Malcolm raises concerns about the biomass plant proposed in Leith
Letter about the proposed Biomass Plant at Imperial Dock, Leith To The Scottish Government Energy Consents Unit
Energy Consents Unit
5 Atlantic Quay
150 Broomielaw
GLASGOW
G2 8LU


Dear Sir or Madam,

OBJECTION LETTER-MALCOLM CHISHOLM MSP


I object very strongly to the application for a biomass plant at Leith Docks by Forth Energy. In objecting I am not just speaking for myself but for literally hundreds of constituents who have raised concerns and objections about the proposal. Indeed it is fair to say that nobody has contacted me in support of the proposal so I am in no doubt that the proposal is overwhelmingly opposed by the community in Leith and further afield. There are a large number of reasons why that is the case. I shall outline what may be regarded as local objections in relation to negative impacts on local residents and the local environment. I shall then go on to argue that the proposal is not environmentally beneficial in relation to wider climate change objectives.

A fundamental objection, quite apart from everything else, is that the proposed plant is very close to an extensive amount of residential accommodation. Even if the plant was a good idea, which it is not, this in itself would rule out this particular location. The proposal is also contrary to the local plan and the Leith Docks Masterplan, not just in relation to the specific site but also more generally. The particular location is designated for residential use and green space and clearly that is being overturned. More fundamentally however, the proposal is completely at odds with the regeneration goals being pursued for the wider area. Residential, leisure, retail and tourism objectives are all fundamental for the Leith Waterfront and all are put at risk by this proposal. It will not contribute towards a high quality, sustainable living or working environment, as required by Policy Des 1. It will certainly have a negative impact on the development of residential housing which is, incidentally, important for the tram business case. It will also create a less attractive environment for the tourism which is being encouraged by Tax Increment Finance and other investment. It is contrary to Policy Des 9 which requires developments on the edge of the water to provide an attractive frontage to the water and fails to meet any of the criteria for tall buildings in Policy Des10 . The 120 metre tall chimney will be an eyesore that also destroys the view corridors which were identified as a key element in the Leith Docks Masterplan. The Council has also recently promised World Heritage experts much stricter guidelines to curb tall buildings which threaten to damage the City’s skyline. New guidelines for the Waterfront include a presumption against new buildings more than six storeys high. The proposed structure also self evidently fails to preserve or enhance the special character or appearance of a conservation area, as required by Policy Env 5. The original Masterplan referred to 15,900 houses and 11,600 direct jobs resulting from development of the Leith Waterfront. When some people refer to some jobs being created by the Biomass plant we should remember how many jobs will not materialise as the inevitable knock on effect of such a bad neighbour development.

There are many concerns about the transportation aspects of the proposal. Much of the biomass material will be brought in by ship, about which more in a moment, but there will also be a very significant number of HGV movements involving biomass material or ash. 64 a day are mentioned by Forth Energy which amounts to 20,000 or so heavy lorry trips a year. Air quality on many of the arterial routes in and around Leith is already poor, about which more later also, and there are already considerable concerns about HGV movements in Leith for environmental and other reasons. For example, those working in the King’s Wark on the Shore have reported that passing lorries already cause serious vibrations and result in plaster coming off the wall on a not irregular basis. Problems with HGV movements have been a longstanding issue in the area but there has been a further heavy surge recently following the leasing by Forth Energy to European Metal Recycling of the site next to the casino. It would be quite intolerable to have further extensive lorry movements on top of the existing serious problem, not least because of the air quality issues which are discussed below.

Under transportation there should also be mention of the proposed ship movements over thousands of miles. This in itself throws a big question mark over the climate change credentials of the proposal. It is the stated objective to procure as much of the fuel as is practicable from indigenous suppliers, taking into account both economic and environmental concerns. It is recognised however that, with the limited availability of UK sourced biomass, the majority of the fuel will be imported from overseas. The logistics involved in the transportation of biomass from harvest to incineration will undoubtedly have an effect on the level of carbon released into the atmosphere. This will be dependent on the location of the stock and the distance it must travel. We do not have details about particular geographic regions or transport links but we do have a general idea of the countries that Forth Energy has in mind and the distances involved are large. The assumption made by Forth Energy of 6g of CO2 per km tonne for sea transport is bad enough but is also somewhat heroic. This figure only seems to be reached by large deep sea tankers but it is doubtful if any of the ships capable of entering Leith Docks would achieve much less that 11 or 12 g per Km tonne. 16 is in fact the mean for coastal shipping. Ship transportation is certainly not particularly environmentally friendly and it has astonished many people that Forth Energy is seriously suggesting the transportation of the bulk of its biomass supplies from countries which for the most part are thousands of miles away.

