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 28 SD 98449 34067 ///overpaid.arching.common
Map of walk to T28 Middle Moor. WTRG on CWFL elevation baseToday, a brisk walk to T28 Middle Moor with Ali West, who has been with this blog almost from the beginning. T28 is the one I noticed was 342 metres out from the maps when the PEIR came out, when it was given as SD 98627.603 33774.699. Its correct position inside the square ///overpaid.arching.common spookily prefigures the theme of this blog, which is the overarching comment of the Planning Inspectorate (PINS), given at the beginning of their Scoping Opinion, adopted by the Secretary of State (then Ed Miliband, now Miatta Fahnbulleh) on 10 October 2025. The previous blog Crow Hill Junction describes the bog burst problems on Crow Hill.
In this blog we shall show that the moral authority of the CEP proposal has been squandered on three shameless lies that attempt to cover up major deficiencies. We shall also destroy the peat landslide hazard and risk assessment. The proposal cannot survive as designed. Even if redesigned, it cannot be ready until November 2027 and Algihaz will pull the plug. Investors cannot tolerate startling incompetence on this scale and neither can the Planning Inspectorate.
Overarching comment
“The Scoping Report defines a set of ‘search areas’ as the design is at an early stage with the locations of components not yet confirmed. The Scoping Report includes details of several components/processes which may be required during construction and operation.
The Scoping Report also sets out the sensitive location of the proposed development site, located in or near a number of designated sites. The Inspectorate considers therefore that by the time of the preparation of the ES the amount of sensitive environmental receptors could change. The ES should therefore carefully set out how the design has evolved in response to environmental constraints and in response to consultation feedback from relevant consultation bodies. This should include demonstration of how a mitigation hierarchy approach has been followed in the development of the design.”
Scoping Report map of search areas. CWFL
PINS are highlighting a feature of the blue access corridors. If access is taken from the east (M62/Halifax/Cock Hill) the turbine area can be reached on public roads without extra effects on the internationally designated SPA, SAC and on the Brontë Moor, which is the statutory setting of the Grade I listed Haworth Parsonage. However, if access is taken from the west (M65/Colne/Crow Hill) new tracks would have to be built through land with triple international significance, inverting the mitigation hierarchy in favour of private convenience.
Mitigation hierarchies structure every planning application
The moral authority of the planning system depends on assessment of alternatives relative to mitigation hierarchies using evidence baselines. The CEP proposal involves many levels of alternatives, like the gaps between vertebrae in the spine: cervical (C1-C7), thoracic (T1-T12) or lumbar (L1-L5).
Right at the top the National Policy Statement for Renewable Energy Infrastructure (EN-3) is assessed relative to the international designations: SPA (call it the cervical “C1-C2 gap”); SAC (“C2-C3”); and the globally renowned Brontë Moor (“C3-C4”). The proposal can break fatally at any of those places. We know there is a major “alternative sites” problem for CEP, because there weren’t any. The Algihaz lawyers, Pinsent Masons, will try to justify a generic idea of “alternatives” that is not common sense, and their wriggling is already outlined in PEIR Chapter 5 on Alternatives and Design Evolution. We have plenty to say on this, but not in this blog.
It is easier for everyone if we show the proposal is already broken in the thorax, at a decision to prefer Crow Hill to Halifax for access. The evidence base and case law weight have such unstoppable force that CWFL have already launched a cover-up.
Further down still, in the lumbar region, another example of a mitigation hierarchy determines the watercourse crossings. In PEIR Appendix 10-5, the choice between bridge, open culvert and piped culvert is made using “catchment area above the crossing”. The PEIR is clear and rational here, but the crossings are not existential like site alternatives or access. It reduces credibility to attack everything in the PEIR. The things that are suitable contrast with the things that are disastrous. Nonetheless, we shall engage later with wc14 and wc15 where “We’re gonna need a bigger pipe!”.
