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: [email protected]
Turbine 13 Heather Hill SD 95318 35026 ///tones.decisions.audible
23 February 2025 It’s my last turbine walk before the birds return, and a group of us are heading up from Clough Foot. We’ve had the first reading of the Planning & Infrastructure Bill, and this blog will briefly describe the state of T13 Heather Hill while we look at the way the new planning approach relates to Walshaw Moor in particular. We are over the watershed now at 33/65 and by 38/65 we will know whether Christopher ‘440 Kelvin-Volts’ Wilson is going to open his account with the Planning Inspectorate (nothing yet, the PI say) and start a round of non-statutory consultation “in the Spring of 2025”. If that is the schedule, initial proposals should be bouncing between Calderdale Wind Farm (CWF) and Natural England right now, in the iterative process mentioned by Christopher Wilson.
The method of this blog is patiently to quantify the difficulties faced by the investors in CWF, because in the end, we have to pay for them. I expect thereby slowly to drive a wedge between the investors represented by Dr Osman, and the Executive Chairman Christopher Wilson and the British people (who love nature) and any government representative or planner who thinks this might be a well-sited wind farm. There is no slam dunk in this approach. Local engineering difficulties can sometimes be overcome by the application of more money, but there is no magic money tree for CWF. It has to earn its keep at a strike price in line with other onshore wind.
Four kinds of factor have moved firmly against the investors (and the bill-payers, who love nature) in Calderdale Wind Farm Ltd since 2021: financial, engineering, legal & political and the campaigners under Stronger Together; and this blog, whose authors speak for themselves under the kindly but (goodness me!) incisive eye of Mark Avery, who has been on the Walshaw beat for decades.
Financial
Calderdale Wind Farm Ltd was incorporated on 15 February 2021. The interest base rate was 0.1%. Since inflation was 0.4%, the real interest rate was negative. In the UK, real interest rates were mostly negative from the financial crash in 2008 until January 2024.
Dr Ghazi Mohammed Ahmed Osman was appointed a director on 21 March 2022 and Christopher Wilson went from founder to Executive Chairman. The base rate was now 0.75% but UK inflation was 7%, so the real interest rate was -6.25%.
In the Summer of 2022, TNEI sent out “a young lad and lass” who were seen “slipping about north of the Gablestone where the peat’s really deep”. In the three months that the hard-working pair were probing the peat, the base rate went from 1% to 1.75%, but inflation was very high, and the real interest rate was -8.15%, a figure you may not see again in your lifetime unless you are a teenager. We are still plodding through the scorched earth of the great bond swindle. Those spivs worked out how to spend the future’s money as though it was their own; now the future has arrived, and the money has already been spent. The solution has been to create £895 billion, ten Olympic swimming pools full of crisp fivers, by quantitative easing. Allowing for inflation, that is 250 times more money than the Germans counterfeited in Operation Bernhard, a serious attempt to collapse the British economy. You can buy a real counterfeit Operation Bernhard £10 note on eBay for £170, while ten real wartime pound notes are £13.
The interest rate peaked at 5.25% after the Truss experiment and is on a slow decline to the current 4.5%, so the real interest rate now is + 1.5%. This is agony for public services because the national debt is continually being refinanced at much higher rates as low-interest gilts mature. The same is true for mortgage holders on floating rates or remortgaging after their fixed deal ends. The Truss experiment showed that things can go catastrophically wrong for the UK economy in a week if we pretend the National Debt is not a problem, for we depend on the kindness of strangers, and they think the National Debt might be a problem.
The tide is finally going out on negative interest rates and as Warren Buffet says, we can see who was swimming naked. Wind is free, but the cost of a wind farm’s electricity is the cost of the capital borrowed to build it plus a share of the cost of new grid, storage and parked gas back-up . In the short life of Dr Osman’s association with Calderdale Wind Farm, the cost of capital has gone from 0.75% to 4.5%. It isn’t that Dr Osman’s Saudi-based backers are short of capital, rather that there are now risk-free ways of investing their money in the UK, so there needs to be a much bigger incentive for the risky business of building CWF. You can now get 3.8% at the Halifax without having to dig a single hole in the deep peat of Walshaw Moor. Properly understood, wind power at system level is not “cheap” and it is now much more expensive than it was.
This wild swing in what accountants call “the risk-free discount rate” might have been weathered by a simple and efficient project (on the pattern of Ovenden Moor 22.5 MW or Whitelee 539 MW) but a complex and controversial project like Calderdale Wind Farm is exposed to very unusual forces. For example, it is to be built on the catchment area above Hebden Bridge which has suffered terrible floods, even in summer. For another, it pickets Haworth Parsonage, the Brontë moors and Wuthering Heights with 200-metre-tall wind turbines, and Christopher Wilson’s turbine layout seems not to know that these places celebrate the lives and achievements of three of the most famous women in the history of the world. The economic life of Hebden Bridge and Haworth depend on Walshaw Moor above them in an unusually intense way. In Hebden Bridge it can flood them out. It Haworth it supplies a huge tourism income even in the winter. This was evident to everyone in Calderdale and the Worth Valley, but such a direct economic bond between catchment and populace is unprecedented in the UK on the site of a proposed wind farm. Whatever happens, both Brontës and floods will constrain CWF.
