Forth Energy Leith Biomass Objection

! ! Greener Leith!
! ! 36, Newhaven Road

! ! Edinburgh
! ! EH6 5PY
! ! justask@greenerleith.org
! ! www.greenerleith.org
! !
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
3rd March, 2011
Dear Ms McNeil,
Objection to the proposed Forth Energy Leith Power Plant
On behalf of the members of Greener Leith, I enclose our objection to the proposed Forth
Energy Leith Power Plant. I would be most grateful if you could confirm receipt. Please
also note that we request the full publication of this objection on the Scottish Government
website. We would also actively encourage you to share it with the other statutory
consultees.
In summary, we strongly object for the following reasons:
1. Security of supply
A large thermal electricity generating plant is not justified on this site, and not required to
guarantee security of electricity supply. We question whether sufficient supplies of quality
sustainable fuel are available globally, without diverting biomass resources from other,
lower carbon, uses.
2. Use of heat
Despite the rhetoric of the developer, the proposals contain no guarantee that any of the
heat from the plant will be used. The developer has supplied a CHP feasibility study which
is inadequate. It fails to address the practical, political and economic barriers that relate to
the development of a large district heating network. This is fundamental to a project of this
scale and without it very few of the claimed key economic and environmental benefits will
be delivered.
Greener Leith is a Scottish Charity SCO40838 and a Company Limited by Guarantee No. 365095.
3. Carbon savings claims
The Environmental Assessment supplied by the developer makes no assessment of how

the plant will operate if none, or very little, of the heat is used. Instead, it is based on an
extremely optimistic vision of how the plant might operate, which assumes that
considerable quantities of heat will be used. The carbon savings claims are also based on
assumptions that serve to grossly over exaggerate the carbon savings the plant will
practically deliver.
4. Local environmental impact
The plant is sited in area where public health is already blighted by air pollution and high
traffic levels. The environmental statements provided by the developer fail to provide
sufficient information on the full geographic extent and range of possible toxins that the
plant may emit. Air quality studies are based on inadequate baseline information, do not
assess cumulative impacts sufficiently, and do not appraise the impact of the full range of
fuels that may be used in the plant. No attempt is made to show how the plant will help
Scotland to meet future air quality targets on PM2.5
5. National energy policy
As a large, centralised, thermal electricity generation plant, the proposal does not support
the energy generation priorities set out by Scottish Government, or policies that relate to
the development of CHP plants, energy efficiency and renewable heat.
6. Planning policies
The proposal is not supported by any national, structure or local planning polices.
7. Visual impact
The proposal will have an very significant visual impact, both locally and throughout the
Edinburgh area. It does not comply with tall building policies for the area, nor ʻprotected
view corridorsʼ set out to maintain the integrity of the Edinburgh World Heritage Site, and
praised by UNESCO. The developer has sought to actively mislead the public and public
officials by providing poor quality materials and visualisations to support the application.
8. Socio-economic impact
The proposed power station will be viewed by many as an imposing ʻbad neighbourʼ
development, and local business organisations are concerned that any jobs created by the
development would be offset by jobs lost in local retail, leisure and tourism businesses.
The power station would not be built without massive public subsidy. Yet, it is not clear how
this proposal is consistent with current plans for mixed use regeneration of the the docks.
Whilst the profits from the proposed plant will go to Forth Energy shareholders, much of
the ongoing financial risk of promoting mixed use regeneration on the docks remains with
local tax payers through the Edinburgh tram project and the Waterfront Tax Incremental
Finance arrangements.
9. Lack of public support
There is clearly no public support for this proposal. At least six local community councils,
many of the local residents associations and politicians of at all levels and from a range of
parties have expressed opposition the plant.
We provide a detailed elaboration of these points below.
1. Security of Supply
Forth Energy claim that the size of the plant is justified in order to ensure that Edinburgh
and indeed Scotland can 'keep the lights on.' In public meetings Forth Energy
representatives have been keen to emphasise that other sources of renewable energy are
intermittent. However, we note that the latest government policy, as well as research by
the largest independent renewable energy consultancy in the world, show that this
argument is a straw man. In the modern era, electricity need not be generated by large
thermal plants in the midst of densely populated areas.
In fact, Scotland is expanding the amount of energy generated from other renewable
sources so quickly that this security of supply question is not an issue. In the coming
decades Scotland will be able to close many of the large thermal plants that are currently
operating and replace them with renewables from other sources.
We note the key conclusion of the latest Scottish Government policy statement, “Draft
Electricity Generation Policy Statement 2010: Scotland – A Low Carbon Society,1” which
states:
“As a result of renewable generation ambitions and interconnection upgrades, there is no

current need for an increase in overall thermal capacity.”
Similarly, The Power of Scotland Secured Report2 concludes:
“By 2020, renewables could be providing over 100% of Scotlandʼs electricity needs, and
185% by 2030. By combining this level of renewable electricity production with moderate
efficiency measures, Scotland could decarbonise at least 50% of our total energy needs
by 2030.”
It is clear therefore, that new large scale thermal generation of any type, such as that
proposed by Forth Energy for Leith, is by no means a vital or necessary part of the
Scottish electricity generation mix in the future. Indeed, on present projections there is
likely to be less and less requirement for any form of large thermal plant.
Furthermore, Forth Energy also cite that the large scale use of biomass fuel is important to
diversify the range of fuels that are used to generate electricity nationally. Yet, we note that
the “ global dash to biomass” is putting increasing pressures on biomass fuel availability. In
our view, these proposals will do nothing to promote a secure reliable power system in
Scotland. They rely on foreign imported resources that will become increasingly scarce,
and expensive.
1“Draft Electricity Generation Policy Statement 2010” Scotland - A Low Carbon Society - Scottish
Government. http://www.scotland.gov.uk/Publications/2010/11/17094217/0
2 “The Power of Scotland Secured Report” Garrad Hassan. http://www.foe-scotland.org.uk/power-secured
At an EU level, The Institute for European Environmental Policy 3 suggests that, “Overall,
the bioenergy contribution to final energy consumption is expected to more than double,
from 5.4% in 2005 to almost 12% (124Mtoe) in 2020. Solid biomass and forestry biomass
in particular will continue to be the major source for bioenergy, and is estimated to
represent 36% (83Mtoe) of the EU renewable energy target by 2020...it remains to be
seen how much the European Union as a whole can secure its supply needs from internal
resources and how much will be imported from third countries.”
In particular, we question whether Forth Energy will be able to source adequate supplies of
high quality, FSC certified fuel, given the rapidly rising global demand for biomass fuels
and timber products. In Scotland, the rate of productive timber planting is currently
decreasing4. Furthermore, independent reports note that to supply all the proposed large
scale biomass plants currently proposed in the UK alone, the volume of timber required to
supply them would require a doubling in the quantity of wood biomass traded globally.5
The developer has not supplied a robust fuel supply plan, which assesses the impact of
cumulative biomass developments in the UK and Europe.
It would be prudent to use public subsidy to support the efficient use of Scotlandʼs own
indigenous biomass energy sources in smaller plants, off the gas grid, rather than
supporting the development of giant power plants that will rely on foreign fuel sources to
generate high carbon electricity at low efficiencies. For this reason, the plant should not
receive consent.
2. Use of Heat
Forth Energy have produced elaborate plans outlining the technical feasibility of
developing a heat network linked to the proposed giant power station. However, Forth
Energy have done nothing to show that they will invest sufficient funds to overcome the
manifold practical, legal, and financial hurdles to deliver a functioning heat network that will
use the large amounts of heat produced by the plant.
On the contrary, the fact remains that no district heating system will ever be built as part of
this proposal unless it is ʻcommercially feasible.ʼ We propose that it is extremely unlikely
that the extensive network that Forth Energy describe in the planning documentation will
ever be built, and as a consequence the plant will operate very inefficiently and should not
be given planning consent.
Forth Energy estimate the costs of installing a functioning district heat network at £1million
per kilometer, with an additional cost of £3000 per dwelling, if a heating system is to be
3“The role of bioenergy in the National Renewable Energy Action Plans: a first identification of issues and
uncertainties” Institute of European Environmental Policy. Available at: http://www.ieep.eu/assets/753/
bioenergy_in_NREAPs.pdf
4“Scottish Forestry at the crossroads.” CONFOR, Available at: http://www.confor.org.uk/Upload/Documents/
37_ConforGreenFutureBookletNov2010.pdf
5“Woodfibre availability and demand in Britiain 2007 - 2015.” CONFOR. Available at: http://
www.confor.org.uk/Upload/Documents/37_WoodFibreAvailabilityDemandReportfinal.pdf
retrofitted to an existing building. In addition, the Forth Energy CHP feasibility study 6 that
forms part of the application acknowledges the following points with regards the barriers
associated with building a district heat network in the UK (our emphases added in bold):
“Easements and Highways Licenses need to be obtained for access, construction, and
maintenance of the pipes. There is a significant financial implication for obtaining
easements...There is also a considerable amount of work required to negotiate the
traffic management requirements resulting from having to install pipes in large trenches
within major access roads within Leith.”
The CHP feasibility study continues:
“Another factor is the current use of the existing natural gas supply network to supply heat
to housing and other buildings. The retrospective installation of hot water mains and
domestic heat exchangers is expensive when compared to the continued use of this gas.”
“DH schemes will generally only be cost effective in the development of new housing
estates and only where the development exceeds 300 to 400 dwellings, if no housing
association/local community funding is provided. The high capital cost of the
infrastructure is known to deter private housing developers.”
We also note that the feasibility study cites a number of large scale housing developments
as possible customers for the heat produced by the plant. However, the ongoing financial
crisis has crippled large scale private sector domestic housing development in the area,
and indeed the development of a large ʻbad neighbourʼ power station in the area will only
serve to restrain private sector investment in the local area further.
Given this we question whether it is realistic to suggest that even the larger private sector
developments of any kind will be able to support the investment required to develop a
district heating system of the scale required to make use of all the heat this plant will
generate.
We also question whether there is the political will to support the extensive travel
disruption that the construction of a viable district heating system would entail, given the
negative local economic impact that digging up major public roadways will have on the
local area. Local businesses and residents are only too familiar with the travel disruption
and the associated negative economic impacts of major public works given that they are
still living with the consequences of the incomplete Edinburgh Tram project. In their
application Forth Energy have done nothing to explain how they would overcome these
barriers to obtain the necessary consents and way-leave agreements to practically build
the network.
6“Leith Renewable Energy Plant: CHP Feasibility Study.” Forth Energy, http://www.forthenergy.co.uk/pdf/
biomass-project-update-leith/06%20S36%20Supplementary%20Information/01%20CHP%20Feasibility
%20Study%20-%20Leith.pdf
It is clear that there are other barriers that deter private sector development of district
heating networks. For example, the report fails to note that heat, when billed
independently from rent, is charged at 20% VAT. If it is included in rent, it is billed at a
significantly lower 5% VAT rate. This is another financial barrier that will reduce the
likelihood that a commercially viable, private sector model for retro-fitting a heat network to
older mixed tenure and private properties in Leith can be found. Yet it is not mentioned in
the CHP feasiblity study.
There is also a contradiction at the heart of the Forth Energy power plant proposals. Forth
Energy have often claimed at public “consultation” meetings that when the plant reaches
the end of its operational life, (we note this would coincide with likely termination of public
subsidy for the plant via the Renewables Obligation Certificates scheme) that the plant will
be demolished with the aim of reverting to the current mixed use regeneration plan.
Clearly, if this is the long term vision of Forth Ports for the area, then this will act as a
further disincentive for investors in a potential district heating system. Who afterall would
spend £1million per kilometre on a pipe system that may become redundant in a few years
time?
It is instructive that Forth Energy have made no commitment to connect Ocean Terminal to
a district heating system at this stage. Forth Ports owns a significant stake in the
developer, Forth Energy. It owns all the land between the proposed power station and
Ocean Terminal. Forth Ports also owns the Ocean Terminal Shopping Centre outright, and
the shopping centre itself is set to benefit from a major upgrade as part of a loan
underwritten by local tax payers via the Tax Incremental Finance scheme.
It is clear that the fact that Forth Energy and Forth Ports have not committed to building a
district heating network to supply Ocean Terminal as part of this application, even under
the above circumstances, demonstrates that the practical development of a viable district
heating system is simply not going to happen without massive, ongoing, further public
subsidy. This application does not provide convincing evidence that Forth Energy have the
capacity, business model or commitment to secure the scale of funding required to deliver
a suitably scaled heat network.
Furthermore we understand from council sources that speculative efforts to repurpose the
docks as a ʻrenewable energy manufacturing hubʼ are likely to have a lead-in time of more
than 10 years. Whilst laudable, the hope that a large manufacturing facility may be built in
10 years time does not justify the negative impacts associated with the early construction
of a large, ʻbad neighbour plant,ʼ that is not designed to match a specific heat demand.
The prospect that an unspecified industrial customer for some of the heat may be found in
the future, does not alter the probability that the plant could practically end up operating for
many years as a massively inefficient power only plant. This risk is too great to justify
consent on this basis.
Forth Energy may have shown that it is technically feasible to build a heating network, and
we share the view that it is entirely desirable to use as much of the heat produced by the
plant as possible. However, we maintain that it is extremely unlikely that further private
sector investment on the scale required will be available to support the development of the
extensive heat network that Forth Energy describe. Even the most successful CHP
schemes in Scotland have developed on a non-profit basis and relied upon extensive
public subsidy.7 It is difficult to see where this public subsidy will come from in the current
economic climate.
Given the practical constraints we outline above, we believe there is no reasonable

