Friends of the Earth Tayside challenges Forth Energy’s Air Quality findings

Attached below is the Friends of the Earth Tayside response to Forth Energy’s Addendum on Air Quality, in relation to its application for a Biomass “Renewable Energy Plant” in Dundee.

Biomass submission to ECU on Forth Energy Addendum 2 by FoE Tayside FINAL

It is fairly length and the following summary remarks may be helpful.

In relation to air quality, we believe the methodology used in the calculations of nitrogen dioxide is flawed, and is designed to produce findings which are conveniently reassuring for Forth Energy. If the method recommended by the Environment Agency were applied (as in Table 11 in the Addendum) this would result in levels which are twice as high, resulting in safety levels being breached.

There is also the optimistic expectation that the Air Quality Management Plan will lead to background reductions in nitrogen dioxide levels, even though levels have actually increased since the Air Quality Management Area was introduced in 2006, and road traffic is expected to increase over the coming years.

Like NHS Tayside and Fife, we are very concerned that particulate levels have not been included in the assessment, since biomass combustion produces higher levels of the very fine particles than burning coal, and there is growing evidence of the range of serious health effects when people inhale these. These range from lower birthweight of babies, to reduced life expectancy for those surviving heart attacks.

We have also drawn attention to two other developments since consultation was carried out on the original application.

Firstly, there is clear evidence that burning trees to produce electricity can produce higher carbon emissions than burning coal, and it can take generations for new trees to re-absorb these emissions. The UK Department for Energy and Climate Change is now investigating the consequences for achieving our emission reduction targets.

Secondly, the Scottish Government’s Electricity Generation Policy Statement issued a year ago states that “we need to encourage the most efficient and beneficial use of what is a finite resource. We would prefer to see biomass used in heat-only or combined heat and power (CHP) schemes, off gas-grid, and at a scale appropriate to make best use of both the available heat, and of local supply.” The proposal by Forth Energy would meet none of these policy criteria. Even in terms of CHP, it would produce mainly electricity and would therefore be highly inefficient, burning twice as many trees and requiring heavy subsidies from the public. It would be very different from small-scale installations such as biomass boilers in schools, and district heating schemes, which are much more efficient and can help reduce carbon emissions if they use locally sourced waste materials.

There are other reasons set out in our original submission in 2010 (see attachment below), in terms of the impact on forests, biodiversity, and poor communities in other countries, why this proposal fails to meet international standards on sustainable development. But purely in terms of air pollution, it should be rejected by Dundee City Councillors next month. If it comes before Scottish Government ministers for a decision, they should reject it for all these reasons. It is completely contrary to their policy.


If you agree with us – or with just some of our arguments – please contact your local councillors before 24 June to ask them to object to Forth Energy’s application.  It’s easy, just go to this page.