Engineering
At negative interest rates, the engineering problems of CWF, which taken together are severe compared to every existing UK onshore wind farm, might have been paid for with cheap money. What is now known is summarised below and discussed in the linked blogs.
- The onsite rock is too weak and porous to make roadstone or foundation concrete and strong aggregate must be imported from distance. The closest supply of strong aggregate is North Yorkshire limestone which maybe chemically unsuitable on acid ground. (T54 Bedlam Knoll)
- The deep division in the site at Walshaw Dean requires an expensive slalom down from the plateau to a new bridge which has no parallel inside a UK wind farm. Normal wind farms stop at such obstacles or start again from a second access point on a public road. (T57 Lower Stones). We have proved in these blogs that there is no realistic second access point. (T60 Cock Hill Swamp)
- Blade access requires an offsite access road to be built from Ovenden Moor Wind Farm, partly on Yorkshire Water land, and YW and CWF have opposite views on what “integrity of the Walshaw catchment” means. Other more expensive and disruptive alternatives may be available. (T60 Cock Hill Swamp)
- Very deep peat, which reputable developers would skirt, blocks the access across the Wadsworth plateau. Skirting or abandoning deep peat destruction pushes the size of CWF below 200 MW and is then ‘uneconomic’ according to Executive Chairman Christopher Wilson (Hilltop Parishes meeting, December 2023). Well-sited wind farms can be profitable at 30 MW if they are in the right place. CWF is evidently in the wrong place if even the developer says it can’t wash its own face at 200 MW. (T42 Middle Moor)
- No named National Grid substation is available. CWF is accepted to connect at Rochdale DNO (not NG) for a maximum of 240 MW despite the company claiming for a year that it was accepted to connect at Padiham, which was wishful thinking. The distance to Rochdale by the specified buried cable is too great for the alternative 170 MW CWF to bear. (T17 Jackson’s Ridge T56 Slack Stones)
- Gradient, unstable peat and gross habitat destruction, combined with an evident increase in flood risk to Hebden Bridge via an overwhelmed sluice in Greave Clough, make development of the west slope of Greave Clough particularly unlikely. The failure to complete the peat survey here (two day’s work left undone) shows that the developers themselves had little confidence in their chances in this quarter. (T14 Foul Sike, T5 Grey Stone Hill)
- The current flood alleviation proposals in Hebden Bridge do not allow for increased flow rate from CWF because it is the developer’s responsibility to prove that there is no increased run off. The difficulty of doing this is superbly dealt with in a post by Jenny Shepherd of Stronger Together. (Fact check – is Flood Alleviation Scheme’s purpose to protect against 2m high flash floods caused by wind farm?)
A storm slows over the Upper Calder catchment
The extent of the developer’s task on flooding can be understood from this meteorological account given in the Calderdale Flood Recovery plan (March 2013) published by Calderdale Council.
“According to the Environment Agency Hydrological report (December 2012), the flood event of 22nd June 2012 was the largest fluvial flood event on record at most sites across the upper Calder catchment. It was the third highest fluvial event across the lower reaches of the Calder. Rainfall on the 22nd started at around 6am as a low pressure system over the region travelled to the north dragging with it several weather fronts that fed in bands of warm, moist air from the west. This low pressure circled the region during the day before finally tracking northwards at midnight.
2.2 There were three distinct periods of rainfall during 22nd June. In the morning the intense storms over the River Calder catchment raised river levels at all locations and also filled much of the available storage. From midday and throughout the afternoon, steady rainfall continued at a lower rate across the Calder catchment. At around 6pm an intense storm developed in a line from west to east over the southern edge of the upper Calder. Within half an hour a second storm line developed slightly further to the north over Todmorden, Hebden Bridge and Mytholmroyd. The heavy rainfall continued until around midnight when the low pressure and its associated fronts began to move northwards.
2.3 More than one month’s rain fell in the 24 hours of 22nd June. The rivers rose to unprecedented levels, causing the worst flooding Calderdale has experienced in 12 years, since 2000. Communities and infrastructure worst affected by the flooding were principally those located in the Upper Calder Valley immediately adjacent to the River Calder, Walsden Water and the Rochdale Canal.”