justification for the size and scale of the plant as it is highly likely to operate for the larger
part of itʼs lifetime primarily as an ʻelectricity generationʼ plant. This is a key point, and
undermines many of the environmental claims made by the developer, and the
justifications for the size of the plant.
2.1 Quality of CHP feasibility study.
We note that the developer is obliged to supply a CHP feasibility study as part of the
Section 36 application process. In our view, the quality of the information in The CHP
feasibility study that Forth Energy have supplied is poor and in our view insufficient to
support a development of this scale and impact. As a consequence, consent should not be
given.
It would appear that the CHP feasibility study is largely “a desk exercise,” save for a few,
more detailed, consultations with the City of Edinburgh Council and the Scottish
Government. For example, the Seafield Waste Water Treatment Works are included in the
survey as a possible heat customer, despite the fact that this site itself is currently close to
generating more renewable energy that it consumes. A more detailed feasibility survey
would acknowledge that there would be little commercial justification for connecting this
site to the proposed power plant.
Using Freedom of Information legislation8 , we have conducted our own research to identify
the organisations that Forth Energy have contacted to discuss the practical potential for
use of heat from their proposed plant and note that some organisations cited as potential
customers in the feasibility study have had no direct contact with Forth Energy or agents
acting on their behalf. The Scottish Parliament, Lothian Buses, The Royal Botanic
Gardens, Lothian and Borders Police, Lothian and Borders Fire Brigade, National
Museums Scotland (who own Customs House at the Shore) & Telford College have never
been directly contacted as potential heat customers.
The CHP feasibility study makes no assessment of whether the Renewable Heat Incentive
would make a district heating system commercially viable. Whilst we appreciate that the
level of RHI subsidy is yet to be confirmed, we believe a more meaningful study would
have attempted to scenario test the financial viability of a district heating system under
various indicative subsidy regimes.
7“UK Housing Awards 2008: Outstanding Achievement Award. Aberdeen Combined Heat and Power.”
Chartered Institute of Housing. Available at: http://www.cih.org/ukha/pdfs/2008Winners/AberdeenCC-
CombinedHeatPower-OAH-UK-Winner.pdf
8Freedom of Information Requests by Greener Leith on WhatDoTheyKnow.com Available at: http://
www.whatdotheyknow.com/user/greener_leith
Furthermore, the study makes little attempt to examine the business models of successful
CHP schemes in the UK. Many of the most successful projects have been developed on a
non-profit basis, in partnership with charities and local government partners. Furthermore,
they have relied on significant public sector funding to support the capital investment
needed to establish the network, yet Forth Energy has done very little to elaborate
possible sources of public funding for this work, or a rudimentary business model.
These flaws only serve to underline the fact that, despite the rhetoric of the developer,
there is very little practical likelihood that the heat from the plant will ever be used.
3. Carbon Savings Claims
We note that the Carbon Savings claims made by the developer are extremely optimistic,
and based on a number of assumptions that do not reflect the practical operating
conditions that the plant will is most likely to operate under. Given this, we believe that the
proposal should not receive consent until the developer can present a more realistic
Sustainability Statement for consideration.
3.1 Claimed carbon savings relative to carbon intensity of the UK national grid.
CO2 Intensity of Generation. (From “Draft Electricity Generation Policy Statement 2010: Scotland – A
Low Carbon Society,” Scottish Government)
On page 26 of the Sustainability Statement9, in the footnotes, it is acknowledged that the

baseline figure used to calculate the carbon savings for the proposed plant are based on
the “emissions from UK grid electricity, using the three year average for 2006 to 2008.”
9“Sustainability Statement for the Leith Renewable Energy Plant” Forth Energy. Available at: http://
www.forthenergy.co.uk/pdf/biomass-project-update-leith/00%20S36%20Main%20Documents/
03%20Sustainability%20Statement%20-%20Leith.pdf
Adopting this figure serves to considerably overstate the carbon savings that plant is
practically likely to deliver, as the carbon intensity of the national grid is likely to drop
significantly during the lifetime of the proposed plant - regardless of whether the Leith
Biomass plant is given consent or not.
3.2 Claimed Carbon Savings: Comparison to unabated coal emissions
Section 4.1.2.2 of the Sustainability Statement (pg. 27) states, “The Leith Renewable
Energy Plant is to be a base-load plant, and electricity from the plant would be expected to
replace electricity generated in a coal fired power plant.”
This assumption is also incorrect. Over the lifetime of the plant, it is extremely unlikely that
there will continue to be any significant coal fired electricity generation in Scotland which is
operating without some form of carbon capture and storage (CCS).
This shift away from coal is already underway, with Scottish Power seeking permission to
covert Cockenzie to lower carbon natural gas, and pioneer CCS at Longannet coal fired
power station. Looking to the future, the proposed biomass plant is therefore likely to be
displacing coal-fired plant that is fitted with CCS technology, nuclear, or natural gas fueled
ʻbase-loadʼ plant from the grid. These are all much lower carbon fuels that unabated coal,
and by failing to acknowledge this, the Sustainability Statement supplied by Forth Energy
overstates the carbon savings that the proposed plant is likely to deliver.
3.3 Claimed Carbon Savings: Use of heat
As we have established above, the application for the Leith Biomass plant contains no
guarantee that any of the heat from the plant will be used. Given the costs, political and
practical constraints on delivering any district heating system, it it is extremely unlikely that
the heat from the plant will be used in significant quantities.
Despite this, we note that section 4.1.28 (pg. 29) of the Sustainability Statement states:
“The results presented in this Section take into account an initial assessment that the Leith
Renewable Energy Plant will also be producing around 60 MWth of heat which will be
utilised.”
We note that no attempt is made to assess the carbon impacts of the plant, if none of the
heat is used - even though this is the ʻworst caseʼ condition, and in our view, the most
likely condition, that the plant will operate in. This assumption serves to massively
overstate the carbon savings that the plant is practically likely to deliver.
Furthermore, we note that no attempt to relate the size of the plant to any practically
feasible heat demand has been made.
The application should be rejected, as the Sustainability Statement is based on over

