Tomorrow is the deadline for objections and comments on the proposed Leith Biomass proposals. This is what I have sent in, and I urge others to do likewise!
Proposed Biomass ‘Renewable Energy’ Plant at Leith Docks, Edinburgh
Application by Forth Energy under Section 36 of the Electricity Act 1989
I object to the application for a Biomass Plant at Leith Docks made by Forth Energy and detailed above. I am a City of Edinburgh Councillor representing the Scottish Green Party in Leith Walk ward, which adjoins the ward in which the Plant is proposed.
My objection is on the following material grounds:
2. Visual impact;
3. Air quality;
4. Traffic Congestion;
5. Marine ecology.
I wish to raise these additional points:
1. Sustainability and fuel security;
2. Climate Change and Greenhouse Gas Emissions;
3. Market for district heat.
The location of a major power station in a heavily urban environment is inappropriate. It conflicts with existing Plans, in the form of the Edinburgh City Local Plan and the Leith Docks Masterplan. The Edinburgh City Local Plan does not identify this site for power generation, and was fully consulted on as a guide for development in this area at this time. The Leith Docks area adjoins significant residential, retail and leisure areas. The reason why the Edinburgh City Local Plan does not identify this site for massive industrial facilities is that the increase in vibration, noise, light and general nuisance associated with the site would substantially diminish quality of life for residents in the immediate vicinity and across the north of Edinburgh.
2. Visual Impact
The proposed development is massive in scale. It would dominate the Leith skyline, and detract from the newly built residential, commercial, government and leisure buildings in the area, as well as the historic Leith architecture. An imposing building such as this is likely to inhibit future development as well as seriously diminishing the amenity of existing residents.
3. Air Quality
Air quality is a very serious material concern. Burning biomass creates emissions, in particular small (PM 2.5, PM10) particulate matter, which are can cause serious health problems. Irritant gases, such as nitrogen dioxide, can trigger respiratory conditions in otherwise healthy people and can be potentially deadly to those already vulnerable, which includes children and old people.
There are a number of schools and nurseries within a mile of the proposed site. Even small amounts of dioxins and heavy metals (possible emissions from burning chemically treated wood) can cause cancer and birth defects. This is an unacceptable health risk to the local population.
Great Junction Street, less than a kilometre from the proposed site is an Air Quality Management Area, so significant problems already exist with air quality in the area. The Biomass plant will only exacerbate these problems.
4. Traffic Congestion
The proposed development will be fuelled substantially by seaborne biomass. There will, however, be a significant increase in HGV movements in the greater Leith area as a result of additional fuel being delivered and the removal of ash. The areas affected are largely residential or commercial, with schools and other public amenities.
The application can be read to suggest that around 20 000 heavy lorry trips will be generated per year. As already mentioned, there is an Air Quality Management Area in Great Junction Street, where emission levels are at a level that is already unacceptable. By adding thousands of lorry journeys to the already over capacity roads of Leith, emission levels will rise well above acceptable levels.
5. Marine Ecology
The discharge of cooling water, post-generation will raise ambient water temperatures. This may cause thermal shock to fish and will diminish levels of suspended oxygen, diminishing the marine biodiversity of the Forth.
1. Fuel Security
Anticipated demand for biomass far outstrips supply. This means that any plans to burn shipped-in biomass may not be sustainable. Rises in the prices of orthodox biomass may result in burning of ‘recycled’ wood. This is a fuel that may be highly toxic. There is a real concern that a plant designed to burn biomass will end up burning a wide variety of other materials including cardboard and paper. There is no binding commitment on fuel sourcing in the application, so the operator would be free to burn whatever was available and cheap. This is likely to exacerbate all of the material concerns detailed above.
2. Climate Change and Greenhouse Gas emissions
The nature of biomass power generation is such that it substantially shortens the carbon cycle of the material being burned. Because burning immediately releases carbon, it is only when the substitute biomass crop reaches maturity that this carbon is again fixed. This creates a ‘carbon debt’ that is only repaid once replanted tree crops reach maturity. Even where material would otherwise go unused, burning releases carbon more quickly than almost any natural process of biodegradation, and so the plant will make no contribution to Scotland’s Greenhouse Gas targets by 2030 and may make a very small contribution to targets for 2050.
3. Market for District Heat
The sustainability of the project, both financial and environmental, is based on supplying local district heat networks. These networks do not exist at present, nor is there any substantive indication of how they would be created. This means there are unlikely to be available clients for district heat from the early operation of the plant, and there may well be few if any at any stage of the plant’s operation.
In summary, this proposed development is wholly inappropriate.
I call on you to reject it outright.