Government agencies line up to criticise Leith Biomass plans

It is no secret that Forth Energy have few friends when it comes to their giant power plant proposals for Leith. However, now that the election is over, it would appear that the Scottish Government is finally getting around to publishing some of the objections that other organisations have made on the Leith Biomass plan.

Here are some of the highlights, which show that a range of government agencies have serious reservations about the proposed Forth Energy plants which echo many of the things we said in our own objection.

The Wood Fuel Task Force

The Wood Fuel Task Force was reconvened to advise the Scottish Government in the light of the increasing demand for wood fuel from biomass plants. It brings together industry stakeholders, forestry companies and government agencies. Ironically, Scottish and Southern Energy, who are a joint venture partner in Forth Energy, the company which fronts the Leith Biomass proposals, is a member of the Wood Fuel Task Force.

It must be slightly embarassing for SSE to read the full Task Force Report, given that it appears to directly criticise the wisdom of pursuing the large plants like the one they propose in Leith:

“The Task Force believes that biomass policy, rather than making a dash for biomass through a series of large scale electricity only power stations, should encourage the incremental growth of the biomass industry, focussing on heat and combined heat and power, and avoiding lock in of the resource to a small
number of large plants.”

You can read the full report here.

The Forestry Commission

The Forestry Commission response is very critical, pointing out the Forth Energy proposals conflict with Scottish Government policy on biomass. However, the most interesting bit is what they have to say about what will happen if Forth Energy get the go ahead to build all four plants they have applied for:

“If all four [biomass] plants were to be built, including Leith, then this would require up to 6 million green tonnes of fuel supply.  This volume is a very significant proportion of current global trade in biomass.  It would also mean, at 10-30% of total supply, that 0.6-1.8m green tonnes of biomass would be required from the UK.  However, there appears to be no real consideration of where that supply will come from. 

The Scottish timber harvest is currently 5.2 million green tonnes, all currently being used.  Maximum annual potential availability of timber in Scotland is projected to increase to around 7 million green tonnes by 2020 but competition for the resource is likely to be strong from both the renewable heat and timber processing sectors.  Much of this increase will be in the form of sawlogs which in added value terms would be better processed into construction products.”

Visit Scotland

Yes, Visit Scotland have voiced serious concerns, pointing out that tourism is worth £1billion to Edinburgh, and that for many Edinburgh is the gateway to Scotland. Here’s what they say about the size and location of the Leith Biomass plant:

“A 120m high chimney stack will not only be visible in Leith, but from many other parts of the city. The height of the chimney as well as the overall size of the development could undermine Edinburgh’s continued status as a World Heritage site, which plays a key part in making Edinburgh a destination of choice for so many visitors.”

And here’s what they say about the economic impact of the industrial nature of the plant:

“This will almost certainly contribute to a higher level of noise and pollution in Leith and Edinburgh, which would not be welcoming for visitors or conducive to further investment into the tourism sector in Leith. It is our view that this could undermine the destination proposition for our visitors and damage tourism growth locally.”

You can download the full Visit Scotland response here.

Architecture and Design Scotland

Architecture and Design Scotland, is a Scottish Government body that provides independent advice on placemaking and design. They also say that the plan could affect Edinburgh’s World Heritage Status:

“With regard to proposals for the site at the Port of Leith, we note that in recent years the Port of Leith has undergone widespread transformation with the development of Ocean Terminal and Victoria Quay, as well as numerous new residential areas. A significant masterplan is on going for the waterfront, which removes industry from this area and is subject to substantial support from both public and private bodies.

“A Category B listed Imperial Grain Elevator that exits on the site is proposed for demolition to make way for the proposed plant; however it remains to be demonstrated that the listed building could not be re-used as part of the proposals, and that the plant could not be positioned elsewhere on the site. The development of a plant in this area could also be detrimental to the community of Leith, as well as the city of Edinburgh’s UNESCO status.


The Scottish Environmental Protection Agency, stopped short of objecting to the Leith proposal at this stage. But they do make the following significant criticisms in their comments.

On the subject of carbon savings the plant will deliver, SEPA also echo our concerns that the Forth Energy assessment may significantly underestimate the carbon savings the plant is likely to deliver.

“In particular, we are concerned that the methodology deployed to calculate the lifetime green house gas savings of the schemes includes an assumption of zero emissions from land within the growing cycle of the fuels…This is likely to be incorrect and therefore leads to a potentially significant underestimate of green house gas emissions from the fuel. The calculation of green house gas savings from transport may also be underestimated.”

The agency is also concerned about the negative environmental impact of large plants like the the proposed Leith Biomass plant through land-use changes in other parts of the world, saying:

“It could also lead to land use change in unsustainable ways, despite a commitment to certification, through indirect land use change.”

When it comes to nature conservation SEPA had this to say:

We consider that the information included in the Environmental Statement fails to adequately demonstrate that there will not be a significant effect on the Firth of Forth Special Protection Area.”


“We consider that the Environmental Statement has failed to demonstrate that the proposed plant is unlikely to damage the integrity of a number of Sites of Special Scientific Interest (SSSIs).”

You can read the full SEPA response here.

Scottish Natural Heritage

SNH have submitted a very strongly worded objection, which is worth reading all the way through. They are extremely critical of the visual impact of the plant. 

“The prominent location, height and mass of the plant would significantly impact upon Edinburgh’s setting and on key views to and from the city. This setting is an important part of the city’s character and is a key feature contributing to the quality of the Edinburgh UNESCO World Heritage Site. Key aspects of the World Heritage Site, such as the views to and from Arthur’s Seat and the Firth of Forth coastline, as well as the many other key vistas and views that contribute to the site’s quality, need to be retained. The location and scale of the proposal means that its landscape and visual impacts could not be adequately mitigated.”

Leithers will be particularly keen to read that SNH have specifically noted the local impact of the plant too:

“We are particularly concerned that the development would impact on users of, and the general amenity of, Leith Links. 2 of the 3 viewpoints identified within and around Leith Links (classed as a premier park) will be subject to adverse visual impacts which can’t be mitigated. The 3rd will suffer significant adverse
impacts when the plume is visible. This is a particular concern given the relatively limited large greenspace available in this area for local residents.”

Given the extent of these criticisms, there can be little wonder why Forth Energy requested a six month extension to the planning process. The City of Edinburgh Council are now, we understand, unlikely to formally consider the Leith proposal until much later in the year. All of a sudden, the video clip about the Leith plant that automatically plays when you visit their website starts to look a bit optimistic, doesn’t it?

You can read the Greener Leith objection, and all the other formal comments that the Energy Consent Unit have decided to publish (they seem to be slowly publishing more and more) on the Scottish Government website, here.

We collected some local objections from local politicians and organisations on our website in this post, and note that they are not all up on the Scottish Government website yet. If you have sent an objection in you may wish to contact the Scottish Government to ask why your objection has not been made public.