What made the 22 June 2012 flood particularly intense is that the stormline slowed over the Upper Calder catchment. The purpose of Calderdale Wind Farm is to subtract kinetic energy from bands of air coming mostly from the west above part of the Upper Calder catchment, turn that kinetic energy into electrical energy, and send it offsite. Average windspeed must reduce downwind of a turbine field by the law of conservation of energy, and there will be wake effects that will promote slowing at local scales as well. Over the nine square miles, a huge air mass comes in fast and goes out slower and more turbulent, like a millrace and tailrace. As a vast trap designed to harvest the kinetic energy of moving air, and turn it into slower-moving, more turbulent air, Calderdale Wind Farm can only increase the probability of the stormline settling over the Upper Calder catchment, with the following faster-moving airmass piling up on the slower air at hub height and toppling over at greater heights. The effect is inevitable. It is for the developer to quantify the extent and the consequences in the environmental impact assessment (EIA). The science on the effect is solid and can be read here in Nature. The magnitude of the effect depends on location. If it rains more in the sea over offshore turbine fields, the effect on land flooding may be non-existent. CWF is on the catchment.
The requirement to make this assessment may seem unusual, but it is also unusual to build a huge wind farm on the catchment of a deep river valley that has already been subject to frequent intense flooding focused by the terrain.
The most obvious potential effect on flooding from CWF will be through accelerated runoff because of changes to surface drainage and this will certainly be a major part of the EIA . The aerodynamic effect described may be small when averaged out over a decade but may be very large in the “once in a decade” rainstorms that flood the Calder valley.
This idea may prompt scorn from the developers. “How can our wind farm significantly slow the speed of bands of moist air? We’ve never heard of such a thing!” The answer is that slowing the speed of bands of moist air is exactly what a turbine field is supposed to do.
It is a key maxim of economics that you never find a £10 note in the street because somebody else will already have picked it up. Well-sited wind farms will be developed by experienced developers. Developers without a reputation will be left with sites that would be rejected by reputable developers who have much better places to invest risk capital. Walshaw Moor comes loaded with unusual engineering risks.
Legal & Political
CWF is almost wholly inside the boundary of the South Pennine SAC. The SPA/SAC network is now at the core of England’s response to the Kunming-Montreal Protocol. Walshaw Moor was already as strongly protected by the SPA and SAC designations as anywhere in England; Kunming-Montreal makes the SACs and SPAs even more vital for the natural world of a younger generation who will live in a rapidly warming world. Blanket bog will do its best to protect us and nature if it is itself protected.
The developers’ consultants, Natural Power, stated the scale of the legal problem very clearly in the 2023 Scoping Report that Christopher Wilson accepted and then submitted to Calderdale Council, as follows:
“8.8 Potential impacts. It is considered that the construction, operation and decommission of the Proposed Development has the potential to result in the following:
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- Habitat loss and degradation (negative, long-term, international, irreversible)”
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To survive those four withering adjectives, voiced by their own consultants, the developers must have been hoping for a revolutionary change to planning law, taking the UK out of the international habitat regulations framework, and they have spent millions on that gamble, which is a lot to us, but mere lubrication to a venture capital mindset. A merely radical change in Planning Law might have adjusted the way environmental damage was dealt with further down the habitat hierarchy, but Walshaw Moor is literally at the pinnacle in English nature conservation in being SSSI & SPA & SAC and there is no higher category. The National Parks and AONBs are not primarily for the conservation of nature. Only revolutionary change could make Walshaw Moor a legal site for a wind farm. The Planning & Infrastructure Bill 2025 is neither radical nor revolutionary change to the treatment of sites like Walshaw Moor which are at the pinnacle of the hierarchy.
In the event that the habitat regulations hierarchy at the sharp end remained unchanged, the backstop for the developers was that CWF might still be passed by Ed Miliband, acting alone, and in defiance of the most vigorous possible rejection from the Planning Inspectorate, themselves informed by Natural England. How might Christopher Wilson have persuaded the investors that this “Maverick Miliband” backstop was effective insurance for the main gamble on revolutionary change in the Planning and Infrastructure Bill 2025, a gamble that has now failed?
Capitalists tell many stories, and they don’t have to be true provided the investors are charmed by them. In Liar’s Poker Michael Lewis tells of the fluent storytelling of a Salomon bond salesman on the first news of Chernobyl. He sold one client two tankersful of crude oil (a sudden-love-for-fossil-fuels story) and another potato futures (a fear-of-fallout story).
There must always be a story to catch the investor’s imagination, and Christopher Wilson’s for Dr Osman may have been this mash up of Sigmund Freud and Jeffrey Archer.
“From the deep shadow of a powerful father and charismatic brother, the future Secretary-of-State for DESNZ seeks the light in a spectacular vanity project. The deeper the legal obstacles and the higher the megawattage, the stronger becomes his ‘edifice complex’, a joke, if it is one, that escapes me. We must flatter his ego with the greatest power in England on the most deeply protected land in the British Isles. Forget 49.99 MW in some lifeless Sitka plantation. We turn our greatest weakness into a paradoxical superpower by offering him 302 MW on a special protection area and special area of conservation that is knee-deep in breeding curlews!”
If that was the story, CWF got the wrong man, for Ed Miliband loves our West Yorkshire moors as a sacred space to his father’s memory, and he has already told his own story to Ralph Miliband’s grandchildren.
