Nick MacKinnon is a freelance teacher of Maths, English and Medieval History, and lives above Haworth, in the last inhabited house before Top Withens = Wuthering Heights. In 1992 he founded the successful Campaign to Save Radio 4 Long Wave while in plaster following a rock-climbing accident on Skye. His poem ‘The metric system’ won the 2013 Forward Prize. His topical verse and satire appears in the Spectator, and his puzzles and problems in the Sunday Times and American Mathematical Monthly. Email: nipmackinnon@gmail.com
Boft Hole SD 95858 36319 ///crumples.escape.landowner
Map of walk to Boft Hole and Crow Hill. WTRG1 October 2026 Things are moving fast now. CWFL say they will be making a DCO application in November, but one fortnight in September makes that seem unlikely.
14 September 2026. In a Halifax multi-storey, Deep Stoat (he’s our mole) handed me a thick envelope of information he had obtained from Natural England in response to the Statutory Consultation. It included a letter of overarching comment.
“Natural England advises that we consider it will not be possible to agree effective measures that adequately compensate for the effects of this development.”
“Overall, Natural England considers that these issues are likely to be insurmountable in our engagement with this application and compliance with the Habitats Regulations.”
“We do not expect it will be possible to reach agreement on key issues.”
Lydia and Wayne (welcome!) loaded the big stuff to the Stronger Together website, where many have now read the documents.
Natural England sent their first response to CWFL on 10 June 2026, the day that Statutory Consultation should have closed. The bunglers at Cavendish Consulting gave the wrong email address in the brochure, so the period for the public to respond was extended to 10 July 2026. On that day, Natural England sent further advice to CWFL, who wanted NE’s advice about their proposed compensation site.
Natural England advice to CWFL on compensation site selections. 10 July 2026. NEFrom response on compensation site selection NE to CWFL 10 July 2026. NE
This expectation of a full compensation plan must surely prevent a November 2026 submission of the DCO application. The compensation plan has to be different from anything discussed yet with Natural England, since NE regard the issues as “insurmountable”. If CWFL submit an application without consulting NE on a full compensation plan “sufficiently in advance”, the Planning Inspectorate may reject the application “at the gate.” The new guidance EN-1 (overarching) and EN-3 (onshore renewables) is intended to streamline NSIPs, but it assumes a competent developer, and a competent developer is not on Walshaw Moor.
The NE response then has a list of features that a compensation site must have,and what must be done to show that it is adequate, relative to all the qualifying features of the Walshaw Moor SPA and SAC. This is to include a peat depth survey, and the low grade England Peat Map is explicitly ruled out. Effectively, CWFL have to make a whole new Walshaw Moor “another Eden, demi-paradise”. They must supply this “fortress built by Nature (and Algihaz) for themselves” with everything that (as stated examples) a merlin and a golden plover could want, perhaps including predator control, though that point is redacted. Further redaction disguises the compensation land location, but we reveal what CWFL are planning further down the blog.
This is why the competent developers are not on Walshaw Moor. When Natural England say “insurmountable” they do not use the world lightly.
14 September 2026 Haworth with Stanbury VC used their perfect locus standi (the parish was inundated by massive bog bursts on 2-4 September 1824) to send CWFL a legal letter before action (under Gunning) on the unassessed bog burst risk on Crow Hill. After all, Haworth with Stanbury can hardly have been consulted on this matter if Algihaz were in ignorance of the 1989 event because their consultant Dr Mills had got his bog bursts in a twist. Perhaps Mustapha Hajjar was himself led astray by the shameless lieCavendish Consulting published, that Crow Hill was “the safest” of the options. Kevin Whitmore of Cavendish can “manage reputations under pressure”, but does he really know enough about pore pressure in thixotropic peat to claim that Crow Hill was “safest”? Does he consider the shameless lies published as FAQs by Cavendish will “protect reputation during periods of scrutiny or crisis”?
