The following is an email to Elsie Blundell, MP for Heywood and Middleton North, following a meeting with Friends of the Moorlands on the 30th May 2025. Elsie generously provided time to discuss a number of key issues which we presented as separate papers with actions requested in each case. The email below summarises what we discussed and links to the individual papers presented at the meeting.

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Dear Elsie

Thank you for taking the time to meet with representatives of Rooley Moor Neighbourhood Forum to discuss Cubico’s proposed Scout Moor 2 Wind Farm development.

We were conscious of the limitations on your time and the volume of information we wanted to cover. Given the breadth of concerns we hoped to cover, we were unable to discuss everything in detail. We trust the papers we provided will support your review and help you effectively represent our position.

We would greatly appreciate the opportunity to meet again in late June to explore these matters further and discuss how best to move forward.

Our position on the proposed Scout Moor 2 Wind Farm is very clear – this is the wrong proposal in the wrong place, and it should NOT go ahead.

During our meeting we presented very strong evidence to support our position:

• Decommissioning – Anne McKown emphasised the serious gaps in wind farm decommissioning regulations, underscoring the urgent need for a clear specification detailing both required actions and financial responsibility. Full paper here.
• Carbon Neutrality – Steve Davison highlighted critical flaws in the Carbon Calculator used to justify offsets, making it clear Cubico cannot credibly demonstrate environmental benefits for this project. Full paper here.
• Health – Evidence presented by Nigel Morrell on behalf of retired GP Dr. Chris Woods raises serious concerns about the negative impact of wind farm noise and diminished amenity on both physical and mental well-being, particularly for residents and frequent users of Rooley Moor. The use of ETSU-97-R as a noise measurement instrument is inappropriate as it is not fit for purpose and risks exposing local populations to unnecessary health risks. Full paper here.
• Amenity – John Newcombe demonstrated that the reasons for refusing to previous wind farm applications, similar to the current proposal, are more relevant today given the increased impact larger turbines would have. Full paper here.
• Finance – Alan Rawsterne presented Fran Healey’s media article detailing the immoral profits wind farm operators make through exploitation of government policy that enables funds collected through green levies on domestic energy bills to be squandered. It is clear initiatives like the “Community Wealth Fund” is simply a conduit to give “selective” residents back a very small percentage of their own money. Full paper here.
• Planning Process Bias – Alan Rawsterne compiled this paper, which unfortunately we didn’t have time to discuss, but hope you take the time to read. This paper demonstrates some of the reasons for the David and Goliath scenario that exists for major planning applications where the applicant has a clear advantage over Local Planning Authorities and the public. Full paper here.

At the end of our meeting, we left the following summary of actions that we would like you to pursue on behalf of your constituents:

Decommissioning

• There is still a gap in the current legislation allowing onshore wind farms to operate without holding funds to cover decommissioning liabilities and other liabilities.
  • Could legislative measures be introduced to ensure wind farm operators secure funds for decommissioning liabilities before construction begins?
  • And can you do this by introducing a private members bill?

This would go some way to protect other communities from largely unexpected and potentially huge financial liabilities.

• Are Councillors who sit on Planning Committees and Planning Departments themselves aware of these risks so that it appropriately informs their decision making?

Furthermore, would you reach out to them to so ensure that this is brought to their attention?

• Could you contact Cubico to clarify their definition of what constitutes decommissioning and restoration of the proposed Scout Moor 2 wind farm please?

Carbon Neutrality

• Make a request to the secretary of State for the Department of Energy Security and Net Zero to block the application for Scout Moor 2 until at least the completion of the review into the Scottish Government Carbon Calculator is complete.
• Further, to request on completion that national wind farm planning policy on peat moorlands is updated to reflect the conclusions of that review.
• Contact Cubico, Rossendale and Rochdale Councils to raise our concerns about the proposals to site turbines on peat over 30cm in depth (the definition of deep peat will be revised, so that deep peat is counted as anything over 30cms rather than 40cms – see https://www.gov.uk/government/news/new-proposals-to-ban-heather-burning-on-peatland-to-protect-air-water-and-wildlife).

Health

• Urge Cubico and the LPA`s to make only safe decisions in relation to this scheme.
• Urge Cubico not to merely mitigate the ill-effects of their scheme, but eliminate them by revised siting. There are 600Hectares of moorland available to them, it is perfectly possible for them to site turbines at a safe distance from residential properties and heritage assets.
• Commit all concerned to have as a paramount consideration, the health and safety of future generations.
• Recognise the value, established during Covid, of a moorland as a vital health and safety space.
• Consider backing a call for an adjournment / Westminster Hall debate on the subject of the health effects of new massive Onshore Wind Turbines.

Amenity

• Ensure that Cubico provide accurate photomontages including those representing effect on sensitive receptors. They must provide images that the public feel real concern about.
• Consider the application and relevance of Inspector John Woolcock’s conclusion on SMWFEL to the current Cubico model and to comment on his conclusions.
• Confirm the validity of the guidance at NPPF paragraphs 202 et seq against Cubico’s proposals and declare where she stands on the planning balance of this application. What benefits are there to her constituency?
• To follow the example of her predecessor, Simon Danczuk, who also supported Labour Party policy on approval of onshore windfarm development but who wrote to SMWFEL and to Coronation Power (the Coronation Power application was rejected by Rochdale LPA) and to the Heads of Planning at Rochdale and Rossendale to opine very strongly that the proposals were in the wrong place and too close to habitations. In his letter dated 17th April 2015 Simon said “My view is that the proposed developments are far too close to houses, farms and farmland. They are also too close to important aspects of our cultural heritage within Prickshaw” and “I support windfarms but feel that the proposal to place them in this area is Ill-considered. I would request that Coronation Power and Peel/United Utilities build on another site”. Elsie – it is entirely possible to support party policy and protect your constituency. Both are mutually exclusive.
• Discuss with Heads of Planning and Conservation Officers the feasibility of extending the defined P&BFCA Boundary as proposed in Para 3.6 of the LPA’s Appraisal paper and assist with the RMNF charitable aims of protecting and promoting our unique irreplaceable open spaces.

Finance

• Investigate alternatives to the Community Wealth Fund.
• Raise a parliamentary question to explore peatland restoration for a fraction of the public funds Cubico will receive, ensuring tangible environmental benefits.
• Demand reform of funding models for wind energy.
• Validate Cubico’s claims regarding investment in the community.
• Request transparency on job creation.

Planning Process Bias

Raise a question in the House of Commons to require the appropriate Minister to review the planning process to;

• Ensure planning processes actively engage affected communities rather than interpreting public silence as implicit approval.
• Ensure members of the public have access to the same standard of representation as the applicant.
• Ensure LPAs are properly resourced, and able to secure expert advice on technical matters.
• Ensure planning compliance and enforcement is a mandatory LPA obligation.
• Make planning conditions meaningful.
• Make LPAs responsible for the applications they approve thought the lifecycle of a development.
• Improve the Council Complaints process so it is customer focused and less a war of attrition.

Throughout our discussion, no tangible benefits for your constituents from this project were identified. While significant concerns remain, addressing the issues outlined above would provide meaningful advantages to the broader community. We suggest prioritising Health & Safety and decommissioning.

We look forward to continuing this discussion and working together toward responsible decision-making.

Kind regards,

Friends of the Moorlands