Guest blog – Walshaw Turbine 23 by Nick Mackinnon

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 

Turbine 23 Black Clough Butts SD 97875 34021 ///collide.ribcage.section

This blog was sent for comment on 24 November 2025 to the CWF Ltd auditor Fozia Gulzar, to CWF Ltd at their preferred email address, Dr Ghazi Osman at the company address, and Marc Davies at Logika. The blog has been corrected since first publication to acknowledge that Dr Osman may after all be contactable at the company address. 

20 November 2025 Snow fell yesterday on Walshaw Moor. The natural place for T23 is up on the plateau where the spine road would go. Instead, a spur leads quite steeply down to a 21% gradient site, in a misconceived attempt to destroy less peat. Christian Egal had some reason for his very steep site choice, but we don’t know what it was, and 50m away is flatter ground. The spur will accelerate storm run-off from the plateau into Black Clough and the reservoirs but not so egregiously as the spurs to T12 and T13. The obvious problem is that T23 is too close to T21, which has already been pushed sideways so that it is much too close to the Pennine Way. At the Oxenhope Public Exhibition, I was pointing all this out to lead consultant Alison Sidgwick when Sue Birnie bustled over to deal with the troublemaker.

NM: “I was asking Alison if public and construction worker safety had been primary design criteria in the layout you have published.“

SB: “What do you mean?“

NM: “Public safety and construction worker safety being paramount seems an obvious requirement of any careful design process and that point of view, commonly held, does not need to be explained.”

SB: “Give an example of public safety.“

NM: “Turbine 21 is less than 60 metres from the Pennine Way. The blades will overhang the footpath and represent a blade throw and ice throw threat to the walkers using the path.  General Electric recommend a setback of “topple height plus 10%” relative to public areas and this would be 220 metres, not less than 60 metres.“

SB: “Why is that a matter of public safety?“

NM: “It would surely be considered as a matter of safety in a careful layout design process.“

SB: “It isn’t unsafe. It is you who say it is unsafe. It is a matter of opinion.“

NM: “Do you seriously think that is how the Planning Inspectorate will see it?“

Their incompetent layout, T21 and all, was sent to the Planning Inspectorate and the statutory consultees. Natural England may be frightened by the nature-bashing rhetoric of Sir Keir Starmer and Rachel Reeves, but with somebody as staunch as Tony Juniper in the trenches, they should be able to defend the irreplaceable habitats and flourishing red-listed birds of Walshaw Moor, because the developers are so incompetent. This is not a lucky coincidence, but an inevitability: competent developers (Vattenfall, SSE …) would not be trying to develop a site as unsuitable as Walshaw Moor.

T21 gives a clear illustration of the carelessness of Christian Egal’s layout with regard to the national trail, which took Tom Stephenson a lifetime to create, and is an institution of our democracy, representing a compromise between the feudal land-owning pattern and a British people who are no longer serfs. As Natural England observe:

“One turbine in particular (T21) appears from available mapping to be immediately adjacent to the Pennine Way at SD 97638 33419 and should, for safety reasons, be sited further away from the trail i.e. at least fall-over distance plus 10%.“

I tried to tell them, and now they know. Sue Birnie was the applicant for Stornoway Wind Farm and a bone-dry joke from a Free Church sermon is still much enjoyed by the people of Lewis and the Calvinist diaspora, including, no doubt, our friend Donald ‘Transparent’ Mackay.

“And the fornicators will be led by demons to the cauldrons of boiling brimstone and they will cry, ‘Faither! Faither! We didnae ken!’ And the Lord will reply, ‘Well. Ye ken noo!”

Peat, terrain gradients, the Pennine Way and Wuthering Heights combine to create maximum nonsense in the T21-T24 cluster (“They’re close together” murmured Donald Mackay.) T24 will be the only survivor once an engineer has looked at the layout, and it will still have to be pulled back uphill off the 24% gradient on Nouch Brink. T23 and T24 illustrate the fundamental misconception that the turbines do less damage if they are pushed over the edges. They do more damage and increase flood risk. Scout Moor (where Peel Cubico were the developers) shows what a competent layout on Pennine terrain looks like.

The dog and I head south for T23 from where the Pennine Way crosses the watershed. The peat is cushiony at first and we make fast progress despite the snow, until the ground disintegrates in the clough, and I have a thigh deep plunge into an iced grough. The Airedale terrier understands this terrain and has asked to be off the lead to improve his chances of survival.  He finds the mown path to the grouse butts and sets off down it while I fiddle with the OS App. I find him waiting at the site. The peat depth map suggests a depth in the low 100s, but the avalanche probe finds 175 cm, the yellow band.  If Christian Egal’s layout design meeting of 21 February 2025 had any aim, it was to get the turbine sites off the yellow-depth peat, but it failed at T23. The problem for CWF Ltd is that the peat damage is mainly caused by the tracks, but moving the turbine sites onto very steep ground also means more destruction in levelling the platform for the crane hardstanding and the component laydowns and more damage from the spurs.

T23 has the deepest peat in CEP, equal with T3 and T4, themselves  the two most destructive turbines in the whole layout. The Hokey-Cokey in the T21-24 cluster from CWF to CEP is shown below. Remember that CWF was correctly designed for aerodynamics by Natural Power (no overlaps between the spacing rectangles) and was thus a valid first iteration of a wind farm layout, because they always start with the wind. Nonetheless, Donald Mackay described CWF as “worse than useless” leaving even that gifted communicator short of words to describe CEP.

CEP is not a second iteration of CWF, and it isn’t a first iteration of itself either. As the statutory consultees universally observe, we need to see a genuine wind farm layout before we can make proper assessments of CEP. At Oxenhope, Tom Andrews of Cavendish Consulting told John Page that a “high twenties” layout would appear in November, but that was before the statutory consultees laid out the flooding and Brontë Country problems which on their own will force a “low to high teens” layout, depending on how much extra flood risk for Hebden Bridge is allowed by the EA. My money is on “zero extra flood risk” and that leaves a pointless 90 MW wind farm that will not be permitted on the SPA/SAC.

The dog and I head back up the line of the access spur to the watershed spine. This way is longer but much easier because the peat on Walshaw plateau is completely unspoiled. The over-wintering golden plovers heard a year ago are getting through another Walshaw winter and peep quietly as we slip by. Walshaw Moor is the best breeding ground for golden plovers in all of Scotland and the north of England. If Calderdale Energy Park is built, they are doomed.

Nobody has ever designed a wind farm the way Christian Egal and his team did on 21 February 2025, The Day of the Eagle. He had to forget the 65-turbine CWF and start again with correct spacing for the Vestas 162 7.2 MW turbines and a flooding hierarchy if he was to create a genuine first iteration. Instead, he did the Hokey-Cokey with the “worse than useless” but correctly spaced CWF, with its Vestas 120 4.8 MW turbines. Now the Environment Agency have told him to start again with the terrain graded into High, Medium and Low flood risk, and Natural England have insisted on the force of the Pennine Way. His self-imposed constraint is to keep the turbines off the yellow peat, and Natural England won’t let him go back on that. He has some awareness of Wuthering Heights, and the statutory consultees have told him whom to ask. These pressures add up.

It was always going to be difficult to write a report that was more incompetent than the layout it was scoping, but Logika succeeded, and the evidence is detailed in these blogs and spread all over the Planning Inspectorate website. A confident consultancy would have told CWF Ltd to give them a properly designed layout first. Logika simply accepted the nonsense, submitted to a schedule that meant their work would be hopelessly rushed, and used prima facie A.I. to cut corners. Then Christian Egal sent Revision 00 unchecked, and surely unread, to the Planning Inspectorate. Expert consultants are thinking, incredulously, “He sent Revision 00!” Had anyone read it, they would at least have picked up the map errors and the River Kelvin. Lydia MacKinnon and John Page found those minutes after opening the 577-page document. There were so many road numbering errors that it took Ali West a day to pin them down.
I have challenged Marc Davies, Growth Director of Logika, who works out of the Leeds office and should know the Walshaw terrain, to show me any other Scoping Report for a wind farm that has even 5% of the crass errors (road numbers, A.I. hallucination, maps of the wrong layout, hydrology features misnamed) found in Logika’s for Calderdale Energy Park. These crass errors light up a more comprehensive incompetence, caused by Logika’s inexperience onshore and the absurd rush. The occasional good maps in the report are by sub-contractors in experienced firms like SLR.