Other local environmental concerns relate to noise and air quality. Some of that in each case relates to the transportation issues discussed above. There is also the operation of the plant itself which will cause noise on a 24 hour basis, particularly during construction but also thereafter. This would be bad enough but the consequences for air quality are even more disturbing. Small particulate matter resulting from biomass burning, particularly PM2.5, could lead to serious health problems. Nitrogen dioxide is linked to respiratory disease and dioxins, which would arise through the use of recovered biomass, are also a threat to human health. There will also be large quantities of ash requiring sealed containers and any fugitive emissions would pose a health risk. All of this is contrary to Policy Env18 which requires that a development should have no adverse effect for health, the environment and amenity. These threats are particularly serious in Leith since it is already an Air Quality Management Zone where air pollutants already exceed or are forecast to exceed EU objectives. For example, at most of the properties close to the access roads the annual mean NO2 concentrations in 2015 are forecast to exceed acceptable levels. Some argue that further increases in NO2 and other pollutants will not be massive, which is itself contentious. Even if that were the case however, this area simply cannot afford to have any further increase in air pollution. NHS Tayside has expressed concern about air quality and specific pollutants arising from the proposed biomass plant in Dundee. The same arguments apply here but even more strongly.

Turning to wider climate change and energy policy issues, it would seem that the proposal is contrary to the Scottish Government’s Renewable Heat Strategy and also its Draft Electricity Generation Policy which states that “large scale biomass developments which do not maximise heat may displace supply from our priority of delivering our heat target”. Proposals to use heat from the plant are very poorly developed. Documentation provided in the planning stages of the development proposed that the plant would run throughout its lifespan at an efficiency level of 80-90 per cent on the basis of it being a combined heat and power system. Meetings with Forth Energy have highlighted however that the proposals are being submitted without an adequate investigation into the potential efficacy of a network for heat redistribution. If the plant were to run on a basis of electricity production alone the predicted efficiency would be just 30 per cent. On top of the cost of plant construction, Forth Energy’s proposals outline additional costs relating to grid expansion and the installation of CHP systems. This amounts to £1 million per kilometre of expansion and £3000 per dwelling. This would require massive public subsidy from the Scottish Government on top of the massive public subsidy which will already come from the UK Government for the electricity generation. Very little detailed work has been done on the heat issue and it therefore seems likely that the plant will take even longer to deal with the massive carbon debt it will build up , as described below.

Last year’s study into the sustainability of biomass conducted by the Manomet Centre has been criticised by Forth Energy but Mary Booth, writing for the Clean Air Task Force, argues that it actually underestimates the Greenhouse Gas problems caused by biomass which in the short run emits more carbon than coal. This can of course be recouped to some extent by replanting the right kind of trees but Forth Energy will have no control over whether that happens or not. None of the reputable Environmental Groups Such as Friends of the Earth or Greener Leith believe Forth Energy’s claim that the carbon debt will be paid off over twenty five years or that there will be 90 per cent carbon savings over coal over the same period. The time it takes to pay off the carbon debt will be affected by the life cycle of the wood, the type of energy generated, the type of fossil fuel being displaced and the management of relevant forests. In the case of the Leith development, the method of combustion will most likely not utilise the heat bi-product and will displace a fossil fuel technology that according to the Environment Agency is most likely to be redundant by 2030. In addition it may displace to some extent many clean energy sources in the renewable sector such as tidal energy and wind. So far as the management of the forest or indeed the short rotation coppice crops that will help to fuel the Leith plant are concerned, the descriptions provided in the documents of Forth Energy lack explanation of the subtleties of crop management , maintenance of soil quality and regional biodiversity that are of primary importance to the environmental sustainability of biomass.

Much more could be said about the negative environmental consequences of large scale biomass for climate change and deforestation. I hope these factors will be taken into account alongside the many grounds for local objection outlined earlier in this submission. In combination these powerful and manifold objections make the case against a biomass plant in Leith both unanswerable and overwhelming.

Yours sincerely,

MALCOLM CHISHOLM
March 2011