The following is a suggested template objection letter for residents of the Prickshaw and Broadley Fold conservation areas. Please do adapt the content to suit your own priorities.

 

[Your name]

[Your address, Prickshaw]

Rochdale

[Postcode]

[Date]

Rachel Carney

Principal Planning Officer (Growth), Economy

Rochdale Borough Council

Floor 3, Number One Riverside

Smith Street, Rochdale OL16 1XU

James Dalgleish

Principal Planning Officer

Rossendale Borough Council

The Business Centre, Futures Park

Bacup OL13 0BB

 

By email: rachel.carney@rochdale.gov.uk; jamesdalgleish@rossendalebc.gov.uk

 

Dear Ms Carney and Mr Dalgleish

Re: Application 25/00680/FUL (Rochdale Metropolitan Borough Council) and Application 2025/0267 (Rossendale Borough Council), Scout Moor II Wind Farm, Objection from a resident of Prickshaw

I am writing to object to the above linked applications as a resident of Prickshaw, within the Prickshaw and Broadley Fold Conservation Area. As the two applications together comprise a single scheme, I am sending this letter to both Councils and would be grateful if it were recorded as a formal objection against each application. I object on the grounds of harm to the Conservation Area and its setting, direct conflict with the Councils’ own adopted and emerging planning policies, and the combined effect of visual intrusion, noise and aviation lighting on this small, historic settlement, for the reasons set out below.

1. The Conservation Area’s own appraisal identifies Rooley Moor and Scout Moor as defining views

Rochdale Borough Council’s own Conservation Area Appraisal for Prickshaw and Broadley Fold describes the settlement as lying within an almost unspoilt rural setting, surrounded by “open, uncluttered moorland”, with Rooley Moor directly adjoining the settlement.

The appraisal’s townscape analysis identifies four significant views as being of “particular importance to the established significance” of the Conservation Area, the views towards Whitworth, Rochdale, Rooley Moor and Scout Moor. Rooley Moor is the moor immediately adjacent to Prickshaw, and is named in the same list as Scout Moor. These are not peripheral or incidental outlooks: they are the defining views the Council’s own heritage assessment has identified as underpinning why this Conservation Area is significant in the first place. Scout Moor II would place several turbines, at up to 180 metres to blade tip, directly on and around Rooley Moor.

This concern is not mine alone. Rochdale’s own emerging Local Plan requires development within this landscape type to “reflect and respond to the special qualities and sensitivities” of the location, expressly including “views and perceptual qualities” and “archaeology and cultural heritage” (Places for Everyone Policy JP-G1, now part of the statutory development plan). Rochdale’s wind energy evidence base goes further still: the Council’s own Climate Change and Flood Risk Topic Paper, published in August 2026, states in terms that further large-scale wind development in this part of the borough carries “issues around environmental impacts in particular in relation to peat, and in terms of landscape impacts”, the Council’s own words, naming the very two concerns at the heart of this objection.

2. The Council’s own appraisal shows that even partly-screened infrastructure has a substantial impact on this setting

The appraisal records that existing electricity pylons, although “largely screened from key view points by the combination of the built environment and natural topography”, nonetheless have a “substantial impact, particularly affecting the views from within the local residence’s properties”. It goes on to say that any proposal affecting the setting of the Conservation Area “will potentially have a substantial impact upon the character of the settlement and must take into consideration the key views and rural, unspoilt setting which is crucial to the significance of the settlement”.

Unlike the pylons, the proposed turbines would not be screened. They would be large, moving structures, visible in daylight and illuminated at night, sited within the very view the Council’s own appraisal identifies as key to the area’s significance. If partly-screened, static pylons already have a substantial impact on this setting, a materially more prominent, moving and illuminated development cannot properly be assessed as having anything less. The nearest proposed turbine to a residential property, Willowfield Barn, would stand approximately 960 metres away: closer than the height of three turbines placed end to end.

