Dear Calderdale Energy Park
On 8 April 2026 Calderdale Energy Park (CEP) commenced statutory consultation (the Consultation) in respect of your proposals for the installation of an onshore wind electricity generating facility and associated infrastructure which would allow for the generation and export of electricity with a maximum generating capacity of approximately 240 Megawatts, namely Calderdale Energy Park (the Proposed Development). This Consultation closes on 10 June 2026 and is intended to inform an application for a Development Consent Order (DCO) under section 37 of the Planning Act 2008 (the 2008 Act).
The Council was surprised that CEP chose to commence such a critical statutory consultation during the pre-election period, despite being expressly advised of the timing concerns. Proceeding in this window risks significantly undermining fair and effective engagement, as it restricts the ability of elected Members to participate, reduces democratic accountability, and may limit community confidence in the consultation process. A request was therefore made at the time to delay and extend the consultation period.
Through the Consultation, you provided to all consultees a number of documents, including the Preliminary Environmental Information Report (the PEIR) and supporting materials to enable them to understand the Proposed Development, its likely environmental effects, and to facilitate meaningful engagement. As the host local authority and statutory consultee, the Council has tried to engage constructively with the Consultation. However, in doing so, the Council has identified a significant number of errors, inconsistencies and omissions within the consultation materials, including across multiple PEIR chapters.
The Council has repeatedly raised these issues throughout the Consultation period (see Table 1 below) clearly identifying concerns regarding the accuracy, completeness and reliability of the material presented.
Despite CEP’s acknowledgment of errors and inaccuracies, these concerns remain unresolved. Corrections have been issued piecemeal during the Consultation, resulting in a fragmented document set lacking clarity, coherence and internal consistency.
Significant deficiencies persist, including fundamental gaps in information and, in some cases, the absence of sufficient methodological detail. As a result, consultees are unable to properly understand or robustly assess the likely effects of the Proposed Development at this stage.
Table 1 – Consultation chronology of engagement and errors/ inconsistencies
Date Summary of message
19.02.2026
Council submitted comments on the draft SoCC, raising concerns about
the length and timing of the statutory consultation and the adequacy of the
PEIR.
07.04.2026 Indya Waite responded outlining changes made to the SoCC following the
Council’s comments.
08.04.2026 Ruth Hardingham raised concerns about replacing the Halifax Courier
with the Lancashire Telegraph for statutory notices.
23.04.2026 Ruth Hardingham wrote to Harriet Cole highlighting discrepancies in the
PEIR, particularly turbine coordinates and mapping inconsistencies.
24.04.2026 Indya Waite responded stating corrections were not material and
confirmed the consultation would continue.
28.04.2026
Council highlighted further errors identified by the Conservation Officer
and indicated it may raise concerns with PINS under Section 55(4) if not
addressed.
01.05.2026 Harriet Cole confirmed updates would be made to the PEIR documents by
8 May.
06.05.2026 Harriet Cole confirmed updates to PEIR figures and appendices had been
completed and the Errata table updated.
11.05.2026 Richard Seaman set out additional errors identified by the Conservation
Officer in response to the updated material.
15.05.2026 Andrew Thornton responded explaining the PEIR is a preliminary
assessment and will be refined in the Environmental Statement.
21.05.2026
Ruth Hardingham requested missing Ornithology Data (Appendix 9.2)
from Andrew Thornton.
22.05.2026
Andrew Thornton provided the missing Ornithology Data to the Council.
Statutory Consultation requirements
As you will be aware, CEP is under a statutory duty to carry out meaningful
consultation with anyone with a relevant interest in the Proposed Development prior to
submission of any application for a DCO (2008 Act, ss.42, 47 and 49).
The ability to discharge this duty is contingent upon consultees being provided with
adequate information of sufficient quality, clarity and completeness to enable them to
understand the nature of the Proposed Development and its likely effects. The
Government’s consultation on streamlining infrastructure planning states that ‘high
quality early, meaningful and constructive engagement and consultation’ is expected
with those affected by DCO proposals.
The Planning Inspectorate Guidance aligns with this aim, stating that:
“The importance of consultation during the Pre-application stage cannot be
overemphasised, given the ‘front loaded’ approach established by the PA2008.
Such consultation needs to be appropriate, proportionate (in terms of content,
timing and clarity) and reported fully in the Consultation Report such that the
response of the Applicant to the comments made in terms of the evolution of the
Proposed Development can be clearly understood.”
It goes on to say that:
“Applicants must be able to demonstrate that the statutory consultation
requirements under the PA2008 (sections 42 and 47) have been complied with.
It is possible to comply with these sections… with less than full information about
the Proposed Development, but unless there is a clear iterative consultation
process… and further documentation provided… the Applicant may risk being
unable to demonstrate that the proposals have been considered in the light of
consultation responses received.”
The Planning Inspectorate Guidance on the pre-application process is also clear about
the need for adequate consultation. It provides that:
“The adequacy of consultation milestone should be early enough to enable
applicants to consider how to undertake any additional engagement that may be
needed, but sufficiently towards the end of the pre-application stage to assess
the adequacy of the consultation that has been done.”
Given the deficiencies outlined above—including information that is limited, immature
and unclear—consultees are unable to meaningfully understand the proposals or
identify their implications. In these circumstances:
1. consultees cannot engage with the substance of the Proposed Development;
2. any responses would necessarily be uninformed and speculative; and
3. it would not be possible for CEP to demonstrate that the Proposed
Development has been refined in light of consultation responses.
Accordingly, the Consultation cannot be regarded as appropriate or proportionate in
content, clarity or timing, and the statutory requirement for meaningful consultation
has not been met.
The Government’s Pre-application Prospectus (2024) further emphasises that
deficiencies and unresolved issues at the pre-application stage can significantly
impede examination and delay or prejudice the determination of a DCO application.
Rochdale Envelope
The Council notes that the PEIR adopts a parameter-based approach to the Proposed
Development, consistent in principle with the use of a Rochdale Envelope. However,
when read alongside the wider concerns set out in this response regarding errors,
inconsistencies and the evolving nature of the information, it is not always clear that
the assessment has been undertaken on the basis of a defined and robust worst-case
scenario. In particular, a number of key components of the scheme, including turbine
layout, access arrangements and the cable corridor, remain indicative and subject to
refinement. This level of flexibility, when combined with the broader issues identified in
relation to incomplete baseline data and limited methodological clarity, makes it
difficult for the Council to understand how the likely significant effects of the Proposed
Development have been established.