optimistic assumptions that do not reflect the practical conditions that the plant is likely to
operate under for much of itʼs operational lifetime.
3.4 Claimed Carbon Savings: Use of Waste Paper and Cardboard
We note that the proposed plant will use a proportion of recovered waste as fuel, including
significant quantities of paper and cardboard. An updated ʻmeta-studyʼ 10 by Scottish
Government Agency, WRAP, that provides an analysis of the results of several
independent research reports on the most sustainable treatment of waste paper, shows
that incineration of paper wastes is only likely to deliver a carbon saving if the heat from
the process is used. The study concludes:
“The general idea that landfill is, in most cases, the worst option is maintained. However,
the results of comparing recycling to incineration are less concrete than in the previous
report, where recycling had a slight advantage. Most probably the advancements in
incineration technologies (mainly energy recovery efficiencies) have been integrated to the
recent LCAs. In this new group of studies, there is no case where incineration is used as a
disposal option with no energy recovery, as opposed to the previous report where two out
of nine studies do not include energy recovery from incineration at all. Three out of five
studies include heat production from incineration as well. On the other hand, there was no
analysed study that took into account the alternative use of the incineration capacity, a
factor that was deemed quite decisive in the previous study.”
As we have noted above, Forth Energy provide no guarantee that the heat generated by
the proposed plant in Leith will be used. Therefore, this meta-study shows that there is a
strong probability that greater carbon savings could be delivered if recovered waste paper
and cardboard were recycled, rather than burnt in a plant where none of the heat is used.
Far from providing a carbon saving, burning waste paper and cardboard in the proposed
Leith plant, as it will practically operate on construction would incur a carbon cost - not a
saving. The Sustainability Statement fails to acknowledge this, and therefore
overestimates the carbon savings that the plant is likely to deliver. Given this, we believe
that consent for the plant should not be given, as the information supplied does not
provide an accurate assessment of the carbon savings the plant is likely to deliver.
3.5 Claimed Carbon Savings: Use of Energy Crops
As the Sustainability Statement is based on an optimistic operating scenario where

significant quantities of heat are used, as opposed to the minimum likely efficiency that the
plant will operate at, the carbon benefits claimed by the developer for the use energy
crops, such as straw, as a fuel are also questionable.
10Environmental Benefits of Recycling, 2010 Update. WRAP. Available at: http://www.wrap.org.uk/

downloads/Environmental_benefits_of_recycling_2010_update.28da7246.8816.pdf
Graph from “Biomass: Carbon Sink or Carbon Sinner?” Environment Agency.
We note from the above graph that some energy crops, when not used in plant where the
heat is used efficiently, emit more greenhouse gases than an equivalent Natural Gas
powered electricity plant.
The Environment Agency report, “Biomass: Carbon Sink or Carbon Sinner?” 11 concludes:
“In the short term, improvements in energy conversion efficiency and lifecycle emissions
from biomass fuels will help to reduce emissions. However by 2030 some fuels will be at
risk of becoming redundant. Biomass plants generating only electricity, a number of which
are currently in development, cannot have a long-term future in the UKʼs energy mix as
they are not able to produce sufficiently low carbon energy. The only way electricity
production from biomass can keep within the Committee on Climate Changeʼs
recommended trajectory is if the heat generated at the same time is put to domestic or
industrial use.”
As the proposed plant for Leith is likely to operate primarily as an electricity generation
plant it cannot have a long-term future in the UKʼs energy mix. It should therefore not
receive consent.
11“Biomass: Carbon Sink or Carbon Sinner?” Environment Agency. Available at: http://www.environment-
agency.gov.uk/static/documents/Leisure/Biomass__carbon_sink_or_carbon_sinner_summary_report.pdf
3.6 Claimed Carbon Savings: Timescales for Delivery
Scottish Government legislation enshrines a commitment to reduce our national carbon

emissions by 42% by 2030 and 80% by 2050 in law. Forth Energy claim that their
proposed biomass plants will help Scotland to meet these targets.
However, there is strong evidence to suggest that the Forth Energy proposals will in fact
hinder national attempts to cut carbon emissions in the timescales set out by Scottish
Legislation. Burning biomass creates an immediate release of CO2, like any other carbon
based fuel. In the short term, biomass plants release more carbon, per unit of useful
energy generated, than burning coal or gas. This means that every biomass plant creates
a 'carbon debt,' compared to burning fossil fuels, that is only paid off after many decades.
Independent research suggests that for large scale, mainly electricity generating biomass
plants, like the proposed Forth Energy plants, this process can take many decades, with
net carbon emissions likely to be higher than an equivalent sized coal fired plant after 30
years of operation12 . Indeed, a research review by the Clean Air Task Force 13 in the US
concludes that plants like those proposed by Forth Energy should not be permitted as they
are ,‘a threat to climate and forests.’
Forth Energy claim the lifetime of the plant is 25 years. If this is the case, then public
subsidies will be better used to invest in technologies that will generate a reduction in
carbon emissions in the timescale we need.
Forth Energy claim that the research these claims are based on cannot be applied to their
proposals. In one sense they are right - each proposed plant is different, and so the
precise numbers will differ. However, it is clear that the principles that underpin the
research below and the model they use can be applied to any plant. Greener Leith has
repeatedly asked Forth Energy to provide specific information on how long it will take their
plants to pay off their 'carbon debt'- relative to simply burning fossil fuel. They have not
provided this information - although their independent researcher acknowledges that there
will be one. Forth Energy's paid research team at SISTECH, has this to say about the
carbon debts associated with large biomass plants14:
“The size of any short-term "carbon deficit‟ associated with the use of biomass fuel (i.e.
the carbon deficit that arises between CO2 emissions from combustion of the first cropping
and subsequent CO2 re-capture from the re-growth of replacement crops) depends on the
source of the biomass and the management of the biomass resource. Using hardwood
timber with a re-growth period of 40 years will obviously lead to a bigger deficit than using
other species which achieve maturity in a shorter timeframe. Even then, this could be
further reduced by re-planting at an increased rate or at an earlier date.”
12 “Manomet Study of Woody Biomass Energy” Manomet Centre for Conservation Sciences. Available at:
http://www.manomet.org/node/322
13“A review of the Manomet Biomass Sustainability and Carbon Policy Study” Clean Air Task Force.
Available at: http://www.catf.us/resources/whitepapers/files/201007-
Review_of_the_Manomet_Biomass_Sustainability_and_Carbon_Policy_Study.pdf
14“SISTECH response to the recent press coverage of Manomet “Biomass Sustainability and Carbon Policy”
Study. SISTECH. Available at: http://www.forthenergy.co.uk/pdf/SISTech%20letter%20Manomet%20for
%20Forth%20Energy%20v2.pdf
Carbon Flux (from “A review of the Manomet Biomass Sustainability and Carbon Policy Study” Clean
Air Task Force).
Whilst the precise fuel mix associated with the plant is uncertain, in it is clear from the
information in the application that virgin timber is likely to play a significant role in fueling
the plant. The earliest that the Leith Biomass plant is likely to become operational is 2015.
If it operates for 25 years, the earliest that the plant could become close to delivering a
90% carbon savings claimed for the plant is 2080, based on the advice provided by
SISTECH above. However, we contend that other credible, independent research
suggests that the likelihood is that any carbon savings could take significantly longer to
deliver than this.
This is because it is not sufficient to base a carbon debt analysis, in comparison to using
coal as an energy source, simply on the lifecycle of a tree, or indeed on the lifecycle of any
energy crop, as the SISTECH response implies. In fact, the Manomet study demonstrates
that there are a number of other factors that must be considered. These include the way
the biomass fuel is used. If it is used primarily to generate electricity, without using all of
the heat, the Forth Energy plants will take many, many decades to deliver a carbon saving
over burning coal. The graph above, that models a hypothetical, electricity only biomass
plant burning wood - shows that after 32 years, carbon emissions are still 147% greater
than a coal fired plant.
Similarly, it is not sufficient to simply commit to replacing each tree harvested with another
one as Forth Energy do. Carbon stocks in forests are complex. For example, research into
the effects of clearing forests on carbon stored deep in soils, show that carbon is lost from
forest soils decades after harvesting - with 50% of stored carbon lost 30 years after
harvesting 15. These carbon losses would also have an effect on the time scale that any
biomass plant would deliver a carbon saving in. However, Forth Energy do not provide a
time-based analysis of the carbon impact of their proposals as part of their application.
Whilst the lifecycle analysis that is supplied by Forth Energy is based on an extremely
optimistic interpretation of EU guidance, there is a growing body of research that calls into
question the current EU policy treatment of biomass with regards to climate change 16. This
is not acknowledged by Forth Energy or SISTECH in the documentation provided.
Recently, ninety leading environmental scientists wrote to the US government17 calling for
a policy review into just this matter:
“Many international treaties and domestic laws and bills account for bioenergy incorrectly
by treating all bioenergy as causing a 100% reduction in emissions regardless of the
source of the biomass. They perpetuate this error by exempting carbon dioxide from
bioenergy from national emissions limits or from domestic requirements to hold allowances
for energy emissions. Most renewable energy standards for electric utilities have the same
effect because bioenergy is viewed as a renewable energy even when the biomass does
not eliminate or even reduce greenhouse gas emissions. This general approach appears
to be based on a misunderstanding of IPCC guidance. Under some scenarios, this
approach could eliminate most of the expected greenhouse gas reductions during the next
several decades.”
Similarly, a European research report released in May 2010, titled the “Upfront Carbon
Debt of Bioenergy,” questions the current EU policies on bioenergy, stating 18:
“In the current climate change policy framework, the use of biomass for energy is
considered a carbon neutral source. According to the principle of carbon neutrality, the
GHG emissions produced by combustion of plant biomass are assumed to be recaptured
instantaneously by new growing plants...When the raw material is wood, the time needed
to re-absorb the CO2 emitted in the atmosphere can be long, depending very much on the
source of wood.”
15 Looking deeper: An investigation of soil carbon losses following harvesting from a managed northeastern
red spruce (Picea rubens Sarg.) forest chronosequence. 2008, Forest Ecology and Management. Available
at: http://www.sciencedirect.com/science?
_ob=ArticleURL&_udi=B6T6X-4TP7H5N-1&_user=10&_coverDate=01%2F31%2F2009&_rdoc=1&_fmt=high
&_orig=search&_origin=search&_sort=d&_docanchor=&view=c&_searchStrId=1639888393&_rerunOrigin=g
oogle&_acct=C000050221&_version=1&_urlVersion=0&_userid=10&md5=7d9802ea2c20e490fe60930cf3bc
31ad&searchtype=a
16“Question and Answers for Fixing a Critical Climate Accounting Error.” Searchinger, Princeton University.
Available at: http://www.princeton.edu/~tsearchi/writings/Questions%20and%20Answers%20-%20Fixing
%20a%20Critical%20Climate%20Accounting%20Error.pdf
17“90 Scientists Urge Congress Not to 'Cook the Books' in CO2 Accounting for Biofuels, Other Bioenergy
Sources” - Available at: http://www.prnewswire.com/news-releases/90-scientists-urge-congress-not-to-cook-
the-books-in-co2-accounting-for-biofuels-other-bioenergy-sources-94741714.html
18
“The Upfront Costs of Bioenergy” European Federation for Transport and Environment. Available at:
www.transportenvironment.org/Publications/prep_hand_out/lid/591
“This delay can create an upfront “carbon debt” that would substantially reduce the
capability of bioenergy to reduce the greenhouse gas emissions (GHG) in the atmosphere
in the short to medium term.”
Of course, until Forth Energy, pay for a detailed appraisal of the carbon debt associated
with their proposals it is not possible to know when the proposed plant will deliver a carbon
saving with certainty. This is why Greener Leith has called for a moratorium on all large
scale biomass plants19 , and a withdrawal of public subsidies for the types of plant that
Forth Energy propose20, until processes are put into place to verify the carbon savings
claims made by all developers of such plants. This call received cross party support21 at all
political levels.
As a consequence, we note that the Scottish Government has announced a policy