CWFL must provide all the evidence baselines. I think the Ornithology baseline is suitable for examination and I would not expend credibility, nor antagonise PINS, by disputing its specifics; the proposed mitigation, relative to the PEIR evidence of a wonderland, is much more vulnerable. The baseline for the Brontë Moor is non-existent and the proposal will fail at examination if this is not supplied. I happen to know what it should look like, but I am not going to do the work for Wessex Archaeology, because it is 300 hours of skilful work. As Bradford Council observed in 2023, “Innovation will be required”. The EN-3 Alternatives baseline is being constructed to retro-fit Walshaw Moor, and Pinsent Masons will be on danger money to get that through examination.
Some people underestimate the global force of the Brontë Moor. I walked the dogs early on Bank Holiday Saturday to avoid the Brontë pilgrims crush, yet at 7 a.m. I met a Japanese woman alone at ‘Wuthering Heights’ and she was in tears. “Everything here!” She had walked up from Ponden Hall (‘Thrushcross Grange’) the hard way that Cathy and Heathcliff ran as children, past ‘Penistone Crag’ and across the course of the 1824 bog burst that almost killed Emily (6), Anne (4) and poor Branwell (7) the above-average boy in a family of heart-breaking genius. “Everything here!”
The fatal break
The choice of access to the site is not so obviously fatal as the cervical mitigation hierarchies; perhaps it is thoracic (T1-T2). In the PEIR, CWFL opted for the western access by Colne/Crow Hill, for all the turbine components and 616,000 tonnes of non-calcareous aggregates. The turbine area infrastructure is designed in detail relative to that choice. We shall show the PEIR design is unlawful because they should have chosen Halifax/Cock Hill, for three legally compelling reasons.
Crow Hill access inevitably takes more of the internationally significant SAC, SPA and Brontë Moor than the eastern route through Halifax; the choice inverts the Ecology and Heritage mitigation hierarchies, and the PINS overarching comment asks for clear explanations. The map below illustrates the access routes from the motorways and indications of three hierarchies: safety, ecology, Brontë Moor. EN-3 cannot muddle the choice of Crow Hill because there is a clear alternative via Halifax. There is a convoy of law from the highest courts on this point, laid out later.
Readers may wonder why the same convoy does not also apply to the “cervical choices” too. It does apply, so the Algihaz lawyers, Pinsent Masons, must complicate the idea of “alternatives”, and persuade PINS that the legalistic fuzz they whip up is justified by EN-3. If they can’t convince PINS on that, the proposal dies. This is the roulette table on which Algihaz have placed their venture capital bet. Because it has taken so long to get to the spin, Algihaz have already spent a lot of money. Even if the proposal goes perfectly from now, Algihaz have paid £30 million for a chance to own a site they can flip for £35 million, but at huge cost to their reputation for competence. This blog will show that they have no chance, must redesign, and try for November 2027. With credibility lost, they will have spent £45 million for a tiny chance (given total loss of credibility and moral authority) to flip the site for £35 million. Algihaz are now chasing their mounting losses. Had they got their original 312 MW proposal through they would have spent £15 million on a site worth £46 million
If consented, CEP will have irreversible effects on the SPA, SAC, and Brontë Moor. The EN-3 conception of what “alternatives” means may somehow allow this. The destruction is unavoidable if a wind farm is consented. However, the destruction can always be reduced by designing the proposal via Halifax rather than Crow Hill, yet CWFL have chosen Crow Hill.
Algihaz may now realise that the proposal is already broken in the thorax on Crow Hill. Their Cavendish henchmen know; they have published three shameless lies to cover-up the break. CEO Mustapha Hajjar knows. I have sent him this analysis.
The map below shows the relationship of Options A and B relative to safety (bog burst), ecology (SAC/SPA), and heritage (Brontë Moor) mitigation hierarchies.
Option A M62/Halifax/Cock Hill and Option B M65/Colne/Crow Hill relative to the Safety (black bog bursts) Ecology (purple SAC and dotted SPA) and Brontë stars. WTRG on Defra MAGICOption B quantitatively destroys more of the international SPA/SAC/Brontë Moor and there is nothing of that calibre on Option A to balance it.
Qualitatively, the pink shaded Crow Hill, which was added at PEIR to the site, is the most sensitive for Brontë heritage; it also has the deepest peat (SAC) and the least human intrusion (SPA) so again Option B is much worse than Option A. Turbines have already been delivered by Option A to Ovenden Moor WF. Option B passes through the only repeated bog-burst zone in Great Britain.
