Rossendale SPD – Climate Change
1st August 2022

Rossendale Emerging Supplementary Planning Documents (SPD)

Climate Change

The Council has commenced a consultation on the Climate Change SPD, this will end at 17:00 on 24 August 2022.

Please send your representations to:

Due to concerns about the environment and the escalating cost of energy the RMNF trustees have sent the following representation:


Subject: Rossendale Consultation – Climate Change – Supplementary Planning Document

We are writing in response to Rossendale’s invitation to comment on the Climate Change Supplementary Planning Document, in particular policy ENV7: Wind Turbines.

Considerable information and knowledge has been amassed since the development of Scout Moor Wind Farm. The adverse effect on wildlife, the destruction and permanent loss of vast areas of valuable carbon capturing peatlands and the destruction of areas of the moorlands by illegal motorised traffic accessing the uplands via the wind farm service tracks is irreversible. Unfortunately, there are no acceptable end of life decommissioning terms that will ever restore the moorlands to their predevelopment condition.

Today it is unthinkable the existing Scout Moor Wind Farm development would be accepted, we must learn from the mistakes of the past to ensure the planning balance is considered extremely carefully and financial matters are not put ahead of other matters requiring earnest consideration.

We believe it is essential policy EVV7 does not conflict with Section 41 of the Natural Environments and Rural Communities Act (2006), which directs Local Authorities to have regard to the conservation of habitats of priority for the conservation of biodiversity. These include threatened, rare and sensitive habitats such as hedgerows, acidic grassland, native species broadleaved woodland and blanket bogs, etc.

Whether a new build or a re-powering option the carbon created during the manufacturing and transportation process should be taken into consideration. Current calculations assume wind farm structures materialise out of thin air and, of course, we now acknowledge the planet does not discriminate on how the wind circulates greenhouse gases around the globe. Consideration should also be given to the effects of wind turbines on the immediate micro climate (for example, do turbines take sufficient energy out of the wind to change the local weather, increasing rainfall and causing flooding?). The effects of infrasound and low frequency noise from wind turbines needs to be better understood and there should be an adequate decommissioning bond to facilitate restoration of the moorland to its pre-development condition.

Operator subsidies funded through green levies ensure the provision of the most expensive electricity available. Current analysis “What is NetZero Costing Now?” by Andrew Montford of NetZero Watch provides the following breakdown for the overall impact of NetZero policies on the economy and households:

Economy (£m) Household (£)
Direct levies 9,748 348
Spending programmes etc 8,170 292
Grid costs 4,600 164
Inefficient gas-fired power 13,759 491
Higher gas prices 22,287 825
Total 58,564 2,120

The Net Zero policy comes at a significant cost to families at over £2,000 per household per annum and does not address the point that the contribution by any extension of the wind farm is so completely insignificant as to be universally useless. We know solar panels don’t work at night, wind turbines don’t work when there’s no wind or it’s the wrong type of wind and battery storage requires vast amounts of energy in the manufacturing process. Each of these supposed “green and sustainable” solutions require the use of rare earth metals and none of them, individually or combined, generate sufficient electricity to solve the energy crisis or justify the destruction of natural habitats.

We fully support the Council’s policy to refuse any development on areas of deep peat, however, we think the Council should go further with the introduction of a new policy specifically focused on improving the natural environment and increased carbon capture through natural means. Rossendale is in privileged position as a guardian of our areas of peatland (deep or otherwise) and we urge officers to afford this privilege some serious thought. Peatlands are rare, fragile, valuable and vulnerable. They capture carbon, support rare flora & fauna and provide a place of work for upland farmers, which is essential to the local food chain.

Our local landscape is also a historic landscape. It is home to the Cotton Famine Road, a reminder of the harsh times cotton millworkers had to endure during the Cotton Famine. The road, now a
bridleway and part of the Mary Towneley Loop national trail, provides a unique link to the American Civil War, at a time when the Rochdale Pioneer Movement influenced social thinking
and local millworkers supported the struggle against slavery. We believe this historic landscape is of international importance that is worthy of recognition and protection!

The Covid crisis has demonstrated the social value of our open spaces, where it is still possible to find solitude and peace of mind. There has been a very significant increase in the numbers of equestrians, walkers, runners, mountain bikers and other users who have discovered Rossendale and Rochdale have responsibility for protecting this wonderful, accessible asset. It is not
overstating the point by saying this amenity on Common Land has been the saviour of many souls over these past two or three years.

We respectfully suggest Rossendale should go further than resisting all aggressive development in our upland peat areas and engage with other partners to develop a programme to
permanently protect our moorlands to ensure they remain in their natural state for future generations.

We would be very grateful if you will acknowledge receipt of our consultation and ensure that its contents are clearly visible on your Planning Portal.

Thank you.

RMNF Trustees