The Scottish Government Carbon Calculator

Cubico need to show that their wind farm will make a net contribution to reducing to the amount of CO2 emitted into the atmosphere. The only method available for this assessment is the Scottish Government Carbon Calculator Tool:

https://www.gov.scot/publications/carbon-calculator-for-wind-farms-on-scottish-peatlands-factsheet/

https://www.gov.scot/publications/carbon-calculator-technical-guidance/

Going back to the 2016 public enquiry to extend Scout Moor, I pointed out that the applicant Peel Energy was aware that the calculator was not suitable for upland peat moors. Therefore, I argued that it was impossible to know whether the wind farm would make a positive contribution to reducing carbon emissions.

It is now clear that this issue has been recognised by the Scottish Government, and they have taken the first steps to investigate how the calculator needs to be updated, the last update being in 2014.

In January 2025 ClimateXchange “Scotland’s centre of expertise connecting climate change research and policy” produced a report entitle “Carbon Calculator for wind farms on Scottish peatlands: an evidence assessment”:

https://www.climatexchange.org.uk/publications/carbon-calculator-for-wind-farms-on-scottish-peatlands-an-evidence-assessment/

The key findings from this report state:

“Based on the findings of a technical assessment, evidence review and quality control mechanisms, we recommend that when considered against recent policy updates and advancements in science, the Carbon Calculator, in its current form, should be updated. Each area of the Carbon Calculator was assessed for scientific accuracy and data availability:

•  The ‘payback time and CO2 emissions’ are not relevant/consistent with the findings of the technical assessment and literature review. It is important to consider whether emissions due to turbine life and back up are required, given new planning policy and the applicability of whole lifecycle carbon assessments.
• For all peat-related areas of the Carbon Calculator, as well as the forestry area, accuracy is lacking in one or more methodologies, use of emission factors and assumptions.

While some data are accessible to users, it is not clear if they are able to accurately obtain some of that data – in particular, for variables that drive the results (the water table depth and extent of drainage), which could affect the accuracy of outputs.”

Amongst many other issues, the report highlights the following:

• The calculator was designed for up to 1MW turbines, whereas larger turbines generate more carbon emissions.
• Need to assess the peat depth/conditions for individual turbines
• The need for an alternative counter-factual. I.e. instead of comparing wind farm to fossil fuel generation, consider the alternative of simply restoring the peat. Over time the fossil fuel counterfactual will become irrelevant as the grid average decarbonises.
• Estimations only account for lifetime emissions attributed to turbine structures and concrete hard standings. The methodology disregards emissions from the manufacture, construction, and disassembly of other wind farm assets (such as access tracks and battery storage).
• Carbon emissions resulting from the transport of labour and materials to the construction-site is also excluded. This underestimates emissions and does not align to common Whole Life Carbon Assessment (WLCA) practice.

Public Recognition

This issue of peatland carbon sequestration is getting public recognition with a recent petition and a question in parliament from Robbie Moore, Conservative MP for Keighley and Ilkley. He asked the following on the 8th May with respect to the proposed Calderdale Wind Farm over the border in Yorkshire:

Our peatlands store 26 times more carbon than forests. They improve water quality and protect communities up and down the UK from flooding. The Nature Minister rightly called peatlands our “country’s Amazon rainforest” and launched a consultation to protect them. She is right, because once they have been destroyed, they can never be replaced. At the very same time, the Energy Secretary plans to rip up 2,000 hectares of protected peatland on historic land in West Yorkshire for a vast wind farm development, opening up communities to flooding and destroying the peatlands that Labour says it wants to protect. How can the Government claim to be protecting our irreplaceable peatlands when the Department for Energy Security and Net Zero is actively considering destroying one of our most environmentally important landscapes in the country?

Emma Hardy, Labour MP for Kingston upon Hull and Haltemprice) replied:

I pay tribute to the hon. Member’s ability to weave a question for the Department for Energy Security and Net Zero into a question on flooding. He will have heard from the Nature Minister how important peatlands are and how essential they are for this country and heard our commitment to protecting them.

Local Peat Depths

Locally we have been looking at our peat situation and data from Natural England and the turbine positions proposed by Cubico:

From this map we derived the peat depths for each turbine:

Turbine	Lowest Depth (cm)	Thickest Depth (cm)		Turbine	Lowest Depth (cm)	Thickest Depth (cm)
T1	43	82
T2	42	64		T12	86	109
T3	54	65		T13	163	287
T4	68	114		T14	73	119
T5	62	95		T15	48	90
T6	53	99		T16	85	109
T7	56	80		T17	56	127
T8	89	175		T18	40	77
T9	84	103		Construction Compound	56	119
T10	65	100		Substation	38	76
T11	33	90		Mast	63	131

17 turbine depths are over 40cm minimum, and all over 40cm at maximum depths.  Rossendale’s Local Plan, in line with Natural England recommendations, says no development should take place above 40cm. See paragraph 313 in the inspector’s report:

https://www.rossendale.gov.uk/downloads/file/17244/rossendale_local_plan_2019_to_2036_-_inspectors_report

Conclusions

1. Cubico cannot prove that their proposed wind farm would lead to a net reduction in emissions since the Scottish Carbon Calculator is known to be inadequate for peat moorlands.
2. Cubico want to site their turbines on deep peat (over 40cm) which Rossendale Council have identified as unsuitable for development.

Requested Actions

1. 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 review into the Scottish Government Carbon Calculator is complete.
2. Further, to request on completion that national wind farm planning policy on peat moorlands is updated to reflect the conclusions of that review.
3. Contact Cubico, Rossendale and Rochdale Councils to raise our concerns about the proposals to site turbines on peat over 40cm in depth.

Dr Steve Davison