- What follows is Ban the Burn!’s initial response on 18th October 2023 to news of the proposed Calderdale Windfarm. We didn’t have a website at the time, so posted our response on the Turning Calderdale Green blog.
- We are reposting it from Turning Calderdale Green because although things have moved on, we think it remains a useful attempt to summarise and question the totally unexpected news, while many people are still in the dark about the proposal.
A Saudi-owned and -controlled company called Calderdale Windfarm Ltd, in partnership with a Wiltshire-based residents property management company called Worldwide Renewable Energy (Global) Ltd, has announced it is at a very early stage of the design process for a 2,352 ha, 65 turbine wind farm on Walshaw Moor Estate, part of the Hebden Water catchment above Hebden Bridge. This would be one of England’s biggest wind farms.
You can read about the corporate players here.
Does the proposed site of Calderdale Windfarm make environmental and climate sense?
Walshaw Moor is one of the rare areas of upland blanket bog in the UK, and as such, should be protected as a vital carbon sink on a par with tropical rainforest. However, the Moor’s ecological condition has been seriously degraded as a result of prolonged mismanagement.
With the aim of restoring the upland blanket bog to a good state, Walshaw Moor has the highest level of conservation protection as a Site of Special Scientific Interest, a Special Area of Conservation and a Special Protection Area. As a result, Walshaw Moor Estate is subject to a legally binding Catchment Restoration Plan agreed with Natural England.
The 2018 Catchment Restoration Plan on Natural England’s website is subject to a 2019 Addendum that withdraws Walshaw Moor Estate’s proposed firefighting track from the Plan, due to the damage to blanket bog it’d cause. As mentioned in more detail below, this has to be of significance to the Calderdale Wind Farm proposal, which includes building 65 tracks for the construction and maintenance of the turbines.
To date there are 0 turbines in England on recognised blanket bog habitat 7130 that is protected under the EU Natura 2000 network – as the blanket bog on Walshaw Moor Estate is (now under post-Brexit amendments to EU directives.) It would set a precedent if Calderdale approved Calderdale Wind Farm.
Most of the turbines would be built on protected blanket bog which Habitats Regulations require to be restored to favourable conservation status
The Habitat Survey for Calderdale WInd Farm Ltd’s Enviromental Impact Screening Opinion application on the Calderdale Council planning portal shows that most of the proposed turbines would be built on blanket bog or degraded blanket bog.
“Degraded” blanket bog is a way of describing the habitat when it has lost key vegetation species, including Sphagnum moss, which has subsequently led to a reduction in the water table (Allott et al., 2022) and, in turn, loss of the conditions which protect the accumulated peat and maintain blanket bog habitat. However, within this sweeping categorisation there are various blanket bog conditions.
Natural England’s Common Standards Monitoring identifies these blanket bog conditions as:
- Favourable
- Unfavourable declining
- Unfavourable no change
- Unfavourable recovering
Blanket bog land management guidance from the Uplands Management Group identifies 6 states of blanket bog. It shows how blanket bog restoration improves the various states to a good condition – as required by the 2019 Conservation of Habitats and Species (Amendment) (EU Exit) Regulations. These Regulations establish management objectives for protected sites like the Walshaw Moor Special Area of Conservation/Special Protection Area.
These are the 6 states of blanket bog
In 2022, Moors for the Future surveyed 10,156 ha of Calderdale blanket bog and found most is state 3 Dwarf shrub dominated(2,366 ha) and Grass and/or sedge dominated state 4 (6,092ha).
(These types of vegetation include heather and cotton grass which are peat-forming plants, so even in these states the blanket bog can continue to form peat.)
There is 28 ha of State 6 blanket bog habitat focused on Soyland around the Turvin Road area as well as other isolated survey squares in this category. For example, 8 ha west of Widdop Reservoir.
So how can Calderdale Wind Farm Ltd propose building and operating its turbines on this protected blanket bog, which is required to be restored to good condition? Particularly since Walshaw Moor Estate’s proposed stone and timber track across protected blanket bog was unable to go ahead in 2019 because, among other harms, it would damage the protected Blanket Bog, as well as Dry and Wet Heath habitats?
There is reliable evidence that stone tracks compress and compact blanket bog, reducing its ability to hold water and reduce run off. This would increase flood risk in Hebden Bridge.
What then, of the tracks needed for construction and maintenance of 65 huge wind turbines, plus battery storage and solar panels on south facing slopes? Not to mention the concrete bases for these massive feats of engineering?
