Greener Leith has finally just sent a 14,000 word objection to the proposed power plant on Leith docks. Supported by more than 64 external references, our objection is based on 9 main points:
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.
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
The proposed plant is 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 ‘protected view corridors’ 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.
The proposed power station will be viewed by many as an imposing ‘bad neighbour’ 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.
You can read our objection in full here: