New Questions about the Forth Energy Biomass Plans
September 11, 2010 by Ally 
Today, Alastair Tibbitt, from Greener Leith was amongst the speakers at the Edinburgh Communuty Energy Conference. We were set to be part of a debate with Calum Wilson from Forth Energy, about the giant biomass plant that Forth Energy plan to build on Leith Docks.
In the event, Calum brought with him a 29 slide power point presentation - and Alastair had 4 sides of A4. Nevertheless, our 4 sides of A4 had a few questions for Calum that he couldn't answer on the day, and so we've made sure that we furnished him with a paper copy of our question and invited him to respond, in writing, on this blog.
So, whilst we wait for the official reponse from Forth Energy, which we will publish in full here, here is the full text of what we said:
Background
Greener Leith is strong advocate for decisive action on climate change, both locally and nationally. We have followed the regeneration of Leith Docks closely and encouraged others to do so. We believe that there is a tremendous opportunity in the docks to deliver a decentralised, diversified, low carbon energy system that will future-proof the docks, with scope for an element of community ownership. Indeed, we are currently working with other organisations to develop a number of small scale renewable energy projects in the area.
Sadly, we do not believe the Forth Energy proposal to build a giant Biomass plant on the docks is the answer to the problem we’re trying to solve. We’ve no doubt it will make a great deal of cash for Forth Ports and SSE shareholders, and in the long term, it may be environmentally preferable to a new coal fired plant. However, like a great deal of other people and organisations, we believe that the proposed Forth Energy biomass plant, in Leith, is too big, in the wrong place - and it may do little to help tackle climate change over the timescales that we need to take action.
Forth Energy try to frame this discussion in terms of commercial viability. They claim that building one, massive power plant is the only viable option - but actually none of the options are really commercially viable without public subsidy. The Forth Energy Biomass plant in Leith will attract nearly £1billion pounds over 20 years in public subsidy through Renewable Obligation Certificates alone. We believe that there are better ways to spend that £1billion worth of public money and we’d be delighted to work with Forth Ports, Forth Energy, Scottish Water and the City of Edinburgh Council and indeed the Edinburgh Community Energy Coop to deliver our vision of a sustainable energy system in our neighbourhood.
Lest anyone try to characterise Greener Leith as an extremist group of ‘tree huggers’ or a group of NIMBY’s who would oppose any and all development of any kind in our neighbourhood, it’s worth listing the other people and organisations that have expressed misgivings about the Forth Energy plant.
Politicians
Reps from LibDems, SNP, Labour and Greens:
- Sheila Gilmore MP
- Mark Lazarovicz MP
- Kenny McAskill MSP
- Malcolm Chisholm MSP
- Robin Harper MSP
- Shirley-Anne Sommerville MSP
- Cllr Rob Munn
- Cllr Gordon Munro
- Cllr Marjorie Thomas
- Cllr Tom Buchanan (CEC Economic Development)
- Cllr Jenny Dawe (Council Leader)
- Cllr Jim Buchanan (Planning Leader)
- Cllr Brock (Culture and Leisure Leader)
Community Councils, residents groups and local organisations:
- Leith Harbour and Newhaven Community Council
- Leth Central Community Council
- Leith Links Community Council
- Greener Leith
- Rennies Isle Residents Association
- Leith Links Residents Assocation
- Friends of the Water of Leith Basin
- Port of Leith Housing Association
- More than 300 members of the local facebook page.
Nationa/ City-wide Organisations
- Friends of the Earth Scotland
- Climate Camp
- Cockburn Assocation
- WWF Scotland
- Confederation of Forest Industries
Questions for Forth Energy
Carbon Debt
How long will the plants take to pay off their Carbon Debt? Professor Jowitt at Sistech, who is the ‘independent’ person that Forth Energy commissioned to look at the life cycle impact of the proposed plants, acknowledges that they will need to pay of a ‘carbon debt’ if they are built. If the carbon savings delivered by the FE plants are only realised many decades into the future, is this too late? If it is too late, should public subsidy not be spent on energy generation technologies that deliver carbon savings sooner?
