NHS Tayside has raised serious concerns over possible health risks related to the proposed biomass plant planned for Dundee’s docks area.
In a consultation response to Forth Energy’s proposals for a renewable energy plant in the Port of Dundee, leaked to The Courier, the health board considers there is a potential for negative effects on human health.
Its response was requested by the city council, whose policy and resources committee meet tonight to debate the proposal and issue instructions to the city development director, who will then give the city council’s formal response to the Scottish Government’s consultation on Forth Energy’s planning bid.
The report also shows NHS Tayside is requesting that Scottish ministers require the applicant to set up and resource an ongoing health-specific community forum or consultation group centred on effects on human health, and an ongoing health liaison group, as a forum for health concerns or issues raised by members of the public and for review of monitoring data, which will involve public health, Dundee City Council, SEPA and other relevant stakeholders.
NHS Tayside also requests that: Ministers require a reasonable period of monitoring of actual air quality in an agreed distribution across all areas of potential impact, including pollutants of potential concern, in order to more accurately establish baseline or ambient air quality…so that a more informed health risk assessment be undertaken. Ministers require from the applicant higher levels of guarantee that the use of heat in a local heat network will be at or near capacity from the outset of the operational phase of the proposed facility, perhaps in the form of binding contracts, in order that there be much more confidence about the efficient use of energy. Ministers require that as a condition of approval that the applicant undertake to convene, maintain and conduct an ongoing health liaison group during the life of the construction, operation and decommissioning of any such facility.
The health authority, a non-statutory consultee, points out that for most of the area to the east of the proposal, where 19,398 people are at risk of being subjected to small increases in nitrogen dioxide concentrations, there is relatively little monitoring.
This includes populations with respiratory conditions potentially exacerbated by irritant pollutant gases, including nitrogen dioxide, at levels much lower than those of otherwise healthy individuals.
The report states, “NHS Tayside is of the view that a comprehensive understanding and knowledge of the actual historical and current levels of a wide range of air pollutants is not available, and is of the view that the existing data is insufficient to fully characterise, with confidence, the ambient air quality in all areas of relevance.
“Furthermore, NHS Tayside notes that the historical record in some parts especially at Broughty Ferry Road indicates past and recent exceedances of Air Quality Objectives (AQOs) and notes there is in fact a trend showing some levels are increasing over time, over and above the AQO.
“Limited data from Dundee City Council that is cited in the application in fact indicates a range of sites in Dundee in areas of proximity to the proposal where the concentration of nitrogen dioxide and particulates are currently exceeding, or have recently exceeded Air Quality Objectives.
“On this basis, NHS Tayside questions the validity of the assumed baseline values taken for ambient air quality.”
On the sustainability of the plant the report says, “Given the potential for impacts on local populations by the siting of this proposed facility within the confines of a large city, should not such a facility only proceed if national policy objectives around sustainability are fully met?”
The authority is also concerned about effects that might arise from increases in non-threshold pollutants. The report adds, “NHS Tayside notes with concern that the siting of this facility is within an area where there are existing air quality issues that has been declared an Air Quality Management Area for nitrogen dioxide, and will soon be for particulates.
“The need and requirement is stated as being for a significant reduction of a range of airborne pollutants and the addition of this facility can only contribute to an increase in levels. How will increases in air pollutants such as those modelled assist the achievement of obligations to reduce pollutants of concern?”