“Managing reputation under pressure” and “building trust”. From the Mission Statement of Cavendish Consulting, authors of three shameless lies about access over Crow Hill. CavendishOn 10 June 2025, NE and CWFL had a minuted meeting, also in the Deep Stoat bundle.
The first mention of the “Brontë bog burst error”. NEThis is the earliest known occurrence of the “Brontë bog burst error”. It was made here by a redacted CWFL “Peat Lead” who may have been Dr Andrew Mills himself. The error is repeated in the Scoping Report, and was corrected by Haworth with Stanbury VC in their response (PINS Scoping Opinion adopted by Secretary of State 10 October 2025 p 326). This correction went unread by CWFL and the error thus persisted into the PPL HRA of the PEIR, written by “AJM”, who is Dr Mills. The choice of access over the Wague and Wage of Crow Hill, the most unstable bog in England, was therefore made while the “Peat Lead” was telling the engineer Donald Mackay that the bog bursts happened in 1824. In fact there have been at least eight bog bursts, at three different times (1824, 1902?, 1989) and these are documented in Dr Mills’ own references, which he did not read, with a photo of the 1989 burst appearing in the Mills PhD thesis, mislocated to North Yorkshire. CWFL were thus misleading Natural England about bog bursts as early as 10 June 2025. CWFL were sent a formal notification of their bog burst errors by WTRG on 18 June 2026 and there is no evidence that CWFL have informed Natural England, the Environment Agency and Yorkshire Water about the errors.
Only the legal action by WTRG and Haworth with Stanbury is likely to correct this dangerous incompetence before DCO submission. The Mills error has painted the design into a corner on Crow Hill.
On 19 September the CWF lawyers Pinsent Masons made a first response to the Aggregates claim of Colne TC and Laneshaw Bridge PC that they have not been consulted on a coherent transport assessment, nor had a reasonable worst-case scenario for the aggregate deliveries past Richard Bannister’s Boundary Mill. Our legal team reckon the letter will have cost £20,000 and… they don’t want me to say anything else as the legal exchanges continue. 19 September is the current latest “proof of life” for CWFL as a going concern, as Pinsent Masons must reckon there is still somebody at home to settle their invoices. If I were lawyering for CWFL now, I’d want the money up front.
On 20 September and in print on 27 September, the Telegraph published a photograph of four dangerous subversives and a wire-haired dachshund on the cover of the Sunday section. The long article on Walshaw Moor was written by Robert White who is a financial reporter. Mr White and his photographer Lorne Campbell got right round the moor (Colne, Stanbury, Haworth, Hebden Bridge) and spoke to councillors, campaigners and Rebecca Yorke at the Brontë Parsonage. Cavendish Consulting even gave him a quote about Wuthering Heights.
Do not approach these dangerous subversives. Teddy, Ali West, Nick and Lydia MacKinnon and Pebbles. Lorne Campbell/TelegraphThe Telegraph published Calderdale Council’s pessimistic statement.
“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.”
Thanks to Deep Stoat, we were able to give Mr White Natural England’s response, which appears in the Telegraph as:
“Natural England also concluded the ecological issues posed by the wind farm were “likely to be insurmountable”, according to documents released under freedom of information laws.
The conservation body argued that the “irreplaceable” blanket bog and “internationally important” bird habitats could not be recreated or compensated for elsewhere, undermining the project’s compliance with habitat protection laws.”
What we liked best (and my father-in-law noticed its significance) was that the article concluded with this sentence:
“Al Gihaz Holding was contacted for comment.”
