Open file - Lesley McNeil Consents and Deployment Team Dundee

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					Lesley McNeil
Consents and Deployment Team

Dundee Renewable Energy Plant - Application

Onshore Renewables Team Comments

1. General

We would offer the following on the Forth Energy (FE) application. Our
comments are focused primarily on the heat and fuel elements of the

2. Heat

The submitted documentation makes it clear that FE recognise the renewable
energy and heat targets. However, it is also clear that the plant has been
designed primarily for electricity production at the detriment to potential heat
production and use. The application is for a 100 MWe plant with an expected
thermal output of 30 MWt. Given the scale of the plant, the potential heat use
is considered to be low.

Forth Energy should refer to Scottish Government Guidance on thermal
power stations in Scotland (March 2010) and address the key issues therein,
including the emphasis on biomass for relatively small scale, renewable heat.

At the gate checking stage we noted that there was little detail on the pipe
work for any district heat network. We note that FE have now produced an
indicative first phase pipeline routing at figure 3.4 of Annex D to the CHP
feasibility study. Unfortunately this figure could not be found at Annex D and
we would welcome sight of this plan.

FE make reference on numerous occasions to it only being possible to
undertake detailed heat feasibility studies / commercial discussions post
consent. We remain of the opinion that this should not be any different to any
of the other aspects of the proposal. We do recognise that some further
analysis of potential heat users as well as the inclusion of a letter of intent are
now included in the documentation. However, it remains a concern that there
is no guarantee that the heat will be used.

The CHP report states that initial feasibility study would be required to assess
the technical and economic viability of the district heating scheme.      Again,
there is a concern that any heat potential will not be realised due to the need
for supplementary reports. Not convinced that this is necessary if FE are
already committed to using the heat.

FE state that one of the factors in selecting the site for the plant was to do
with accessibility of potential heat users. However, the CHP report seems to
state that the installation of pipework would pose some challenges due to
roads and rail disruptions. Grateful if FE can clarify the position.

More generally on the heat intentions, at times this continues to be
contradictory and confusing.    FE appears to be suggesting that there is
potential and provide a wide range of documentation to support that position.
However they also include details about the difficulties. It remains difficult to
gauge how firm FE intentions are.

3. Fuel

The plant will require up to 1 million tonnes of biomass per year (dependant
on calorific value). We note that the majority of the fuel will be wood chip or
wood pellet but that the Plant would be WID compliant to allow various waste
streams to be used as fuel.

Section 5.3.3 of the Scoping Opinion for this application stated that applicants
should consider the finite nature of the domestic supply of wood fibre. It went
on to state that the potential demand on the Scottish and UK timber harvest
should be set out by the developer within a robust fuel supply plan covering
the life span of the proposal. No fuel supply plan could be found and we would
ask that this is provided.

At least 85% will be delivered by ship (80 vessels per annum       =
                                                                1 to 2 per
week). Capable of accepting 15% by road 23 lorry loads per day.

The main fuel store will accommodate up to 38,000 tonnes of biomass
(enough for 15 days continuous operation).

4. Sustainability

The sustainability of the fuel has been addressed in the sustainability
statement, which highlights that Forth Energy is committed to using
sustainably sourced fuel which meets the appropriate sustainability standards.

In terms of carbon accounting, the Carbon accounting methodology recently
outlined by the European Commission has been used.

You should be aware that the recently published consultation on changes to
the Renewables Obligation (Scotland) Order 2010 contains proposals on
introducing sustainability criteria for biomass plants. This can be found at:    0/09/06152625/4.       The     UK
Government is holding a similar consultation, which can be found at:
http://www. decc. qov. uk/assets/decc/Consu Itations/Renewables %200bl iqation
/261-statutorv-con-renewables-obliqation.    pdf
5. Security of Supply

We note that FE has set out potential security of supply issues, as well as
potential solutions. The Environmental Statement also recognises the
potential impacts on supply markets in Scotland and the rest of the UK.
However, the fact that there is little detail regarding the supply means that it is
difficult for Energy Security to be demonstrated. We would therefore reiterate
that we seek more detail on how security of supply would be managed.

6. Cumulative Impacts

Despite our previous request, there does not appear to be any detailed
analysis of cumulative supply impacts on other wood fuel users or large scale
biomass plants (e.g. Port Talbot). Has this been provided?

7. Economic Analysis

Scottish Ministers are particularly keen to see wider benefits for communities
from renewable energy schemes such as this. Unfortunately, no mention of
this could be found and we would ask that FE outlines what they propose to
do in order to maximise benefits for the local community. For example for a
wind project, the norm is for developers to offer the local communities a
community benefit" by way of a sum per MW of renewable electricity
generated.    The money is usually held in a specific fund to support local
projects.   Interested to learn what FE's intentions are in this regard.

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