review22 of the public subsidy available to large, electricity only biomass plants. Given the
uncertainty over the true carbon impact of the Forth Energy proposals, at the very least,
the Scottish Government should not give consent to the Leith Biomass plant, or indeed
any other large scale, electricity only biomass plant, until this subsidy review process has
been completed. Otherwise, because subsidies are “grandfathered,” the government risks
committing tax payers to expensive public subsidies for plants that may not deliver the
carbon savings we urgently need.
3.7 Claimed Carbon Savings: Fuel Sources
A large proportion of the fuel used in the Forth Energy power plants will be virgin timber,
mostly sourced from outwith the UK. Forests can be managed to provide a sustainable
source of timber, and to act as a carbon sink. However, where forests are managed
intensively - they can provide a sustainable yield of timber, but act as an overall carbon
source. There are currently no forest management certification schemes that guarantee
that forests are managed to act as a 'carbon sink.'
Forth Energy claim that they will guarantee that one tree will be replanted for each one that
is burnt. Simply replanting a replacement tree does not guarantee that all the carbon lost
during harvesting shall be recovered during the lifetime of the tree. This full carbon
recovery depends on the way that the forest the tree comes from is managed. If the forest
is converted from a semi-natural rainforest to a Eucalyptus plantation, or even if it is simply
managed more intensively as a result of increased demand, then there will be a net carbon
emission that will take many decades to mitigate - or the planting of extra forest.
We note that the methodology used to calculate the Greenhouse Gas Emissions for the
plant is based on EU methodologies that do not take account of the whole lifecycle of the
19“National Call To Halt Big Biomass.” Greener Leith. http://www.greenerleith.org/greener-leith-news/

2010/10/6/national-call-to-halt-big-biomass.html
20“Greener Leith Submission to the Renewables Obligation (Scotland) Order Consultation” Greener Leith.
Available at: http://www.greenerleith.org/storage/SG%20Biomass%20Consultation%20.pdf
21”S3M-07356# Shirley-Anne Somerville (Lothians) (Scottish National Party): Moratorium on Large-scale
Biomass Plants” Motion to Scottish Parliament. Available at: http://www.scottish.parliament.uk/Apps2/
business/motions/Default.aspx?motionid=20154
22 Renewables Obligation (SCOTLAND) Order Consultation - Scottish Government Response. Available at
http://www.scotland.gov.uk/Topics/Business-Industry/Energy/Energy-sources/19185/17612/ROSC1210R
fuel. This has caused concern at a EU policy levels, with the Institute of European
Environmental Policy 23 arguing for a solid biomass sustainability standard as part of the
Renewable Energy Directive that takes into account:
“...technology efficiency; in addition to accounting for fuelʼs inherent efficiency. Moreover,

the RED GHG calculation method only takes account of emissions from direct land use
change, but excludes emissions from the degradation of carbon stocks and sinks due to
the production of biomass.”
Forth Energy do not even commit to sourcing all fuel from Forest Stewardship Certified
(FSC) sources. This is widely held as the most reliable standard. There are other
"sustainable forest management" standards in existence, however these have been shown
to be significantly less robust than FSC 24, and Forth Energy themselves accept in their
application that other sustainability standards have “have attracted near universal
condemnation from NGOs.” Without a commitment to FSC certified fuel - there is an
increased chance that the timber used in the Leith plant will be sourced from illegal
suppliers, and may not in fact be replaced.
In their application, Forth Energy give contradictory commitments on the regions of the
world where they will source their timber. To date, no biomass plant operators in the UK
have been given approval for a plant with a binding planning condition on the source of
their fuel. For example, last year, DECC approved MGT Power's application to build a 295
MW biomass power station at Teesside Port. Shortly after winning planning consent they
signed a Memorandum of Understanding with Suzano Papel e Cellulose for most of the
wood to come from Brazilian eucalyptus plantations despite pledging to source fuel from
North America in their planning application25 .
If the application is to be given consent, specific planning obligations should be placed