The Council is concerned that the degree of flexibility applied to core elements of the
scheme introduces uncertainty as to whether the full extent of potential environmental
effects has been captured. As identified throughout this response, there are significant
gaps in baseline evidence across a number of topic areas, including ecology,
archaeology, hydrology and transport, and in several cases the assessment relies on
assumptions or incomplete information. In these circumstances, it is not always
evident how the assessment has combined the upper bounds of key parameters to
ensure that a realistic worst-case scenario has been consistently examined,
particularly where different elements of the scheme may interact to give rise to greater
impacts.
Furthermore, the Council’s technical consultees have highlighted that aspects of the
scheme design and mitigation strategy remain under development, with some
measures subject to ongoing discussion or to be secured at a later stage. This is of
particular relevance given the concerns raised regarding the application of the
mitigation hierarchy, the absence of adequate survey information, and the lack of
evidence that environmental constraints have informed the design of the scheme.
Taken together, this raises uncertainty as to whether the assessment reflects a
precautionary worst-case position or is, in part, reliant on mitigation and design
refinement that is not yet fully defined or secured.
In this context, the Council considers that further clarification is required as to how the
Rochdale Envelope has been applied in practice, including how parameter ranges
have been defined, how worst-case scenarios have been derived, and how these
have been consistently applied across the various technical assessments. Without
this, and in light of the wider deficiencies identified in the PEIR, the Council does not
consider that it is currently possible to arrive at a clear or reliable understanding of the
likely significant effects of the Proposed Development.
Response to consultation
For the reasons set out in this letter, the Council considers that the Consultation has
not been carried out on an adequate basis.
In particular, the scale of errors, omissions and inconsistencies, coupled with the
piecemeal and evolving nature of the information provided, has prevented the Council
from understanding the Proposed Development and its likely impacts, and from
engaging in a meaningful and informed way.
In these circumstances, the Council formally requests that CEP:
1. withdraws the current Consultation;
2. addresses the identified deficiencies in full, including ensuring that all
environmental information is accurate, consistent and complete; and
3. undertakes a fresh statutory consultation exercise on the basis of a stable,
coherent and reliable set of materials.
Absent such steps, the Council does not consider that CEP will be able to
demonstrate compliance with its statutory consultation duties under the 2008 Act, with
the consequent risk that any subsequent DCO application will be delayed, refused
acceptance or otherwise prejudiced.
The Council remains committed to constructive engagement with CEP on the scope
and approach to any re-consultation, to help ensure it is delivered effectively and in full
accordance with statutory requirements and guidance.
Notwithstanding the above concerns, the Council has sought to engage with the
Consultation in good faith. The Council’s technical teams have sought to respond to
specific points raised by CEP, and to engage with amendments made to the submitted
information during the consultation.
Responses have been obtained from across the Council’s internal consultees, and the
Council has sought to coordinate and consolidate technical feedback wherever
possible.
In addition, several external statutory and technical consultees have raised objections
or significant concerns, including NATS, Manchester Airport, the Met Office and the
British Horse Society.
Technical Responses to the Statutory Consultation
For the purposes of the Statutory Consultation, the Local Planning Authority (LPA) has
undertaken a consultation process with the relevant internal and external consultees.
A summary of the responses received is provided below, with full copies of all
consultation responses included in the accompanying Appendices.
Ecology, including Biodiversity and Ornithology
The Council’s Biodiversity Team raises substantial and wide-ranging concerns
regarding the adequacy, timing and robustness of the ecological information
presented within the Preliminary Environmental Information Report (PEIR) for the
Calderdale Energy Park. Taken as a whole, the submission is considered insufficient
to support a meaningful understanding of ecological impacts or to demonstrate
compliance with national policy, particularly in relation to avoidance of harm, the
mitigation hierarchy and the protection of sensitive habitats and species.
A central concern is that the ecological assessment is incomplete and prematurely
applied. Significant elements of baseline survey work remain outstanding, including
key habitat, species and peat investigations, and are unlikely to be completed before
submission of the Development Consent Order. Despite this, the applicant has
proceeded to apply the mitigation hierarchy and develop a site layout, which the
Biodiversity Team considers fundamentally flawed. The current design does not avoid
impacts on deep peat, irreplaceable habitats or areas supporting Special Protection
Area species such as golden plover and merlin and therefore fails to demonstrate that
harm has been minimised at source in accordance with policy expectations.
The PEIR is also criticised for a lack of engagement with the Local Planning Authority
and other relevant stakeholders, which has limited the opportunity to shape survey
methodologies, mitigation proposals and overall design evolution. This disconnect is
reflected in the absence of clear evidence that environmental constraints have
informed the siting of turbines, access routes and infrastructure, with mitigation
instead presented as a secondary, post-design exercise rather than an integral part of
scheme development.
In ecological terms, the site is identified as being of very high sensitivity and value,
forming part of the Calderdale Wildlife Habitat Network and supporting a range of
protected habitats and species. However, the PEIR does not adequately assess
impacts on ecological networks or their wider function, including connectivity with
adjacent areas and resilience to future pressures such as climate change. The
Biodiversity Team emphasises that the scale of the development is likely to result in
significant adverse effects on these networks, both within the turbine area and along
access and cable routes, and that these effects have not been properly quantified or
addressed.
Survey limitations represent a recurring and critical issue across multiple receptors.
Existing survey work is described as partial, seasonally constrained or
methodologically inadequate, including for reptiles, amphibians, bats, invertebrates
and priority habitats. In several cases, evidence gaps appear to have led to
underestimation of ecological value or risk. For example, insufficient reptile survey
effort may have failed to identify important populations such as adders, and
invertebrate surveys are limited to a single-season snapshot. Similarly, survey work
for internationally important CHEGD fungi is extremely limited despite early indications
that the site may be of exceptional value, potentially meeting criteria for designation.
The Biodiversity Team is clear that comprehensive, multi-season survey work is
essential to properly understand impacts and inform any subsequent assessment.
Ornithological impacts are identified as a particular area of concern. The site supports
important upland bird populations, including SPA qualifying species, yet the PEIR
underestimates their conservation value and proposes construction during the
breeding season, which is considered unacceptable. The team advises that such
activity would result in likely significant adverse effects at a regional scale through
disturbance and displacement, and that mitigation measures are insufficient and not
embedded within the scheme design. The approach conflicts with established
guidance that requires avoidance of harm as a primary step.
The proposed treatment of peatland and hydrology is similarly problematic. The
development risks direct and indirect impacts on deep peat and blanket bog, which
are recognised as irreplaceable habitats and important carbon stores. The Biodiversity
Team highlights a lack of detailed justification for infrastructure such as floating tracks
and turbine placement in sensitive areas and raises specific objections to elements of
the layout where damage appears disproportionate. There is also insufficient
information on watercourse impacts, surface water management and the use of
culverts, with policy requiring clear demonstration that less harmful alternatives have
been fully explored.