3. The Environmental Statement’s own “not significant” conclusion for the Conservation Area does not survive scrutiny

Chapter 12 (Built Heritage) of the Environmental Statement, Volume 1, records a Moderate adverse effect on the Prickshaw and Broadley Fold Conservation Area, but concludes this is “Not Significant” for the purposes of the Environmental Impact Assessment Regulations. The supporting Heritage Assessment (Environmental Statement, Volume 2, Appendix 12.1) reaches the same conclusion. This conclusion does not withstand scrutiny, for two clear reasons.

First, the “Not Significant” conclusion applies a specifically heritage-focused legal test (whether the effect “substantially diminishes” the heritage interest) which is a different and narrower question from whether the harm matters. The Conservation Area’s own appraisal shows that this settlement’s significance rests substantially on its defining views, including the view towards Scout Moor; a Moderate adverse effect on that view goes to the heart of what makes the area significant, whatever label the EIA Regulations attach to it.

Second, the visualisation prepared for this viewpoint (Viewpoint CH02, Prickshaw Lane, part of the Environmental Statement’s Volume 1 heritage visualisations for Chapters 11 and 12) shows 10 sets of blade tips and 9 hubs visible on the applicant’s own wireline, while the accompanying Chapter 12 text (Volume 1) describes only “eight turbine hubs and one turbine blades” as visible, a materially lower count than the applicant’s own drawing shows. The Council should clarify which figure was actually used to reach the “Moderate adverse” and “Not Significant” conclusions, and require the applicant’s ground-truthing evidence, referred to in Chapter 12 but not published, to be provided before that conclusion is relied upon.

4. Noise, including amplitude modulation

The final turbine has not been selected, and the Environmental Statement’s noise assessment (Volume 1, Chapter 7, and the supporting Volume 2 noise appendices) is based on a candidate turbine only. Amplitude modulation, the characteristic “swishing” or thumping noise turbine blades can produce, has not been assessed at all; the applicant’s position is that this is best addressed through a complaint-based planning condition after construction, not before permission is even considered.

This matters because Rossendale’s own adopted Local Plan, Policy ENV7 (Wind Turbines), expressly requires that a wind scheme would “not result in unacceptable noise impacts, including amplitude modulation, on residential properties and other sensitive users” as a named, binding criterion of the development plan, not merely a desirable outcome. Rochdale’s own Core Strategy, Policy G3, requires the same for the application covering my own home. It is not reasonable for residents of a small, quiet settlement like Prickshaw to be told that if the noise turns out to be a problem, the remedy is to complain and wait for a lengthy assessment process to run its course, rather than for the scheme to be properly bounded and tested against these adopted policies before permission is even considered.

5. Aviation lighting

The Environmental Statement’s own Landscape and Visual chapter (Volume 1, Chapter 11) concludes that, even with a reduced-intensity lighting scheme, night-time effects would remain Significant for a number of named communities. Prickshaw, on the edge of open moorland with unobstructed views west, would be directly affected by any illuminated turbines within that view. The applicant’s own Aviation and Met Radar Impact Assessment confirms this reduced scheme was approved by the Civil Aviation Authority for the previous 17-turbine layout only, and states plainly that it “will be re-submitted to the CAA for approval” for the current 12-turbine scheme. No evidence has been provided that this re-submission has taken place or that approval for the current layout has been granted. The lighting scheme this application relies on to reduce night-time harm to Prickshaw has not, on the applicant’s own account, actually been approved for the scheme now before the Councils.

6. Policy ENV7 and Policy G3: criteria this application has not been shown to meet

Rossendale’s adopted Local Plan sets out, in Policy ENV7, around twenty specific criteria a wind development must satisfy. Rochdale’s own Core Strategy, Policy G3, the principal policy governing renewable energy development in this borough, requires development to avoid the same harms and, in particular, requires the same 40cm peat depth test set out below. As Prickshaw sits within Rochdale, Policy G3 is the development plan policy that applies directly to the application covering my own home, in addition to the equivalent Rossendale policy. In view of the fact that Rooley Moor contains deep peat, independently confirmed by Natural England’s own England Peat Map (Peaty Soil Extent layer, published 2025) in addition to the applicant’s own survey data, three of these criteria deserve particular emphasis.

