was on my way to assess the steep descent off Hoar Nib in February “Are you Nick at Upper Heights?” We talked about the moor, genially. We both love it, but his love is deeper and better informed than mine. I made a peace offering for publishing a photograph of bait eggs which had annoyed him. “I’ve been on hundreds of burned strips and only seen one spot, the size of a beermat, where the burning had got into the peat, at most a centimetre deep.” In return he said, “One of the things you need to know is that we never use limestone to build tracks. We use blue granite.”)

Donald Mackay said there might be places where CEP could use limestone, and I take that as uneasiness about all that granite. Wind farm planners always resist reduction of the envelope in which they will game the system. My aim is always to narrow the proposal so it is less attractive to the investors; today I am after the granite.

I drew a cut trench through metre-deep peat.

“The bottom is boulder clay. When you build the track, how much is bulk fill and how much is granite?”

“It would depend on how competent that boulder clay was. We call it subgrade and measure it by CBR.”

“California Bearing Ratio?”

He nodded a quarter inch at this, as once the dominie of Uig Primary School nodded at a young Donald Mackay.

We are both products of the golden age of Highland education, when what was good gained measured approval and what was bad earned four from the heavy leather tawse, expertly deployed. Thanks to this objectivity, Uig and Ardrishaig would be places we came from. Until the Curriculum for Excellence (2010), Scottish education was anchored in the objectivity of the  Scottish Enlightenment for the benefit of the poor, which was everyone in the Highlands. Now each child is on a subjective “learner journey”. The poor children get the Scottish Enlightenment at home if they are fortunate in their parents.

“I would say point six of bulk fill, then probably a textile membrane and a plastic grid and then point four of hardstone on top.”

I asked about the floating tracks. “You want the track to be as light as possible. So, you wouldn’t use any bulk fill, just the hardstone.”

I said, “If you get to build this in an SAC it’s going to be granite. Is the delivery a problem?”

“We can always truck it in. I built a 50-turbine wind farm in Morayshire where we trucked in the lot. It’s best if the aggregates come from different quarries. If they all come from one place the lorries form a convoy. It’s better to have it even out. Sometimes we find little pockets of good stuff. We found a tiny outcrop right on top of a hill once. Couldn’t have known till we got there. Pounced.”

I’ll do some analysis on granite in a later blog. It might come from Glen Sanda on Loch Linnhe (ship and truck) and Mountsorrel in Leicestershire (rail and truck) and Shap in Cumbria (90 miles by truck).

Donald Mackay didn’t think the logistics were a problem. I think the lorry movements will be huge locally, and will reduce investor enthusiasm at high interest rates. If ten thousand rigid tippers from Shap, ten thousand more with granite from Moutsorrel and Glensanda, three thousand with concrete limestone from Grassington and twenty thousand from Alison Sigwick’s bulk fill “quarries to the east of the site” are the last question, the communities on the stone routes will be told to suck it up by Ed Miliband. The emissions from the trucks are not good, but they are second-order items in the CO₂ budget.

The only first-order CO₂ items, dwarfing all others, are actual oxidised peat caused by direct digging and by drying far around the drained infrastructure, offset by notional CO₂ saved by not burning fossil fuels to generate the electricity, which depends on the grid mix used in the calculation. Some say the carbon calculation is primary, but on Walshaw Moor it will be almost peripheral, because local flooding and the two international factors are so powerful. Readers will have noticed how quiet ministers are about CO₂ when they speak about Net Zero to general audiences. Wind and solar are promoted to the bill-payers on energy security and price claims. Wind energy can be free at the point of production, but it is not cheap at system level. Rich consumers with plant rooms and off-street parking already like the bursts of cheap electricity when it’s windy, because they can afford to store it at home, filling a battery bank and home-charging the Tesla at 7p/kWh and 5% VAT. The people in terraced cottages on the stone routes have no plant room, and their car will need public charging at 52p/kWh and 20% VAT. In Scotland, this is called the Just Transition.

The CWF Ltd consultants are serene on the CO₂ budget.