The approach to Biodiversity Net Gain (BNG) and compensation is also considered
underdeveloped. While the applicant proposes to submit a Biodiversity Gain Plan, the
level of detail is currently inadequate to enable assessment, and there is a lack of
clarity on how on-site avoidance, mitigation and enhancement will be prioritised before
reliance on off-site measures. The Biodiversity Team stresses that BNG must be
informed by a full evidence base, aligned with the Local Nature Recovery Strategy and
supported by detailed management and monitoring plans. More broadly,
compensation measures, including habitat restoration opportunities, have not been
sufficiently developed or discussed with the Council, despite clear policy requirements
for early engagement.
Finally, the PEIR does not adequately consider wider ecosystem services and natural
capital. Although the importance of these is acknowledged, there is no clear
methodology for quantifying baseline conditions, assessing impacts or monitoring
outcomes. Given the scale of the development and the sensitivity of the landscape,
the Biodiversity Team considers this a significant omission, particularly in relation to
cumulative impacts on carbon storage, hydrology and biodiversity.
In conclusion, the Biodiversity Team considers that the ecological assessment is not
yet fit for purpose and does not provide a reliable basis for consultation or decision
making. A comprehensive reassessment is required, underpinned by complete and
robust survey data, meaningful engagement with stakeholders, and a clear
demonstration that the mitigation hierarchy has been properly applied. Without this, it
is not possible to accurately identify, assess or weigh the ecological harms arising
from the proposal against its potential benefits.
Access, Traffic and Transport
The Local Highways Authority (LHA) has reviewed the submitted PIER documentation
and associated consultation material. In their response they have stipulated that it is
clear that the proposed NSIP has the potential to generate significant highway impacts
arising from abnormal indivisible load movements, substantial HGV activity, extensive
track construction, off-site highway works and prolonged construction activity across
constrained rural highway networks.
The LHA has confirmed that currently, there is insufficient information to fully assess
the proposed access arrangements, mitigation measures and overall deliverability of
the scheme. They have also highlighted that further detail will be required in relation
to:
• abnormal load routing and route definition
• swept path analysis
• highway constraints
• verge stability and potential widening requirements
• temporary traffic management arrangements
• utility and statutory undertaker impacts
• cumulative construction traffic effects
It has also been stated that the swept path information and associated drawings will
need to be provided at an appropriate scale and level of detail to allow proper
assessment of:
• carriageway overrun
• verge encroachment
• impacts on walls, structures and street furniture
• interactions with non-motorised users
• the extent of any required widening or temporary engineering works
The LHA conclude in their comments that given the scale of the proposed NSIP and
the cross-boundary nature of the access arrangements, continued engagement with
the relevant highway authorities will be essential as the design evolves. While the
principal access corridors are becoming more defined, the preferred construction and
abnormal load routes must be further refined to enable a detailed assessment of key
constraints, accommodation works and necessary mitigation. Additionally, broader
considerations including Public Rights of Way, environmental constraints and utility
infrastructure will need to be addressed alongside highway impacts.
Public Rights of Way
The Council’s Public Rights of Way (PROW) Officer raises significant concerns
regarding the adequacy of the PEIR in assessing the impacts of the proposed
development on public access and recreational use, with particular reference to
relevant national policy in the National Policy Statement for Renewable Energy
Infrastructure (EN3) and the National Planning Policy Framework. The application site
encompasses an extensive and highly valued network of public rights of way,
including nationally important routes such as the Pennine Way, Pennine Bridleway
and Calder Aire Link, alongside large areas of Open Access land that contribute to a
distinctive sense of remoteness and wild landscape character. These routes are not
only important linear corridors but form part of a wider recreational network that
supports a range of users and experiences, and their significance is not fully captured
within the PEIR.
While the documentation acknowledges the presence of these routes and the need for
mitigation, there remains a lack of clarity regarding the direct physical relationship
between proposed infrastructure and the PROW network. Elements of the scheme,
including several turbines and the substation, are close to existing routes, yet it is not
clearly demonstrated whether these would directly affect path alignments, safety or
user experience. Although some design changes are noted in response to the
Pennine Way, turbines continue to over-sail or sit close to key routes, and the extent
to which this may affect users has not been fully explained or mitigated.
The PEIR identifies that significant adverse effects on visual amenity are likely for
users of public rights of way, including strategic trails. However, the assessment is not
supported by sufficient evidence, with key omissions such as missing baseline
photography and photomontages from representative viewpoints. Without this
information, it is not possible to fully understand the extent of visual intrusion or the
degree to which the landscape experience of users, particularly those seeking a sense
of tranquillity and remoteness would be altered.
Transport and construction impacts also raise concerns. Although the presence of
public rights of way is acknowledged, there are inaccuracies in route identification and
insufficient detail on how users will be protected during the construction phase. Given
that construction activity will intersect with much of the network, there is clear potential
for disruption, safety risks and delays, particularly for vulnerable users such as
walkers, equestrians and cyclists. The need for measures such as Temporary Traffic
Regulation Orders, safe crossing arrangements and alternative routes is recognised,
but the PEIR does not yet provide a detailed or coherent strategy. It is therefore
essential that these matters are fully addressed through a comprehensive Onsite
Access Management Plan and a dedicated PROW Management Plan.
In addition to physical and visual effects, the PEIR identifies that noise levels
experienced by users of key recreational routes are likely to exceed existing baseline
conditions, further affecting amenity and enjoyment. However, mitigation measures for
these impacts are not clearly articulated. By contrast, it is noted that shadow flicker is
not expected to give rise to unacceptable effects for equestrian users, indicating that
certain potential impacts have been considered in more detail than others.
More broadly, the assessment is considered too narrowly focused on a limited number
of strategic routes and does not adequately address the full extent and usage of the
wider access network. There is little analysis of how the network is used, patterns of
recreation across the site, or the role of Open Access land in supporting informal
access. The absence of usage data or proxy indicators, such as digital activity
mapping, limits understanding of the scale and sensitivity of receptors.
Even within the limited focus on strategic routes, the assessment of the Pennine Way,
as a nationally significant trail, is insufficiently developed. Further work is required to
demonstrate how its recreational value and user experience will be maintained or
enhanced.
The PROW Officer also highlights the need for a dedicated assessment of Open
Access land under the Countryside and Rights of Way Act, including a clear account
of the extent and function of access land before and after development, and the
adequacy of any proposed replacement land. Opportunities to secure enhancements
to the network, including improved connectivity, facilities and public health outcomes,
should be explored in line with national policy expectations.
Overall, it is concluded that the PEIR does not yet provide sufficient information to fully
understand or mitigate the impacts of the proposed scheme on public rights of way
and recreational access. A more comprehensive and evidence-based assessment is
required, addressing the full network, all user groups, construction and operational
impacts, and opportunities for enhancement. Detailed mitigation measures and firm
commitments must be secured at the DCO stage to ensure that the integrity, safety
and enjoyment of the PROW network are protected and that the requirements of
national policy are met.