No explanation for this inversion of the safety, ecology and heritage mitigation hierarchies is given in the PEIR Hydrology, Biodiversity or Historic Environment chapters. No overall explanation is given in the Project Design and Evolution chapter either; it should be in the vicinity of 5.7.39.
Instead, three explanations are given in the FAQs that are shameless lies. Christian Egal is responsible for them, but he has plausible deniability. He didn’t have time to read the incompetent Logika Scoping Report, so he can hardly be expected to read the FAQs. They are written by Cavendish Consulting for ordinary readers, who, it must never be forgotten, are paying for all this in their electricity bills. Until I hear otherwise, Cavendish were directly responsible for writing and publishing these shameless FAQs.
Two lies about the western route’s effects on environment and heritage: CWFL“Following further technical and environmental assessments, the western route is now the proposed (Abnormal Indivisible Load) AIL route, as it avoids or minimises impacts on key environmental and heritage features.” This is obviously untrue. The western route maximises the environmental and heritage impacts at the pinnacle (SAC, SPA, Grade I listed) of the hierarchies.
The biggest lie: “The western corridor provides the most suitable and safest route”: CWFLThe western access route cannot be the “safest” of two options, A or B, nor is it the “safer”. It requires heavy haulage tracks to be built over the only repeated bog-burst zone in Great Britain, and the hazard was known but unassessed when CWFL published the “safest” FAQ.
The moral authority of the proposal evaporates with these three shameless lies, thought good enough to bamboozle the bill-paying public, but not to show PINS in the PEIR. As usual, once exposed, the cover-up highlights the problems. Somebody at CWFL already came this way, saw some of the trouble, and wrote those FAQs. Lies always point to the truth. CWFL could not state the only reason for the choice of Crow Hill which was “private convenience”.
Whoever wrote “safest” cannot have known how much trouble the peat landslide assessment is in on Crow Hill.
The PPLHRA
The crucial baseline for the safety assessment of the western access is the Preliminary Peat Landslide Hazard and Risk Assessment (PPLHRA). The author “AJM” is Dr Andrew J Mills, and consultancy OWC own the liability. I met Dr Mills at Hebden Bridge on 21 April 2026, where I had just served Christian Egal with a formal notification that T28 was 342 metres out of position. I worked that out using the last map in the PPLHRA, since revised, because it was luckily both the most legible and the only one that had the wrong positions. The CWFL engineer Donald Mackay said, “Great spot on the turbine locations, by the way!”
In the PPLHRA, Dr Mills first disclaims the possibility of assessing the Crow Hill bog bursts with the information he has been given.
“The spatial scope of this PPLHRA at PEIR is limited to the Turbine Area within which turbines are proposed and does not extend to covering the Access Routes nor the Bradford West Cable Corridor, as shown in Plate 1.1. These components of the Proposed Development will be assessed once supporting peat depth data is available.”
This already means that CWFL had no basis for their shameless lie that the western route is “safest” because they had no expert assessment of the bog-burst hazards on Crow Hill.
“A bog burst was documented on Crow Hill near Haworth by Brontë in 1824, and this is likely the nearest recorded failure to the Turbine Area (Ross, 2021).”
Dr Mills will get his bog bursts in a twist because he thinks there is only one event. The reference to “Ross, 2021” is slapdash. Dr Mills means “Ross, 2020”. Had he read Ross, 2020, he would know that there are eight recorded bog bursts on Crow Hill, in three separate events between 1824 and 1989. The 1824 events are not “the nearest recorded failure to the Turbine Area.” We shall later meet that in Dr Mills’ PhD thesis…
“The term “bog burst” is used to refer to very large-scale (usually greater than 10,000 of cubic metres) spreading failures in which the landslide retrogresses (cuts) upslope from the point of failure while flowing downslope. Where such events occur, the peat is typically deeper (greater than 1.0m and up to 10m) and more amorphous than sites experiencing peat slides, with shallower slope angles (typically 2°-5°). Much of the peat displaced during the event may remain within the initial failure zone. Bog bursts are rarely (if ever) reported in the UK, other than in the Western Isles of Scotland (e.g. Bowes, 1960), and notably, immediately to the north of the Turbine Area.”
