Leith Scottish National Party

Lesley McNeil, The Scottish Government

Energy Consents & Deployment Unit
Energy Directorate, Renewable Energy Division
4th Floor, 5 Atlantic Quay
150 Broomielaw
Glasgow G2 8LU

February 2011

Dear

Proposed Biomass ‘Renewable Energy’ Power Station at Leith Docks, Edinburgh Application by
Forth Energy under Section 36 of the Electricity Act 1989

This submission on behalf of Leith Scottish National Party (SNP) should be considered as an objection
to the proposal to build and operate a Biomass Power Station in Leith Docks, Edinburgh as lodged by
Forth Energy. Leith SNP have considered the proposals and the implications of the proposal on the
communities of Leith and Edinburgh as well as considering the implications of the proposal on
Scotland and has reached the conclusion that this proposal is wrong for the local communities of
Leith and Edinburgh and wrong for Scotland.

The specifics of the objection are set out as follows;

1. Setting – The location chosen as the site of the power station while making some sense in
relation to the intention of applicant to have the wood required to fire the plant delivered
by sea, has long lasting implications for existing and future developments in Leith Docks.
There are also impacts on views to Leith from the UNESCO Edinburgh World Heritage site. In
terms of the existing developments those at Constitution Place and Ocean Way are the most
directly affected being within a few hundred yards of the proposed site. There are also
recently consented residential and hotel developments planned adjacent to the site. In
terms of the approved development plan for the regeneration of the docks (Leith Docks
Development Plan) there are plans for a series of ‘urban villages’ throughout the docks. The
site chosen for the Biomass plant would have implications for the delivery of the public open
space which was envisaged for this location. In a recent report to the City Of Edinburgh
Council’s Planning Committee (24 February 2011, Edinburgh City Local Plan – Progress with
Actions) regarding progress with the Edinburgh City Local Plan this area was highlighted as
follows ‘Open Space & Recreation Proposals Ref OSR 3, Site name: Leith Docks Central Park,
5.3 hectares publicly-accessible park’. This significant park provision in a part of Edinburgh
which has an established need for more open space would be lost for a generation or more
should the Biomass proposal go forward. There are also implications for the deliverability of
OSR 7 Leith Links Seaward Extension which would have linked Leith’s historic links park to
the seafront. The site of this extension is adjacent to the Biomass proposal. It is also worth
noting too that immediately east of the Biomass proposal there is a site identified for
educational use – a site for a new 1000 pupil capacity Secondary School. There is an existing
building of historic importance on the proposed site of the Biomass plant – a former grain
store which is a ‘B’ listed building that would be required to be demolished were the
Biomass proposal to go ahead. In the Leith Docks Development Framework this building was
 to remain in situ and is shown on the plans submitted with the Outline Planning Application
for Leith Docks.
The site and the scale of the building proposed would dwarf the existing grain store which is
itself significant in height and massing. The footprint height and massing of the Biomass
building would have a significant impact on both local views such as the historic Shore and
Bernard Street/Constitution Street as well as significant impacts on views from Edinburgh’s
UNESCO World Heritage Site. The scale of the building would in the view of Leith SNP
compromise the City Council’s views study and policy. In particular view n11b from Calton
Hill and Edinburgh Castle to the Leith shoreline would be directly affected. In a culture
where a multi-story 5 star hotel had its planning permission turned down by Scottish
Ministers it would seem strange indeed if a large industrial building which would be clearly
seen from the World Heritage Site were to gain consent. Therefore the application should be
turned down because of its impact on the World Heritage Site alone.

2. Emissions – there is concern at the risk to health of emissions from the plant and particularly
from a plant of this size (200MW). The City Of Edinburgh Council already has a moratorium
on inclusion of biomass boilers in new schools and care homes for precisely this reason.
Emissions from biomass burning release particulate matter with PM 2.5 and PM10 being of
concern for health of the local populace. There are two Primary Schools a Secondary School
and a Special School nearby as well as the previous indication in the LDDF and OPA for future
new primary and secondary schools in the docks development. One of the areas for urgent
improvement of air quality is in Leith at Great Junction Street. This plant could add to this
problem and create new areas of poor air quality. It is also stated by the applicant that
recovered wood would be sourced to supplement supplies from overseas. Such material
would be likely to be chemically treated and dioxins and heavy metal would be emitted from
the burning of chemically treated woods. The risk from this is considered as an unacceptable
health risk to the local population. There is therefore considerable concern over the impact
of emissions from such a large scale Biomass sited in close proximity to concentrations of
population and the application should be turned done on these grounds.