upon Forth Energy to ensure that the fuel sourced for the Leith Biomass plant meets
Forest Stewardship Council (FSC) certification standards, as well as being sourced from
specific geographic locations that exclude regions where deforestation or conversion of
primary or old-growth forest continues. A large biomass plant given consent in Wales had
similar condition places upon it26 .
Whilst these measures would still fail to guarantee that the fuel was sourced from forests
managed as ʻcarbon sinksʼ - they would go some way to ensuring that the fuel was
sourced from relatively sustainable, well managed forests, with verifiable chain of custody
processes.
23“Energy: Mandatory Standards for Solid Biomass for Energy Increasingly Unlikely.” Institute of European
Environmental Policy. Available at: http://www.ieep.eu/assets/684/20_November_-_Energy_-
_Biomass_sustainability_criteria.pdf
24“FSC summary report - Comparative analysis between the FSC Controlled Wood requirements and PEFC, PEFC
Germany and SFI”.(2009) Available at: http://www.fsc.org/fileadmin/web-data/public/document_center/publications/
PEFC_and_FSC/FINAL- Summary_Report_FSC_CW_and_PEFC-EN.pdf
25
“Objection to Forth Energy Grangemouth Plant” Friends of the Earth Scotland. Available at: http://
www.greenerleith.org/storage/FOEs%20Grangemouth%20Objection.pdf
26“Biomass plant gets go ahead but will not use waste heat” The Ecologist. Available at: http://
www.theecologist.org/News/news_round_up/330743/
biomass_plant_gets_goahead_but_will_not_use_waste_heat.html
Local Environmental Impacts
The plant will have a number of local environmental impacts that we do not believe justify
consent, nor the public subsidy the plant will quality for.
4.1 Air Quality
Parts of Leith are already designated as Air Quality Management Areas, as air pollution is
getting worse year on year due to increased traffic. This means that the areas in question
exceed, or are at risk of breaking EU air quality laws already.
The Lothian Joint Health Protection Plan27 states: "The physical environment plays a
significant role in the causation of the top ten diseases which contribute to death in
Lothian." Local research28 , commissioned by the NHS, suggests that poor air quality in
Edinburgh leads to around 1000 extra GP admissions each year. It also notes that the
impact of poor air quality has a disproportionately high impact on people who are in low
income groups. Many residents of Leith fall into this category, particularly around the parts
of Leith with the worst air quality. In these areas, poor air quality already takes nearly 227
days off an average persons life expectancy over 75 years.
The fact that air pollution is already a clear public health problem in Leith is a good reason
in itself not to add another significant point source of air pollution. For this reason alone we
object to the Leith plant being given consent to operate.
The Forth Energy Planning Application for the Edinburgh plant includes a poor quality
study that claims to assess the cumulative impact of the proposed power plant, combined
with other planned developments on the docks. It concludes:
"The results indicate that at most of the properties close to the assessed roads the annual
mean nitrogen dioxide concentrations in 2015 are forecast to range from 32.2μg/m3 –
46.9μg/m3. This range exceeds the annual mean air quality objective of 40μg/m3."
The study acknowledges that the plant will lead to an increase in NOx levels on many
streets throughout Leith, but somehow contrives that the role of the plant in the cumulative
increase in the coming years will not lead to 'new exceedences' of air quality standards. It
blames other planned developments on the docks. This conclusion seems illogical and
wholly untenable, as each individual development could equally claim that it is ʻother
proposed developmentsʼ that cause the predicted exceedences.
The information on particulate emissions, and other toxins, appears particularly sparse. It
is not clear from the information provided which areas are locally likely to be impacted by
increases in particulate emissions. The air quality study also appears to take little account
of ʻfugitiveʼ emissions of particulates relating to the storage and removal of ash. Whilst the
developer may contend that these emissions will be well controlled by ensuring that ash is
stored in covered areas, local residents with experience of the infamous “Seafield stench”
will only be too aware of how frequently such commitments can fail.
27“Lothian Joint Health Protection Plan” NHS Lothian. Available at: http://www.nhslothian.scot.nhs.uk/news/
documents/nhslothianHealthProtectionPlan.pdf
28“Health benefits of Local Air Quality Management: Edinburgh - A Case Study” NHS Lothian. Powerpoint
Presentation available at: http://www.slideshare.net/greenerleith/edinburgh-air-quality-health-impact
We would also wish to highlight recent UK wide research29 into the health impacts of
PM2.5, that shows that even a small increase in exposure to these particles can have a
significant impact on public health, regardless of specific legally defined thresholds.
Because of this, we contend that the Leith plant should not receive consent as it will act as
a point source of particulate matter, in close proximity to a densely populated area with
existing air quality problems.
Furthermore, we note that the baseline information used to estimate the weather and
background levels of air pollution are based on survey measurements from as far away as
Staffordshire. This is not a sufficient level of detail for a proposal of this scale and potential
impact.
We also believe that the Scottish Government should consider recent controversy over the
accuracy of the City of Edinburgh Council air quality monitoring information that suggests
that some of the baseline information used by Forth Energy consultants may
underestimate air pollution levels by as much as 40%.30 Lastly, we also note that the
baseline year selected by the developer for particulates, 2008, was a year described by
the City of Edinburgh Council31 as:
“...an anomaly, in as much as it was a wet year and levels of Pm10 were reduced
dramatically.”
Before the plant is given consent to operate more detailed studies into baseline
particulate levels in Leith, as well as other relevant pollutants, must be conducted. The Air
Quality Study provides very limited assessments of the cumulative effects of the pollutants
generated by the plant, and their geographic extent, apart from NOx. Furthermore, the
cumulative impact of the new gas power plant proposed at Cockenzie is not included in the
study. Remarkably, the air quality impact study does not appear to include the emissions
generated by the traffic that the plant would generate. This is clearly an important omission
considering that HGV traffic is a key source of air pollution in the area.
In order that officials and politicians at all levels of government can make an informed
decision on the health impacts of the plant far more detailed information is required. This
view is supported by Dr Margaret Douglas, Consultant in public health medicine for NHS
Lothian who has stated publicly 32:
"While we welcome, in principle, any attempts to increase the provision of renewable

energy, the environmental and public health impacts need to be assessed.
"Following the application submitted to the Scottish Government by Forth Energy, we

believe that a fuller assessment of the health impacts should be done."
29 “The Mortality Effects of Long Term Exposure to Particulate Air Pollution in the UK.” The Committee on the
medical effects of air pollutants. Available at: http://www.comeap.org.uk/documents/reports/128-the-mortality-
effects-of-long-term-exposure-to-particulate-air-pollution-in-the-uk.html
30
“Edinburgh Air Pollution Grossly Underestimated, say Campaigners” The Guardian. http://
www.guardian.co.uk/uk/2011/feb/03/scotland-pollution
31 “Gate Checking Document for Forth Energy Biomass Application” Scottish Government. Available at:
http://www.scotland.gov.uk/Topics/Business-Industry/Energy/Infrastructure/Energy-Consents/Applications-
Database/Biomass/Leith-Index/gate-checking
32“Health Chiefs Air Plant Fears”. The Scotsman. Available at: http://news.scotsman.com/scotland/Health-
chiefs-air-plant-fears.6705247.jp
We also note that the fuel mix scenarios used in the air quality statement are not
consistent with those described elsewhere in the application. The Air Quality Statement is
based on two scenarios - one where 70% virgin timber is used, and one with 100% virgin
timber. The Sustainability Statement suggests that other fuel sources and mixes may be
used. Furthermore, we note that the air quality assessment assumes that no heavy metals,
dioxins, hydrogen chloride and hydrogen fluoride will be produced when virgin wood only
is burned. We believe this is a questionable assumption that is not supported by research
evidence33.
There is also no clear information provided by the developer on the assumptions that
underpin the composition of the waste wood fuel that may be used. It is therefore
impossible to judge how realistic the air quality impacts proposed by the developers are.
Given that waste wood may contain lead paints, creosote and other chemical treatments, it
is important to get an accurate picture of how these may impact on the health of local
residents when they are burnt.
During the operating lifetime of the plant, new arrangements for managing air quality will
come into force. These will include a ʻreduction targetʼ for PM2.5s that is likely to be set at
10% of the Average Exposure Indicator for 2010 34. We doubt whether building a large
biomass plant in an area of ongoing regeneration will help to achieve this statutory target.
For these reasons the developer should not receive consent for the plant until they can
demonstrate without doubt that it will have no impact on local human health.
4.2 Impact on sites of high conservation value.
The cumulative impact of the proposed plants in the Firth of Forth will lead to air quality
exceedences for various pollutants in many locations protected for nature conservation
reasons. These include the Imperial Dock Local Leith Special Protection Area, The Firth of
Forth Special Protection Area/ Site of Special Scientific Interest and the Arthurs Seat Site
of Special Scientific Interest. For this reason the Leith plant should not receive consent to
operate.
The plant will return cooling water to the Firth of Forth at a temperature 10 degrees
centigrade warmer than the ambient temperature. We do not find claims from the
developer that this will have no impact on marine ecology credible.
4.3 Local traffic impact
Local residents are particularly concerned about the traffic impact of the proposal on the
local area. This said, the precise nature of this traffic impact on the area is unclear as
different parts of the application cite different figures, and it is not clear whether all the
vehicle journeys have been taken into account as part of the supplied transport
assessment.
33 “Standardized Toolkit for Identification and Quantification of Dioxin and Furan Releases”. UNEP. Available
at: http://www.chem.unep.ch/Pops/pcdd_activities/toolkit/Toolkit%202-1%20version/Toolkit-2005_2-1_en.pdf
34 Consultation on the Transposition of Directive 2008/50/EC on the European Parliament and of the Council
of 21 May 2008 on ambient air quality and cleaner air for Europe. Scottish Government. Available at: http://
www.scotland.gov.uk/Publications/2010/01/25153504/5
Adding up all the journeys associated with the normal operation of the plant, including staff
journeys, fuel lorries, ash lorries, and lorries bringing “additional supplies” we calculate
that the plant will generate 136 vehicle movements per day, with many of these
movements occurring during peak times. This is equivalent to one vehicle movement every
ten minutes, every hour, of every day of the year.
Whilst Forth Energy may claim that the majority of the heavy goods vehicle traffic will not
affect the already congested and narrow routes in Leith as it is to be routed via Seafield
Street and the bypass to the east, like many locals we question whether the routing
protocols can realistically be consistently guaranteed.
Residents of the Shore know from bitter personal experience35 that lorry drivers that use
GPS navigation tools are frequently directed via smaller residential streets that have not
been designed for this type of traffic, regardless of officially agreed HGV protocol routes.
Already traffic levels on The Shore/ Bernard Street are causing structural damage to some
of the areas most historic buildings in the Leith Conservation Area.
Furthermore, we note that during the construction phase of the plant that the project will
have a noticable, detrimental impact on the local area. Para 5.1.11 of the Sustainability
Statement states:
“During the peak of the construction phase (2014 with 700 construction staff), there is
predicted to be a potential for difficulty crossing roads by pedestrians (severance).”
The transport study appears to take no account of the further travel disruption that will be
caused by laying the grid connection cable or the laying of any pipes associated with the
district heating system. Should these works coincide with the completion of the Edinburgh
Tram network to Newhaven, then considerable travel disruption could occur.
Lastly, we remain unclear why bulky supplies and ash cannot be transported onto and off
site via the existing railway line to the docks.
5.0 National Energy Policy
The latest Draft Electricity Generation Policy Statement summarises the current Scottish
Government view on biomass thus:
"The Scottish Government would prefer to see biomass deployed in heat-only or combined
heat and power schemes, off gas-grid, at a scale appropriate to make best use of both the
available heat, and of local supply."
35Leith campaigners hoping for a car free zone on the Shore. The Scotsman. Available at: http://
news.scotsman.com/edinburgh/Leith-campaigners-hoping-for-a.5768400.jp
It continues:
"Whilst the Scottish Government is not categorically opposed to large scale development,
it is likely that the larger the proposed scale, the more difficult it will be for the developer to
utilise the heat generated and to source supply locally. Hence any development should be
scaled appropriately to make efficient use of the available heat and local supply. Large
scale developments which do not maximise heat use may also displace supply from our
priority of delivering our heat target."
This policy has been restated by the First Minister and the Environment Minister in
parliament when asked about the Forth Energy proposals. The Forth Energy plants are not
scaled to maximise the use of heat, nor are they off the gas grid. Therefore, they do not
support National Energy Policy and should not be given consent.
Similarly, The Scottish Renewable Heat Strategy 36 explicitly supports the development of
CHP schemes to provide renewable heat. The Scottish Energy Efficiency Action Plan37
has also identified that 56% of the Scottish Government's carbon emission reduction target
in domestic buildings must be delivered through CHP with district heating.
Despite the rhetoric of Forth Energy, it is clear that their current proposals for Leith,
designed to generate more electricity than heat, runs counter to both the Renewable Heat
Strategy and the Energy Efficiency Action Plan.
If the plant is given consent, there is a risk that scarce biomass fuels will be used to
generate electricity inefficiently in these plants. This will raise fuel costs and make smaller,
more efficient, off gas grid CHP installation more expensive to operate.
In addition, as the plants are located on the ʻnatural gas grid,ʼ even in the unlikely event
that some of the heat is used - it will not deliver large carbon savings as it will be likely to
displace gas heating, which is relatively low carbon. The current Scottish Government is
correct to seek to deploy biomass away from the gas grid as this is where the potential for
carbon savings is greatest.
For these reasons the proposals should not be granted consent.
6.0 Planning Policy
The proposed plant is in contravention of every planning policy, from the national scale to
the most local plans. For this reason it should not be given consent.
36“Scottish Renewable Heat Strategy” Scottish Government. Available at: http://www.scotland.gov.uk/

