Letter of objection to Dundee biomass burner
We sent the following letter today to the Scottish Government, objecting to the proposed biomass burner in Dundee:
Dear Sir/Madam
On behalf of Green Alternatives to Incineration in Scotland I wish to object to proposals for a biomass burner at Dundee docks.
As you know, the Dundee proposal is one of four biomass burners proposed by Forth Energy. The other three are Grangemouth, Leith and Rosyth. The Scottish Government itself has expressed several concerns about the proposals in its 'Scoping Opinions', including:
1. “The biomass plants exhibit similarities to the pulp and paper industry (albeit without chlorination but with combustion) which has many well-known pervasive and displaced environmental impacts" (p126 of Leith Scoping Opinion).
2. “Although biofuels are a renewable source of energy, depending on where and how they are produced their carbon payback can be very lengthy and, if particularly badly sourced may result in a net increase in emissions” (p127 of Leith Scoping Opinion).
Forth Energy says that most of the biomass will be virgin wood. This is a particularly critical time for the global climate, and although wood may be ‘renewable’ in the long term, in the short term it emits high quantities of CO2. It takes upwards of 50 years to re-grow the felled forests and thereby re-absorb the CO2 generated by burning them. Furthermore no account is made of all the energy used to extract and transport the timber from Russia etc.
3. “The proposed plant at Leith is very large (200MW), and therefore although SEPA will regulate the plant it will be challenging to control emissions to meet with the Scottish Air Quality Regulations” (p46 of Leith Scoping Opinion)
Although the proposed plant at Dundee is smaller than the Leith proposals, it will nevertheless be one of the largest biomass burners in the world. As with any type of incinerator, it will emit a lot of very fine particles in the PM2.5 micron range. A report from 2007 found that up to a third of PM2.5 particles in a medium-sized Swedish city came from a new incinerator (see reference here). Figures from the British Society for Ecological Medicine (click here) indicate that a plant of the size proposed for Dundee – 1.25 million tonnes per annum – would emit around 75 tonnes of particulates annually, mostly in the PM2.5 range. DEFRA estimates that particulate emissions produce health costs of around £40,000 per tonne. According to the European Commission, 350,000 Europeans die prematurely each year from inhaling PM2.5 particles, cutting the average life span by 8 months (click here).
4. As demand for biofuels grows around the world, there can be no guarantee of continued supplies (section 5.3.3 of Grangemouth Scoping Opinion).
The Global Alliance for Incinerator Alternatives says that wood waste often contains hard-to-detect contaminants such as chromated copper arsenate (CCA), pesticides, preservatives, lead paint, black liquor, copper, creosote and chlorine, which can result in harmful emissions.
Claims that Scotland needs to generate renewable energy from burning biomass are unfounded. A recent study by Scottish Natural Heritage shows that Scotland can meet its 2020 target for renewable electricty 3 times over without incineration. Alex Salmond recently stated that "By harnessing just a third of the potential wind, wave and tidal resource off Scotland's coast, by 2050 we could power Scotland seven times over - enabling us to become a massive exporter of clean, green energy, generating an estimated £14 billion in value and supporting around 60,000 jobs." In general we take the view that there are other, more environmentally friendly sources of renewable energy than biomass burning.
For these reasons, we ask the Scottish Government to reject these proposals.
Yours sincerely
Michael Gallagher
On behalf of Green Alternatives to Incineration in Scotland
33 Precinct Street
Coupar Angus
Perthshire
PH13 9DG
Tel/fax 01828 627124
Dear Sir/Madam
On behalf of Green Alternatives to Incineration in Scotland I wish to object to proposals for a biomass burner at Dundee docks.
As you know, the Dundee proposal is one of four biomass burners proposed by Forth Energy. The other three are Grangemouth, Leith and Rosyth. The Scottish Government itself has expressed several concerns about the proposals in its 'Scoping Opinions', including:
1. “The biomass plants exhibit similarities to the pulp and paper industry (albeit without chlorination but with combustion) which has many well-known pervasive and displaced environmental impacts" (p126 of Leith Scoping Opinion).
2. “Although biofuels are a renewable source of energy, depending on where and how they are produced their carbon payback can be very lengthy and, if particularly badly sourced may result in a net increase in emissions” (p127 of Leith Scoping Opinion).
Forth Energy says that most of the biomass will be virgin wood. This is a particularly critical time for the global climate, and although wood may be ‘renewable’ in the long term, in the short term it emits high quantities of CO2. It takes upwards of 50 years to re-grow the felled forests and thereby re-absorb the CO2 generated by burning them. Furthermore no account is made of all the energy used to extract and transport the timber from Russia etc.
3. “The proposed plant at Leith is very large (200MW), and therefore although SEPA will regulate the plant it will be challenging to control emissions to meet with the Scottish Air Quality Regulations” (p46 of Leith Scoping Opinion)
Although the proposed plant at Dundee is smaller than the Leith proposals, it will nevertheless be one of the largest biomass burners in the world. As with any type of incinerator, it will emit a lot of very fine particles in the PM2.5 micron range. A report from 2007 found that up to a third of PM2.5 particles in a medium-sized Swedish city came from a new incinerator (see reference here). Figures from the British Society for Ecological Medicine (click here) indicate that a plant of the size proposed for Dundee – 1.25 million tonnes per annum – would emit around 75 tonnes of particulates annually, mostly in the PM2.5 range. DEFRA estimates that particulate emissions produce health costs of around £40,000 per tonne. According to the European Commission, 350,000 Europeans die prematurely each year from inhaling PM2.5 particles, cutting the average life span by 8 months (click here).
4. As demand for biofuels grows around the world, there can be no guarantee of continued supplies (section 5.3.3 of Grangemouth Scoping Opinion).
The Global Alliance for Incinerator Alternatives says that wood waste often contains hard-to-detect contaminants such as chromated copper arsenate (CCA), pesticides, preservatives, lead paint, black liquor, copper, creosote and chlorine, which can result in harmful emissions.
Claims that Scotland needs to generate renewable energy from burning biomass are unfounded. A recent study by Scottish Natural Heritage shows that Scotland can meet its 2020 target for renewable electricty 3 times over without incineration. Alex Salmond recently stated that "By harnessing just a third of the potential wind, wave and tidal resource off Scotland's coast, by 2050 we could power Scotland seven times over - enabling us to become a massive exporter of clean, green energy, generating an estimated £14 billion in value and supporting around 60,000 jobs." In general we take the view that there are other, more environmentally friendly sources of renewable energy than biomass burning.
For these reasons, we ask the Scottish Government to reject these proposals.
Yours sincerely
Michael Gallagher
On behalf of Green Alternatives to Incineration in Scotland
33 Precinct Street
Coupar Angus
Perthshire
PH13 9DG
Tel/fax 01828 627124
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