Name and address of sender at bottom of letter
Email to: leithbiomass@scotland.gsi.gov.uk
Mail to:
Lesley McNeil, The Scottish Government
Energy Consents and Deployment Unit
Energy Directorate, Renewable Energy Division
4th Floor, 5 Atlantic Quay
150 Broomielaw
Glasgow G2 8LU
February 2011
Dear Ms McNeil
Proposed Biomass ‘Renewable Energy’ Plant at Leith Docks, Edinburgh
Application by Forth Energy under Section 36 of the Electricity Act 1989
Personal Statement: I strongly support all the points below.
I wish to express my deep concern and to lodge an objection to the above application by Forth Energy. I believe
the application to build a biomass power station in Leith, Edinburgh should be rejected due to: the
inappropriately huge size of the proposed plan; its location in an urban and residential environment; conflict with
existing plans for the area and indeed with national policy; possible health risks from emissions and pollution
from increased traffic; and the nature of biomass in general as an inefficient yet high carbon fuel, when only the
generated electricity is used and the heat is wasted. Specifically, my objections to the Leith biomass proposal
are as follows:1. Wrong Place
The proposed site is within the City of Edinburgh, a World Heritage site and a popular tourist destination. It is
very close to densely populated residential areas, to a prime shopping site (Ocean Terminal) and to leisure and
tourist facilities (eg. bars & restaurants on the Shore, hotels, etc.). This is completely at odds with the Edinburgh
City Local Plan and indeed with Forth Ports’ own ‘Leith Docks Masterplan’ both of which designate the area in
question primarily for leisure and green spaces. Based on evidence from other sites around the world, I am
concerned that the proposed biomass incinerator would be a ‘bad neighbour’ for both residents and businesses
in the area, bringing with it (as well as increased traffic and pollution, see below), an increase in noise, vibration,
dust, lights, and fire hazards. This is quite simply the wrong place for a massive industrial construction of this
type.
2. Wrong size - Visual Impact
It is clear that the enormous scale of the proposed biomass incinerator would completely dominate the Leith
area and indeed many parts of Edinburgh as a whole. While creative architecture and design may mitigate to
some extent the visual effect of industrial buildings, the sheer size of this one means that it will always stand out
as harshly dissonant. In addition to the importance of Leith’s historical buildings, the Leith docks area has been
regenerated in recent years with the creation of housing, leisure & retail facilities, offices, restaurants, hotels and
indeed international tourist attractions such as the Royal Yacht Britannia. More is planned – the Big Wheel etc.
Permitting the construction of this huge incinerator on the doorstep would negate all that and set the area and
community back decades.
3. Emissions - Damaging Effect on Air Quality
A key concern is that of risk to health. Emissions from burning biomass, in particular small (PM 2.5, PM10)
particulate matter, are well known to cause serious health problems. Even small increases in irritant pollutant
gases, including nitrogen dioxide, can cause respiratory disease in otherwise healthy people and can be
potentially deadly to those already vulnerable, which includes children and old people. There are a number of
schools and nurseries within a mile of the proposed site. Even small amounts of dioxins and heavy metals
(possible emissions from burning chemically treated wood) can cause cancer and birth defects. This is an
unacceptable health risk to the local population.
4. Increased Traffic - Congestion and Pollution
Although a large percentage of fuel is expected to come in by sea, there will inevitably be a significant increase
in HGV movements locally, through residential and commercial areas and close to schools and public areas, to
bring in supplementary fuel, and to remove ash. Forth Energy’s application glosses lightly over (and probably
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underestimates) these but even with their own figures, some elementary arithmetic shows a tally of around
20,000 heavy lorry trips per year. This brings with it an unacceptable increase in traffic congestion in an already
congested urban area, along with a guaranteed increase in atmospheric pollution and carbon emissions. This is
likely to get worse over time, as the issue of fuel security and sustainability arises, making it more likely that
fuels of various types may be sourced more locally. Great Junction Street in the heart of Leith and only a few
hundred metres from the proposed plant is already designated an Air Quality Management Area (by City of
Edinburgh Environmental Health Dept.), so allowing further high polluting development on this scale within the
area would exacerbate the situation and is simply wrong.
5. Marine Ecology
Fish and other aquatic life in the Firth of Forth will suffer. Cooling water will be discharged back into the river at
up to 10˚C higher than when it was extracted. Even if partly mitigated as indicated in the application, it is known
that sudden changes of temperature (even if the temperature itself is not unduly high) are exceptionally
dangerous to fish (thermal shock). Oxygen levels in the water are reduced, further affecting the aquatic ecology.
6. Sustainability / Fuel Security
There is growing evidence that demand for certificated sustainable (and indeed, all) biomass is set to quickly
outstrip supply, worldwide. This will push prices up and reduce availability. When fuel becomes scarce, Forth
Energy will resort to bringing in timber by road on HGVs and burning an increasing proportion of ‘recycled’
wood, which can be highly toxically contaminated. Forth Energy already plan to burn cardboard and paper
based material to service this plant, and it would be a short step from this, when fuel becomes harder to source
to incinerating other types of waste. Their application includes no binding policy commitment on fuel sourcing so
could change after consent was granted, as has happened in other places. The European Commission has
launched a consultation on actions to ensure that biomass used for energy purposes is sustainable. It would be
irresponsible to go ahead with the Forth Energy plans, before hearing the outcome of this consultation.
http://ec.europa.eu/energy/renewables/consultations/20110329_biomass_en.htm
7. Carbon Footprint and Climate Change
It is highly misleading to claim that the proposed plant is ‘carbon neutral’ or offers carbon savings. Burning
biomass creates an immediate release of CO2, like any other carbon based fuel. Burning biomass actually
releases more carbon, per unit of useful energy generated, than burning gas or oil. This means that every
biomass plant creates a 'carbon debt’ that is only paid off after many decades (estimated at 40-100 years) as
replanted trees reach maturity - if trees are replanted. But evidence from around the world indicates that old
forests are often not replaced ‘like for like’, but with plantations of fast-growing ‘cash crops’, so the long term
damage to the planet and to biodiversity is potentially very extreme. So as well as threatening the health and
well-being of local residents, the proposed development will not help Scotland to meet targets for reduced
carbon emissions by 2030 or even 2050 and is damaging to the planet.
8. CHP Feasibility
Scottish Government policy prefers heat only or CHP biomass developments over electricity-only. Although
Forth Energy propose use of heat in as yet non existent buildings, their claims to supply heat locally from the
outset are of questionable sincerity. There is no district heating infrastructure, there are no binding contracts,
and details of how supply of heat would be achieved (and paid for) are vague and lacking in detail. Minimal
research reveals that at least some of the companies that Forth Energy suggest as ‘potential customers’ have
never actually been approached by Forth Energy with any serious proposal, but may just have ‘ticked a box’ on
a superficial survey of attitudes.
In summary, this proposed development is wholly inappropriate.
I call on you to reject it outright.
Please acknowledge receipt of this letter.
I wish this objection to be registered and permit its publication.
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