Publications/2008/03/11102501/0
37
“The Scottish Energy Efficiency Action Plan” Scottish Government. Available at: http://
www.scotland.gov.uk/Topics/Business-Industry/Energy/Action/energy-efficiency-policy/ActionPlan
6.1 National Planning Framework Document (NPF2)
The National Planning Framework (NPF2) Document38 states that: "Biomass plants should
be sited where they can make best use of locally available resources" (para 148). The
Forth Energy plant is designed primarily to generate electricity. Therefore, given the
distance and quantity of fuel that will be required to travel to supply to the plant, it is
difficult to see how the Forth Energy proposal for Leith could be said to be of an
appropriate scale, or in an appropriate location to comply with this policy.
The same document also states:
"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" (para 164).
Again, the scale and lack of guarantees provided by Forth Energy regarding the
development of a local district heating system, do not align well with this objectives set out
in NPF2.
6.2 - Edinburgh and Lothians Structure Plan
The proposals are not supported by the current Edinburgh and Lothian Structure Plan39 . It
states that support for renewable energy projects is:
“...based on the principle that it should be accommodated where the technology can
operate efficiently and environmental impacts can be addressed satisfactorily.”
As we have established earlier, in our view the proposed plant will not operate efficiently,
and the environmental impacts have not been addressed satisfactorily. Therefore, the
plant should be given consent.
6.3 - Edinburgh City Local Plan
The proposed site for the proposed power plant is not supported by the Edinburgh City
Local Plan40 . There is land earmarked for a power plant to the east of the docks - near
Seafield sewerage works. However, the site proposed by Forth Energy is currently zoned
primarily for use as public green space in the future. Therefore the proposal should not be
given consent as it runs contrary to the Edinburgh City Local Plan.
38“The National Planning Framework 2”, Scottish Government. Available at: http://www.scotland.gov.uk/
Publications/2009/07/02105627/0
39“Edinburgh and Lothians Structure Plan 2015.” Available at: http://www.elsp.gov.uk/
CurrentStructurePlan.htm
40“Edinburgh City Local Plan.” City of Edinburgh Council. Available at: http://www.edinburgh.gov.uk/
downloads/file/1991/eclp_written_statement_part_4_chapters_10-11
6.4 Leith Docks Development Framework
Forth Ports obtained outline planning permission41 to redevelop the docks, largely in
accordance with the Edinburgh City Local Plan, and the Leith Docks Development
Framework42 (LDDF), which provides further supplementary planning guidance relating to
the area.
We note the overarching aim of the LDDF:
“To provide an extension of Leith and the city which integrates the old and new areas in a
mixed, balanced and inclusive waterfront community while responding to contemporary
aspirations, concerns and ideas regarding urban planning.”
The Forth Energy power plant proposals are not supported by the LDDF and contradicts
many of the key aims of that document.
Forth Energy and Forth Ports claim that the impact of the global economic recession has
slowed the pace of regeneration in the docks - and therefore that the proposed power
plant will be built, and then removed after around 25 years of operation - when the
'regeneration edge' has moved from Ocean Terminal eastwards. When the plant is
removed, Forth Ports claim that they will revert to a plan akin to the original LDDF, based
largely on mixed use residential/leisure/office/retail.
In our view, this vision is not credible, and Forth Ports must present a revised vision for the
regeneration of the whole docks to accompany this proposal. If the power plant is built, it is
unlikely that mixed use regeneration will ever move eastwards from Ocean Terminal -
given the ʻblightʼ that will be caused by the widespread perception that large power plants
are 'bad neighbours'.
There are several proposed developments in the near vicinity of the site that have already
received planning consent. All of these developments would be significantly impacted by
the proposed plant.
We note also that the site where the proposed power plant is to be built is earmarked as
public green space. Neither Forth Energy, nor the landowners, Forth Ports, make any
alternative proposals as part of this application to provide an equivalent area of green
space within the LDDF area.
According to the City of Edinburgh Council Open Space Strategy 43, Leith residents have
access to far less green space than the city wide average. Meanwhile, key existing green
spaces are already acknowledged as below standard and in need of investment.
41
“Leith Docks Outline Planning Application”. Forth Ports. Available at: http://
www.leithdocksdevelopment.com/documents.asp
42
“Leith Docks Development Framework”. City of Edinburgh Council. Available at: http://
www.waterfrontcommunitiesproject.org/downloads/Edinburgh/LDDF_Complete_Document.pdf
43 “Open Space Strategy” City of Edinburgh Council. Available at: http://www.edinburgh.gov.uk/downloads/
file/2016/open_space_strategy
Part of the Open Space Strategy, the Leith Action Plan44 sums up the local planning
policies for this site:
“The Leith Docks Development Framework adopted by the Council as supplementary

planning guidance sets out a long term vision for the redevelopment of Leith Docks. The
framework identifies this site as Central Park and states that a major new community park
should be developed providing amenity for a variety of leisure pastime activities.”
“The park should have a mix of uses. There should be no public roads through the park to
allow an uninterrupted landscape between the two docks, and incorporate existing dock
features such as the cranes, rail lines and cobbling into the landscape design.”
“The site is identified in the ECLP as an open space proposal for a publicly accessible
park.”
Were the Forth Energy proposal to be given consent, without considering the impact on
the wider regeneration proposals for the area, there is a risk that the area could be ʻover
developed.ʼ at too high a density and without regard for the needs of local residents, both
current and future, for access to quality, local, free to access, green space.
Before the Scottish Government consider giving consent for these proposals, the
developer, and the landowner, Forth Ports must provide a binding commitment to provide
an equivalent amount of public green space elsewhere in the Leith Docks regeneration
area. If this is not forthcoming, consent should not be granted.
6.5 The Draft Waterfront Area Development Framework
The City of Edinburgh Council is developing a Draft Area Development Framework45 that
identifies a “Heart of Leith,” where work should be undertaken to:
“Strengthen the character of areas such as The Shore, Commercial Street and Great
Junction Street as nodes of community and city significance.”
Given the significant negative visual, economic and environmental impacts the plant will
have on this “heart” of Leith, it is difficult to see how the power plant will support this
objective of the Draft Area Development Framework.
44
“Leith Masterplan, Open Space Strategy.” City of Edinburgh Council. Available at: http://
www.edinburgh.gov.uk/downloads/file/2022/leith_action_plan
45
Draft Waterfront Area Development Framework. City of Edinburgh Council. Available at: https://
www.edinburgh.gov.uk/downloads/file/3878/draft_waterfront_and_leith_area_development_framework
6.6 Leith Conservation Area
The proposed power plant will have a negative visual, economic and environmental impact
on large parts of the Leith Conservation Area. We note that the current Leith Conservation
Area Management Plan46 states the following on how development on the docks should
relate to the Conservation Area (2.4):
“It is essential that this extension of Leith to the seafront builds on the existing character of
Leith and the docks, with high quality public realm and modern buildings that change in
scale and architectural treatment to repeat the characteristics of the various key elements
of the site.”
The power plant proposal will have a negative impact on many of the key assets that the
Leith Conservation Area seeks to protect. These are summarised in paragraph 2.10 of the
Management Plan:
“The Leith Conservation Area Character Appraisal identifies the following significant
character elements:
• the areaʼs unique and complex architectural character.