Christian Egal would do best to dispense with Logika who evidently lack the capacity, write off the failed work and start again from scorched earth. He can’t go back to Natural Power because Donald Mackay called their layout “worse than useless” while James Lightbody called CWF “some wind farm near Halifax”. The top consultancy firms will naturally not want to be the Walshaw Moor Rishi Sunak following Natural Power’s Boris Johnson and Logika’s Liz Truss.

Reputable onshore consultancies like SLR have better things to do than bail out Christian Egal’s drowning wind farm on Walshaw Moor. Their reputations mean they attract work from established developers like Vattenfall and SSE who have no interest in a site as poor and complex as Walshaw Moor. To be clear, I respect the correct and illuminating work of Natural Power on Walshaw Moor and find the switch to Logika to be indicative of panic at CWF Ltd.

This is a stern assessment, but anyone can check at a glance the relative onshore competence of Christian Egal’s two (so far) lead consultancies by comparing the infantile hydrology map produced by Logika with the Natural Power one.

If we ever see a properly designed layout on Walshaw Moor, there might be 90-150 MW left, depending on how much extra flood risk to Hebden Bridge the Environment Agency permits. With a realistic layout, we can then start to think about the international designations, the Defra-DESNZ Joint Report “Unlocking Benefits” and the Kunming-Montreal framework, which the UK claims to have led.

If there was plenty of patient shareholder money, and patient shareholder confidence in CWF Ltd as developers and Walshaw Moor as a site, the failed Scoping Report Revision 00 would be withdrawn, and a properly designed layout would be given to the statutory consultees. The fatal impatience is because confidence is draining away.

Financially, what we see is a naive attempt to get 312 MW past Calderdale Council that cost about £3 million, followed by the sunk-cost fallacy that the money wasted on CWF might be recovered by CEP. To keep impatient investors onside, CEP was designed and launched in absurd haste, using the inexperienced Logika to write a Scoping Report which has simply alerted the statutory consultees and Planning Inspectorate to flaky developers and gauche consultants pushing a poor site. Consultants Birnie and Mackay are not gauche. Why were they not given the Scoping Report to proofread? Was it because Christian Egal did not want to know how bad it was? Is that why he submitted Revision 00?

If Natural England or the Environment Agency ever feel leant on by the government in the case of Calderdale Energy Park, they can simply point to the incompetence of the Scoping Report. It is their job to keep this nonsense at arm’s length from DESNZ because it corrupts confidence in Net Zero and onshore wind if a demonstrably hapless developer gets as far as making an application for a giant wind farm on such a bad site as Walshaw Moor.

CWF Ltd are now about £8 million underwater, and all they have to show for it is a giant billboard hosted by the Planning Inspectorate detailing the obvious complexities of the site, the long-standing incompetence of CWF Ltd and the onshore gaucheness of Logika. They need a load more money to pay for an Environmental Impact Assessment that must be attempted on the rubble of their Scoping Report.

We think the shareholders cannot have a clear picture, so we now write to them, fortnightly.

The auditor is Fozia Gulzar of FGA, based in Croydon. I wrote the following letter (27 October 2025) informing her of the possibility that the shareholders will lose all their money and might look for insured people to sue, like FGA.

Dear Fozia Gulzar,

You were the statutory auditor for the Calderdale Wind Farm Ltd (CWFL) 2024 accounts and we believe you will be the auditor for the 2025 accounts.

We believe that CWFL may now be in danger of not being a going concern because the size of the wind farm “Calderdale Energy Park” they can build on the land they are acquiring is too small to carry its connection costs and meet regulatory constraints. The extent of the problem has become clear following the highly negative response of the Statutory Consultees to the CEP Scoping Report, and particularly the Environment Agency.

The Executive Chairman Christopher Wilson has previously said (Hilltop Parishes meeting December 2023) that CWF is not economic below 200 MW.  We believe the size range of the windfarm, given constraints pointed out by the Statutory Consultees in response to the CEP Scoping Report, is now likely to be 90-150 MW, but that the shareholders may still believe that 200-302 MW is realistic. If the range is indeed 90-150 MW or indeed much less than 200 MW, it is unlikely that the wind farm will be built and the shareholders will lose all their investment. This was always a possibility, of course, but if the limits are now 90-150 MW, then a possibility becomes almost a certainty, and this fact should be made clear to the shareholders by the management.