You can also hear their confidence on the peat and blanket bog because they know how to game that too. These Scottish consultants have dug up megatons. Donald Mackay said, “Och fifteen years ago we were … gung-ho about peat, but we’ve learned a lot.” Alison Sidgwick boasts, “We’ve built wind farms on eight-metre-deep peat”. They reckon they can use bog restoration to finesse the SAC designation. I think that’s going to be wrong, but in a complicated way. Something like this: “Blanket bog restoration is already a requirement of ownership under the agreement with Natural England which runs from 2018-2042. If you do enough extra bog restoration to make a real impact on the SAC, given that most of it is going to be wrecked by the wind farm, there won’t be enough left to get to 100 MW, and you still haven’t reckoned with Emily Brontë and the SPA curlews, neither of which can be gamed with a bulldozer.”)

Walshaw Moor, taken in isolation as a local moor for local people, is the kind of factor the consultants always face. They know they can buy off Calderdale Council, who represent some of those local people west of Wuthering Heights, at about £5000 per MW spread over the 30-year lifetime. Some say that Calderdale Council in a closed session have already decided to submit before they have seen a genuine layout. This would be such contemptible behaviour in elected officials and public servants that it cannot be true.

The Pennine Way is a national trail celebrating its Diamond Jubilee: obviously it has had no impact so far in the planning of Layout 210225-41t because T21 is right on top of it.

The three extraordinary hurdles: flooding, Kunming-Montreal and Brontë Country

Donald Mackay faces three extraordinary hurdles. Two are international: the SPA/SAC Kunming-Montreal designations; and Brontë Country. The third hurdle is local and intense: the flooding.

CWF Ltd haven’t started to think about flooding, and the proof is in the hydrology map. It’s only use so far has been to make sure that no turbine in Layout 210225-41t is on top of a watercourse, though in fact T21 is within 10 metres of a significant stream that isn’t even on my laminated OL 21: part map, part horse blanket.

CWF Ltd must show that CEP will not increase the rate of runoff. The proper test would be “CEP won’t accelerate run-off during a once-a-century event” (because in Hebden Bridge that is already once-a-decade). Aviation and nuclear power deal with low-probability high-mortality outcomes all the time, and so must CEP if it going to squat on that dangerous catchment. It is not possible to do much analytical without a complete peat map and a track network, but more on flooding when we get back to Donald Mackay.

The first internationally significant hurdle is that Walshaw Moor is a Special Protection Area for birds and a Special Area of Conservation for habitats. These European designations (it is a Natura 2000 site) have become worldwide because the UK led the Kunming-Montreal Protocol. One of the K-MP targets is area-based conservation for 30% of each country by 2030 (“30 by 30”). England (conservation is devolved) is one of the most nature-depleted countries in the world, so it is very difficult to put our money where our mouth was. Nearly all the land in England’s target 30% is privately owned. The Defra standards for what can count as 30×30 are laid out here and look at this:

“All areas that will be used to count towards 30×30 must meet each of these criteria, regardless of the land being inside or outside of an existing Protected Area. […]

1. 1. 2. Protection: Is the conservation of this area secured for at least 20 years, through legal or other effective means?”

If even an internationally designated SPA and SAC can be developed by the landowner within three years of a comedy Scoping Report (disowned by Donald Mackay as “worse than useless”) then anywhere can be and we have 0% that meets the standard. No wind farm in the UK has ever faced a higher hurdle than K-MP, but the consultants have already started to game the SAC element, and layout 210225-41t is part of that plan.

The second internationally significant factor is that Walshaw Moor is the nucleus of Brontë Country, an internationally revered wedge of land, compact because the sisters walked, which was the inspiration for three of the most famous women in the history of the world, and an eternal expression of British soft power. It is the chosen task of the Worth Valley group, who campaign under the Stronger Together umbrella, to define and document Brontë Country and its relationship to CEP. They will not lack champions among the Statutory Consultees, and one of them will be Bradford Council who are led by Brontë fans and for whom Brontë Country is a major asset. It is an asset for Calderdale Council too, but they may be tempted by the sugar rush. Two wind farm insiders (one engineer, one planner) who have spoken to WTRG in the last fortnight have said that Brontë Country  is the most powerful argument. Seven wind farm insiders have had the courage to speak to me and Lydia now, one of them literally world-leading. They are never on the record, nor would we let them speak on the record. A tenured or emeritus professor can say what they like about academic blanket bog. The post-doctoral peat scientists and ecologists, ornithologists and engineers, visualisation experts and EIA specialists must not risk being blacklisted.