Sustainability
We note from the information you provide in the Dundee planning application that you intend to only use wood from certified sources. As there is not enough FSC certified wood available to fuel the plants, you acknowledge that Forth Energy will also need to use wood certified under the PEFC scheme which allows logging in old growth forests. Conversion of old growth forest to plantations for biomass will in many cases lead to a net carbon emission.
Greenpeace has documented evidence of PEFC certified logging operations in Finland, where Old Growth forests are indeed being logged. We understand that you intend to source your fuel mainly from Russia, Scandinavia and Canada, where the PEFC certification scheme recognises the Canadian “CSA” certification programme - another logging scheme which has come in for robust international criticism.
Given that PEFC certified wood does not guarantee sustainable forest management practice, and that there is not enough FSC certified wood available, how will you source all of the fuel you need in an ethical, and truly sustainable manner?
[Note for a report that compares different certification sytems click here.]
Community Benefit Fund
When we spoke in February, you said you’d certainly consider compensating local residents for the inconvenience of living near a giant power station by establishing something like a “Leith Climate Challenge Fund” that would support local carbon reduction projects. Recent statements you’ve made in the press seem to suggest that you’ve decided that local people should not receive any compensation for being forced to live as close as 200m to a giant power station. Can you confirm that it is only the shareholders of SSE, Forth Ports and the lucky handful of people who will work in the plant who will see any financial return from your proposals?
Local Air Quality
We note that the Dundee proposal will entail two HGV movements per hour into and out of the power station, even with a very low use of local feed stock. What is your message to the people of Leith who already live in a neighbourhood where most of the main roads risk breaching EU Air Quality Standards even before the Leith plant, which will be larger than the Dundee plant is built?
The DERL waste-to-energy plant at Baldovie, in Dundee, was hailed as “state of the art” when it opened in 2000, yet it has reported breaches in emission limits for particulates, metals, dioxins and furans on more than 120 occasions in the last 3 years, despite strict regulation by SEPA. Can you understand why many people do not feel reassured by your reassurances that the plant will not have any harmful effect on local air quality?
Local Regeneration
Forth Energy continues to claim that building a giant power station within 200m of residential homes will have no negative effect on the current residents or the mixed use regeneration of the neighbourhood.
Leith has been hit hard by the credit crunch - this week it transpired that nearly 1 in 5 shops in Leith is empty at the moment. However, Leith also has more Michelin starred eateries than any other area of Scotland. The council, local people, and even Forth Ports, continue to try to build on this success, to deliver sustainable mixed use regeneration of the docks. To this end, it looks extremely likely that the public sector will invest more than £80million in Forth Ports land, to try to bring renewed vigour into the mixed use regeneration process of the area. Why should tax payers bother spending £80million on Forth Ports, if Forth Ports choose to ignore their own masterplan by building a giant, bad neighbour, biomass plant?
At the Conference we learned that Forth Energy plan to submit a planning application for their Edinburgh plant in November this year. You can comment now on a similar proposal by Forth Energy to build a Biomass plant in Dundee.
Greener Leith has asked for a written response from both SISTECH and Forth Energy on how long the plant proposed for Edinburgh will take to become carbon neutral.
Ally
The comments from the Statutory Consultees response to the Dundee Application are also interesting. It would appear that even the Forestry Comission question the wisdom of building such a large plant.
Biomass, Energy & Climate Change, Planning and Regeneration Forth Energy, Forth Ports 
Reader Comments (19)
And when it comes to logging in old-growth forests, you may be interested in http://www.greenpeace.org/raw/content/france/presse/dossiers-documents/underthecoverofforestcertification.pdf in which Greenpeace looks at old growth logging in FSC certified forests - and this is about forest certification, not FSC certification.
I am simply astonished by the preference that is shown for FSC in many blogs, not only yours. It is as poeple don't know that not only has the FSC standard so many loopholes that it is a much better bet to focus on reading the FSC guidelines and advisory notes to figure out what the standar is really about, but one should not forget that FSC is financed by industry and focusses on certifiying industry, while PEFC is the organisation that certifies small and family forest owners and actually requires support.
Chain of Custody certification is important, but not enough, to guarantee that the wood burnt in these power plants will be sustainably sourced.
I'm basing my view on what I read on pages like this:
http://credibleforestcertification.org/other_systems/other_certification_systems/
Where there seem to links to lots of other credible reports, e.g:
http://assets.panda.org/downloads/theforestdialoguesdiscussionpaperforestcertification.pdf
you might want to take a second look at the pages you read.
A few things that you might want to look into when it comes to credibleforestcertification.org:
- Have you looked at who is responsible for the site? Have you checked the relationship that these organisations have with FSC? You'll find that they are members, founding members, board members....
- Have you noticed that the published reports you are referring to are produced by the organisations in charge of the website?
- Have you noticed that the organisations fail to published reports critical of FSC, even though they have published them themselves, like the Greenpeace report referenced in my previous post?
- Have you noticed that they omit to mention other critical voices about FSC, in example all the the material available on http://fsc-watch.org/
- Have you noticed that the omit to reference positive reports about "other" certification system?
- Have you noticed that all the references are at least 5 years old? You need to keep in mind that all systems endorsed under PEFC need to be revised every five years (FSC has a similar requirement, but it is not implemented). This means that none of the reports listed takes into account the evolution of the certification systems.
- Are you confident that all information about FSC given there is correct? I wouldn't be that sure. In example, at the bottom of the page it states: "Transparency and public participation consistently required. FSC:YES". The majority of FSC standards are so-called interim standards, where certification bodies set the standards against they themselves certify. These standards do not require public participation at all but only a limited form of public consultation, which is quite different. I can give you the reference in the FSC documentation if you like to chekc it out.
Is it really the best choice to base your views on a site that is obviously biased?
Regarding the WWF report that you originally reference and called "credible": Again, I urge you to have a second look. Aside from the fact that it is outdated, you might want to look at the following:
- WWF is a founding member of FSC, has invested millions of dollars in FSC, and sits on the Board of Directors of FSC at international level as well as in many national FSC organisations. Given this involvement that WWF has in FSC, expecting them to publish a negative report about FSC is like expecting Bill Gates to go for Apple.
- One example that you might want to look at is the WWF FCAG report (http://assets.panda.org/downloads/2008_11_17_final_fcag_assessment_.pdf), and the reponse by PEFC (http://pefc.org/news-a-media/general-sfm-news/news-detail/item/download/29). Most interesting are the footnotes. I've checked them all out, and PEFC's response is correct on all issues. Now, would I still call WWF's report credible after reading the fundamental challenges of the report as revelead by PEFC? I think not.
- Just because it's WWF doesn't mean that it is credible. You may recall the discussion at the beginning of the year about the errors in the IPCC report. A number of those were actually based on incorrect information originating from WWF reports. We need to always keep in mind that NGOs are not by default beyond mistakes. We should also keep in mind that we do have control over governments and know what they are doing (through governments, through NGOs, through laws concerning freedom of information), the same applies to business (through shareholders, through NGOS, through laws concerning accountability and transparency), but we do not have any control over NGOs - most laws concerning transparency and accountability do not apply to them, there are very few NGOs watching what other NGOs are doing, so we base our judgement that they are doing good on the simple fact that we believe that they are doing good, omitting the fact that it is people working there, with the same ambitions, weaknesses and desires as people working for government or business.
Note that the FERN report that you are now referencing is also outdated. I am also wondering why you have modified the text to update it with other critical reports about PEFC, but failed to include critical references about FSC? You might want to do so - www.fsc-watch.org has more than enough examples. By the way, it is interesting that you link to pefcwatch.org, but fail to link to fsc-watch.org. Makes me wonder whether you have a political agenda yourself and are not interested in writing factual, but rather in writing political.
