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Leith Biomass Application Submission

Leith Biomass Application Submission

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Published by robm2
Submission by Leith Scottish National Party regarding Forth Energy's Leith Biomass Proposal Application
Submission by Leith Scottish National Party regarding Forth Energy's Leith Biomass Proposal Application

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Published by: robm2 on Mar 01, 2011
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Leith Scottish National Party
  Lesley McNeil, The Scottish GovernmentEnergy Consents & Deployment UnitEnergy Directorate, Renewable Energy Division4
Floor, 5 Atlantic Quay150 BroomielawGlasgow G2 8LU February 2011 Dear 
Proposed Biomass ‘Renewable Energy’ Power Station at Leith Docks, Edinburgh Application by
Forth Energy under Section 36 of the Electricity Act 1989 
This submission on behalf of Leith Scottish National Party (SNP) should be considered as an objectionto the proposal to build and operate a Biomass Power Station in Leith Docks, Edinburgh as lodged byForth Energy. Leith SNP have considered the proposals and the implications of the proposal on thecommunities of Leith and Edinburgh as well as considering the implications of the proposal onScotland and has reached the conclusion that this proposal is wrong for the local communities of Leith and Edinburgh and wrong for Scotland. The specifics of the objection are set out as follows; 
The location chosen as the site of the power station while making some sense inrelation to the intention of applicant to have the wood required to fire the plant deliveredby sea, has long lasting implications for existing and future developments in Leith Docks.There are also impacts on views to Leith from the UNESCO Edinburgh World Heritage site. Interms of the existing developments those at Constitution Place and Ocean Way are the mostdirectly affected being within a few hundred yards of the proposed site. There are alsorecently consented residential and hotel developments planned adjacent to the site. Interms of the approved development plan for the regeneration of the docks (Leith Docks
Development Plan) there are plans for a series of ‘
throughout the docks. Thesite chosen for the Biomass plant would have implications for the delivery of the public openspace which was envisaged for this location. In a recent report to the City Of Edinburgh
Council’s Planning Committee (24 February 2011, Edinburgh City Local Plan –
Progress withActions) regarding progress with the Edinburgh City Local Plan this area was highlighted asfollows
Open Space & Recreation Proposals Ref OSR 3, Site name: Leith Docks Central Park,5.3 hectares publicly-accessible park
. This significant park provision in a part of Edinburghwhich has an established need for more open space would be lost for a generation or moreshould the Biomass proposal go forward. There are also implications for the deliverability of OSR 7 Leith Links Seaward Extension which wou
ld have linked Leith’s hi
storic links park tothe seafront. The site of this extension is adjacent to the Biomass proposal. It is also worthnoting too that immediately east of the Biomass proposal there is a site identified foreducational use
a site for a new 1000 pupil capacity Secondary School.  There is an existingbuilding of historic importance on the proposed site of the Biomass plant
a former grain
store which is a ‘B’ listed building
that would be required to be demolished were theBiomass proposal to go ahead. In the Leith Docks Development Framework this building was
to remain in situ and is shown on the plans submitted with the Outline Planning Applicationfor Leith Docks.
The site and the scale of the building proposed would dwarf the existing grain store which isitself significant in height and massing. The footprint height and massing of the Biomassbuilding would have a significant impact on both local views such as the historic Shore andBernard Street/Constitution Street as well as sig
nificant impacts on views from Edinburgh’s
UNESCO World Heritage Site. The scale of the building would in the view of Leith SNP
compromise the City Council’s views study and policy
. In particular view n11b from CaltonHill and Edinburgh Castle to the Leith shoreline would be directly affected. In a culturewhere a multi-story 5 star hotel had its planning permission turned down by ScottishMinisters it would seem strange indeed if a large industrial building which would be clearlyseen from the World Heritage Site were to gain consent. Therefore the application should beturned down because of its impact on the World Heritage Site alone. 
there is concern at the risk to health of emissions from the plant and particularlyfrom a plant of this size (200MW). The City Of Edinburgh Council already has a moratoriumon inclusion of biomass boilers in new schools and care homes for precisely this reason.Emissions from biomass burning release particulate matter with PM 2.5 and PM10 being of concern for health of the local populace. There are two Primary Schools a Secondary Schooland a Special School nearby as well as the previous indication in the LDDF and OPA for futurenew primary and secondary schools in the docks development. One of the areas for urgentimprovement of air quality is in Leith at Great Junction Street. This plant could add to thisproblem and create new areas of poor air quality. It is also stated by the applicant thatrecovered wood would be sourced to supplement supplies from overseas. Such materialwould be likely to be chemically treated and dioxins and heavy metal would be emitted fromthe burning of chemically treated woods. The risk from this is considered as an unacceptablehealth risk to the local population. There is therefore considerable concern over the impactof emissions from such a large scale Biomass sited in close proximity to concentrations of population and the application should be turned done on these grounds.