It was good that the Telegraph contacted Mustapha Hajjar in Riyadh, an example of the once-vivid phrase: “Don’t ask the monkey; speak to the organ-grinder.” Hajjar cannot expect his comedy subsidiary to provide much protection now. The WTRG bog burst letter will cost him £100,000 just for the first reply, because somebody at Pinsent Masons has to get an understanding of thixotropic peat at least as good as Haworth with Stanbury Parish Council’s. The itemised bill will include “Purchase of two copies of Charlotte Brontë at the Anthropocene by Shawna Ross £100.” “Reading time by specialised counsel of 326 pages of post-doctoral text £32,600.” Of course, they could save fifty quid by using the copy Dr Mills showed me at Hebden Bridge. They will find my thumb-print on page 68 where I had to point out the 1989 bog burst. Pinsent Masons must keep in mind that Ross, 2020 was Dr Mills’ own reference and we know for certain that he did not read it, so Pinsent Masons better had. There will be a test.
Shawna Ross, in College Station, Texas, is delighted by the sudden importance of her rather hard book. By getting her hands dirty in multiple disciplines, she understood the bog bursts on Crow Hill better than the world’s leading expert on peat landslides. Dr Mills cited the 21 pages of Dykes & Warburton 2007 seven times, but Professor Ross noticed its photograph of the Crow Hill bog burst.
On 17 September the Peatland Alliance published the Environment Agency’s replies https://saverestorewalshawmoor.wordpress.com/2026/09/17/environment-agency-has-not-approved-windfarms-flood-model-or-commented-on-flood-risk-to-hebden-bridge/ to questions they had asked. In summary:
The EA undertook an initial review of CWFL’s baseline flood risk model in April 2026. The EA were not convinced that the infiltration parameters used in the applicant’s baseline hydraulic model are fully representative of upland peatland conditions. They asked CWFL to review the selected parameters for upland peatland conditions and provide a clearer evidence base to justify their use, and update where necessary.
CWFL has not yet submitted a “with development” model to show the CEP’s impact on flood risk, including any changes to blanket bog topography during the construction, operation or decommissioning phases of the proposed development.
The EA have not approved CWFL’s draft direct rainfall hydraulic model and CWFL has not yet responded to the comments the EA raised during the April 2026 review.
The EA comments included the need for CWFL to validate the model by simulating a historical flood event, such as the 2015 Boxing Day flood, and then comparing its modelled hydrograph against the observed hydrograph recorded at the Nutclough gauging station on Hebden Water.
The EA cannot currently comment on any flood risk implications associated with CEP, as CWFL has not provided any detailed development plans or assessments of flood risk.
On 18 September Friends of Brontë Country sent a legal letter-before-action contesting the unscoped extension of the red line to encompass Crow Hill. In their FAQs, CWFL had stated that this western access had less impact on heritage features than the eastern access via Halifax. FoBC observe that this cannot be so, since the western access includes an extra wedge of moor from Crow Hill to Wuthering Heights that is perhaps the most sensitive Brontë receptor after the Grade I listed Parsonage itself. Somebody at Pinsent Masons now has to get upwind of FoBC, one of whose directors is a leading Brontë authority. If they ask their retained consultants, they will get Wessex Archaeology mumbling about lithic scatters.
On 19 September WTRG formally notified the Environment Agency of the hydrological deficiencies in the PPLHRA, including the false claim that the bog burst activity on Crow Hill took place “two hundred years ago.”
On 23 September Natural England acknowledged receipt of the WTRG report on the PEIR PPLHRA, the peat landslide risk assessment that we shredded in these blogs.
On 24 September Worldwide Renewable Energy Global, Christopher ‘440 Kelvin-Volts’ Wilson’s company, sprang back to life with a new website. Wilson had applied for voluntary strike-off on 7 April 2026 but had a change of heart on 9 April and on 14 August 2026 published the 2025 accounts, in which there is still no sign of Mustapha Hajjar’s £114,015, given to WWRE in 2021, that might have funded some effective due diligence.
The WWRE site is mainly “teasers”, short accounts of proposals that you might like to invest in (40 MW wind farm near Skipton with bird work started; 99.99 MW BESS in Lancashire). There is a 20 MW wind farm in the Caribbean, for WWRE are not only worldwide but also global.