British Horse Society
The Council has also received comments from the British Horse Society which
highlight issues relating to Public Rights of Way. They have confirmed that having
reviewed the PIER and associated consultation documentation they object to the
proposals due to its impact on an already limited and fragmented rights of way
network for equestrians, who currently have poor access locally and nationally and
face significant road safety risks. They highlight the economic value of horse riding in
the Halifax area, its health and wellbeing benefits particularly for women and less
active groups and the vulnerability of riders on increasingly busy roads. They request
clearer information on affected rights of way, upgrades from footpaths to bridleways,
improved off-road connectivity, and consideration of facilities such as horsebox
parking and a community arena. They also seek assurances on driver training for
HGVs, access to haul roads post-development, and investment in equestrian
infrastructure.
Historic Built Environment
The Council’s Conservation Team raises significant and overarching concerns
regarding the adequacy of the Preliminary Environmental Information Report (PEIR) in
assessing the impact of the proposed Calderdale Energy Park on the historic
environment. In its current form, the PEIR is considered to fall materially short of policy
and good practice requirements, particularly in its treatment of heritage significance
and the contribution of setting.
At the heart of these concerns is a fundamental failure to robustly analyse how the
wider historic landscape contributes to the significance of heritage assets across
Calderdale. The upland moorland landscape is not simply a backdrop but integral to
the Borough’s historic development, shaping settlement patterns, agricultural practices
and industrial growth. This relationship underpins the significance of over 2,000
designated heritage assets and many more non-designated assets. The Conservation
Team considers that the PEIR consistently underplays this relationship, placing undue
emphasis on immediate or “primary” setting and neglecting the critical role of wider
setting, intervisibility, landscape experience and cultural associations.
The scale and nature of the proposed development of up to 34 turbines of up to 200m
in height with associated infrastructure has the potential to introduce a highly
conspicuous and industrialising influence into a landscape currently characterised by
remoteness, openness and historical continuity. The Conservation Team is clear that
such change could fundamentally alter how the historic landscape is experienced and
therefore harm the significance of heritage assets, even where there is no direct
intervisibility. However, the PEIR does not adequately articulate or assess this
potential harm, nor does it provide the evidence base required to reach robust
conclusions.
A key criticism relates to the methodology applied in the Historic Environment Chapter
and its supporting Initial Settings Report. The assessment is considered incomplete,
inconsistent and in places inaccurate, with substantial gaps in both data and analysis.
Many heritage assets have been omitted from detailed consideration without sufficient
justification, and the rationale for grouping assets is unclear and often inappropriate.
Site visits essential to understanding setting have been extremely limited given the
scale of the study area, undermining confidence in the findings. The Conservation
Team emphasises that desk-based analysis alone cannot capture the experiential and
dynamic aspects of setting that are central to heritage significance.
The approach to assessing impact and harm is also flawed. The methodology relies
heavily on identifying “likely significant effects” in EIA terms, with insufficient regard to
the requirement in national policy to identify and assess all levels of harm, including
less than substantial harm. By equating “not significant” effects with “no harm” and
filtering out lower-value or non-designated assets, the assessment risks excluding a
wide range of impacts that must be considered in decision-making. The Conservation
Team stresses that any level of harm to heritage significance must be clearly
identified, justified and weighed against public benefits in line with the National
Planning Policy Framework and National Policy Statements.
In addition, the PEIR is criticised for failing to properly consider a number of important
impact mechanisms. These include cumulative effects with existing wind farms,
skylining impacts, changes to views along key routes, and experiential factors such as
noise and shadow flicker. Potential physical impacts, including damage to heritage
assets from construction traffic and infrastructure works, are also not adequately
assessed. Similarly, proposed interventions such as the relocation of historic boundary
stones or partial demolition of listed vaccary walls are not supported by the level of
justification required for works resulting in harm, particularly where that harm may be
substantial.
The Conservation Team also highlights a lack of meaningful engagement with the
Council to date, including the absence of a Planning Performance Agreement and
limited opportunity to influence key aspects of the assessment such as viewpoint
selection and visualisations. This has constrained the ability to ensure that heritage
considerations are properly integrated into the assessment process.
Finally, the PEIR is considered to undervalue the historic landscape itself as a
heritage asset. The upland landscape, with its assemblage of archaeological remains,
historic features and long-standing land-use patterns, contributes collectively to local
distinctiveness and cultural identity. The failure to treat this landscape as an asset in
its own right, and to assess the impact of the development upon it, represents a
significant omission.
In summary, the Council’s Conservation Team concludes that the historic environment
assessment is currently insufficient to support informed consultation or decision
making. A comprehensive reassessment is required, based on robust methodology,
full coverage of relevant heritage assets, and a thorough understanding of setting and
significance. Only through such work can the level of harm be properly identified and
weighed against the public benefits of the proposal in accordance with national and
local policy.
Archaeology
The West Yorkshire Archaeology Advisory Service (WYAAS) raises fundamental
concerns regarding the adequacy of the archaeological assessment presented within
the Preliminary Environmental Information Report (PEIR) for the Calderdale Energy
Park. In its current form, the PEIR is considered insufficient to support informed
decision-making, primarily due to the absence of robust baseline evidence and an
over-reliance on assumptions that underestimate both the presence and significance
of below-ground archaeological remains.
A central issue identified by WYAAS is that the PEIR does not provide a reliable
assessment of the archaeological and geoarchaeological resource across the site.
Instead, it presents a position which downplays potential impacts and defers essential
baseline investigations until after consent is granted. This approach conflicts directly
with national policy requirements, which require a clear understanding of heritage
significance prior to determination in order to enable appropriate avoidance and
mitigation. The current reliance on limited desk-based analysis and non-intrusive
surveys is considered wholly inadequate for a site of this nature and sensitivity.
In particular, the archaeological potential of the upland peat landscape is identified as
being significantly underestimated. The blanket peat deposits across the site are
recognised as having high geoarchaeological value, with the potential to preserve
intact prehistoric land surfaces and nationally significant Mesolithic remains. WYAAS
emphasises that such deposits are highly sensitive to changes in hydrology, and that
construction activities particularly drainage, track installation and dewatering could
result in widespread degradation of the palaeoenvironmental record, not just at turbine
locations but across the broader site. However, the PEIR incorrectly assumes that
impacts will be localised and limited in extent, thereby failing to capture the true scale
of potential harm.