“When I was a little boy and we lived in Leeds, my father used to make up these stories about two sheep in the Yorkshire moors called Boo Boo and Hee Hee, who had magical adventures. And so, when I had my two boys, I started telling them Boo Boo and Hee Hee stories too. There’s all sort of characters in Boo Boo and Hee Hee, including a magician who is rather useless and spends all his time watching cricket. My sons are 10 and 11 now, so I can still get away with telling them these stories, but they’ll get to an age soon where they don’t want to hear it anymore, which is sad. What I love about it is that, as an adult, it can be quite hard to let your imagination run riot, and this puts you under quite a lot of pressure to make the story funny and exciting. It’s fun.”
I like to imagine Dr O’s reaction to this devastating revelation at a meeting of CWF Spectre inside Richard Bannister’s extinct volcano in Colne. “When were you going to tell us about Boo Boo and Hee Hee, No.2?”
The Planning & Infrastructure Bill 2025 (the dog that didn’t bark and even says it didn’t bark in the opening statements), papers from Defra and Natural England about Kunming-Montreal, and the recent announcement about conserving deep peat, must all have been heavy blows to investor confidence in Calderdale Wind Farm. The loss and degradation adjectives “negative”, “long-term”, “international”, “irreversible” have become much more clearly understood in government since Dr O bought control of CWF Ltd in 2022.
Stronger Together
The fourth factor is that the developers face concerted opposition from Stronger Together to Stop Calderdale Wind Farm, a coalition campaign body formed from eight local groups dedicated to both stopping CWF and getting the government to ban wind farms on protected peat in England. If you want to assess the extraordinary power of Stronger Together, click on the Flood Alleviation link above. Stronger Together want to achieve landscape-scale blanket bog restoration as a better alternative to the proposed wind farm in terms of climate mitigation, biodiversity restoration, flood risk mitigation and socio-economic benefits. A group of campaigners is travelling to the House of Commons to lobby MPs to support this ban. A petition to achieve the ban has been signed by over 7000 people and a crowdfunder has raised over £4500 so far, a sum that can run rings round CWF’s lavishly financed PR firm Cavendish Consulting, who work primarily in the medium of mime. Thousands of leaflets have been distributed in Calderdale and the Worth Valley and information stalls have been held in towns and at many local events. The campaign’s Facebook page is Calderdale Wind Farm Action Group whose light touch moderation has allowed differing points of view to be expressed, a culture noted and approved of by academics at Leeds, Manchester, and Santiago di Compostela universities.
Stronger Together have commissioned world-class envisioned images of CWF. A letter has been published in the TLS signed by over 300 writers, actors, environmentalists, and other creatives. There is a forthcoming Book of the Bog with contributions from Patti Smith, Robert Macfarlane, and Amy Liptrot to name a few. Reporters from the Guardian and the Daily Mail have sat around our kitchen table. Radio 4 News has given us coverage and we feature regularly in the local press. A packed meeting was held at Haworth at which Mark Avery and Robbie Moore, MP, and Shadow Defra minister, spoke. Robbie Moore has worked tirelessly for our cause and has asked questions in Parliament, and Keighley and Ilkley Constituency Labour Party (now led by Martyn Oliver and previously by Pam Johnson, who spoke brilliantly at the Haworth meeting) brought a motion on the wind farm to the Yorkshire and Humber Labour conference. In the Calder Valley MP Josh Fenton Glynn has accepted 200 signed letters from constituents asking him to support the ban on wind farms on protected peatland. He’s also acknowledged the 1,300+ constituents who have signed the Parliamentary petition. Campaigners who collected the Calder Valley signatures door to door found that 80% of those asked to sign said yes immediately. Josh Fenton Glynn has said that he will make an evidence-based decision about whether to support the petition.
All this is meticulously written up by Jenny Shepherd along with a huge resource of up-to-date and fact-checked information.
Deep peat now 30 cm
On 31 March 2025 the very definition of “deep peat” in England changed, from 40 cm to 30 cm. This is even more serious for CWF than it appears because the company had already used the wrong boundary of 50 cm in its peat survey (a Scottish definition from Scottish consultants) and this error, which they have repeatedly been asked to correct, will have leaked into their regulatory deliberations (such as they are), themselves undermined by the casual incompleteness of the 2022 peat survey. “50 cm” is one of two “Scottish” assumptions made by the Castle Douglas-based consultants. Another is that the onsite rock is suitable for roadstone and concrete, which it usually is in Scotland, but not in West Yorkshire.
The approximate appearance of a corrected peat map with a 30 cm contour is shown below. It shows a strange thing. The turbine layout is meant to avoid the deep peat. Instead, the turbines are allergic to the shallowest peat.
A quick walk to T13 then back to the Planning & Infrastructure Bill
Several of the group are nursing injuries sustained in action, but Mo and ‘Drainage Queen’ Ginnie show no mercy and set a cracking pace up the tarmac. I talk to Julian on the way up, last seen at our gate in lockdown on one of those “one-hour walks on our own”, when he turned out to be a university friend of my wife Lydia. Since he lives in Hebden Bridge and we are in the suburbs of Stanbury, he had set a world record on the outward leg and still had to break the half-hour barrier on the way home or face arrest.