Increased Traffic - Congestion and Pollution
Although a large percentage of fuel is expected to come in by sea, there will inevitably be asignificant increase in HGV movements locally, through residential and commercial areasand close to schools and public areas, to bring in supplementary fuel, and to remove ash.
Forth Energy’s application glosses lightly over (and probably underestimates) these but even
with their own figures, some elementary arithmetic shows a tally of around 20,000 heavylorry trips per year. This brings with it an unacceptable increase in traffic congestion in analready congested urban area, along with a guaranteed increase in atmospheric pollutionand carbon emissions. This is likely to get worse over time, as the issue of fuel security andsustainability arises, making it more likely that fuels of various types may be sourced morelocally. Great Junction Street in the heart of Leith and only a few hundred metres from theproposed plant is already designated an Air Quality Management Area (by City of EdinburghEnvironmental Health Dept.), so allowing further high polluting development on this scalewithin the area would exacerbate the situation and is simply wrong. It is also worth notingthat while Leith Docks is still an operating dock for bulk materials and as such generatessignificant vehicle movements this activity is not likely to stop because of the presence of the Biomass plant and therefore the estimate of 20,000 heavy vehicle movements would bein addition to other docks associated traffic. It is further worth noting that significant areasadjacent to the docks (Salamander Place/Elbe Street) and the Biomass site have changedover the years from industrial to residential and the impact of an increase in vehicle
impacts more widely as these vehicles disperse. The impact on the local air quality andamenity would be such that the application should be rejected.
- This proposal is framed as a sustainable green alternative to coal and gaspowered energy plants. It is claimed by the applicant that the supply of wood to fuel theplant would come from abroad
the Baltic States, Scandinavia and the Americas have beenmentioned. They have made the case that shipping the material in is in their view of lessercarbon impact than trucking. Baldly that may be the case but they do not factor in any truckmovements to get the material from source to port for shipping to Scotland. Given that ithas been stated by the Forestry Commission that there is not the capacity in either Scotlandor the whole UK to supply the wood required to fuel this plant (or the others proposed byForth Energy elsewhere in Scotland) it would seem that large scale Biomass is not the waythat Scotland should be going. Indeed the direction of travel of the Scottish Governmentitself seems not to favour large scale Biomass. Therefore Leith SNP would contend that thisproposal sits well outside what should be considered as sustainable renewable energygeneration.  The application does not evidence any binding policy commitment on fuelsourcing and that raises concerns that what is stated now will be subject to change if consent were granted. It is the view of Leith SNP that this proposal is not truly sustainableand therefore should not be granted.
Combined Heat and Power Feasibility
Forth Energy’s proposals to
use the heat generatedby this proposal seem to be sketchy to say the least. It was not mentioned in early iterationsof the proposal and their answers to local residents on this issue have not inspiredconfidence. A list of possible customers is given in the application but apart from perhapsthose close to the plant (i.e. within the dock area) the infrastructure costs for connectingother potential users would outweigh the benefits as Forth Energy have claimed that theplant would have a life span of 25 years after which it would be dismantled and thepreviously planned open space and mixed use development could take place.  It seems onlya little odd to sign up customers and put in significant infrastructure to then shut theoperation down after 25 years. It is worth noting that creating the connections betweensupplier and customer are un-costed and would entail digging up streets. This element of the plan is unconvincing and raises real doubts about the application and the
 intention and should therefore be rejected.
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 immediaterelease of CO
, like any other carbon based fuel. Burning biomass actually releases morecarbon, 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-beingof local residents, the proposed development will not help Scotland to meet targets forreduced carbon emissions by 2030 or even 2050 and is damaging to the planet. For thesereasons the application should be rejected. 

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