We locals live in Brontë Country and may take it for granted. For many people all over the world it is somewhere they come to once and find to their astonishment that it really is there. The Guardian’s list of the 100 greatest novels of all time has Jane Eyre at 6 and Wuthering Heights at 10. Lord of the Rings is 3 and Middle Earth it isn’t anywhere but our imaginations, but nobody in New Zealand would propose a wind farm under Mount Doom. Barad-dûr had only one red eye. At night, CEP will have 82.

In planning arguments, the compactness of Brontë Country is crucial. Hardy’s Wessex can’t be paramount in every planning proposal between the Thames and the Channel, but Brontë Country is quite another matter. Anyway, Thomas Hardy’s only entry in the top 100 is Jude the Obscure at 49.

Neither flooding, Kunming-Montreal nor Brontë Country were part of the design process of Layout 210225-41t. If the “mitigate-and-cull-dummies” method was used with those three factors in the driving seat, we’d end up with a single 300 MW wind turbine in Richard Bannister’s back garden. The developers must pretend that the international factors simply don’t apply, by bogging the argument down in peat, which is Donald Mackay’s home ground. The more he can talk about peat, the less he has to talk about curlews and Heathcliff. Gaming the SPA is far more difficult than rearranging the SAC with a bulldozer.

Layout 210225-41t is what you get by pretending that Walshaw Moor is in Scotland, that only the Scottish Carbon Calculator matters, and then doing the usual with the peat and grid mix. The way the calculator works means that only two factors count during the mayfly lifetime of a wind farm: Bronze Age peat deposits and the grid mix. Active blanket bog sequestration and transport emissions are small by comparison and are only in the calculation because if they were left out somebody would complain. The useless CWF 65-turbine proposal had turbines and tracks on very deep peat, and it would have been “the dirtiest power station in England” by 2040. The only design principle of Layout 210225-41t is “Get to 300 MW on the shallower peat without putting them in rivers or on top of a merlin.” This is why it is so ludicrous by all the other criteria, like aerodynamics, public access, worker safety and flooding.

The two international aspects cannot be gamed by the usual wind farm planning tricks. We either have 30% of England that is conserved as our promise to the world, or we destabilise the international designations and we have 0%. Sir Keir Starmer will have to explain to Sir David Attenborough why Angela Rayner destroyed the Kunming-Montreal Protocol almost without noticing. Similarly, we either have Brontë Country or Calderdale Energy Park: they can’t co-exist. This is less of a problem for Sir Keir because he cannot name a favourite novel, though Lady Starmer surely can.

We can relocate Calderdale Energy Park in the national interest. Friends of the Earth have made a map of suitable places, and Walshaw Moor is not on it, because with Friends of the Earth, the clue is in the name.

We cannot palm off our K-MP commitments to the Falkland Islands and deport the Brontë sisters to Nebraska.

Back in Trawden, I open flooding with Donald Mackay. He is a lad o’pairts like Colin Maclaurin, who aged 11, left Kilfinan on Loch Fyne on a donkey with two sacks of oatmeal to start at Glasgow University, and eight years later was elected their Professor of Mathematics. If you did A-level maths, that was Colin’s theorem.

“I can’t draw a track network west of Greave Clough.”

“Show me what you mean.”

I point between T37 and T39.

“There was a turbine T38 here.”

Donald laughs.

“Of course there was! It was on the blank section of the peat. We moved it.”

He thinks this is the costless truth.

“We can’t go sideways between T37 and T39 across the slope.”

“No. We call that crossfall and it’s asking for a peat slide.”

“So, the access to T37 and T39 is straight down from above or straight up from below, and both those routes create the drainage line that accelerates the runoff and overwhelms the Greave Clough sluice, which is here, just above the rocky gully.”