Mo’s concession is that we will go the smooth way of the turbine blade deliveries, and we are soon ambling past Mere Stones. It is the first day of spring. The degraded condition of the summit of Heather Hill is shown in the photograph, taken by the line of grouse butts that have been countersunk in the deep peat. Very little of Walshaw Moor is like this. Much of it is a secret wonderland only understood by the gamekeepers. One of them studies and treasures the merlins.
We wander towards the butts where the peat survey has failed again, but not so badly as it does in the white patches around T14, and the algorithm allows itself a guess at the depths in the unprobed area. My avalanche probe finds 180 cm where the algorithm reckons 100 -150 cm and I think we can dismiss that spurious light green island (50-100 cm) east of T13 whose basis is a single data point.
The flat top is scored by numerous parallel grips.
On the way down Mel and I fall in with Paul and we recount our various accidents and rescues. Paul has recently broken his leg while mending a path with the CROWS and is delighted with his titanium tibia. By the plantation, photographers in camo are snapping crossbills and are astonished that T49 is going in the middle of this very popular wood. If we had a dance off between the eight most hated turbine sites, scruffy T49 Sutcliffe Plantation would be the winner. Back at Clough Foot, the lapwings have arrived while we were sauntering up and down.
The Planning & Infrastructure Bill 2025 (first reading)
The lapwings and crossbills might have been worried about the Planning & Infrastructure Bill, sponsored by Secretary-of-State Angela Rayner. They need not have been. The guidance is here. It opens with a statement on the European Convention of Human Rights and then these environmental statements.
This staunch defence of the habitat regulations has dismayed a group of MPs called Labour Growth, who want the hierarchy of nature protections to be dismantled and have sent a letter to the Prime Minister saying so. The list of signatories only has one MP whose constituency contains deep protected peat, Oliver Ryan, the disgraced MP for Burnley who sits as an Independent following the withdrawal of the Labour whip. If he had spent more time walking to the summit of his constituency with an avalanche probe and less sniggering about his constituents on Whatsapp with the former Health Minister, he’d have been a better member for the people of Burnley. That said, the existence of the letter shows that Labour Growth believe in the strength of the habitat regulations to protect the SACs and SPAs. They want revolutionary change to the whole hierarchy and they didn’t get any change at the sharp end. Both the Bill and the revealing reaction to it are hammer blows to Calderdale Wind Farm Ltd. They know what it doesn’t say.
Hard on this news came a remarkable announcement by the Nature Minister Mary Creagh.
Heather burning ban 31 March 2025
“Our peatlands are this country’s Amazon Rainforest – home to our most precious wildlife, storing carbon and reducing flooding risk.
The UK has 13% of the world’s blanket bog. A rare global habitat, it is a precious part of our national heritage, and that is why we are announcing a consultation on these measures to ensure deep peat is better protected.
These changes will benefit communities by improving air and water quality, and protect homes and businesses from flood damage, which supports economic stability and security under our Plan for Change.
If implemented, these changes will increase the area currently protected from 222,000 to more than 368,000 hectares of England’s total 677,250 hectares of deep peat, meaning an area equivalent to the size of Greater London, Greater Manchester and West Midlands put together will now be better protected.
The definition of deep peat will be revised, so that deep peat is counted as anything over 30 cm rather than 40 cm. The entire area of upland deep peat that is potentially subject to burning will be protected.”
Had I written this myself it would not have been more hostile to CWF. The extension of “deep peat” to 30 cm is a necessary step because of the 30 by 30 requirements of the Kunming-Montreal protocol. More peatland can plausibly be considered as “protected”.
As Ruth Davis, the UK Special Representative for Nature puts it:
“We need to put nature at the heart of our discussions on climate and development. A thriving natural environment is critical for building our resilience to face the demands of a changing climate. We know that our global network of peatlands, seas, and forests act as carbon sinks, sequestering and holding carbon dioxide to regulate the Earth’s climate. It is not possible to reach our net zero or sustainable development goals without restoring nature.”
30 by 30
The importance of sustaining the legal protection of the SAC and SPA network and extending the protection of peatlands is shown vividly in our national response to the Kunming-Montreal Protocol. This was adopted at COP 15 on 19 December 2022 by the UK and nearly 200 other nations, with the USA and Vatican City holding out somewhat, and DR Congo saying afterwards that they wouldn’t stand for it. It has been described as “the Paris Agreement for Nature.” Its clearest goal is that signatory nations should by 2030 conserve for nature 30% of their territory, the 30 by 30 target. It is easy for Vatican City since the Pope’s back garden is 47% of the area of the Holy See. Of all the countries on Earth, England has perhaps the biggest problem getting anywhere near 30%. At present only 8.5% meets the standard and this is mostly the SPAs and SACs. You can read the new policy in 30 by 30 on land in England: confirmed criteria and next steps (29 October 2024). Calderdale Wind Farm is doomed under any coherent policy that makes the SPAs and SACs central to our response to the nature and climate emergency. We have led the world into a policy that it is impossible for us to carry out ourselves if we destabilise the SPA and SAC regulations.