But Calderdale Windfarm Ltd claims its
“proposals offer additional environmental measures that go above the objectives set out within the estates’ Catchment Restoration Plan.”
If true, this is a favourable change from the ongoing battle with Natural England that the Walshaw Moor Estate owner, local businessman Richard Bannister, has waged for years over his mismanagement of the moor for intensive driven grouse shooting. This has been at odds with protecting this vital blanket bog habitat, the diverse wildlife it should support and its mitigation of flooding in Hebden Bridge and downstream.
But then again, if the environmental measures required by the Catchment Restoration Plan can and have been undermined by non-compliance, what’s to say that wouldn’t continue if the WInd Farm were to go ahead?
The Calderdale Wind Farm Ltd FAQs say the wind farm would end grouse shooting – but there’s only been a few shoots for the last two years as grouse numbers on Walshaw Moor Estate can’t be sustained.
The corporate guys say the Calderdale Wind Farm would mean the end of grouse shooting on Walshaw Moor Estate. But after all the Estate’s intensification of grouse breeding (and related habitat degradation), the numbers of grouse needed for shoots just can’t be sustained. For the last two years there has been hardly any shooting anyway.
Therefore, presumably, no £31.8m income – the amount, over a 5 year average, that Mr Bannister valued his driven grouse shooting business at, in an Assessment for Compensation claim he made against Natural England in 2011.
This was part of his fight against a move by Natural England to limit Walshaw Moor Estate’s burning of blanket bog – a practice related to intensive red grouse breeding.
Since then, Walshaw Moor Estate’s land management practices to support intensive grouse breeding have continued to conflict with many of the requirements of the Estate’s agreement with Natural England to return the moor to a favourable ecological condition, in exchange for substantial Environmental Stewardship payments funded by you and me, as taxpayers.
Calderdale Wind Farm’s proposed site covers 11 units designated by Natural England as vital for ecological restoration
The proposed site for Calderdale Wind Farm’s 65 wind turbines is around the three Walshaw Dean Reservoirs (Lower, Middle and Upper). This area covers 11 Site of Special Scientific Interest units that Natural England has designated by habitat, ecological condition and estimated date of restoration to favourable condition.
These designated units on the South Pennine Moors Site of Special Scientific Interest are 044-051, 55,84 and 166. You can view Natural England’s unit reports on their Designated Sites search website. (The names of the sites to enter into the search are listed in the section below, “Designated South Pennine Moors Site of Special Scientific Interest units.”)
Ecological restoration of all the units is vital – not just for restoring biodiversity and sequestering carbon, but also for hydrology and reducing the flood risk to Hebden Bridge and the downstream Calder Valley.
But how is ecological restoration of these land units compatible with the construction, operation, maintenance and eventual decommissioning of 65 x 150-200m turbines (nearly twice as tall as the Ovenden wind turbines?) Plus possible battery storage and solar panels on southern slopes, and possibly other renewable technologies?
How is the chosen site and project option even environmentally defensible, given the conflict between the Habitats Regulations and the proposed Windfarm’s degradation of large areas of the blanket bog to State 2 Bare Peat?
And doesn’t it seem likely that the proposed environmental measures that “exceed the Catchment Restoration Plan requirements” will involve carbon and biodiversity offsets to compensate for the damage done to the site? Rather than avoiding – or even repairing – damage to the site?
And if, by chance, Calderdale Wind Farms is planning to fund its 300K tree planting on Walshaw Moor Estate through the government’s Woodland Carbon Guarantee scheme, that’s part of the financialisation of everything that’s turning the natural environment into another set of markets for the financial services industry to get fat off.
The proposed Calderdale Wind Farm site is only around half the area managed by Walshaw Moor Estate
The proposed wind farm site occupies only 11 of the 26 Site of Scientific Interest land units that Walshaw Moor Estate is responsible for. The 15 that are not in the proposed wind farm site are 35-37, 56-57, 79-83 and 90. So what is going to happen with these 15 Site of Scientific Interest land units? And who owns them?
Apparently the Land Register records that Richard Bannister/Walshaw Moor Estate owns the Moor to the north west of Walshaw Moor which is known as Lancashire Moor. The Land Registry should also confirm that the land to the south of the Widdop Road, Heptonstall Moor, is owned by Yorkshire Water but the sporting rights on that land are held by Richard Bannister/Walshaw Moor Estate.
