Please feel free to use some or all of our template objection letter. If you can please personalise to add your own emphasis. It is best to submit to both planning authorities.

• Rossendale with reference number 2025/0267
• Rochdale with the reference 25/00680/FUL

Subject: Objection to planning application [Rossendale reference 2025/0267 | Rochdale reference 25/00680/FUL]

Dear Planning Officer,

I wish to object in the strongest possible terms to the above application submitted by Cubico on the following grounds:

1. Firstly, I note the issues that Rossendale Planners themselves raise in the notification letter for this application, dated 23^rd Sep 2025:
   1. May impact a public right of way to which part 3 of the Wildlife and Countryside Act 1981 applies.
   2. The application would not accord with the provisions of the development plan, in the opinion of the Council affect the setting of a Listed Building; and would, in the opinion of the Council affect the character or appearance of a Conservation Area.

   Given these qualifications I have to ask why the application was not dismissed out of hand, and at a much earlier stage of the application process?

2. Much of the information in the application is provisional, including the height, make and model of turbines themselves. Surely these details are too important to be provisional for an application of this size?
3. The proposed development is on Green Belt and Common Land with protected moorland habitats; this development would cause irreparable harm and damage to these.
4. The proposed siting of the development is alongside one of the North West’s and Rochdale’s greatest heritage sites – The Cotton Famine Road (Rooley Moor Road) – which should be valued and not destroyed by such a development.
5. Waugh’s Well would also be severely affected and this again is a site of great significance given that Edwin Waugh is regarded as one of the greatest Lancashire dialect poets.
6. Large areas of peatland will be destroyed immediately. This will include 17 large turbine bases, associated hard standing and 17km of 6m wide access roads. Rossendale’s local policy ENV7 prohibits turbines on areas of deep peat, i.e. peat over 40cm in depth. We know from the applicant’s detailed data presented in ES Technical Appendix 15.1 that the minimum depth of peat to be impacted by turbine bases, hard standing is 45 to 60cm. Therefore, none of the turbines would comply with ENV7. Presumably a great deal of thought was put into developing this policy and it would therefore be shocking to see this overridden. Therefore, why is this application even being considered?
7. The Carbon Payback Period quoted of 1.8 years maximum is impossible to validate. Firstly, it is based on using the Scottish Carbon Calculator which as the official Scottish Government review found “is lacking in one or more methodologies, use of emission factors, and assumptions for all peat-related areas of the Carbon Calculator”. Secondly, Cubico have so far ignored all requests to release their detailed calculations in the form of a spreadsheet (as of 27^th Sep 2025). This means that it is impossible to validate their claimed payback period so we cannot know if the wind farm would reduce carbon dioxide emissions. They are simply asking us to take their word for it. We know this is a contentious area nationally because the government has been asked on several occasions “how much will Net Zero policy reduce global temperature?” and there has so far been no answer. I have to assume that either they do not know or, if they do know, the figure is so small that they dare not publish it.
8. The Peat Moorland Restoration Plan and Community Benefit Fund are cited as reasons to overcome the objections to peat damage and green belt development. However, the funding for these programmes will come from government support for renewable energy projects, specifically Contracts for Difference. I.e., we will be funding these programmes ourselves, from a tiny proportion of the profits that Cubico will receive due to government, i.e. our, support. We are in effect being bribed with our own money – this is an insult. If the moorland needs restoring, then do this without first destroying large areas for a fraction of the public support that Cubico will receive.
9. Further relating to peat and flood risk, the Lead Local Flood Authority for Lancashire County Council have objected stating “…the submitted evidence overall lacks the detail the Lead Local Flood Authority requires at this full application stage to demonstrate how the development will meet appropriate standards and comply with national policy and guidance. Whilst some effort has been made to comply with the necessary requirements, the Lead Local Flood Authority objects to the above application…”
10. NATS and MAGS have highlighted how the wind farm will have a detrimental impact on civil and commercial aviation.
11. Our moorlands, particularly Scout Moor and Rooley Moor, are the natural ‘lungs’ of Lancashire and Greater Manchester. We live in a densely populated area and given the proposed housing developments will become even more so. As such we need these moorlands to continue providing some of the best recreational opportunities for residents and visitors alike. Regardless of what Cubico say, my experience is that wind turbines make a noise; they grate and grind and they also create shadow flicker which ruins the experience of enjoying the moor.
12. The British Horse Society Regional Bridleways Officer for the NW, objected, concluding “If permission is granted for the Scout Moor wind farm extension I personally feel it will be the end of the Mary Towneley Loop for horse riders.” I agree, and it is not only horse riders but anyone walking or cycling up the road who will be impacted.
13. On a related point, the access roads criss-cross the moorland destroying historic footpaths and trails and provide access for illegal off road motor bikers who regularly rip up the moorland. They leave trails of oil polluting water courses and worry wildlife and sheep and cattle. They are also aggressive to legitimate users of the moorland.
14. The proposed height of the turbines (up to 180m), taller than Blackpool Tower, is totally unacceptable and will ruin the moorland by their disproportionate size to the surrounding area. This will be particularly devastating for the conservation area of Prickshaw and Broadley Fold. This raises the issue of “why create conservation areas if they are to mean nothing with respect to aggressive developments like this?”
15. Most of the equipment will come from overseas so there will be no benefit to either the UK or local economies in this respect. Accounts for Scout Moor 1 show that this proposal would create zero long term jobs in the local area. All required maintenance work would be carried out by contractors, with specialists coming from outside the area.
16. I note that the Coal Authority make no objection but request several conditions required for “intrusive” investigations particularly concerning positions of access tracks. Although they note that turbine locations consider the positions of previous mine workings, not all workings are recorded accurately and hence the need for investigation. There is no consideration of future re-siting of turbines for other reasons (e.g. for peat protection). Given the complexity of balancing positioning with respect to deep peat, potential mine workings and wildlife habitats, surely all these issues should have been addressed before the application was submitted? Otherwise, what happens if they are not able to balance all these requirements? As just one example, one way to balance may require the construction of additional access roads, which would then have a knock-on impact on carbon payback calculations.

Overall, considering the planning balance, I have outlined a large number of points that weigh heavily against this application. On the other hand, there are no benefits. Benefits cited by Cubico will all flow from taxpayers, being a small fraction of the considerable profits that Cubico will make from public subsidies for renewable energy.

Yours sincerely,

Name

Address