First, and most concretely: “No development is proposed on areas of peat of over 40cm depth” is a standalone, numeric criterion of this adopted policy, reinforced in the supporting text by reference to Natural England’s own standard that “siting of turbines and supporting infrastructure on these areas should be avoided.” Rochdale’s own Core Strategy, Policy G3, requires the same, so this test applies on both sides of the application, not only the Rossendale side. The Environmental Statement’s own Figure 14.9 records peat depth at the site reaching up to 3.7 metres, with foundations excavated to around 3.5 metres. Wherever meaningful peat depth exists at a turbine or access track, this 40cm threshold is very likely to be breached. I would also note that Natural England’s own current guidance has since moved beyond the 40cm figure both policies relied on at adoption: Natural England’s 2025 Definition of Favourable Conservation Status for Blanket Bog recommends a stricter 30cm depth threshold as the more scientifically grounded definition of deep peat, meaning the protection these policies were designed to provide is, if anything, understated by their own wording.

Second, this same peat impact is not confined to turbine foundations and tracks. The applicant’s own Chapter 4 confirms that the on-site electrical cabling connecting each turbine to the substation will generally follow the route of the internal site tracks, in trenches approximately 1.2 metres deep and 2 metres wide, backfilled with “soil / peat” reinstated depending on location. Applying these figures to the 10.2km of new track the cabling would follow gives an estimated 24,500 cubic metres of additional ground, including peat wherever the route crosses it, disturbed by cable trenching alone. I have calculated this myself from the applicant’s own stated dimensions; it is an estimate, not a figure taken from the application, and it does not appear anywhere in the Environmental Statement’s own peat volume calculations, which should be required to address it explicitly.

Third, these two points are not matters of planning judgement or weight: they are specific, checkable tests, and the applicant should be required to demonstrate compliance, turbine by turbine and trench by trench, before the application is determined.

7. Common land, Rooley Moor Road, and the public’s own right of access

Rooley Moor Road, immediately adjacent to Prickshaw, is locally and popularly known as the Cotton Famine Road, reflecting its long-standing association with unemployment relief work carried out in the area during the Lancashire Cotton Famine of the 1860s. Independent heritage research places the road’s origins considerably earlier still, possibly as early as the 13th century, with the first official record of it in 1729. Whatever the precise origin of its popular name, a road with evidence of construction and use across seven centuries, and a direct association with one of the defining social and economic events in this region’s history, is itself a heritage asset of real significance, and one this application places directly at risk.

The road is also registered common land to which Section 193 of the Law of Property Act 1925 applies: members of the public, myself included, have a statutory right of access for air and exercise over the whole of the common, not merely along marked paths. This is a personal right, not an abstract one, and it is directly affected by this application.

Local Rochdale and Rossendale residents, myself included here in Prickshaw, regularly support Greater Manchester Police’s Operation Dragster initiative, which targets the illegal use of motorised vehicles on the moor, a problem that causes considerable nuisance to lawful users, including walkers, cyclists and riders exercising their proper rights of access, and does real damage to the moor itself. These operations are conducted randomly, by necessity, and frequently involve coordinated action with Lancashire and West Yorkshire Police, reflecting how this open, cross-boundary upland is exploited by illegal riders regardless of administrative boundaries. A police presence sufficient to actually deter this behaviour, rather than respond to it after the fact, would need to be available around the clock, not on a periodic or occasional basis.

The application proposes 10.2km of new turbine service tracks, forming part of a 15.1km network once combined with the 4.9km of existing tracks through the existing Scout Moor Wind Farm that would be retained. This is a substantial increase in rideable surface across open moorland, and I am concerned it would make an already serious illegal vehicle problem significantly worse, not better. The applicant’s own response is to support the creation of a dedicated Ranger and an Apprentice Ranger, two people, to manage trails and control unlawful access across the whole of this large moorland area, and this is framed as something the development “could” or “would support,” not as a secured, binding commitment. For a Ranger service to meaningfully address a problem of this kind, a presence across the moor would realistically need to be maintained around the clock. Two additional staff cannot be expected to provide that, across an area whose network of rideable tracks this development would substantially enlarge.