Back in Richard Bannister’s extinct volcano in Colne Dr O has another question for his Executive Chairman: “When were you going to show us the red and blue map, No. 2?”
These multiple shocks from government must be hard for poor old ‘440 Kelvin-Volts’ to comprehend. The regulatory ground is moving fast under him like a peat slide. He was better off under the Conservatives. Never the very sharpest Executive Chairman of an Electricity GenCo, he may try to deflect the blame to the consultants. “But the consultants spent loads of your money No. 1! We had two youngsters probing the peat for the whole of their summer holidays. A firm put down some carpet squares to attract newts. We’ve published a map with 65 turbine sites on it and some of them were not on very deep peat. We paid Natural Power hundreds of thousands for a Scoping Report filled to the brim with Grade II listed buildings and archaeological remains scraped off cheap databases and then dumped it. Ask No. 7 how this has happened!”
But unlike No. 2, who has no reputation in renewable power to lose, this is not No. 7’s first rodeo.
“I ask No.1 simply to read section 8.8 of the Scoping Report that No. 2 accepted in September 2023.
- Habitat loss and degradation (negative, long-term, international, irreversible)
As you will see we did all we could to warn you about the difficulties you faced, and we used the starkest terms. That said, we didn’t see 30 cm coming!”
There is a further ‘potential’ 26.8% coloured blue in the map, but much work must be done. We cannot count a pop-up nature reserve which could be a caravan site in five years. The announcement by the Nature Minister Mary Creagh that burning will be banned on deep peat, and the definition of “deep” will be 30 cm or more, means that another 148,000 hectares of peatland might soon count towards 30 by 30. The ‘potential’ area for our 30% includes the National Parks which do not have to meet the high standards required of Walshaw Moor, which as an SAC and SPA is at the pinnacle of the hierarchy. I have said this before, and you can check it for yourself this spring on the Pennine Way: Walshaw Moor is a wonderland for birds in a way that the high ground of Yorkshire Dales National Park really isn’t. As a major Dales and Lake District landowner, the National Trust has a lot of work to do if they are going to help England get to 30% by 2030, and it won’t just be ticking boxes. There must be cultural change if we are to bring the National Parks, AONBs and the National Trust’s land somewhere near the standard required of Walshaw Moor, and there is more to do to keep all of Walshaw Moor up to that standard too.
The UK can be justifiably proud of the Kunming-Montreal Protocol and the government has said so.
“In 2020, the government committed to protecting 30% of the UK’s land by 2030 (30 by 30).
Thanks to UK leadership, a global 30 by 30 target was adopted at the UN Biodiversity Summit at COP15 in December 2022, as part of an ambitious Global Biodiversity Framework.”
It would be a disaster for every child on Earth if we had to pull out of the Kunming-Montreal protocol because England couldn’t keep its paws off the SPAs and SACs. The global south has misgivings about the K-MP. In England, we have already abstracted commercial advantages from our destruction of nature. There is a feeling that we are hypocritical. Can we call for everybody’s 30% if we cannot secure even the 8.5% that we have set aside for years? What a bonus for the gold-braided Colonel when he can say to his adoring and savagely oppressed people, “At the first time of asking, England has surrendered the hypocritical Kunming-Montreal agreement to the legitimate appetites of a rich man, with the blessing of an autocratic minister, made in the mould of your own determined and beloved leader. Today, we will resume God’s plan for the exploitation of our resources by logging our infinite forests for the benefit of all our citizens and the climate!”
That isn’t going to happen. Ed Miliband is not going to declare his maverick opposition to the Kunming-Montreal Protocol. The next section shows why the Planning Inspectorate (who are by definition non-maverick) are not going to subvert Angela Rayner’s Bill either.
CWF and the Planning & Infrastructure Bill 2025
The first stated purpose of the P&I bill is to “Deliver a faster and more certain consenting process for critical infrastructure.” The habitat regulations as they apply to a wind farm proposal on the Walshaw Moor SPA and SAC already operate at lightning speed. They are a rock of certainty when developers or campaigners are trying it on. The new National Planning Policy Framework (December 2024) sets out the position in an admirably clear way.
It is very good to have Circular 06/2005 given such legal prominence in the framework. This expands what Section 192 calls the ‘hierarchy’ of designated sites. Right at the top of the hierarchy are the “Internationally Designated Sites” and as an SPA (for red-listed birds) and SAC (irreplaceable habitat) Walshaw Moor is doubly designated. Nowhere in England ranks higher in importance for nature conservation, and that includes the National Parks, which do not prioritise wildlife and habitats. A flow diagram from the circular shows how quickly a planning application can be decided for the 302 MW CWF: about two minutes.
The sequence for 302 MW CWF is No, Yes, No, No and now we are here.
