Forestry Commission Scotland – Forth Energy – G’mouth - response
Summary

The size of the plant may be excessive given the size of the
available local and regional resource

Forth Energy has not considered options for the development of a
smaller plant that could more reasonably make use of local or
regional resources

Given the large scale of the plant, information on fuel supply is
very limited in the context of a rapidly evolving regional and
global biomass market

Issues of potential displacement of material from other wood
using industries have not been addressed

The cumulative impact on supply of four Forth Energy plants has
not been considered.
Recommendation

Consideration should be given to making the proposed use of
heat a formal condition of any consent.
Introduction
Forestry Commission Scotland (FCS) serves as the Scottish Government’s
forestry directorate. FCS jointly leads on biomass policy with the Scottish
Government’s Renewable Energy team.
FCS provided comments to Forth Energy at the gate check stage of this
application. The comments below primarily relate to supply, focussing on the
Sustainability Statement. Colleagues in Renewable Energy will provide
further comment on heat issues.
Main points
Given the size of the plant and the potential cumulative impact of four plants it
is extremely disappointing that Forth Energy has not provided better quality
information on fuel supply and considered how it might avoid or mitigate
potential displacement issues with regard to existing wood processing
industries.
Domestic supply and cumulative impacts
The annual Scottish timber harvest is currently around 5.2 million green
tonnes. 20% of this harvest (over 1 million green tonnes) is currently used for
wood fuel with a further rise in use of 600k green tonnes expected in 2010.
Preliminary new assessments of wood fibre in Scotland suggest that, although
the timber harvest is rising, future supply will become progressively tighter to
2020 and that competition for the resource may become very intense.
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This plant plans to use 1.5 million green tonnes of material (imported and
domestic) and cumulatively for all four proposals, 5.5 million green tonnes. Of
this, the proposal is to use 150k to 450k green tonnes of domestic material
(up to 30% of all fuel by 2025); and cumulatively for all four developments,
550k to 1.6 million green tonnes of domestic material.
However, there is no discussion of the displacement issues in respect of the
current processing industries that might arise from this, as required in the
scoping guidance.
At p16 of the Sustainability Statement, Forth Energy suggests that supply
could come from Eucalyptus energy crops on an eight year rotation. This is
highly unlikely in Scottish conditions. Forth Energy identifies willow and
miscanthus as well as eucalyptus as potential crops but gives no information
as to where these are likely to be sourced from. There is very limited current
supply in the UK.
Forth Energy also notes that there is a considerable amount of waste wood
available but provides no evidence to support this. The Remade Scotland
report in 2009 identifies around 400k oven dried tonnes (800k green tonnes)
of material potentially available from the waste stream in Scotland.
However, there will be issues around the percentage of that material that is
recoverable as well as very significant competition for it from other biomass
plants such as the new Tullis Russell plant (50MWe) in Fife, which will be in
operation before any Forth Energy development, as well as the wood panel
industries.
Global supplies of biomass
Forth Energy has identified North America as the major supplier for their fuel
supply but has also identified that there is likely to be a considerable biomass
deficit in Europe and that other European countries will also be competing for
the North American supply.
Forth Energy has not considered what the impact of North American
renewable energy policies (which are to heavily promote the use of biomass)
are likely to be on North American demand for biomass produced there.
Forth Energy should have considered both these competing demands for
North American biomass supplies in the medium to long term in their
assessment of supply, particularly around security of supply and price.
Sustainability of fuel supplies
It is positive to see Forth Energy’s commitment to sourcing sustainable
supplies of fuel by using only material which is FSC/PEFC approved.
However, UK and Scottish Government procurement policy recognises that
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evidence of sustainability may also be provided in other ways. In England
and Wales, the main route would be Category B evidence. See:
http://www.cpet.org.uk/evidence-of-compliance
In Scotland, procurement policy is slightly different.
Forth Energy should look at Scottish Procurement Policy Note SPPN 09/2004
http://www.scotland.gov.uk/Resource/Doc/1265/0005315.pdf
This states that purchasers should ensure documented or certified evidence
under a credible scheme is provided by suppliers; where this is not possible,
purchasers should obtain full assurance that the timber or timber product has
come from a sustainably managed forest or a viable alternative.
An aim of the policy is to ensure that smaller woodlands which are sustainably
managed but for which certification is prohibitively expensive, would not be
excluded from procurement opportunities.
This is relevant in this application where Forth Energy will look to provide
opportunities for local biomass supply chains which could include smaller,
uncertified woodlands.
FCS would be happy to discuss further with Forth Energy.
Heat
Forth Energy’s proposals to maximise the use of heat are to be welcomed but
given the Scottish Government’s priorities on the use of heat, consideration
should be given to making it a condition of any consent that Forth Energy do
follow through with their proposals.
Policy
Para 2.3.5 Forth Energy should note that the Biomass Action Plan for
Scotland is now a relatively old document; and that other, more recent, SG
policy documents are more current.
Para 2.4
Forth Energy should note that the UK and Scottish Government
are currently holding consultations on the sustainability of biomass used in
generating electricity under the Renewable Obligation for the UK and
Scotland respectively. These can be found at:
http://www.decc.gov.uk/assets/decc/Consultations/Renewables%20Obligation
/261-statutory-con-renewables-obligation.pdf
http://www.scotland.gov.uk/Publications/2010/09/06152625/0
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Reference should also be made to Scottish Government policy, particularly as
it relates to efficiency and making use of local resources, as set out in:

Scottish Government Guidance on thermal power stations in Scotland

Scottish Government - General Biomass Scoping Advice

National Planning Framework 2
The relevant parts of these documents are set out in Annex 1.
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Annex 1
Scottish Government Guidance on thermal power stations in Scotland
Page15 of this guidance is set out below.
"Using biomass for energy offers a number of benefits and, if properly
planned, it can be considered a low carbon and sustainable option.
3.17 The biomass heat and power sector has a small but significant role to
play as part of the overall energy mix and in contributing towards our
renewable electricity and heat targets as set out in:
Scotland's Renewables Action Plan (Scottish Government 2009)
http://www.scotland.gov.uk/Resource/Doc/278424/0083663.pdf
Scotland’s Renewable Heat Action Plan (Scottish Government 2009)
http://www.scotland.gov.uk/Publications/2009/11/04154534/15
3.18 Sources of biomass include virgin wood, certain energy crops,
industrial wood residues, marine algae, and certain agricultural residues.
3.19 Given that much of the biomass resource is located off the gas-grid
where displacement of fossil fuel heating systems will have the greatest
carbon benefit, biomass will have a particularly important role to play in
meeting renewable heat targets.
3.20 On efficiency grounds, the Scottish Government would particularly like
to see biomass utilised for heat-only or for combined heat and power plant,
while accepting that there will also be a continuing role for stand-alone
electricity applications in certain circumstances.
3.21 In terms of scale, it is anticipated that new biomass plant will be
relatively small in scale, both to optimise local supply and, where heat is
deployed, to serve localised heat markets. Indeed, whilst biomass is a
renewable resource, there is also a finite supply of sustainable biomass
available at any one time, and a limited indigenous supply. Without utilising
the potential for heat deployment within biomass power plants there is a risk
that larger plants will use the available biomass resource in a way that does
not use whole energy content effectively, and Scotland could therefore fall
short of its renewable heat target.”
Scottish Government - General Biomass Scoping Advice
Developers should also refer to the Scottish Government’s General Biomass
Scoping Advice.
In respect of forestry, the Advice notes that Developers should consider the
finite nature of domestic supply; the potential demand on the Scottish and UK
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harvest from the proposed project; issues around energy security when
proposing to use imported fibre; and sustainability issues.
The Advice also sets out requirements re the use of heat; and in particular,
around biomass.
National Planning Framework 2
There is some reference to the NPF2 but Forth Energy should make
reference to paragraph163 of the NPF2.
163. “The Government is keen to facilitate the development of a more
dispersed pattern of energy generation and supply as part of the response to
the climate change challenge. This will involve encouraging community and
household heat and power generation, the decentralisation of generation
capacity and the development of local heat networks. The efficiency of power
stations can be substantially increased by capturing the heat produced by
electricity generation to warm our buildings. Advances in technology which
allow heat to be transmitted efficiently over longer distances may create
scope for developing heat networks based on some of our existing power
stations. Harnessing components of the waste stream and other biomass
offers the potential to develop new, smaller combined heat and power (CHP)
stations close to communities. In some areas, particularly in rural Scotland,
wood or other biomass may provide the most appropriate fuels for local
heating schemes. Investment in transmission and distribution networks may
be required to facilitate more decentralised patterns of electricity generation.
In Scotland, planning authorities have an important role in facilitating more
decentralised patterns of energy generation and supply. They should take
account of the potential for developing heat networks when preparing
development plans and considering major development proposals.”
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