As far as I am aware, no application to deregister or exchange common land has yet been made, notwithstanding that planning permission is being sought now. The applicant’s own documents give conflicting accounts of whether the land proposed for restoration works is inside or outside the registered common, and the draft legal agreements accompanying the application contain no obligation to deliver the common land settlement at all. Permission should not be granted for development on and around registered common land before the common land position itself, including what will happen to the public’s own right of access, and to commoners’ rights, over Rooley Moor, has been properly resolved.

8. This moor has seen this argument before, and the applicant lost it

This is not the first time a wind farm extension on this moor has been tested on landscape grounds. In 2017 the Secretary of State refused a closely comparable extension to the existing Scout Moor Wind Farm on the Rossendale side, specifically because it would “extend the influence of wind energy development” into areas where “views of turbines where none currently exist” would be introduced, causing significant adverse landscape harm that was not outweighed by the renewable energy benefit. The Inspector in that case also found that the applicant had understated how much the existing wind farm already contributes to the cumulative landscape effect. Scout Moor II is a materially larger scheme (turbines up to 180 metres to blade tip, against 115 metres in the 2017 case) proposing to do exactly what was found unacceptable then: extend the wind farm’s presence into moorland, including Rooley Moor, that is not currently occupied by turbines. Nothing has changed to make that acceptable now.

9. The case for this development has not been robustly made

Finally, the Council should consider whether the harm identified above is actually justified by the benefits claimed for the scheme. The applicant’s own Planning, Design and Access Statement states plainly that there is no legal requirement to demonstrate need for this development, and its Consideration of Alternatives chapter confirms that no comparison was made between this site and any other possible location. The benefit figures quoted throughout the application are calculated using the lowest end of the capacity range applied for, not the maximum the permission would actually allow. If the harm to Prickshaw and its setting is as significant as this letter demonstrates, it should not be outweighed by a need case that the applicant itself accepts it was never required to make, for a site it never compared against any alternative.

Conclusion

Taken together, a development sited within the most defining views the Council’s own Conservation Area Appraisal identifies as key to Prickshaw’s significance, including the adjacent Rooley Moor, with the nearest turbine standing under a kilometre from an occupied home; a heritage “not significant” conclusion that rests on a lower turbine count than the applicant’s own drawings show; unresolved noise, including amplitude modulation, from a turbine that has not yet been chosen; an aviation lighting scheme that, on the applicant’s own account, has not been approved for the layout now proposed; direct conflict with specific, named criteria of Rossendale’s and Rochdale’s own adopted wind energy policies, including a peat-depth test the development appears very likely to breach on both sides of the application, and a substantial additional impact from cable trenching that the application does not appear to address at all; a historic road placed at risk, together with the public’s own right of access over it, by an unresolved common land position and a network of tracks that risks making an already serious illegal vehicle problem worse, against which two additional staff would not realistically cope; a repeat of landscape harm already found unacceptable on this same moor in 2017; and a need case the applicant admits it was never required to make, the cumulative effect on this small settlement and its setting is SEVERE. “Not Significant” is not a fair description of what this development would do to the views this Conservation Area was designated to protect, nor of its conflict with the Councils’ own adopted and emerging planning policies.

I would be grateful if these points were recorded as a formal objection to the application, and if the outstanding clarifications requested above, the basis for the viewpoint CH02, Prickshaw Lane turbine count, confirmation of the outcome for the CAA approval for the lighting scheme, and turbine-by-turbine and trench-by-trench compliance with the peat depth test in both Policy ENV7 and Policy G3, could be obtained from the applicant before the application is determined.

Yours sincerely

[Your name]

[Address], Prickshaw

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Prickshaw_Resident_Objection_Scout_Moor_II