One last reference that is really worth reading: http://sustainabledev.org/wp-content/uploads/2010/08/100805-REPORT-Green-excuses-Collusion-to-promote-protectionism.pdf - I think you might be very surprised. Credible? Probably at least as credible as the reports by FERN, WWF, Greenpeace etc.... make up ypur own mind.
Oh, and for an update report that compares the various certification systems, you might want to consider http://www.dovetailinc.org/files/DovetailCertReport0310b.pdf. Given that the UN references this report, I think it can be called credible (see http://timber.unece.org/fileadmin/DAM/publications/sp-25.pdf)
On the other hand, you may also want to consider looking at sources that can be called "independent", in example the assessments performed by the public procurement authorities in the UK (http://www.cpet.org.uk/documents) and in the Netherlands (http://www.tpac.smk.nl/nl/s517/TPAC-home/c413-Documents) - and in both assessments, PEFC and FSC come out as "sustainable".
Thank you for highlighting the limits and shortcomings of FSC too.
Yes, I can see why some people would see it advantageous that PEFC doesn't work to a standards based system - in that it has lower barriers to entry. Those people argue that by having a lower barrier to entry that more forest owners can take part, and the theory goes - improve their forest management over time.
FSC has a higher barrier to entry, as it's standards based. In fact, the more that I've read, the more I am convinced that FSC is the better scheme - from the perspective of guaranteeing sustainable forest management - although I agree neither is perfect.
I don't feel the need to post lot's of links - indeed I followed some of the ones in PEFC press releases you linked to above, like this one:
http://www.rainforest-alliance.org/forestry/documents/aspects.pdf
Which seems to somewhat undermine your case for treating the two schemes with parity, although it is old.
I am not sure about your reference to "standards-based" vs. "not-standards based". Both PEFC as well as FSC set standards. Difference is that FSC sets a global standards that is applicable everywhere almost without adjustment, while PEFC sets global benchmarks that national systems need to meet - requiring quite a bit of adjustment. Reason behind it is that sustainable forestry simply is different in Finland than it is in Gabon or Brazil.
Also, again I would be cautious using references from the Rainforest Alliance. Its certification body, Smartwood, is by far the largest certifier for FSC, thus there is clearly a business interest that Rainforest Alliance has... You might also be aware that small forest owners choose PEFC not because it is easier, but because it is resource efficient as it established the concept of group certification, something that FSC has only recently introduced.
I am wondering why you continue to argue against PEFC and for FSC. But I guess unless you really take the time to read some of the references I provided in detail, we won't be able to have an informed discussions.
Nevertheless, I think that we can agree that with only 8% of the world's forest certified, both systems need to further support to increase the area of forests certified as sustainably managed globally.
http://www.dovetailinc.org/files/DovetailCertReport0310b.pdf
"Whereas competing forest management standards illustrate some fairly distinct differences in defining
responsible forestry, the chain-of-custody standards are much less distinct."
And in the recent UN report you link to that describes the convergence between FSC and PEFC:
[The PEFC Standard]...includes optional proposals to include references to the concept of High Conservation Value Forests and a ban on the use of genetically modified trees.
That 'optional' phrase there is the key isn't it? As I understand it those standards are not optional with FSC certification.
Really I can't labour this enough, I'm not anti-PEFC, but taking a balanced view, or even an informed view, doesn't mean treating all with parity. It still seems that FSC have more rigorous standards for the management of forests - even if there has been more convergence of Chain of Custody process certifcation in recent years.
But why would you argue that a standard - FSC - that allows conversions of up to 20% of the forest area is rigorous?
http://www.fsc.org/fileadmin/web-data/public/document_center/publications/PEFC_and_FSC/FINAL-Summary_Report_FSC_CW_and_PEFC-EN.pdf
well, I don't think that I need to discard the report as biased - it does it by itself. According to the report, PEFC Germany fails FSC CW because it does not have any criteria for indigenous people. This, however, means that FSC itself fails its own CW standard as FSC Germany does not have any criterion for indigenous people either....
Pretty funny if you think about it....