• the concentration of buildings of significant historic and architectural
quality.
• the unifying effect of traditional materials.
• the multiplicity of land use activities.
• the importance of the Water of Leith and Leith Links for their natural heritage, open space
and recreational value.”
We are not convinced that the proposal will have any positive benefit on the Leith
Conservation Area, or on the key assets that the management plan sets out to protect and
enhance. Therefore, the proposal should not receive consent.
6.7 The Harbour, Leith Docks Masterplan
Forth Ports already has permission to build two smaller, 'energy centres' to provide heat
and power to the mixed use developments associated with the Leith Harbour
masterplan47 . These proposals gained planning consent in 2010. In light of this, it is
difficult to understand how the larger proposal can be justified, or regarded as compatible
with these earlier plans.
Indeed, these earlier proposals mitigate against many of the objections we raise to the
current power plant proposal, primarily because their smaller scale allows for them to be
developed in tandem with regeneration efforts in the area, improving the likelihood that it
will be possible to implement these plants as genuine, efficient, low carbon, CHP plants at
the outset.
46
“Leith Conservation Area Management Plan.” City of Edinburgh Council. Available at: http://
www.edinburgh.gov.uk/downloads/file/610/leith_conservation_area_management_plan
47“Leith Harbour Planning Application,” Forth Ports. Available at: http://www.leithdocksdevelopment.com/
documents-theharbour.asp
Therefore, we believe it is reasonable to question whether the huge visual impact, and
potential carbon emissions associated with the much larger plant proposed by Forth
Energy are required at all? 48 Forth Energy do not address this issue sufficiently in their
application, and of for this reason consent should not be given.
7.0 Visual Impact
The proposed plant will be large - with 120m high chimney. They will have a significant
visual impact on the whole of the city, not just Leith. Indeed, the Director of Forth Energy
has acknowledged that the proposed Forth Energy plant "certainly will not be attractive."49
To date public information provided by the developer has been sparse, unrepresentative
and in some cases it would appear to be designed to deliberately mislead the public.
We note for example, that photographs have been taken so that nearby signs, or trees,
deliberately obscure key parts of the site from some viewpoints. Early feedback from the
City of Edinburgh council at the scoping stage on micro-siting of photographs, and the
quality of visual images has been ignored.50 Some of the materials presented to the public
give illustrations from points that are physically impossible to see the plant from.
Visual mock-ups of how the site will appear do not include the plume from the top of the
chimney, nor do they give any realistic sense of the relative scale of the proposed
buildings or their relationship to their immediate surroundings.51
The Forth Energy proposals appear to disregard a key component of the Leith Docks
Development Framework - "the view corridors." These view corridors were said to
safeguard key views into and out of the Edinburgh World Heritage site, and were based on
an Edinburgh skyline study undertaken in 2007 52. It would appear that the plant will block
views along at least two of the 'protected' view corridors that were established in the
Skyline study and incorporated into the LDDF as statutory planning guidance.
UNESCO conducted an investigation in 2009 into the management of the Edinburgh World
Heritage site. In their report it says:
"The mission specifically considered that the skylines study (Colvin & Moggridge) was an
important and proactive tool to protect important views...and to ensure the visual integrity
of the World Heritage property and its skyline. This tool can be used to assess any new
developments and specifically high-rise buildings in the future."
48“Biomass Heat: Who wants it?” Greener Leith. Available at: http://www.greenerleith.org/greener-leith-news/
2010/4/29/biomass-heat-who-wants-it.html
49“Leith BIomass Plant - Itʼs Certainly Not Going To Be Attractive” Scotsman. Available at: http://
news.scotsman.com/opinion/Leith-biomass-plant--It.6609166.jp
50 “Gate Checking Document for Forth Energy Biomass Application” Scottish Government. Available at:
http://www.scotland.gov.uk/Topics/Business-Industry/Energy/Infrastructure/Energy-Consents/Applications-
Database/Biomass/Leith-Index/gate-checking
51
“Biomass Concept Proposed for Leith” Gordon Murray Architects. Available at: http://
www.gordonmurrayarchitects.com/?p=2483
52“Edinburgh Skyline Study” City of Edinburgh Council. Available at:http://www.edinburgh.gov.uk/info/1220/
conservation/1273/edinburgh_skyline_study/1
Given the significant visual impact of the plant, and the importance of tourism to the
Edinburgh and Leith economy, consent for this proposal should be refused.
8.0 Socio-Economic Impacts - Regeneration choices
In the planning application Forth Energy claim the plant will generate 750 temporary jobs
and 75 operational jobs. They maintain that the construction of the plant will not affect the
ongoing efforts, pursued by Forth Ports themselves, to promote mixed use regeneration in
other neighbouring parts of the docks. They also maintain that the proposal will have no
negative economic impacts on the Shore, or the wider area.
The developer fails to acknowledge that the regeneration plan set out in the Forth Ports
OPA to promote mixed use regeneration of the docks would, according to Forth Ports own
figures, generate the following:
• 15,900 new homes

• 11,600 direct jobs
• 6,000 net additional jobs.
• £194 million per annum Gross Value Added (GVA) for the Edinburgh economy.
• For the Scottish economy as a whole there will be a predicted 7,500 net additional
jobs and GVA growth of £248 million per annum. The development will provide an
additional estimated £28 million in Council Tax revenue and a further £28 million in
business tax revenue.
Of course, if the biomass plant is built, some of this growth may happen anyway. However,
despite the claims made by the developer, the power plant will clearly be regarded by
many as a 'bad neighbour' development.
It is apparent to us that there are considerable socio-economic benefits available to Leith,

Edinburgh and indeed Scotland as a whole, available by retaining the original,
democratically agreed regeneration masterplan. Conversely, it would appear that there are
considerable downside risks associated with disregarding the LDDF, simply to allow Forth
Energy to build a giant, temporary, inefficient, publicly subsidised power plant.
It is important to consider that local business representatives are extremely concerned

about the impact that the plant would have on the local leisure and tourism economy
around the Shore. The Chairman of the local pubwatch group, Calum MacKay 53 said:
"I put the plans to our members, and the overwhelming sense was one of sheer horror.
The plant will have a terrible effect on the aesthetics of the area. How can they expect that
tourists will continue to come down to the area, and have a glass of wine or a coffee on the
Shore whilst staring at a great big power station? This proposal will kill Leith. Absolutely kill
it."
Similarly, the Leith Business Association, which represents small businesses along Leith
Walk and Constitution Street have voiced public concerns over the travel disruption and
economic impact that laying the grid connection and any district heating network could
have on the wider neighbourhood. Given the clear economic impact of the Edinburgh tram
works on some independent retail businesses, there would seem to be some justification
in this.
53“Proposed Power Plant on Leith Docks could kill business” STV. Available at: http://local.stv.tv/edinburgh/
news/6766-proposed-power-plant-on-leith-docks-could-kill-business/
We note that the Forth Energy economic impact data provided with the study makes no
attempt to quantify the negative economic impacts the plant is likely to have on existing
small independent businesses in the retail, leisure and tourism industry.
In our view, given the clear local consensus that the plant will have a negative economic
impact on many local business sectors, the proposal should not receive consent. It would
appear that there is a real risk that the benefit of the 70 jobs created by the plant could be
at the expense of at least as many jobs lost in the local area in independent businesses in
the tourism, retail and leisure sector.
If the plant is given consent, the developer must be required to provide ongoing annual
community benefit funding to help to mitigate the ongoing negative economic impact on
the area. This is a common practice in the development of wind farms in rural areas. We
believe that the same principle should apply to this development and we understand that
Scottish Government ministers are keen that local communities benefit from renewable
energy developments directly.54
8.1 Socio-Economic Impacts - Impact on Edinburgh Tram line 1a business case
Section 4.14.4 of the Planning Statement reads:
“...it is considered that there are no grounds to justify any contribution towards the tram,
associated with the development proposals.”
At the time of writing, it appears unlikely that tram line 1A will be delivered to Newhaven
within the current budget available to the City of Edinburgh Council. It is our understanding
that the business plan for the tram was predicated on the existing mixed-use plan for
regeneration on the docks as set out in the current local plan.
We are not alone in the view that the completion of tram line 1a to Newhaven is essential
to the continuing regeneration of Leith and the City of Edinburgh as a whole55. For
example, page 12 of the recent Holyrood election ʻmanifestoʼ produced by the Edinburgh
Chamber of Commerce reads56:
“The tram is a well researched and attested solution to alleviate levels of congestion, offer
quicker transit times in Edinburgh. It is not in Scotland’s interests to have a major
investment incomplete in the capital’s infrastructure. The initial and most difficult phases
(of moving utilities and then laying the track in the City Centre) are well advanced. As Audit
Scotland reported in February, Government must support the completion of this phase.”
However we are concerned that this development could compromise the business case for
tram line 1A by reducing both the private sector contribution to the project during the
capital phase, and reducing the scope for mixed use regeneration on the docks. In the
longer term, this could reduce revenue returns generated by the line, crippling the project.
54“Dundee Adendum -Renewable Strategy and Onshore Renewables Policy Team Response” Scottish
Government. Available at: http://www.scotland.gov.uk/Topics/Business-Industry/Energy/Infrastructure/
Energy-Consents/Applications-Database/Biomass/Dundee-Addendum-Index/Renewables
55
“Poll Results: Leithers want tram to run to Newhaven” Greener Leith. Available at: http://
www.greenerleith.org/greener-leith-news/2010/6/26/poll-results-leithers-want-tram-to-run-to-newhaven.html
“Business Leading the Way” The Edinburgh Chamber of Commerce. Available at: http://
56
www.edinburghchamber.co.uk/wmslib/news/files/Edin_Chamber_Manifesto_final_21_Feb_2011.pdf
This could lead to a greater financial burden being placed on local tax payers for many
years to come - even if more funding is found by Holyrood to complete the line to
Newhaven.
For this reason the plant should not receive consent.
8.2 Socio-Economic Impacts - Public Subsidy
Forth Energy will not disclose the amount of public subsidy that they expect to receive for
generating 'renewable energy' over the lifetime of the plant. However, our own calculations
suggest that the plant will attract at least £1billion in public subsidy for renewable electricity
generation alone in the first 20 years that it operates.This £1billion is additional to the
money the company will receive for selling the electricity.
Forth Energy describe the plant as £600million investment in Leith. It would seem that, if
the plant is given permission to operate, it is the public who pay for this plant through their
fuel bills. Given that the plant is unlikely to deliver any carbon savings at all, compared to
coal, in the first twenty years of its operation, it is reasonable to ask whether this proposal
delivers value for money?
This is a particularly pertinent point given that one reason domestic fuel bills are rising is to
fund subsidies to decarbonise our fuel supplies. There is a proven link between the cost of
domestic energy and the number of households living in fuel poverty. At present more than
a quarter of all scottish householders live in fuel poverty.57
In addition to the considerable public subsidy that will potentially be provided to Forth
Energy for the Leith Biomass plant, it is also pertinent to note that the Forth Ports is one of
the chief beneficiaries of the Tax Incremental Funding initiative recently approved by the
Scottish Government.
Key investments will be made in Forth Ports property, funded by an £84million tax payer
backed loan, with a view to promoting mixed use regeneration of the docks area. The
investment is likely to include the improvement of the Ocean Terminal Shopping Centre,
the development of a cruise liner port, improvement to the lock at the mouth of the docks
and better road transport links.58
Given the significant visual impact of the proposed power station proposed by Forth
Energy, it is difficult to understand how the proposed power plant can possibly be
compatible with any strategy to promote increased tourism and mixed-use regeneration of
the area. Indeed, whilst the financial risk associated with borrowing £84million to support
mixed use regeneration of the docks remains with the local tax payer, we note that the
profits associated with the power plant, supported by further public subsidy will be
distributed to the shareholders of Forth Energy - Forth Ports and Scottish and Southern
Energy.
57
“Scottish Fuel Poverty Forum Annual Report 2009-2010” Scottish Government. Available at: http://
www.scotland.gov.uk/Resource/Doc/1035/0113211.pdf
58
“Edinburgh gets go-ahead for £84m waterfront funding” City of Edinburgh Council. Available at: http://
www.edinburgh.gov.uk/news/article/140/edinburgh_gets_go_ahead_for_84m_waterfront_funding
However, these are not the only significant public subsidies that are destined for Leith.
Forth Ports also has a 'registered interest' in the Scottish National Renewables
Infrastructure Fund.59 This is a fund that aims to support the development of Scottish ports
to supply the growing offshore renewable energy industry. This could see an estimated
£35million from the public purse invested in improving Leith Docks.
Most people might agree that this last investment might lead to some actual green jobs -
manufacturing wind turbines and wave, or tidal power generators. Those 'green jobs' might
be more credible if they were using electricity that is actually 'green' too. Yet, as we have
demonstrated above, in the coming decades power from the national grid is likely to be
lower carbon than the power generated by the proposed Forth Energy plant.
It's worth bearing in mind the scale of the total value of these various public subsidies is
many times greater than the size of the cuts that the City of Edinburgh Council must make
in the coming years as a consequence of the economic downturn. The fact that Leithers
will soon start to see the impact of these public sector cuts in the neighbourhood makes it
even more imperative that the various stakeholders involved work together to make sure
that all tax payers get value for money.
The various regeneration projects proposed on the docks are not inexorably linked, and a
manufacturing hub for renewable energy can be developed without the biomass plant.
Indeed ʻgreenʼ manufacturing may be more compatible with the mixed use regeneration of
other parts of the docks, as it may involve less visual impact, and fewer ʻbad neighbourʼ
impacts.
Furthermore, we note recent policy changes that mean that the council itself can invest
directly in renewable energy generation - and derive an income from the proceeds. Smart
partnership working between the public, private and community sectors could see much
greater local economic benefits, whilst minimising the environmental and social costs of
development.60
In our view the Forth Energy biomass plant does not deliver social, economic or
environmental benefits to justify the huge public subsidy it will receive. For this reason, it
should not receive consent to operate.
9.0 Lack of public support
Forth Energy has consistently tried to misrepresent local public opinion towards the
proposal, and failed to engage promptly, or in sufficient depth, with concerns raised by
local residents. Despite early engagement, the design of the proposed scheme has not
been modified at all, despite a great deal of negative feedback from local residents. To
date, we understand that local opposition is considerable:
• The Leith Links Community Council, The Leith Harbour and Newhaven Community
Council, The Leith Central Community Council, Trinity Community Council and the
Broughton and New Town Community Councils have all voted to oppose the plans.
59“Forth Ports Trading Statement 20/12/2010” Forth Ports. http://www.forthports.co.uk/ports/media/news/