The assessment of prehistoric archaeology is a particular area of concern. The South
Pennine uplands are known to contain important concentrations of Mesolithic activity,
often preserved beneath peat in an undisturbed state. WYAAS strongly disputes the
downgrading of these resources to regional significance, noting that intact Mesolithic
horizons are typically of national importance. The PEIR’s assertion that archaeological
remains are unlikely to require preservation in situ is therefore considered premature
and unsupported, given that no intrusive investigation has been undertaken to confirm
their presence, extent or condition.
More broadly, the methodology employed in the PEIR is criticised for failing to follow
the established mitigation hierarchy. By not undertaking sufficient pre-determination
evaluation, the applicant has been unable to design the scheme to avoid
archaeological remains where possible. Instead, the assessment defaults to a strategy
of “preservation by record” (i.e. excavation), without demonstrating that avoidance or
design modification is not feasible. WYAAS is clear that this approach is contrary to
national guidance, which requires avoidance to be prioritised wherever possible and
informed by appropriate baseline evidence.
The limitations of the current survey approach are also highlighted. Walkover surveys
and other non-intrusive techniques are not capable of identifying buried archaeological
horizons beneath peat or understanding the depth, preservation and distribution of
deposits. WYAAS stresses that a comprehensive programme of intrusive investigation
including augering, coring, test-pitting and trial trenching is essential to properly
characterise the archaeological resource. In particular, geoarchaeological deposit
modelling, supported by scientific dating, is required to understand the formation,
evolution and preservation of the peat landscape and its associated archaeological
potential. Without this evidence, any assessment of impact is considered speculative
and unreliable.
The PEIR is also criticised for its treatment of later archaeological features within the
landscape, including Roman infrastructure, medieval and post-medieval farmsteads,
upland field systems and extractive industries. While some assets are identified, their
condition, extent and significance are not adequately established. In several cases,
the assessment assumes limited impact without sufficient evidence, for example in
relation to the Roman Road crossing the site. WYAAS advises that targeted
geophysical survey and trenching are required to confirm the presence and
significance of such features and to inform appropriate mitigation.
In addition, the cumulative and landscape-scale nature of archaeological impacts is
not fully addressed. The development would affect a coherent historic landscape
shaped by long-term human activity, and changes to peat hydrology, ground
conditions and surface features have the potential to result in widespread and
irreversible loss of archaeological information. This broader context is not adequately
reflected in the PEIR, which instead treats impacts in a fragmented and site-specific
manner.
WYAAS therefore concludes that the current evidence base is insufficient to support
the application. A comprehensive, phased programme of archaeological evaluation is
required prior to determination, beginning with non-intrusive survey and followed by
systematic geoarchaeological investigation and targeted intrusive works across all
areas of proposed impact. Only once this information is available can the significance
of the archaeological resource be properly understood, and an appropriate mitigation
strategy developed in accordance with the principles of avoid, reduce and mitigate.
In summary, the PEIR does not currently demonstrate an adequate understanding of
the archaeological resource or the potential impacts of the proposed development
upon it. Without substantial further survey, analysis and engagement, it is not possible
to reach a reasoned conclusion on the level of harm or to ensure that the
requirements of national policy are met.
Flood Risk and Drainage
The Lead Local Flood Authority (LLFA) considers that the information submitted in the
PIER and associated consultation material is insufficient to determine whether the
proposed development complies with national and local planning policy requirements,
particularly in relation to flood risk and drainage. The current lack of detail does not
provide adequate assurance that flood risk and drainage mitigation measures have
been appropriately addressed. It is considered that further clarification and supporting
evidence are therefore necessary to enable a robust assessment.
The LLFA considers that the information submitted does not include a detailed
drainage strategy that assesses the pre and post development impacts on surface
water management. As the site location being predominately on peat and moorland,
any interaction or disturbance of existing peat and moorland can change local
drainage infrastructure, and this can have a potential cumulative impact on receptors
downstream. Therefore, the LLA argue that it is critical that a site wide drainage
strategy is developed to design and mitigate impacts from permanent and temporary
features and ensure these are being appropriately controlled.
The LLFA highlight that no Construction Phase Surface Water Management Plan has
been provided. This will need to cover each phase of the proposal (including
decommissioning) for the duration of construction with escalation and backup
measures during storm events along with contact details for normal working hours, out
of hours, weekends and holidays. The LLFA in their response have listed what they as
a minimum would expect to see in The Construction Phase Surface Water
Management Plan.
The LLFA would also expect that the Flood Risk Assessment (FRA) should be
informed by a detailed modelling study to assess subsurface flows given the site’s
characteristics. Risk of hydrological disruption could occur, both short and long term
as certain features will remain in situ such as hardstanding, buildings, substations,
turbine foundations and above ground cabling.
The proposed development has a stated lifespan of 35 years; however, a number of
elements will remain in situ beyond this period, and therefore the Flood Risk
Assessment (FRA) and supporting modelling must consider long-term impacts and
apply appropriate climate change allowances. While below ground cabling is expected
to have minimal impact, reinstatement at the surface will need careful consideration to
ensure no adverse effects. The use of swales for access is noted, but these must be
designed to avoid increasing runoff rates or volumes to receiving watercourses or
groundwater. Where infiltration is proposed, it must account for potential impacts on
local hydrogeology and the condition of peatland, including seasonal variations.
The drainage strategy should also avoid over-engineering, which could accelerate
downstream flows; instead, it should incorporate measures to slow runoff, particularly
at features such as watercourse crossings. Access tracks must be carefully designed
to prevent them acting as preferential flow paths that could increase runoff rates. In
line with earlier scoping advice, assessments of slope stability, geotechnical
conditions and contamination are required to inform both the Environmental Statement
and drainage design, and should be undertaken at an early stage. The LLFA strongly
supports the use of Sustainable Drainage Systems (SuDS) and Natural Flood
Management (NFM) measures to manage runoff in a manner that reflects the local
landscape and hydrological conditions.
NB: The comments received from the Local Lead Flood Authority need to be read in
conjunction with the Council’s Community Safety Team comments regarding early
flood warnings (see in section below Meteorology).
Minerals
The Council’s Minerals & Waste Officer has reviewed the PEIR and concludes that it
fails to assess the Proposed Development’s impact on mineral resources.
Chapter 23 directs mineral considerations to Chapter 22; however, Chapter 22
contains no assessment of mineral resources, Mineral Safeguarding Areas (MSAs), or
the potential sterilisation of underlying resources, focusing solely on construction
materials and waste. Although Chapter 10 provides a geological baseline, it is not
used to evaluate mineral resource presence, value or safeguarding implications.
This omission is substantial in the context of national policy (NPPF paragraph 222),
Calderdale Local Plan Policy MS2, the presence of economically important minerals
(including sandstone, gritstone and coal), and the scale and permanence of the
development. There is no evidence of MSA identification, a site-specific Mineral
Resource Assessment, prior extraction, or consultation with the Mineral Planning
Authority. The PEIR therefore fails to demonstrate compliance with mineral
safeguarding policy.
