From Nick MacKinnon (Editor) WTRG

Upper Heights Farm, Stanbury, BD22 0HH

01535 649359

nipmackinnon@gmail.com

To: Christian Egal (Project Director); Christopher Wilson (Executive Chair); Ghazi Osman (Director of

CWF Ltd) Katherine King (Planning Inspectorate)

Material errors in the PEIR for Calderdale Energy Park Preliminary Peat Slide Hazard Assessment

PEIR Appendix 10-4. Consultants OWC, author AJM.

PEIR Appendix 10-4 on peat slide hazard written by AJM of OWC, uses (five times) a reference Ross (2020) to assess the historical frequency of peat slides in the study area. Ross (2020) is a book Charlottle Bronte at the Anthropocene, by Shawna Ross, and gives what is presently the master account of the 1824 Crow Hill bog burst, which is why AJM used it five times in the OWC report.

Calderdale Energy Park are using the north slope of Crow Hill as the sole access for AIL.

Because CWF Ltd have failed (prior to Statutory Consultation) to probe the ground north of Crow Hill up which the turbine components track must come, the analysis of peat slide risk on Crow Hill in the PEIR relies heavily on the references. It is clear that the author AJM of OWC did not read Ross (2020) because the analysis in PEIR 10-4 has no mention of the 1989 peat slide on Crow Hill, which is described in Ross (2020) on page 68. Ross gives a further reference to Dykes and Warburton, Mass Movements in Peat (2007), in which a photograph will be found of the 1989 Crow Hill peat slide. Dykes & Warburton (2007) is referenced in the Appendix 10-4 (for example in 4.2.1) but the author has clearly not studied that reference carefully enough to find the photograph of the 1989 peat slide on Crow Hill.

Because OWC failed to find the 1989 Crow Hill peat slide in their own references, the report falsely informs the Statutory Consultees that the peat slide risk on Crow Hill is historical. The OWC report states:

“A bog burst was documented on Crow Hill near Haworth by Brontë in 1824, and this is likely the nearest recorded failure to the Turbine Area (Ross, 2021).”

“Outside the Turbine Area to the north, the Crow Hill bog burst (a much reported peat landslide, documented by Rev. Patrick Brontë (Ross, 2020) is located to the west of the Western Access Route. The landslide took place in 1824 (c. 200 years ago), and remains visible in the landscape (Plate 3.3d).”

Note the slapdash reference to “Ross 2021” and the unnecessary “c. 200 years ago” as though the Statutory Consultees were unable to subtract 1824 from 2026. The force of “c. 200 years ago” was not to help the Statutory Consultees with the subtraction but to persuade the Statutory Consultees that the peat slide risk on Crow Hill was historical, when in fact the reference that OWC were using to make that point described the 1989 Crow Hill peat slide on page 68 and gave the reference to Dykes & Warburton with its photograph.

Further evidence that the author had not consulted an actual copy of their own reference is that no page references to Ross (2020) are given; there is a reference to a phantom edition Ross (2021); and the number of pages in Ross (2020) is given as the publisher’s leaf number (334 p) rather than the academic scientist’s page number (326 pages).

Perhaps alerted by my showing the book to Christian Egal and Ashley Robinson at the Denholme public consultation, AJM had bought a copy of Ross (2020) and had it at the Hebden Bridge consultation. He was still ignorant of the 1989 peat slide described on page 68 and I had to show it to him. He complained that the reference is mainly a work of literary criticism, but of course Ross (2020) is his reference.

The failure by CWF Ltd to present a correct account of the Peat Slide hazard on Crow Hill based on information that CWF Ltd already had in Ross (2020) and Dykes & Warburton (2007), which are their own references, is doubly culpable because the whole matter was laid out by us in our response to the CEP Scoping Report, adopted by the Secretary of State on 10 October 2025, where the 1989 peat slide on Crow Hill is analysed with full references on p 106.

Culpability is further increased by the failure of CWF Ltd to engage in “positive collaboration” with us as the Planning Inspectorate “encouraged” at their meeting with CWF Ltd on 26 January 2026.

1. OWC failed to read their own references and presented an account of peat slides on Crow Hill as historical (“over c.200 years ago”) when their own references described and even gave a photograph of a peat slide on Crow Hill in 1989.

2. The matter was pointed out by WTRG of Stronger Together in response to the Logika Scoping Report, so failure to report the 1989 peat slide was inexcusable.

3. The Planning Inspectorate “encouraged … positive collaboration” with the authors of the Stronger Together response to the Scoping Report, but CWF Ltd chose to completely ignore our Scoping Report response, causing CWF Ltd to fail to discover the 1989 peat slide and mislead the Statutory Consultees in the PEIR.

We require CWF Ltd to re-run the Denholme, Oxenhope and Hebden Bridge public consultations on the basis of a full and correct account of their own references to the peat slide hazard on Crow Hill. The OWC report should be withdrawn and a full inquiry made into the use of references by the author, AJM, whose behaviour is not excused by his being a doctoral student of Jeff Warburton himself; in fact it makes his negligence on Crow Hill even more culpable.

Nick MacKinnon

Editor Walshaw Turbines Research Group