This is not a template to copy. Planning officers give more weight to representations written in a resident’s own words, describing their own experience, than to identical or near-identical letters. Use this checklist to find the points that matter most to you, and write about them in your own way.
Before you start
| Applications |
25/00680/FUL (Rochdale Metropolitan Borough Council) and 2025/0267 (Rossendale Borough Council). These are a single scheme split across two Councils, so a representation can be sent to one or both. |
| Rochdale contact |
Rachel Carney, rachel.carney@rochdale.gov.uk |
| Rossendale contact |
James Dalgleish, jamesdalgleish@rossendalebc.gov.uk |
| What to call it |
An “objection” or “representation” on the application. Ask that it be made public and recorded against both application numbers if you are sending one letter to both Councils. |
Tips for an effective representation
- Write in your own words. A personal account of how the development would affect you carries real weight, and a letter that reads like everyone else’s carries less.
- You do not need to use every point below. Three or four points made well, in your own words, are more effective than a long list made briefly.
- Say what you actually think and why. “I object because…” followed by your own reasoning is more persuasive than a list of facts alone.
- Stick to planning-relevant grounds: visual and landscape impact, heritage, noise, lighting, ecology and peat, access and common land, highways, and whether the harm is justified by the benefits. General statements that you simply do not want the development, without reasons, carry less weight.
- Where you can, say how a fact affects you personally: a view from your window, a walk you take, a sound you would hear, rather than only quoting the application documents.
- Be factually accurate. Where you quote a document, quote it correctly. If you are not sure of a fact, it is better to describe your own experience than to guess at a figure.
- Ask for anything you want the Councils to find out. If a question has not been answered, say so and ask for it directly.
- End by asking for your letter to be recorded as a formal objection to the application, or applications, you are writing about.
Key facts by theme
Pick the themes that matter to you. You do not need to cover them all.
| Theme |
Key facts you could draw on |
| Views and landscape character |
- The Prickshaw and Broadley Fold Conservation Area Appraisal identifies four significant views as being of particular importance to the area’s significance, including the view towards Rooley Moor and Scout Moor.
- The Environmental Statement (Chapter 11, Volume 1) itself concludes night-time lighting effects would remain Significant for several named communities, including Whitworth, Bacup and Rawtenstall, even after mitigation.
- Think about: which view from your own home or street would be affected, and what it currently looks like.
|
| Heritage |
- Chapter 12 (Built Heritage) records a Moderate adverse effect on the Conservation Area but concludes it is “Not Significant” under the EIA Regulations, a different and narrower legal test from whether the harm actually matters.
- The applicant’s own wireline for Viewpoint CH02 (Prickshaw Lane) shows more turbines visible than the text of Chapter 12 describes.
- Think about: any local heritage feature, building, wall, or historic route near you that the application may affect.
|
| Noise |
- The final turbine has not been chosen. The noise assessment rests entirely on a candidate turbine, not the turbine that would actually be built.
- Amplitude modulation, the characteristic swishing or thumping noise, has not been assessed at all; it is left to a complaint-based condition after construction.
- Rossendale’s adopted Local Plan, Policy ENV7, and Rochdale’s Core Strategy, Policy G3, both require that a scheme would not cause unacceptable noise, including amplitude modulation, as a named condition of the development plan, not just a hope.
- Think about: how close you live to the site, and what a quiet evening or night currently sounds like.
|
| Aviation lighting |
- The reduced-intensity lighting scheme relied on to reduce night-time harm was approved by the Civil Aviation Authority for the previous, now-superseded 17-turbine layout. The applicant’s own report says it “will be re-submitted” for the current 12-turbine scheme, and no evidence has been provided that this has happened.
- Think about: whether you have unobstructed views of the site at night, and what current night skies mean to you.
|
| Peat |
- Policy ENV7 (Rossendale) states: “No development is proposed on areas of peat of over 40cm depth.” Policy G3 (Rochdale) requires the same, so the test applies on both sides of the site. The Environmental Statement’s own figures show peat up to 3.7 metres deep at the site.
- Natural England’s own current guidance (2025) recommends an even stricter 30cm threshold for deep peat than the 40cm figure both policies relied on when adopted.
- Peat stores carbon. Disturbing it releases that carbon, which sits oddly alongside a scheme promoted as a climate benefit.
- Think about: whether you walk, ride or spend time on the moor, and what you have noticed about its condition.
|
| Common land and access |
- Rooley Moor Road is registered common land. Section 193 of the Law of Property Act 1925 gives the public a right of access for air and exercise over the whole common, not just marked paths, a right you may exercise yourself.
- No application to deregister or exchange common land has yet been made, even though planning permission is being sought now.
- The draft legal agreements for the scheme contain no obligation to deliver any common land settlement at all.
- Think about: how you personally use the moor, on foot, by bike, or on horseback, and what that access means to you.
|
| Illegal vehicle use |
- Residents regularly support Greater Manchester Police’s Operation Dragster, which tackles illegal motorised vehicle use on the moor, already a serious, ongoing problem.
- The application proposes 10.2km of new tracks, adding to the surface available for illegal riders to exploit.
- The applicant’s response is to support a Ranger and an Apprentice Ranger, two people, for the whole moor, and even this is not a guaranteed commitment.
- Think about: anything you have witnessed yourself, damage, noise, near misses, or a specific incident.
|
| Precedent |
- In 2017 the Secretary of State refused a comparable extension to the existing Scout Moor Wind Farm specifically because it would extend turbines into areas with no current turbines, causing landscape harm that outweighed the renewable energy benefit. Scout Moor II is larger (180m to blade tip, against 115m in 2017) and does the same thing again.
|
| Need and benefit |
- The applicant’s own Planning, Design and Access Statement states there is no legal requirement to demonstrate need for this scheme.
- No comparison was ever made with any alternative site.
- The benefit figures quoted are calculated on the lowest capacity the scheme could deliver, not the maximum the permission would actually allow.
- Think about: whether the claimed benefits feel proportionate to the harm you have described above.
|
A simple structure, if it helps
☐ Who you are and where you live (this establishes why the development affects you)
☐ Which application(s) you are objecting to, and that you want this recorded as a formal objection
☐ Your main concern, in your own words, with your own reasoning
☐ Any further concerns, briefly, in order of importance to you
☐ Anything you would like the Council to find out or clarify
☐ A closing line asking for acknowledgement
A note on sources
Everything in this checklist is drawn from the application documents themselves (the Environmental Statement, the Planning, Design and Access Statement), from Rossendale’s adopted Local Plan (Policy ENV7) and Rochdale’s adopted Core Strategy (Policy G3), from Rochdale’s emerging planning policies, and from the 2017 Secretary of State decision on a related scheme on the same moor. If you want to check a fact for yourself before using it, the Document and Drawing Schedule on the Councils’ planning portals lists every application document and where to find it.
Useful Links
The application is available from Rossendale with reference number 2025/0267 and at Rochdale with the reference 25/00680/FUL.
Here is a downloadable Word document version of this template:
Scout_Moor_II_Residents_Checklist