Donald isn’t saying anything now. He knows more about wind farms than I ever shall, but for now, I know more about Pisser Clough, The Sod and the Greave Clough sluice & tunnel. I press the argument.

“You can’t get across Greave Clough and up the slope to T1-T4 and T5-T8 without building these tracks that are storm-drains sometimes and blanket-bog drains always. If you came in at the north apex by Option B you’d already be up, but now you’re doing more wet traversing from T8-T5 and you still have to get down. That dotted line called Jackson’s Ridge isn’t really a physical feature like the Cuillin Ridge. You can walk along it (I have) but you don’t want to. You get onto Boulsworth-Crow Hill to move laterally. That leaves T1-T4 isolated by the canyon of lower Greave Clough. And they are on charismatic ground anyway, so I hope you’ll lose them on visuals.”

“Yes, that ridge above the road is attractive.”

“As is T5 at Dove Stones. So that’s what I mean when I say I can’t draw a track network west of Greave Clough.”

It is not the only source of flood risk, but the Greave Clough catchment is an obvious one. Mitigating it means taking out all nine turbines west of Greave Clough and 66 MW. Heather Hill is too crowded and must lose a couple to aerodynamics. We know about T21 and T22. This is how CEP gets down to the “high twenties” 200 MW that Tom Andrews blabbed to John Page at Oxenhope. Remember that Christopher ‘440 Kelvin Volts’ Wilson said the old CWF was uneconomic below 200 MW.

“So, I can’t draw a normal windfarm track network west of Greave Clough, but I can along the watersheds from Cock Hill and around Heather Hill.”

I trace the line to the point where the plateau watersheds meet. I’m fishing here for whether the track will ride the black dashes south along the watershed, or creep along the edge T23-T24-T25. Donald’s hand twitch pulls my finger back onto the watershed. He’s been to this key feature in his mind, or on a site visit, and how you cross this kind of ground is muscle memory.

“South across the plateau,” he says.

“Then down this steep end to the bridge, yes?”

“Yes, we cross at the bridge”.

“I’ve thought about that steep end, which is Hoar Nib. I’m not saying you can’t get down, but it will make a big mess in the most visited bit above Hardcastle Crags. It’s steeper for longer than your Option B zigzags.”

I have had a go at the Option B access to the north apex. Unlike the Consultation Brochure, my diagram below puts the track on a proper base map and reveals that Option B was a rush job, like so much else in the proposal. Anything we check comes apart.

“You need two access options so that the people on the stone route don’t know if it is “us or them”. It’s a divide-and-rule tactic. Do you believe in Option B?”

“I’m a transparent guy.”

Transparency is a quality that needs no self-promotion, though transparent people often wear hazard tape so that people don’t bump into them. Tony Blair said something similar about Bernie Ecclestone’s donations.

“There’s some realignments …”

“£1 million or £10 million?”

“£1 million. You get a lot of road works for £1 million.”

“I’d be more concerned with the mass of unstable and contorted peat at the top, where you’re making a huge compound.”

But Donald Mackay is not afraid of shifting peat if there is no crossfall. For decades the planners have allowed him to say that bulldozed peat in a pile is the same as undisturbed peat with its intricate web of arteries. You might as well do a liver transplant with a sausage.

“Option A2 turning right at the Oxenhope mast is easier than fixing the Two Laws Road. You won’t get Option A1 out of Bradford Council and nor should you, and I am sorry to have suggested it myself. If you walk it when the new curlews have flown, you’ll see the wonderful work the Yorkshire Peat Partnership has done. I first suggested Option A3 18 months ago and locals said at once that it freezes first every winter, and it’s much too steep. I don’t know why it’s in.”

“Oh, if we left it out somebody would ask why we weren’t thinking of it, so easiest just to put it in.”

We are back to the charming costless truth, which is why Donald Mackay is so dangerous to the birds on Walshaw Moor. I ploughed on.

“The thing about Option B is it’s all Bannister…”

“Yes, it’s a great advantage to have one local authority and one landowner with a big area to offer.”