Available evidence from the Calderdale Local Plan and British Geological Survey
indicates that the site lies within the Pennine uplands underlain by Millstone Grit
sandstones, the Borough’s principal safeguarded resource, and is likely to fall within a
Sandstone MSA. Despite this, the PEIR provides no assessment of resource value or
the sterilisation effects of permanent infrastructure, creating a clear risk of
unnecessary loss of a regionally important resource.
Chapter 22 is limited to material supply and waste management and does not address
the interaction with safeguarded minerals. While it promotes reuse of site-won
materials in accordance with the waste hierarchy, it treats excavated materials solely
as construction inputs or waste, without recognising their potential mineral value or the
implications of their permanent use.
It also fails to identify MSA status, consider prior extraction, assess sterilisation
impacts, or demonstrate compliance with Local Plan mineral policies (MS1–MS4),
notwithstanding Chapter 23’s reliance upon it for these matters.
Accordingly, Chapter 22 cannot be relied upon to address mineral impacts. A
standalone Mineral Resource Assessment is required to properly assess resource
value, sterilisation risk and policy compliance
Climate Change, Sustainability and Carbon
In reviewing the submitted PIER documentation and consultation material, the
Council’s Climate and Environment Team noted that Calderdale Council declared a
Climate Emergency in 2019, recognising significant local climate change risks,
particularly flooding. This is evidenced by the 2015 Boxing Day floods, which caused
widespread damage to homes, businesses and infrastructure. Climate projections
indicate more extreme weather, including wetter winters with increased rainfall and
higher river levels, alongside hotter, drier summers and more severe heatwaves. In
response, the Calderdale Climate Action Plan highlights the strategic importance of
renewable energy and supports appropriate developments that benefit local
communities and businesses.
The Committee on Climate Change’s 2025 progress report highlights the urgent need
to cut fossil fuel use, accelerate electrification and rapidly expand renewable energy,
particularly wind and solar to address worsening climate impacts, improve energy
security and deliver the Government’s Clean Power 2030 ambitions, alongside
progress in carbon capture and storage.
In relation to Chapter 11 of the PIER, the future baseline assumptions at paragraph
11.5.19 may underestimate emissions, as the Committee on Climate Change’s 2025
progress report highlights insufficient national progress on carbon capture and
storage; continued unabated gas use would result in higher emissions than assumed,
meaning the carbon savings for the Calderdale Energy Park in Table 11 – 12 may be
understated.
The Calderdale Energy Park could deliver substantial carbon reductions across future
carbon budget periods, with impacts far greater than most other proposed local
projects, though its projected benefits may be underestimated if fossil fuel use without
CCS continues.
Socio-economic
The Council’s Strategic Lead for Inclusive Economy and Voluntary Sector raises a
number of substantive concerns regarding the scope and depth of the socio-economic
assessment presented within the PEIR, concluding that while the methodology broadly
accords with standard EIA practice, it does not yet provide a sufficiently
comprehensive or policy aligned understanding of local economic impacts. The
assessment appropriately recognises the national importance of the scheme in
supporting renewable energy and Net Zero objectives, and it identifies positive
economic effects, particularly during the construction phase, including job creation,
GVA uplift and supply chain activity. However, the analysis is narrowly framed around
conventional measures of economic growth, with a predominant focus on headline
indicators such as employment numbers and output, rather than on the distribution of
those benefits or their contribution to inclusive growth.
The baseline evidence presented within the PEIR reflects well-established local
economic challenges, including lower economic activity rates, skills shortages,
relatively low productivity and high levels of fuel poverty. While these factors are
acknowledged and align with the Council’s Inclusive Economy Strategy, the
assessment does not fully develop how the proposed scheme will respond to these
structural issues or contribute to reducing inequalities. In particular, the analysis treats
the local economy as largely homogeneous, without sufficient consideration of how
different communities or groups may experience the impacts of the development
differently, or how benefits can be targeted towards those most in need.
Although the PEIR identifies a significant beneficial effect arising from construction
employment, it provides only a high-level account of these opportunities and lacks
detail on their quality, accessibility and long-term legacy. There is insufficient clarity on
how residents, particularly those facing barriers to employment, will be able to access
these jobs, or how opportunities for skills development and apprenticeships will be
secured and aligned with local training provision. Similarly, while commitments such
as the proposed employment and skills plan are noted, these are not yet supported by
detailed delivery mechanisms, clear targets or an evidence-based understanding of
the local labour market, creating uncertainty as to the extent to which benefits will be
realised locally.
The assessment of economic value retention and community wealth is also
underdeveloped. While the PEIR highlights potential benefits arising from business
rates retention and a proposed community benefit fund, further detail is required on
governance, delivery and alignment with local priorities to ensure that these
mechanisms effectively support community outcomes. In addition, there is limited
exploration of how the scheme could contribute to wider economic resilience, for
example through improving local energy affordability for businesses or strengthening
the local supply chain. Assumptions regarding supply chain participation are not
sufficiently evidenced and may overstate the proportion of value that will be retained
within the local economy.
More broadly, the assessment places considerable emphasis on short-term
construction impacts, while identifying relatively limited long-term employment and
economic benefits associated with the operational phase. As a result, the scheme is
considered to make only a modest contribution to longer-term inclusive growth
objectives, with insufficient evidence of how it will support sustained economic
transformation, skills development or workforce progression within the local area.
Opportunities to link the development more directly to the green economy transition,
including the creation of enduring skills pathways and sectoral growth, are not fully
realised within the current assessment.
Overall, the Strategic Lead concludes that while the scheme has clear potential to
deliver economic benefits, particularly in the short term, the PEIR does not yet
demonstrate how those benefits will be distributed fairly or aligned with Calderdale’s
inclusive economy and anti-poverty priorities. There is a risk that, without stronger
commitments and clearer mechanisms, the scheme’s local benefits will not be
maximised or may not reach those most in need. Additional evidence and more robust
commitments are therefore required, including measurable targets for local
employment, skills development and supply chain participation, stronger alignment
with local policy frameworks, and clear arrangements for monitoring, governance and
delivery to ensure that economic value is retained locally and contributes meaningfully
to inclusive growth.
Visitor Economy
The Council’s VisitCalderdale team raises clear concerns regarding the robustness of
the tourism and socio-economic assessment presented within the Preliminary
Environmental Information Report (PEIR), concluding that it does not yet provide a
sufficiently reliable or locally relevant evidence base to support its findings.