Dr Mills tells us that though UK bog bursts are rare, they are “notably” clustered on Crow Hill where he says there have been two. “UK” is slapdash because it includes Northern Ireland, where bog bursts are more common. It is clear that Dr Mills means “Scotland, England and Wales” for which “Great Britain” is the correct term. The official bog-burst distribution in GB is Scotland 5, Wales 0, Crow Hill 3.
“There are no published failures or news reports of landslides in proximity to the Proposed Development. Review of the nearby wind farms in similar settings (Hyndburn Wind Farm, Coal Clough Wind Farm, Todmorden Wind Farm, Reaps Moss Wind Farm, Crook Hill Wind Farm and Scout Moor Wind Farm show no evidence of failures in association with construction.”
Dr Mills means by “in proximity” that the South Pennines, except Crow Hill, does not host peat landslides and that the nearby wind farms have not caused any. We see how Dr Mills is failing to understand Bayesian prior probability. The absence of bog bursts at the other wind farms strengthens the case that Crow Hill is very unusual, since it has hosted several. If you build a wind farm anywhere in the South Pennines except Crow Hill, you don’t have a bog burst history.
“To the north of the Proposed Development, there are two recorded peat landslides (eastern and western), one, or both of which are known together as the Crow Hill bog burst (Ross, 2020), described by the Rev. Patrick Brontë. The eastern landslide is connected to Ponden Clough Beck (also Ponden Clough / Cleuch), with impacts on this watercourse being described in Brontë’s account of the event. The western landslide is located closer to Crow Hill, but is connected to Crow Hill Beck. Both were reported by Brontë as occurring during the same meteorological event. Accounts of effects on watercourses documented in Ross (2020) include effects in Leeds and even effects on water colour as far east as the Humber Estuary. These distances are far in excess of impacts documented for peat slides, though some bog bursts documented in Ireland have reported far-reaching impacts extending to tens of kilometres.”
A key error, and it is very serious, is Dr Mills’s claim that Brontë reported both the western and eastern landslides as occurring in the same event. This is false. The bog burst documented by Brontë is only the eastern one between The Wage of Crow Hill and Stanbury Bog. Brontë’s account is set out in Ross, 2020 pp. 38-41. The italics are mine.
“During the time of a tremendous storm of thunder, lightning and rain, a part of the moors in my chapelry … sunk into two wide cavities; the larger of which measured three hundred yards in length, about two hundred in breadth, and was five or six yards deep. From these cavities ran deep rivers, which uniting at a distance of a hundred yards, formed a volume of mud and water, varying from thirty to sixty yards in breadth, and from five to six in depth; uprooting trees, damaging or altogether overthrowing solid stone bridges, stopping mills, and occasionally overwhelming fields of corn, all along its course of ten or fifteen miles.”
The event was in Patrick Brontë’s Stanbury chapelry (an extension of his Haworth parish) on the Yorkshire side of the watershed. There were two cavities, both on Stanbury Bog, with peat outflows “uniting”, accelerating down Ponden Clough and draining to the Worth and Aire. Bog bursts are huge, and there were two on Stanbury Bog, on Tuesday 2 September at 6 p.m. and Wednesday 3 September 1824 at 8 a.m. There were four more separate eruptions on Thursday. The LIDAR map below shows multiple explosions.
The maps show three events on Crow Hill Wague and The Wage of Crow Hill that Dr Mills has compressed into a single meteorological event in 1824.
The three bog bursts on Crow Hill transferred to CWFL hydrology base map from Defra LIDAR. WTRG The three Crow Hill bog bursts like fingerprints. WTRG on Defra LIDAR a) The western bog bursts b) the eastern bog burst (visible multiple foci, described in Ross as two craters and four further bursts, all 2-4 September 1824). Notice how well-defined the rectangular feature is in a). CWFLDr Mills’ “western bog burst” was mainly in Lancashire, but drained to the Yorkshire Calder down Walshaw Dean, because the watershed on the flatness of Wague and Wage is not quite where the boundary stones go. There are in fact two Lancashire bog b