I don’t remind Donald that Laneshaw Bridge and Colne are in Pendle, Lancashire, not Calderdale, West Yorkshire. It is the Two Laws Road, after all.

“There’s an idea that the company must consider other sites before developing on peatland.”

“That just isn’t ever how these stories go. Christopher Wilson finds this site and gets some investors interested enough to make a start. Every wind farm is the same.”

Donald Mackay isn’t interested in spinning the bogus idea that CWF Ltd has ransacked England looking for a suitable site and only Walshaw Moor will do. He knows this is another costless truth. There is no list of alternative sites sought out and considered.

I have a morsel to unsettle him.

“A strange thing happened between the 17^th when I asked Alison Sidgwick about aggregates and the 21^st when you finally answered my question after 390 days.”

“What was it?”

“On 19 May 2025, Dr Osman ceased to be a person of significant control in Calderdale Wind Farm Ltd.”

A longer pause than usual, a minim rest, maybe the thick end of a semi-breve.

“Oh, that kind of thing is miles above my pay grade.”

“It means that CWF Ltd now lacks a human “person with significant control (PSC)” for the first time since incorporation in February 2021. The only PSC is the inhuman entity “Energy Horizon II” and since they are a Saudi-registered company I can’t look up their significant-control tree of actual humans. I haven’t disentangled what the law says about that situation, but the list of jurisdictions hosting entity-PSCs (relevant legal entities) that can be registered at Companies House doesn’t include Saudi Arabia. I was hoping you might know.”

“I build them. The investors pay for them.”

“The electricity bill-payers pay for them. Until I hear a more plausible explanation, I’m putting it down to Dr Osman’s natural reluctance as a distinguished civil engineer to be associated with the horlicks that is Layout 210225-41t, but as he’s still sole Director, Dr O will get his share of teasing until we hear otherwise.”

This was pure swank. I have no idea what Dr O’s backwards step into the anonymity of Energy Horizon II means, but I have written to Companies House to ask for clarification, for as things stand CWF Ltd seem to have no registrable PSC, and hence no register, and failing to keep the list up to date is a criminal offence.  We sent our legal letter to the Project Director, but we could not send one to the PSC.

I liked Donald Mackay immensely and we had a terrific time talking for an hour about something of absorbing mutual interest to two highlanders abroad in the rich, lazy south. We were satirized long ago, in the most famous bit of Boswell’s Life of Samuel Johnson.

Mr Ogilvie then took new ground, where, I suppose, he thought himself perfectly safe; for he observed that Scotland had a great many noble wild prospects. Johnson: “I believe, Sir, you have a great many. Norway, too, has noble wild prospects; and Lapland is remarkable for prodigious noble wild prospects. But, Sir, let me tell you, the noblest prospect which a Scotchman ever sees is the high road that leads him to England!”

We do not need to leave the Pennine Way to visit T21, for it is only 57 metres from the flagstone path and the blades will saw the air above us. Our friend Martin in the Worth Valley campaign says he will have a plaque made, The Ed Miliband Memorial Turbine, and post the site on Trip Advisor (“Beauty beyond my imagination” 5* Dr Ghazi Osman).

After two months of planning dodges and legal work it is a relief to get up to the moor. The air is solid with curlews and their song. It is like being on an open boat in the Minch on a voyage from Ardrishaig to Uig, completely surrounded by dolphins.

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This is the 37th in a series of guest blogs originally based on the 65 wind turbines which Richard Bannister planned to have erected on Walshaw Moor. Turbines 5, 6, 8, 9, 11, 13, 14, 16, 17, 21, 25, 27, 31, 32, 33, 33CEP, 34, 35, 36, 37, 38, 40, 42, 42CEP, 43, 44, 47, 53, 54, 56, 57, 58, 60, 62, 64 and 65 have already been described.

The developers have canned their original 65 wind turbines, quite possibly in response to the public humiliation of having their so-called ‘plan’ publicy shown to be damaging, irrational and probably unlawful. They have come back with a plan for 42 wind turbines and the amazing Nick MacKinnon and friends have regrouped and set off on a new tack too. The series continues.

To see all the blogs – click here.

 

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