greener leith roc consultation response
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8/3/2019 Greener Leith ROC Consultation Response
http://slidepdf.com/reader/full/greener-leith-roc-consultation-response 1/7
Greener Leith
36, Newhaven Road
Edinburgh
EH6 5PY
www.greenerleith.org
justask@greenerleith.org
Neal D Rafferty
Renewables Routemap Team
4th Floor
5 Atlantic Quay
150 Broomielaw
GLASGOW
G2 8LU
Telephone: 0300-244-1227
Neal.Rafferty@scotland.gsi.gov.uk
Dear Mr Rafferty,
RE: consultation on the review of ROC bands applying under the Renewables
Obligation (Scotland) mechanism.
Please find the Greener Leith response to selected questions from this consultation below.
● What are your views on the proposal to remove support for large scale
dedicated biomass electricity plants?
We are of the view that the current Scottish Government policy on biomass is the right oneas it will maximise the carbon savings that can be delivered from this resource. It thereforeseems logical to align the subsidy regime in such a way so that it supports the current
policy of favouring deployment of biomass in heat-only or combined heat and power plants,particularly off gas-grid, and to a scale which maximises heat use and local supply.
Taking the Leith plant currently proposed by Forth Energy as an example, it is not scaled to
supply a specific, identified heat demand. Nor is it scaled to maximise the benefits of local
supply or located off gas grid. Yet it could still claim and estimated £116,880,000pa of ROC
subsidy over twenty years under the current arrangements, even if none of the heat from
the plant is ever used.
By comparison, it is worth noting that a ten year programme for reducing the energydemand of every home in Scotland was costed at £170,000,000 per year by the Association
for the Conservation of Energy1.
1 Submission from the Association for the Conservation of Energy to Scottish Parliament Finance Committee consultation on draft
budget proposals for 2012-2013. Available at: http://bit.ly/skvhyn
Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095
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Lastly, as large plants in urban areas are likely to be perceived as ‘bad neighbour’
developments they inevitably bring with them significant planning conflict relating to, for
example, increases in traffic, negative economic impacts on the surrounding area, visual
amenity, nuisance and air quality concerns.
We believe the simplest means of minimising lengthy, expensive planning disputes,the risks of unsustainable international impacts of large scale biomass imports, AND of
incentivising the construction of biomass plant off the gas grid is to put an upper limit on all
large scale biomass plants beyond which no subsidy will be paid.
Were the Scottish Government to align the ROC subsidy scheme with the banding of the RHI
for biomass then this could create a powerful economic incentive to develop small scale CHP
biomass plants, based on a more sustainable local supply, which could then be connected
up as local heat networks develop. This would help to foster a more sustainable, diversified,
decentralised, and therefore more robust heat and power system.
Placing an upper limit on the size of biomass plants which qualify for subsidy would notprevent the development of urban heat networks, but it would serve to promote an
incremental, and more diversified, approach to the development of efficient local heat
networks, such as those already implemented by award winning Aberdeen Heat and
Power.15 This non-profit firm already supplies low carbon heat to 1000 homes in Aberdeen
from a series of small gas powered CHP generators.
In our view, this incremental approach to developing heat networks is a more practical
and socially just model that the Scottish public sector should aim to support and replicate
throughout the country.
● Do you believe there is a need to revisit the biomass content threshold of 90%?
No. Reducing the content threshold blurs the boundary between biomass fuelled plants and
Energy from Waste plants.
Given the unenviable record on air quality of some existing Waste to Energy plants in
Scotland16, we would prefer to see subsidies for biomass energy used to support genuine
biomass fuels.
The 90% content threshold helps to support this distinction.
15 Combined Heat and Power System reaches milestone. City of Aberdeen Council. October 2010. Available at: http://
www.aberdeencity.gov.uk/CouncilNews/ci_cns/pr_domesticsuccess_090910.asp
16 Dundee Energy Recycling Ltd. Emissions breaches figures from SEPA. See: http://www.gainscotland.org.uk/dundee-derl.shtml
Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095
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About this response
The Greener Leith committee consent to this consultation response being made available
to Scottish Government officials and placed in the public domain. Greener Leith committee
members are willing to be contacted by Scottish Government Officials to discuss thisresponse further.
Prior to submission to the Scottish Government, members of the public were invited to
comment on the draft of this document online via our website and Twitter. After comments
were received, the final version was agreed by our management committee.
About Greener Leith
Established in 2006, Greener Leith is a registered charity that is managed entirely by local
residents who have professional backgrounds spanning planning, green energy, landscapearchitecture, finance and community engagement. Greener Leith, with the support of a
CARES Loan from the Scottish Government, is currently exploring the feasibility of buildingScotland’s first community owned urban wind turbine on the Edinburgh waterfront at
Seafield.
With the help of hundreds of local supporters, Greener Leith promotes community
involvement, sustainable development and better public spaces.
For more information on what we do, see www.greenerleith.org
Yours Sincerely,
Alastair Tibbitt,
Trustee, Greener Leith.
Greener Leith is a Scottish Charity number SCO40838 and a company limited by guarantee No: 365095
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