Leith Central Community Council – like its Broughton and New Town equivalent – has now formally objected to Forth Energy's proposed biomass plant in Leith.
The text of Secretary Roland Reid's letter appears unedited below.
Today's Guardian local quotes the finding of Shirley-Anne Somerville, MSP, that 1,200 people have so far objected to the plans. Her letter of objection can be found in the pdf file at the foot of this page.
Further letters of objection (and support) will be added as and when we have them.
*****
Dear Sirs
I am writing to you on behalf of Leith Central Community Council. The application for Consent for the Leith Renewable Energy Plant by Forth Energy was discussed at our last Community Council meeting of 21 February. The Meeting agreed that I write to you in order to express our opposition to the project as proposed and to raise specific concerns as follows:
1 The Applicant states that the fuel will be predominantly (92.5%) wood chip or pellet delivered by ship. Imported fuel will represent 80-90% of the total.
We believe that this is a high risk strategy and question the sustainability of the development both in terms of cost and availability of supply. World commodity prices are currently very volatile and the present geo-political situation suggests that this is unlikely to change. Given the question over future middle-east oil supplies, the potential timber suppliers as identified by Forth Energy are likely to look to husband their indigenous biomass to safeguard their own economies.
We question if the Applicant will be able to increase the indigenous fuel supplies over time to 30% of the total. The Applicant acknowledges that should proposed plans for this and other plants progress "it would place a strain on internal supply markets". We believe that it would not be prudent of Scottish Ministers to approve this application on the basis of the Applicant's assertion that "not all these plants will be developed". Furthermore, sectors outwith the traditional wood based industries may also look to make use of wood fibre. We note that straw can currently cost as much as £20.00/bale. Farmers are now investigating the use of wood waste as alternative animal bedding material.
We believe it would be more appropriate and prudent for the Scottish Government to direct support to the further development of wind, wave, tidal and to mitigate the impact of coal fired power stations by carbon capture . We support the establishment of Leith as centre for the research and development of indigenous renewables in the areas identified for commercial and industrial in the Leith Docks Development Framework. We support the proposed small scale combined heat and power plants serving identified local users as outlined in the LDDF.
2 We believe that this application should be viewed by Scottish Ministers as a power only generation plant and for this reason a moratorium be placed on consideration of this application until the Scottish Government Review of ROCs for this type of plant is completed. The potential users of waste heat as outlined in the document are vague. The Applicant cites commercial confidentiality as a reason for not providing detailed proposals. However, we again believe it would be a high risk to approve a plant that is more than likely to have waste heat warming the Forth. We question if developers will invest in the heating supply infrastructure connecting to a plant that has only a guaranteed life of 20 years i.e. the period of ROC. Given the situation regarding the trams we question if there would be public support for yet more disruption to lay services.
3 The Application is contrary to the Leith Dock Development Framework and Outline Planning Application Docks Masterplan. We find that the Applicant's proposal to create a park on an alternative location a glib response. The LDDF and subsequent OPA evolved over lengthy discussions with stakeholders including the Leith Community Councils. The proposed central park (site of the biomass plant), located at the heart of the development surrounded by higher density housing, linking to the proposed waterfront promenade and to be served by the tram was a key element. The proposed location of the biomass plant seriously jeopardises the docklands project and undermines the "vision" for the waterfront. Developers, social housing providers, and residents may question if Forth Ports are a reliable and credible partner in respect of future residential developments.
4 We note that the Applicant states that "there are no grounds to justify any contribution to the tram". This represents a further blow to the viability of the tram project. It should be remembered that one of the principle objectives of the tram initiative was to facilitate the residential redevelopment of the docklands. Leith Central Community Council represents the Leith Walk area which has suffered significant disruption over recent years due to the tram works. The biomass proposal adds to the uncertainty and doubts over the completion of the tram line to Leith.
Members have also raised concerns in respect of the predicted emissions, disposal of the ash, the impact on local roads, the visual impact and the risk to Waterfront recreation and tourism. We are aware that our partner organisations having submitted detailed objections in respect of these aspects with which we concur.
Yours faithfully
Roland L Reid
Secretary, Leith Central Community Council