The developers must persuade the Planning Inspectorate that there are no alternative solutions and Walshaw Moor, at the pinnacle of nature conservation, must be destroyed. If they cannot do this then the answer is “Yes”, and the pinball goes down the flashing hole that says:
The developers have themselves announced an alternative solution with lesser effect on the jewel in the crown, a 170 MW CWF. Christopher Wilson has already shot his own 302 MW fox.
Now we must start back at the top of the flow diagram with Mr Wilson’s own 170 MW alternative. Once again, the habitat regulations do not delay the decision for more than a couple of minutes. The layout is yet unknown, but one that might minimise the destruction of irreplaceable habitat is shown below. Some turbines in the layout must be shifted (along the red arrows) because they are presently sited incompetently on very deep peat, most notably T60 at the site entrance. Others are too near the reservoirs without good reason, and one is virtually in the back garden of the only house on the site, owned by John Getty. I should say, in fairness to Mr Wilson, that this 170 MW CWF is an absolutely terrible pair of wind farms, and I haven’t even got room to show the off-site umbilical cord through curlew country to Ovenden Moor that must be built for access, nor the long 132 kV trench down the canal to Rochdale that isn’t really a high enough voltage given the distance, but Dr O isn’t going to pay for 275 kV so we’ll just have to warm up the towpath instead. The green shape and the brown shape taken separately are what large clusters may look like in England, including in Calderdale, but they will be built near substations and just off motorways, not on random deep peat grouse moors. In the volcano at Colne, Dr O is mildly exasperated now. “When were you going to show us this 170 MW shitshow, No. 2?”
We run the flow diagram again for 170 MW CWF and find ourselves in the “Is there an alternative” box again. This time there is no smaller on-site alternative because 170 MW is as low as CWF can go while still being commercially viable. Expert legal opinion is that the answer is always “Yes, there is an alternative” to a wind farm on an SAC/SPA because it could be built somewhere else that wasn’t an SPA/SAC where it will usually be more commercially viable. This is what Marcus Trinick KC says.
“You can’t just plead climate change and all the other arguments in favour of renewables. Your project is almost certainly dead as proving an overriding public interest (IROPI) and that there is no alternative solution to the development is an immense uphill struggle.”
Since Walshaw Moor’s SAC designation is based on its blanket bog and deep peat, the climate change argument is now seen to run the other way. Building on deep peat is one of the most effective ways of increasing global heating. It is an IROPI to preserve blanket bog and deep peat.
This expert opinion was given before Mary Creagh announced the Government’s redefinition of deep peat, not a moment too soon for our futures, but too soon for Christopher Wilson. A tipping point in global heating will be when the peat and boreal forest is burning in a ring at our latitude around the Arctic. On adjacent moors, responsible owners have engaged the Yorkshire Peat Partnership to rewet the peat, but the CWF proposal will dry out Walshaw Moor. In the battle against climate catastrophe there is no more urgent work than blanket bog restoration and peat rewetting, nor any that is cheaper or simpler. The climate change arguments work against wind farms on deep peat, and the good thing about this bizarre wind farm proposal is that this point will be crystallised in our understanding.
The developers may hope that because 170 MW exceeds the 100 MW threshold for a Nationally Significant Infrastructure Project, they can jump the tracks of the flow diagram. The Planning Inspectorate have in September 2024 issued “Nationally Significant Infrastructure Projects: Advice on Habitats Regulations Assessments”. The guidance here reproduces the flow diagram, but it does expand on what “Alternatives” means, and it still includes “A different site” so 170 MW CWF falls at the first “Alternatives” hurdle at Test 1. It does not reach Test 2 “Imperative reasons of overriding public interest (IROPI)” because the tests are in series, not in parallel. It cannot pass IROPI either because the actual IROPI is to rewet the peat, restore the blanket bog and maintain England’s leadership (with the other devolved Home Nations) of the Kunming-Montreal protocol. Richard Bannister’s desire to get shot of his grouse moor is an IROBI, an Imperative Reason of Bannister Interest.
The way “Alternatives” works in the Habitat Regulations has been understood by everyone on both sides since the announcement of a 302 MW CWF. Only an explicit revolutionary change in the Planning & Infrastructure Bill 2025 could change the protection of Walshaw Moor.
What “IROPI” might mean in the case of Walshaw Moor has changed radically since the incorporation of CWF Ltd. It is imperatively in the public interest that we do not destroy the Kunming-Montreal protocol by destabilising out SPAs and SACs. It is imperatively in the public interest that we extend protection of deep peat, and that is precisely what the Nature Minister has announced.
The Planning & Infrastructure Bill 2025 is the dog that didn’t bark. The fact that it didn’t bark is stated in the opening statements, and the reaction of Labour Growth to the bill shows that they know it didn’t bark. It is even harder to build a wind farm on an SAC or SPA now than it was in 2021, because the Kunming-Montreal Protocol gives a special place to the the internationally designated sites in the fight against the nature and climate crisis. Walshaw Moor is now a site of worldwide importance.