3. Increased Traffic - Congestion and Pollution

Although a large percentage of fuel is expected to come in by sea, there will inevitably be a
significant increase in HGV movements locally, through residential and commercial areas
and close to schools and public areas, to bring in supplementary fuel, and to remove ash.
Forth Energy’s application glosses lightly over (and probably underestimates) these but even
with their own figures, some elementary arithmetic shows a tally of around 20,000 heavy
lorry trips per year. This brings with it an unacceptable increase in traffic congestion in an
already congested urban area, along with a guaranteed increase in atmospheric pollution
and carbon emissions. This is likely to get worse over time, as the issue of fuel security and
sustainability arises, making it more likely that fuels of various types may be sourced more
locally. Great Junction Street in the heart of Leith and only a few hundred metres from the
proposed plant is already designated an Air Quality Management Area (by City of Edinburgh
Environmental Health Dept.), so allowing further high polluting development on this scale
within the area would exacerbate the situation and is simply wrong. It is also worth noting
that while Leith Docks is still an operating dock for bulk materials and as such generates
significant vehicle movements this activity is not likely to stop because of the presence of
the Biomass plant and therefore the estimate of 20,000 heavy vehicle movements would be
in addition to other docks associated traffic. It is further worth noting that significant areas
adjacent to the docks (Salamander Place/Elbe Street) and the Biomass site have changed
over the years from industrial to residential and the impact of an increase in vehicle
 impacts more widely as these vehicles disperse. The impact on the local air quality and
amenity would be such that the application should be rejected.

4. Sustainability - This proposal is framed as a sustainable green alternative to coal and gas
powered energy plants. It is claimed by the applicant that the supply of wood to fuel the
plant would come from abroad – the Baltic States, Scandinavia and the Americas have been
mentioned. They have made the case that shipping the material in is in their view of lesser
carbon impact than trucking. Baldly that may be the case but they do not factor in any truck
movements to get the material from source to port for shipping to Scotland. Given that it
has been stated by the Forestry Commission that there is not the capacity in either Scotland
or the whole UK to supply the wood required to fuel this plant (or the others proposed by
Forth Energy elsewhere in Scotland) it would seem that large scale Biomass is not the way
that Scotland should be going. Indeed the direction of travel of the Scottish Government
itself seems not to favour large scale Biomass. Therefore Leith SNP would contend that this
proposal sits well outside what should be considered as sustainable renewable energy
generation. The application does not evidence any binding policy commitment on fuel
sourcing and that raises concerns that what is stated now will be subject to change if
consent were granted. It is the view of Leith SNP that this proposal is not truly sustainable
and therefore should not be granted.

5. Combined Heat and Power Feasibility – Forth Energy’s proposals to use the heat generated
by this proposal seem to be sketchy to say the least. It was not mentioned in early iterations
of the proposal and their answers to local residents on this issue have not inspired
confidence. A list of possible customers is given in the application but apart from perhaps
those close to the plant (i.e. within the dock area) the infrastructure costs for connecting
other potential users would outweigh the benefits as Forth Energy have claimed that the
plant would have a life span of 25 years after which it would be dismantled and the
previously planned open space and mixed use development could take place. It seems only
a little odd to sign up customers and put in significant infrastructure to then shut the
operation down after 25 years. It is worth noting that creating the connections between
supplier and customer are un-costed and would entail digging up streets. This element of
the plan is unconvincing and raises real doubts about the application and the applicant’s
intention and should therefore be rejected.

6. Carbon Footprint and Climate Change - It is highly misleading to claim that the proposed
plant is ‘carbon neutral’ or offers carbon savings. Burning biomass creates an immediate
release of CO2, like any other carbon based fuel. Burning biomass actually releases more
carbon, per unit of useful energy generated, than burning gas or oil. This means that every
biomass plant creates a 'carbon debt’ that is only paid off after many decades (estimated at
40-100 years) as replanted trees reach maturity - if trees are replanted. But evidence from
around the world indicates that old forests are often not replaced ‘like for like’, but with
plantations of fast-growing ‘cash crops’, so the long term damage to the planet and to
biodiversity is potentially very extreme. So as well as threatening the health and well-being
of local residents, the proposed development will not help Scotland to meet targets for
reduced carbon emissions by 2030 or even 2050 and is damaging to the planet. For these
reasons the application should be rejected.
7. Local acceptance – Leith SNP is aware of the strong opposition to this proposal from across
Leith, Edinburgh and further afield. As a local community based organisation Leith SNP and
its representatives have been contacted by a large number of individuals and organisations
regarding this proposal. Not one of these individuals or organisations ranging from ordinary
citizens to residents organisations, environmental groups and community councils has
voiced support for this proposal. They are united in believing the proposal to be wrong for
the community and that if consented this proposal would be a ‘bad neighbour’ development
that would blight the quality of life of the locality for decades to come. It is with this
knowledge of local opinion that Leith SNP wholeheartedly calls for the rejection of this
proposal.

8. Conclusion – In considering this application Leith SNP have taken a position of being in
support of the use of renewable technologies to generate the power required to meet green
energy targets and climate change. Scotland has great potential to develop wind, wave and
tidal generation methods and technologies and has a role to play as a forerunner in these
fields. When considering the merits of this particular application we conclude that for the
reasons given above this application should be rejected. In summary it is of questionable
sustainability, visually intrusive and destructive to the shoreline and views of Edinburgh
and Leith, raises health concerns due to the potential effects of the emissions generated,
raises questions regarding its carbon footprint and its contribution if any to fuel security,
lack of acceptance in the local community. It is wrong for Leith, Edinburgh and Scotland
and should be rejected.

Please acknowledge receipt of this letter. Leith SNP wishes this objection to be registered
and permits its publication.

Signature……………………………………………………….. Organiser Leith SNP

Email…………………………………………………………………….Date…………………

Leith Branch Scottish National Party, c/o 10 Ryehill Terrace, Leith, Edinburgh EH6 8EW