What does not appear anywhere on the website (which feels like a second-hand narrowboat brokerage) is WWRE’s greatest achievement: “240 MW DCO-ready wind farm in West Yorkshire”.
September paints a picture of an incompetent proposal in crisis. It took until September for CWFL to publish the minutes of the Parish Forum that met on 29 June, which had some green corrections about the aggregates, which the Pell Frischmann traffic consultants had been hazy about. The minutes conclude:
“Cllr Kimber asked about the date and agenda for the next meeting. Kevin Whitmore set out the timeline, noting that the next meeting should take place when a design update can be provided, likely in September.”
The proposal as designed is unbuildable, so Kevin Whitmore (Maintaining Stakeholder Confidence!) will not be providing a viable design update “likely in September”. CWFL have to start again, avoiding Crow Hill, and they have to come clean about their PPLHRA to Natural England and the Environment Agency.Haworth with Stanbury VC, who naturally lead the charge on bog bursts, have been told the next meeting “may be in October”.
Natural England advice on ornithology
In this peat slide of fresh material, let’s have a look at the NE response to Chapter 9: Ornithology, one of many sections with a red flag.
Red-flagged NE response on ornithology 10 June 2026. NE
“NE49 Chapter 9 – Ornithology. General.
Natural England advises that the scale and context of the Proposed Development in relation to ornithological receptors is of particular concern.
The evidence presented clearly identifies that the site forms part of a high-quality upland complex of international importance, supporting a wide range of upland breeding and non-breeding bird species.”
The PEIR has poor, non-existent, or false baseline evidence on flooding, traffic, bog bursts and Brontë heritage. Had the baselines in these aspects been evidenced to the adequate standard of the ornithology chapter, it would be even clearer how much trouble the proposal is in. Algihaz has been prevented by the incompetence of their own consultants from assessing the risk profile of their sunk and future investments. On the baselines provided, it is impossible for statutory consultees or Algihaz to give intelligent consideration to aspects of the proposal which CWFL themselves describe as “key”. Mustapha Hajjar can just ask Christopher Wilson for an update, but the only way for the rest of us to extract the relevant facts is bylegal action, which WTRG is supporting on three fronts.
For ornithology, the evidence baseline (although imperfect, as NE observe) “clearly identifies” what is at stake, and Natural England are able to give Algihaz brutaladvice, a flattened can that their runaway consultants cannot kick further down the street.
“The study area represents a significant proportion of the wider SPA (10.72%) and supports a diverse assemblage including many of the UK’s most threatened and priority species. It provides important supporting habitat that contributes to the extent, distribution and availability of suitable breeding habitat within the SPA. Loss of this area would therefore undermine the site’s ability to meet its conservation objectives by reducing its capacity to support the SPA population.”
The “wider SPA” is the South Pennine SPA Phase 1 and Phase 2, part of the anchor of our response to the Kunming-Montreal Global Biodiversity Framework for 2030.
“Recreating an area of this scale and ecological complexity, capable of supporting comparable diversity and densities of upland breeding birds, is not considered achievable within any reasonable timescale. There are also existing Environment Act targets on reducing the risk of species extinction. Given the nature of the habitat and the species it supports, we do not expect it will be possible to agree mitigation and compensatory measures that ensure the coherence of the UK national European Site network is protected.”
The PEIR had stated hopefully:
“The PEIR assumes that measures will be developed to mitigate and compensate for the loss of habitats through the identification of areas for habitat enhancement and/or restoration. Given the sensitive nature of habitats within the study area, the delivery of such measures will require a bespoke strategy to be developed in consultation with relevant consultees.”
It is the result of this “consultation with relevant consultees” that has been by brutally noted by Natural England. Deep Stoat observes that the language of …
“we do not expect it will be possible to agree mitigation and compensatory measures that ensure the coherence of the UK national European Site network is protected”
…is the same language used in the third of three tests (No alternatives, Imperative reasons of overriding public interest, Secured compensati