The thing that is prolonging the Calderdale Wind Farm uncertainty is Christopher Wilson’s refusal to accept the meaning of the words “Permission Must Not Be Granted”, perhaps his wishful thinking that he deserves a result because he has spent so much of Dr Osman’s money, the sunk cost fallacy, and maybe a residual hope in Maverick Miliband. If Dr Osman has had enough of the Wilson rollercoaster and wants to get some of his money back on the grounds of alleged negligence, I offer my services as an expert witness. I would coach our leading silk (nothing but the best for Dr O!) in these questions for Mr Wilson:
Why did you launch the hasty and confidence-sapping application to Calderdale Council and suddenly scrap it?
Why was the website you promoted so rife with scientific errors?
Why were the erroneous and laughable FAQs still available for public mockery six months after they were deleted from your website along with almost everything else?
Why did nobody mention the weak and porous onsite aggregate to my client?
Why does your peat map not have a 40 cm contour?
Why was your peat survey unfinished when two day’s work would have completed it?
Why was there a family living in our substation and does my client maintain their hanging baskets?
How were you going to evade the stark adjectives “negative”, “long-term”, “international”, “irreversible, used of your project by your own consultants?”.
Why was my client allowed to think the Brontë Sisters were a close-harmony trio whose greatest hit is “I saw mommy kissing Santa Claus”, when they are in fact three of the most famous women in the history of the world?
Why did nobody translate the scoping report from Scottish into English?
Why have you attracted the soubriquet ‘440 Kelvin Volts’?
Where is Padiham?
My offer is made in all seriousness. It is nationally embarrassing to have much needed foreign investment dependent on anyone so ignorant about electricity, Lancashire, and light entertainment.
The Planning & Infrastructure Bill and the Kunming-Montreal Protocol
It is now clear why the Habitat Regulations have been left intact, and in fact emphasised, by the Planning and Infrastructure Bill 2025. All of humanity depends on Brazil, Indonesia, Angola, Botswana, and Madagascar staying onside with 30 by 30, and they won’t if we don’t, because we are the beggars here. The Commonwealth expects the mother country to break sweat for the 30 by 30 benefits they are giving us. For too long our sanctimonious attitude to nature has been, “Find out what Johnny is doing and tell him to stop it.” We must stop it. The consequences if England cannot even protect the 8.5% that is already internationally designated would be catastrophic, since it licenses oligarchs to destroy their irreplaceable habitats, with legal cover from the Colonel in gold braid and sunglasses. We were leaders in the Kunming-Montreal negotiations at COP 15, and we must lead on implementation now, and this means there cannot be any backsliding on our SPAs and SACs. When “Labour Growth” call for the habitat regulations to be revoked, they are calling for Isolationism, the philosophy some deplore in Donald Trump’s America. It is to Keir Starmer and Angela Rayner’s credit that they have looked at the habitat regulations, understood the implications, and maintained them, while their government works urgently on further protecting peat. It is a particularly bizarre idea that Ed Miliband, of all people, might want to desiccate the deep peat of Walshaw Moor and destroy the consensus of Kunming-Montreal. Landowners both public, private and charitable may grumble about 30 by 30. It will be hard in England, but if the SAC and SPA backbone is replaced by a spineless free-for-all of fudge and quibble, and the Kunming-Montreal Protocol collapses because of England, who in government will be able to face the young and tell them what we have done?
Richard Bannister is caught in the spotlight doing a runner from his responsibilities, but if he can’t have his Imperative Reasons of Bannister Interest wind farm, he must face up to the burden and glory of being a role model for worldwide nature under Kunming-Montreal and become a noted supplier of climate catastrophe mitigation. He finds himself the English pivot of “a huge historic moment” and “a major win for our planet and all of humanity”. Everything I know about his distinguished family persuades me he will stand firm in the nature and climate crisis, and won’t go down to history as Bolter Bannister after all. Since he has been given millions by Christopher ‘440 Kelvin-Volts’ Wilson and not had to surrender a single inch of his wonderland in return, he is in an excellent position to accelerate the renewal of Walshaw Moor and do his bit to stop the 53rd parallel from catching fire. He should start on Heather Hill.
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Caroline Hudson is an abstract landscape artist based in Haworth, West Yorkshire. She works with paint and clay often incorporating found materials.
Place is integral to Caroline’s art, the essence of her paintings and ceramic work derives from her relationship with the environments she is drawn to, in particular the nearby moorland. Her work exudes an otherworldly exploration of surface, colour, and texture.
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This is the 33rd in a series of 65 guest blogs on each of the wind turbines which Richard Bannister plans to have erected on Walshaw Moor. Turbines 5, 6, 8, 9, 11, 14, 16, 17, 21, 25, 27, 31, 32, 33, 34, 35, 36, 37, 40, 42, 43, 44, 47, 53, 54, 56, 57, 58, 60, 62, 64 and 65 have already been described. To see all the blogs – click here.
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