pressrelease.jsp?ref=236
60 “How Forth Energy Could Win Friends and Influence Leithers” Greener Leith. Available at: http://
www.greenerleith.org/greener-leith-news/2010/10/27/how-forth-energy-could-win-friends-and-influence-
leithers.html
• Several local residents associations are opposed to the plans. At the time of writing We
note that local councillors have not received a single representation from any of their
constituents in favour of the proposal.61
• The Shore Pubwatch group and the Leith Business Association have voiced opposition
to the plans.
• Local councillors, MSPs and MPʼs spanning a range of polical parties are all opposed to
the plan.
• An online petition opposing the proposal has been signed by more than 700 people at
the time of writing62.
• The proposal led to the formation of a dedicated campaign group which acts as a
ʻfederationʼ of people and organisations opposed to the plant. The group has gained
considerable local support.63
The treatment of local residents concerns at a recent public meeting was deeply
unsatisfactory.64 Despite assurances from the developer that all specific questions
submitted prior to the meeting would be answered promptly with the responses placed on
the Leith Neighbourhood Partnership website, it would appear unlikely that any response
will be made available before the end of the formal public consultation process.
There is clearly no public support for the proposal. For this reason the plant should not be
given consent.
About Greener Leith
Greener Leith was established by local residents in 2006 to promote community

involvement, sustainable development and public public spaces. Our management
committee is democratically elected from our membership and drawn entirely from local
residents. The management committee includes energy experts, landscape architects,
community involvement professionals and planners.
Greener Leith has more than 466 local supporters, and is a strong advocate for
meaningful action on climate change. Our projects, have led to significant independently
verified annual carbon savings in the neighbourhood. We are actively pursuing the
development of community owned renewable energy projects in the neighbourhood.
You can find out more about Greener Leith at www.greenerleth.org
61“Leith Councillors struggle to find supporters of biomass plant.” The Guardian. http://www.guardian.co.uk/
edinburgh/2011/feb/24/edinburgh-leith-biomass-protest-scottish-parliament
62“No to Leith Biomass Petition”. No Leith Biomass Campaign. Available at: http://www.gopetition.com/
petition/39477.html
63“About us” No Leith Biomass Campaign. Available at: http://www.noleithbiomass.org.uk/#/about-us/
4544591970
64 “The Big Biomass Meeting - The Tweets” Greener Leith. Available at: http://www.greenerleith.org/greener-
leith-news/2011/2/9/the-big-leith-biomass-meeting-the-tweets.html

Forth Energy Leith Biomass Objection

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Forth Energy Leith Biomass Objection

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! ! Greener Leith!

! ! 36, Newhaven Road

Lesley McNeil, The Scottish Government

3rd March, 2011

Objection to the proposed Forth Energy Leith Power Plant

In summary, we strongly object for the following reasons:

The Environmental Assessment supplied by the developer makes no assessment of how

4. Local environmental impact

5. National energy policy

We provide a detailed elaboration of these points below.

“As a result of renewable generation ambitions and interconnection upgrades, there is no

Similarly, The Power of Scotland Secured Report2 concludes:

The CHP feasibility study continues:

Given the practical constraints we outline above, we believe there is no reasonable

2.1 Quality of CHP feasibility study.

3. Carbon Savings Claims

On page 26 of the Sustainability Statement9, in the footnotes, it is acknowledged that the

3.2 Claimed Carbon Savings: Comparison to unabated coal emissions

3.3 Claimed Carbon Savings: Use of heat

The application should be rejected, as the Sustainability Statement is based on over

3.5 Claimed Carbon Savings: Use of Energy Crops

As the Sustainability Statement is based on an optimistic operating scenario where

10Environmental Benefits of Recycling, 2010 Update. WRAP. Available at: http://www.wrap.org.uk/

Scottish Government legislation enshrines a commitment to reduce our national carbon

As a consequence, we note that the Scottish Government has announced a policy

3.7 Claimed Carbon Savings: Fuel Sources

19“National Call To Halt Big Biomass.” Greener Leith. http://www.greenerleith.org/greener-leith-news/

“...technology efficiency; in addition to accounting for fuelʼs inherent efficiency. Moreover,

If the application is to be given consent, specific planning obligations should be placed

4.1 Air Quality

"While we welcome, in principle, any attempts to increase the provision of renewable

"Following the application submitted to the Scottish Government by Forth Energy, we

4.2 Impact on sites of high conservation value.

4.3 Local traffic impact

5.0 National Energy Policy

For these reasons the proposals should not be granted consent.

6.0 Planning Policy

36“Scottish Renewable Heat Strategy” Scottish Government. Available at: http://www.scotland.gov.uk/

The same document also states:

6.2 - Edinburgh and Lothians Structure Plan

6.3 - Edinburgh City Local Plan

We note the overarching aim of the LDDF:

“The Leith Docks Development Framework adopted by the Council as supplementary

6.5 The Draft Waterfront Area Development Framework

• the areaʼs unique and complex architectural character.

6.7 The Harbour, Leith Docks Masterplan

7.0 Visual Impact

8.0 Socio-Economic Impacts - Regeneration choices

• 15,900 new homes

It is apparent to us that there are considerable socio-economic benefits available to Leith,

It is important to consider that local business representatives are extremely concerned

8.1 Socio-Economic Impacts - Impact on Edinburgh Tram line 1a business case

Section 4.14.4 of the Planning Statement reads:

For this reason the plant should not receive consent.

8.2 Socio-Economic Impacts - Public Subsidy

9.0 Lack of public support

59“Forth Ports Trading Statement 20/12/2010” Forth Ports. http://www.forthports.co.uk/ports/media/news/

About Greener Leith

Greener Leith was established by local residents in 2006 to promote community

You can find out more about Greener Leith at www.greenerleth.org

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