I still don't know how you can argue that FSC is better, given that there's yet no evidence mentioned that cannot be discarded as biased because it is either written by FSC itself or an organisation that has a vested interest in FSC. In fact, the only reports mentioned that are - at least in my opinion - independent, the assessments by public procurement policies, do treat both systems equally. And you may have noticed that the PEFC ranks better than FSC in the summary results of the TPAC assessments.....
I've enjoyed being challenged by you, but your arguments don't stack up for me. There are a lot of reports out there, old and new, that suggest to me that FSC is the better, more reliable standard. You say that they are all produced by organisations with a 'vested interest' but then FSC appears to be more inclusive too, so it would be easy to say this.
I have read critical reports from environmental NGO's about FSC, and clearly it is in their interests that the FSC remains the preeminent certification system. However, it is reassuring that they are also trying to improve it in a transparent way, by providing open criticism:
http://www.greenpeace.org/international/en/publications/reports/holding-the-line-with-fsc/
By contrast there seems to be much less transparency on the PEFC side. Where are the detailed reports that compare performance standards at a national level produced by PEFC? I haven't found them. At the top level, the certification schemes appear to be very similar, but when you get to the detail the FSC appears to me to be more consistent, have better performance standards and have more detailed process standards that are more likely to be enforced.
There are vested interests on all sides of the debate, and it strikes me that PEFC is more tilted towards national producer interests at a countrywide level. I am making a value judgement over who I should trust more - and I'm afraid it is the NGO sector - not the tangled web of private forest owners and trade associations that form the backbone of the PEFC.
I note that the Dutch Government decision to approve the PEFC international brand as 'sustainable' was based to a large extent on the practical sources of PEFC certified timber in the Dutch market - with only a very small proportion of PEFC certified wood entering the Dutch market from countries where the PEFC system was viewed as less robust. In this sense they have taken a pragmatic view for their country based on current market usage. They themselves say that they will need to review it if market usage changes.
It is instructive in any case that the Dutch government has felt the need to assess each individual PEFC national system on a case by case basis. Again this implies to me that simply stating, as Forth Energy do, that PEFC wood is sustainable, without specifying which countries they mean, leaves them open to the possibility that they may end up burning wood from badly managed forests.
In the case of the UK government decision to include PEFC as 'sustainable' wood in their system, I note that this decision was not without it's critics, and that as a consequence there is currently an independent review being undertaken at Oxford University. I suspect we will both be interested to read that review when it comes out.
As far as I can see all of this only emphasises the notion that the 'truth' may not necessarily be out there on some website, although I am slightly more likely to be convinced by an organisation such as WWF or Greenpeace rather than the Institute of Public Affairs, a professional Australian Lobbying organisation -
http://www.sourcewatch.org/index.php?title=Institute_of_Public_Affairs
So, let's stay with what we do know:
1 giant electricity plant proposed burning biomass, profitable only with £1billion worth of public subsedy, paid for by public taxes, earning dividends for unknown shareholders, ie not the tax payers, 200 yards away from a densely populated area, importing wood by ship, no, not sailing boats, from all over the world, from trees that, once cut down and replaced with saplings, will take at least 30 years to mature and store the carbon that was originally released by burning them. Oh, yes, and up to 20% of this wood (no there isn't enough wood in the UK for this) is to come from the UK, brought in by lorry through the aforementioned densely populated area?
DUH!!
Similar for the board membership. I don't trust politicians that sit on numerous boards as I always assume that they have their own best interest in mind. Guess the same applies to NGOs.
I recently read that Greenpeace even lost its charity status in New Zealand. How do we actually know that the information NGOs provide is credible and trustworthy? Charlotte?
Ally, I think that you avoided responding to most of the issues that Chris brought up. I don't think that it is fair to say that he's misleading by pointing out the indigenous people issue in his last post. You're right that this issue is not relevant for Germany, but FSC decided to include it and is therefore misleading the reader, as they failed to state that it is not relevant. Chris is only pointing out this out.