A primary issue is the reliance placed on a 2008 Scottish Government-commissioned
study, which concludes that wind farm development has only minor effects on tourism
at a national level. VisitCalderdale considers that the applicability of this research to
Calderdale is highly questionable, given both its age and the very different geographic
and cultural context in which it was undertaken. The study relates to rural parts of
Scotland and does not account for the distinctive characteristics of Walshaw Moor,
which forms part of the internationally recognised “Brontë Country” landscape, where
tourism is closely tied to cultural identity, literary associations and perceptions of
remoteness and authenticity. The PEIR does not sufficiently justify the transferability
of these findings to this context.
The assessment is also criticised for the absence of a meaningful, site-specific tourism
baseline. The evidence presented relies largely on high-level economic data and
broad descriptions of visitor activity, without analysing the motivations of visitors to the
Walshaw Moor, Haworth and Top Withens area or the particular importance of
landscape character to the local visitor economy. In particular, there has been no use
of targeted visitor surveys or analysis of how tourism in this area may respond to
changes in landscape quality. This gap is considered significant, as destinations
driven by cultural identity and landscape experience are likely to be more sensitive to
change than general tourism markets.
VisitCalderdale further highlights a failure to address the potential impact of the
proposal on place identity and destination branding. The landscape in question is
central to Calderdale’s tourism offer and wider regional identity, featuring prominently
in marketing associated with heritage, literature and the natural environment. The
introduction of large-scale energy infrastructure into this setting has the potential to
affect visitor perceptions, repeat visitation and the long-term reputation of the
destination. However, the PEIR does not explore these qualitative and potentially
long-term effects, despite their relevance to the visitor economy.
Against this background, the PEIR’s conclusion that there would be no noticeable
adverse effects on the tourism economy is considered premature and insufficiently
evidenced. This is particularly the case given ongoing uncertainties around the final
design of the scheme, landscape mitigation measures and wider environmental
effects. VisitCalderdale advises that, in line with EIA best practice, such uncertainty
should result in impacts being carried forward for further assessment rather than
scoped out at this stage.
In conclusion, VisitCalderdale considers that the current assessment lacks the
necessary level of local specificity and methodological rigour to support its
conclusions. Without further site-specific analysis, particularly in relation to visitor
behaviour, landscape sensitivity and place identity, it is not possible to robustly
determine the likely effects of the development on Calderdale’s tourism economy.
Aviation, Defence, and Meteorology
As part of the consultation process the LPA has consulted the following:
• Manchester Airport
• Leeds Bradford Airport
• Humberside Airport
• National Air Traffic Services (NATS)
• The Ministry of Defence (MOD)
• The Met Office
Manchester Airport
Manchester Airport has raised significant concerns and formally objected to the
proposal on aviation safety grounds. In its response, the Airport states that the
development would degrade radar performance beyond acceptable limits, thereby
posing a potential risk to flight safety.
The Airport emphasises that the safety of aircraft operations is of paramount
importance. It notes its understanding, based on discussions with NATS (National Air
Traffic Services), that there are currently no suitably safe or viable mitigation
measures available to address the anticipated radar interference. Consequently, it
concludes that a wind energy development is not appropriate or acceptable in this
location.
Manchester Airport has further made clear that its objection must be given full and
proper consideration. It warns that, should the scheme proceed without resolving
these concerns or without further meaningful engagement, the matter will be escalated
to the Civil Aviation Authority (CAA).
National Air Traffic Services (NATS)
National Air Traffic Services (NATS) has confirmed that the proposed development is
likely to adversely affect the performance of four radar systems and one navigational
aid.
They have stated that they are working with the CEP to explore design changes and
mitigations that could potentially ameliorate these issues but until that process delivers
a solution acceptable to all parties NATS will continue to object to the proposal.
Other aviation consultees, including Leeds Bradford Airport and Humberside Airport,
were consulted; however, no responses had been received at the time of writing.
Should any responses be received subsequently, these will be forwarded separately.
Ministry of Defence (MOD)
The Ministry of Defence (MOD) has concerns with this proposal due to the
unacceptable impact of the turbines on the ATC radar at BAE Warton Aerodrome and
the creation of a physical obstruction to low flying aircraft. The MOD emphasises that
the advice provided within their comments is in response to the ‘Preliminary
Environmental Information Report Volume 1, Chapter 4: The Proposed Development’,
dated 21 April 2026,‘Preliminary Environmental Information Report Calderdale Energy
Park Volume 2, Chapter 19: Aviation and Radar’, dated 7 April 2026, ‘Bradford West
Cable Corridor’ (Figure 3-3 Rev. 1) and ‘Environmental Impact Assessment Scoping
Report’, dated September 2025. Any variation of the parameters (which include the
location, dimensions, form, and finishing materials) detailed may significantly alter how
the development relates to MOD safeguarding requirements and cause adverse
impacts to safeguarded defence assets or capabilities. In the event that any
amendment, whether considered material or not by the determining authority, is
submitted for approval, the MOD should be consulted and be provided with adequate
time to carry out assessments and provide a formal response.
The Meteorological Office
The Met Office in their comments state their objections to the proposed development
due to its potential impact on the Hameldon Hill weather radar, which lies within the
consultation zone approximately 13 km from the nearest turbine. It states that no
acceptable mitigation measures have yet been identified, despite ongoing
engagement with CEP. The Met Office is concerned that the turbines would cause
radar signal blockage and generate false clutter, reducing the accuracy and reliability
of weather data. This would impair the detection and monitoring of severe weather,
particularly heavy rainfall, which is critical for flood forecasting and warning systems in
the surrounding fast-responding catchments.
Additional concerns relate to partial beam blockage, which modelling indicates could
degrade radar performance to around the accepted tolerance threshold of 10%, a
level considered unacceptable given the flood risk in the area. The Met Office stipulate
that it has not been demonstrated that these impacts can be avoided or effectively
mitigated. They have therefore concluded that the proposal would result in material
adverse effects on radar coverage, precipitation estimation, and the ability to issue
accurate severe weather warnings. They have requested further detailed assessment
of turbine locations and heights relative to the radar beam and suggest that turbines
within the radar line of sight should be relocated or reduced in height. The Met Office
also expects to remain fully engaged in ongoing discussions to ensure its interests are
protected.
Calderdale Council Community Safety Team
In the light of the Met Office’s concerns about potential impact on flood warning
systems, the Council’s Community Safety & Resilience Officer was asked to provide
observations. These are set out below.
Calderdale is one of the most flood-prone and severe weather affected areas in West
Yorkshire due to its steep-sided valleys, rapidly responding river catchments and
extensive areas of critical infrastructure located within flood corridors. The borough
has experienced repeated severe weather emergencies over recent years, including
the Boxing Day floods of 2015, Storm Ciara in February 2020, Storm Eva, and more
recent severe rainfall and surface water flooding incidents affecting communities
across Hebden Bridge, Mytholmroyd, Todmorden, Brighouse and Halifax. These
incidents have resulted in risks to life, evacuations, prolonged disruption to transport
infrastructure, damage to homes and businesses, and significant impacts on
community recovery and public health.