We think the rest of the Walshaw Moor Estate land is also probably owned by Yorkshire Water, and that Walshaw Moor Estate leases it. However Yorkshire Water has refused our Environmental Information Request for a map or maps of all the Yorkshire Water land that is leased to Walshaw Moor Estate. It says that “providing maps and locations of our infrastructure could pose a risk to national security as this information is not readily available in the public domain.” But it adds,
The Estate do hold a current sporting lease for some land owned by Yorkshire Water and they undertake shooting activities on the land in line with the terms of the lease and the Natural England management plan.
At the 6th December 2023 ‘Stop Calderdale Wind Farm’ public meeting in Old Town, the Savile Estate manager Charlie Yorke said that since Bannister will still have the sporting rights to the north west and south of the wind farm area, driven grouse shooting will continue.
Although in 2021 Yorkshire Water committed to a phasing out of shooting tenancies, there is so far no indication as far as Ban the Burn know, that this is going to happen any time soon for Walshaw Moor Estate.
Natural England’s slashed budgets have stopped it from enforcing the ecological restoration of Walshaw Moor Estate
Of the 11 land units in the proposed Calderdale Wind Farm site, Natural England records that two are blanket bog on deep peat, three more are blanket bog on shallower peat, one is moribund blanket bog, one is blanket mire, one is mainly water and three more don’t say – but do say that restoration works are required because of damage to habitat from “unconsented operations.” That means the landowner doing things that are not permitted in the land management agreement with Natural England for this highly protected moor.
However none of the units has been assessed since 2014. With its budget slashed over the past decade and a half by central government, Natural England hasn’t had the staff to monitor the Walshaw Moor Estate’s compliance with the Catchment Restoration Plan. So there seems to be no reliable way of knowing the current state of the habitats, or of the wildlife they support.
By its own admission (p 22), the 2022 Moors for the Future survey of 10,156 ha of Calderdale blanket bog only provides a visual assessment of which of the 6 states of blanket bog the surveyed area falls into – not the kind of effective, responsive monitoring with clear feedback to the management of the protected habitat that Natural England admits is needed to support progressive improvements in site condition.
Assuming Calderdale Council allows Calderdale WInd Farm Ltd to proceed towards a planning application, the mandatory Environmental impact assessment Calderdale Wind Farm Ltd would have to carry out would be likely to find the proposed land units for the windfarm are in poor ecological condition.
Is it possible they may be tempted to take advantage of this? To claim that the construction and maintenance of the windfarm will not damage the sites, because the damage has already been done? That would be a pretty rubbish argument.
In order to awaken Natural England to its urgent need to protect Walshaw Moor’s peatland and hydrology, the late Hebden Bridge environmental activist, Dongria Kondh, went on hunger strike outside the agency’s Leeds Office in early 2021.
Enforcing compliance with legally binding ecological protections is vital to restore biodiversity, mitigate climate change and reduce the flood risk in Hebden Water and downstream in the River Calder. But despite Dongria’s hunger strike, Natural England has not had the resources to do this.
So how are they going to start now?
Designated South Pennine Moors Site of Special Scientific Interest units
These are the units where the proposed wind turbines would be built. The SSSI Condition of Units is here. The most recent condition assessments were in early 2014. Some date back to 2010.
Harry Side – 044
Shackleton Moor – 045
Wadsworth Moor – 046
White Hill – 047
Shoulder Nick – 048
Grey Fosse Clough Moss – 049
Grey Stone Hill – 050
Field of the Mosses – 051
Greave Pasture – 055
Stairs Swamp – 084
Walshaw Dean – 166
The units are viewable through the Natural England Designated Sites View website.
Uncertain reception to Calderdale Wind Farm proposal
All this is why there is such an uncertain reception to the Calderdale Wind Farm proposal. A member of Upper Calderdale Wildlife Group said,
“I had a lot of mixed feelings when I heard about the Calderdale Windfarm Plans.
“I suspect many will just tune into the positive effects of wind farms, the promise of planting 300,000 trees on the site, new water management across the site with the aim of reducing flooding within local communities, and cessation of grouse shooting (all valid.) But I have the following concerns :
“How will they protect this Special Protection Area , Special Ares of Conservation and Site of Special Scientific Interest from the negative effects of the massive infrastructure needed to build these very large turbines ?
“How will the turbines affect the deep peat found in the proposed area and how will they mitigate this ?
“What trees will be planted where? The trees aren’t necessarily a good move – depending on where they’re planted and what type of trees.