Our research is ongoing and published fortnightly.  The forthcoming edition of Walshaw Turbines (enclosed) mentions (for the first time) your name as statutory auditor, and we are sending you the edition for your comments. We say that because you are insured, you might be a target for the shareholders if they decide to take legal action against any entities or individuals that led them to believe that 200 MW was realistic. We do not ourselves believe that this would be likely for you on the basis of your audit of the 2024 accounts, but that it will become more likely in future as evidence emerges that CEP must be much smaller than 302 MW. We believe you, and your indemnity insurers, should be informed of this possibility.

We send our editions fortnightly  to the various concerned entities (in this edition the two Members of Parliament, the Project Director Christian Egal, the Planning Inspectorate and the Secretary of State represented by the Planning Inspectorate,  the Environment Agency, Natural England, the consultants Logika, and you as auditor) by email on the Monday before the Friday publication dates. We can only correspond with Dr Ghazi Osman, the Director representing the shareholders, who resigned as PSC on 19 May 2025 by post c/o Enshore. As you know, CWF Ltd has no human PSC and no entity PSC based in the UK. The PSC is Energy Horizon Ii Investment Company in Riyadh. “Ii” is a literal rendering of the entry at Companies House but II or ii may be intended. We do not know whether the control of CWF Ltd meets the terms of the 2006 Companies Act following the resignation of Dr Osman as PSC on 19 May 2025. You will be clear on that point as Statutory Auditor.

We shall send all subsequent editions that may concern you for your comment, but if they go by post your comments (if you have any) are likely to be retrospective. We should be delighted to correspond with you by email, so that with the other entities, you have a chance to comment on our research before publication.

Yours faithfully,

Nick MacKinnon

Editor Walshaw Turbines Research Group

This letter was signed for by Fozia Gulzar. I sent a copy of the letter to Dr Osman, the sole director of CWF Ltd, who represents the shareholders. Abby, of the Companies House compliance department, told me to send all legal letters to the directors at the correspondence address, shown below.

I routinely run these blogs past anyone mentioned in them on the Monday before publication on the following Friday, and the last blog got this reply from CWF Ltd on 11 November 2025.

Dear Mr Mackinnon,

We note your recent correspondence to members of the Calderdale Energy Park project team. To ensure communications are managed appropriately, we ask that you no longer contact individual members of the project team directly. All enquiries should be directed to the project email: info@calderdaleenergypark.co.uk.

Please follow this approach for all future communications.

Kind regards,
The Calderdale Energy Park Team

For once, I was able to reply to this email without being given the automatic reply that the Non-statutory Consultation is closed. I told them that since Fozia Gulzar and Logika are not employees of CWF Ltd (their accounts state correctly that CWF Ltd has zero employees) it would be improper to funnel communications inviting them to comment on what was going to be written about them via CWF Ltd. If the independent addressees didn’t want the right to comment in advance they should write to me directly.

A couple of days later I tried the info@CEP address again and got the usual automatic reply below, so I must continue to try to reach them by the indirect channels at Cavendish Consulting, Logika, and FGA, and at their registered company address in Blyth.

Calderdale Energy Park Info Thu 20 Nov, 18:13

Thank you for your email. The non-statutory consultation on the Calderdale Energy Park proposals has now closed.

We’re now reviewing all comments received as we continue to develop the proposals ahead of a formal statutory consultation in the coming months.

Thank you again for your interest in Calderdale Energy Park.

The Calderdale Energy Park Team

We shall continue the hunt for Dr Osman in a fortnight.

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This is the 49th in a series of guest blogs originally based on the 65 wind turbines which Richard Bannister planned to have erected on Walshaw Moor. Turbines  4CEP, 5, 6, 6CEP, 8, 8CEP, 9, 11, 13CEP, 13, 14CEP, 14, 16, 17, 18CEP, 20CEP, 21, 21CEP, 22CEP, 25, 25CEP, 27, 29CEP, 31, 32, 33, 33CEP, 34, 34CEP, 35, 36, 37, 38, 40, 42, 42CEP, 43, 44, 47, 53, 54, 56, 57, 58, 60, 62, 64 and 65 have already been described.

The developers have canned their original 65 wind turbines, quite possibly in response to the public humiliation of having their so-called ‘plan’ publicly shown to be damaging, irrational and probably unlawful. They have come back with a plan for 42 wind turbines and the amazing Nick MacKinnon and friends have regrouped and set off on a new tack too. The series continues.

To see all the blogs – click here.

 

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