The Council and West Yorkshire Resilience Forum rely heavily on accurate and timely
meteorological intelligence, including Met Office radar capability, to support flood
forecasting, severe weather monitoring, warning dissemination and multi-agency
decision making. Calderdale’s Severe Weather Plan and wider West Yorkshire multi
agency arrangements are fundamentally dependent upon early warning systems and
situational awareness to enable emergency responders to activate proportionate
response measures, warn vulnerable communities, deploy resources, open rest
centres, coordinate evacuations and protect critical infrastructure.
Any reduction in the reliability, accuracy or timeliness of weather radar data
particularly in relation to rapidly developing rainfall events would therefore represent a
serious resilience concern for Calderdale. The borough’s catchments respond
exceptionally quickly to intense rainfall, meaning even relatively short delays or
reductions in forecasting confidence can materially impact the effectiveness of flood
warnings, public information messaging and operational response activities. Effective
warning and informing arrangements are a core requirement of emergency
preparedness and response under the Civil Contingencies Act framework and
associated national guidance.
Of particular concern would be the potential impact on:
• Flood forecasting and Environment Agency warning dissemination;
• Multi-agency situational awareness during severe weather incidents;
• Public warning and informing arrangements for at-risk communities;
• Emergency evacuation and rest centre activation;
• Protection of vulnerable residents and critical infrastructure;
• Operational decision-making across responding agencies.
The National Risk Register identifies fluvial flooding, surface water flooding and
storms as significant national risks, with climate change expected to increase the
frequency and severity of such events. In Calderdale, where severe weather incidents
are both frequent and high impact, any development which could detrimentally affect
severe weather monitoring capability, forecasting confidence or warning arrangements
should therefore be treated with considerable caution.
Given the Met Office’s specific concerns regarding degradation of radar performance,
it would be reasonable for the Council to seek robust assurance that the proposal
would not adversely impact flood forecasting capability, severe weather monitoring, or
the effectiveness of emergency warning and informing systems relied upon by
Category 1 responders and partner agencies across West Yorkshire.
Environmental Health
The Council’s Environmental Health Officer has reviewed the technical material
submitted in support of the PEIR and raises significant concerns regarding both the
adequacy of the assessment and the level of uncertainty that remains. Given the scale
and technical complexity of the proposals, it is noted that the limited consultation
period has materially constrained the ability to undertake a comprehensive review. As
a result, the submission does not yet provide a sufficiently robust or reliable basis on
which to draw firm conclusions regarding potential environmental health effects.
In relation to noise, while the general approach to baseline monitoring and
assessment is broadly understood, there are fundamental gaps and uncertainties
which undermine confidence in the findings. These include reliance on indicative
(“candidate”) infrastructure, omissions in the identification and assessment of sensitive
receptors, and limited clarity in the application of established methodologies. Particular
concern is raised regarding the characterisation of the construction phase as
temporary, despite its anticipated duration and scale, and the potential for prolonged
disturbance to nearby properties in what is currently a very low-noise environment.
Further uncertainty arises in respect of operational effects, including the treatment of
low frequency noise and amplitude modulation, which have not been adequately
assessed at this stage. Additional issues are identified in relation to the substation
noise assessment, where methodological choices and assumptions lack sufficient
justification. More broadly, the submission relies heavily on preliminary or generic
assessments in other areas, including construction dust and private water supplies,
with limited site-specific analysis and reliance on potentially outdated baseline
information.
Overall, the Environmental Health Officer concludes that there is insufficient evidence
at this stage to demonstrate that the development would not give rise to significant
adverse effects on nearby receptors or the wider area. A more detailed, site-specific
and fully evidenced assessment will be required to address the substantial gaps,
uncertainties and omissions identified.
Landscape and Visual Impact
In the absence of a Planning Performance Agreement and in-house technical
expertise, the Council is not in a position to provide its own detailed response.
Notwithstanding this, Calderdale Council endorses the comments provided by
Bradford Council in respect of Chapter 12 (Landscape and Visual Impact
Assessment).
A number of important matters raised by Bradford Council are of direct relevance to
Calderdale and require further attention. Of particular significance is the expectation
that the most pronounced landscape and visual effects will occur within 10km of the
site, including within the Northern Calderdale Moorlands Special Landscape Area. The
PEIR identifies the potential for significant effects on both designated landscapes and
public rights of way within this zone, and it is essential that the Environmental
Statement provides a more detailed and locally specific assessment of these impacts.
The sensitivity of key recreational receptors, including strategic routes and areas of
Open Access land, is also highlighted. Bradford Council’s emphasis on the need for
detailed assessment of sequential views and user experience, particularly along
nationally and regionally important routes should be carried through comprehensively,
given the cross-boundary nature of these receptors and their importance within
Calderdale.
In addition, the identification of gaps in viewpoint coverage and the need for higher
resolution and more legible visual material is supported. This is particularly important
in understanding effects within the nearer study area and in areas where visibility is
high. The need for additional viewpoints in locations with theoretical visibility and
sensitive receptors should be addressed at the Environmental Statement stage to
ensure a complete and transparent assessment.
Conclusion
Overall, the Council is increasingly concerned and disappointed that, given the scale
and potential significance of the proposed development, the consultation material
does not yet demonstrate a sufficiently robust, transparent or considered assessment
of its impacts on communities, the environment and valued landscapes. The level of
detail and clarity provided in a number of key areas falls materially short of what would
reasonably be expected at this stage, raising serious concerns that the scheme has
not been developed with an adequate understanding of the sensitivity of its receiving
environment.
It is essential that these deficiencies are addressed through a further round of
statutory consultation, informed by a materially improved and comprehensive
evidence base. The current submission does not provide a sufficient foundation for
meaningful engagement, and the Council considers that affected communities and
stakeholders must be given a proper opportunity to review and respond to revised
proposals that fully and transparently assess environmental and social impacts.
The Council expects these matters to be addressed in full as the project progresses.
Should the issues raised in this response not be satisfactorily resolved, the Council
will give serious consideration to pursuing its concerns through the Development
Consent Order process and, where necessary, through other appropriate channels.
This may include formal challenge to ensure that the interests of Calderdale’s
communities, environment and valued landscapes are properly recognised and
protected.
This letter has been approved by the Council’s Cabinet Member – Economic
Regeneration and the Director – Regeneration and Strategy in accordance with the
Council’s approved governance arrangements in place for National Infrastructure
Projects (NSIPs).
Yours Sincerely
Ruth Hardingham
Development Manager
Calderdale MBC