“Will they properly consider the impacts of bird strike that could result in such a massive number of turbines?
“Will the biodiversity of Walshaw Moor be sacrificed for emission targets?
“How will it affect access in the 2 year period of building turbines?
“What the hell will it look like !!?
“Will they continue keepering Walshaw estate with all the legal and illegal control of wildlife that this involves?”
Calderdale Wind Farm scoping documents are on Calderdale Council planning portal
On September 25th, Calderdale WInd Farm Ltd sent in a Scoping Report to Calderdale Council Planning Department.
The company says the purpose of the scoping report is to help it to
“identify the significant likely effects of the proposed wind farm which will need to be fully assessed in the Environmental Impact Assessment (EIA), which the company will submit as part of a future planning application.”
The grid connection and associated infrastructure would be subject to a separate planning application.
You can view the scoping documents on the Calderdale Council planning portal . Including Ban the Burn’s and Upper Calder WIldlife Network’s responses to Calderdale Wind Farm’s Scoping Report. If you’re in Lancashire, in areas adjoining Walshaw Moor, you should definitely check out the scoping documents and send your views to Calderdale Council’s planning portal.
Scoping application on parish council October agendas
The 23/06010/EIA Scoping application is on the agenda of Blackshaw Parish Council meeting on Monday 23rd October, 7.30pm at Blackshawhead Methodist Church.
Update – Blackshaw Parish Council’s comment: “The Parish Council discussed this and agreed to object primarily on the basis that in the scoping opinion papers there is no justification for such a large onshore wind farm under the climate change imperative. No detail of whether the scheme would be carbon negative or positive during scheme lifetime. Lots of detail on specific birds etc, but nothing on the basic question of contribution to mitigating climate change, and councillors felt that this was by no means a given, in view of the embedded carbon in manufacture, the transport costs, the impact on the peat, the environment, birds, visual impact and so on. This will certainly have an enormous impact on the environment, councillors concerned about deep foundations, the tracks needed across open moors, the proposed lights on top in a dark sky area. Heavy impact locally on roads, which are considered to be really inappropriate and councillors felt that contractor traffic must certainly not use Widdop road. Would want to see very serious environmental impact assessment. Bogs are equivalent of rainforest in terms of carbon sequestration is this factored in to any carbon targets? One of the ways in which it will impact Blackshaw Parish is in terms of visual impact but there were no views shown in the documents from this parish – that would need to happen for people to understand the impact in a future application. The other way would be potential construction traffic – but no detail available yet about this and routes proposed.”
The scoping application is also on the agenda of Wadsworth Parish Council meeting on Tuesday 24th October. Wadsworth residents can make their views known in the Public Discussion Time. Email wparish@hotmail.com
Unfortunately the Hebden Royd and Hilltop Parishes Neighbourhood Planning Committee has already met on Monday 16th October to consider communications regarding a proposal for an onshore windfarm within the Neighbourhood Plan area.
And on Wednesday 18th October, the Hebden Royd Town Council Strategy and Review Committee met, with an agenda item on Wind Farm Guidance – To review and make recommendations to update the guidance. This is the 2012 Hebden Royd Town Council Wind Farm Guidelines – to use when considering wind turbine planning applications. The guidance requires the Council to refuse applications for wind turbines in the Special Protection Area of moors to the west of Hebden Bridge, and in areas where turbine construction would disturb or destroy peatcover.
Update – The inclusion of Hebden Royd Town Council Wind Farm Guidance in the Strategy and Review Committee agenda was a request of the Full Council which met the previous week. No changes were recommended at the Strategy and Review meeting. The Town Clerk, Jason Boom, said,
“It seemed wise to educate councillors of the policy given recent applications for wind turbines, as individuals or as a farm in this case, have been sparse of late.
“I have no doubt Calderdale MBC will consult through their usual methods via their planning portal in due course. While I am not able to confirm at this point if we will be a statutory consultee in this process, given the application is outside of our area, we will be well within our rights to share our opinion when a process opens.”
There is also a Climate Emergency and Environment Committee meeting on Weds 25th October, but the agenda doesn’t include Calderdale Wind Farm. For info, email the Town Clerk: jason.boom@hebdenroydtowncouncil.gov.uk, or the Climate Emergency & Biodiversity Coordinator: rachel.lightbird@hebdenroydtowncouncil.gov.uk
Save And Restore Walshaw Moor 