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Charlestown, Limekilns and Pattiesmuir Community Council Response to

“Carbon Balance Assessment” Carbon Balance is one of the major tests of sustainability. Sustainability was, and is, one of the main criteria for inclusion in a National Planning Framework for Scotland. It is therefore clear that rigorous analysis of the carbon balance for a proposed container terminal on the Forth at Rosyth should have been carried out and properly exposed to ministerial and public scrutiny before such a proposal was ever considered for inclusion in NPF2. It was not. Instead, as an afterthought to an application for a Harbour Revision Order, a „Carbon Balance Assessment‟ has, in May 2011, been published by Babcock. This is a worrying document. It admits to using a borrowed methodology The “Jacobs Carbon Calculator” was developed for making a carbon assessment of the construction of flood defence schemes. Flood defence schemes are not in any way comparable to the Rosyth scheme. In particular, they do not involve carbon impact of transport which is a key factor in the justification or otherwise for a container terminal. In our own calculations we have worked from first principles which, we would contend, are as good a way of estimating the impact as any model based on derived parameters. We have taken into account construction costs, road haulage costs, tug work, and dredging, both capital and maintenance. While it is stated (P1) that the “report covers the carbon emissions comparison of journey modes rather than providing total emissions …” it brings into its calculations what it refers to „banked’ carbon from the construction of the RD57 site. This is spurious. What Babcock acquired at Rosyth when the Dockyard was privatised was a piece of land. Building a container terminal here is no more or less costly in carbon terms than building it on any other piece of land, greenfield or otherwise. Its main thesis is flawed This is the thesis that a proposed container terminal at Rosyth would reduce carbon emissions through transfer of container traffic from road and rail to sea. It misleads the reader by failing to mention that there is already a multi-modal, modern, and efficient container-handling facility on the Forth at Grangemouth, less than ten miles west of Rosyth and, therefore, ten miles closer to Scotland‟s industrial heartland. Grangemouth is operating at less than 50% of its current capacity, and has the scope eventually to further double its capacity if that were ever required. Any potential that exists or existed for shifting containers from road to sea will already have been exploited by the operators at Grangemouth. The existence of this effective blind spot in reasoning is clear from the following statements which repeatedly suggest that there is still container traffic on roads from the south of England that could be transferred to ship: P 4 Line 6. The development of the Scheme will enable a significant modal shift in container transport to and from Scotland, moving container freight off road and rail onto ship ... the ability to reduce the need for road and rail transport to and from Scotland for freight coming into UK ports such as Felixstowe and Southampton, and European ports such as Antwerp and Rotterdam, will lead to a reduction in net global carbon emissions (MacKay, 2009). P 8 Line11. Import and export of containers between Scotland and England mainly relies on transport by road or rail P9 Lines 20 – 23. Operational (opex) carbon emissions ... can be compared to the emissions from making the same journey by road or rail in order to determine the savings associated with sea freight P9 Line 28. The fuel consumption model assumes that the Scheme diverts containers from overland transport.

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P 10 Line 23. According to the study, the addition of the Scheme will significantly reduce the amount of fossil fuel used to handle Scotland’s containerised cargo shipments by displacing freight movements currently routed overland (rail and road) to ships which are less fuel intensive. P11 Line 30. An additional benefit of the Scheme is that it provides additional freight capacity which ensures that the economic growth of Scotland is not held back by a lack of appropriate infrastructure. P20 Line 15. By 2020, when it is predicted that Scottish port capacity will be fully utilised, this will result in an annual carbon saving of 20% (18% – 23%) over the Base case without the Scheme in place. It takes no account of the additional carbon and financial cost implicit in the road haulage of each container destined for the Glasgow area an additional 15 miles. The report asserts (footnote p10) that “The difference in distance between Glasgow and Grangemouth and Glasgow and Rosyth are not thought to be significant enough to impact the overall results”. Hauliers and shippers may beg to differ when they examine the additional cost, in financial terms as well as carbon emissions, of hauling containers from Rosyth to areas around Glasgow compared with the journey from Grangemouth to the same destinations. Babcock has stated elsewhere that 60% of containers landing at Rosyth will be destined for the Glasgow area. So each truck will have to travel an additional 14 miles (A985) or 17 miles (M8) on top of a journey they would otherwise have made from Grangemouth. This is equivalent to a 50% increase in the length of each single journey. The fuel consumption of a loaded HGV is around 7.5 mpg of diesel at, say, £4 a gallon. The additional fuel cost alone would be of the order of £8 per single journey. Fuel is generally estimated to be around one third of the total cost of running a HGV. On top of that, there are the costs of the driver‟s wage and the costs of routine maintenance and depreciation of the vehicle. So the additional cost of travel from Rosyth, compared with Grangemouth is approximately £24 per one-way trip. Conservatively, this would be £40 for a round trip. In terms of sustainability, there is also the matter of wear and tear on the public highway, (an externality as far as the operator is concerned, but a cost to be borne by taxpayers). It is instructive to compare this with the cost of the container remaining on a ship to be carried 10 miles further up the Forth to Grangemouth. A loaded container vessel may be carrying 300 containers. The additional fuel consumption would be about 1 tonne @ 470 dollars per tonne or £300. This would mean a cost of just £1 for each container travelling on by sea to Grangemouth rather than being offloaded at Rosyth. The additional haulage cost of some £24 incurred by landing it at Rosyth for onward transport by road makes no economic sense. In general, a shipping agent will look for sea shipping to the closest possible landfall to the customer, and thereafter the shortest possible road haulage. The document indicates (p11) that emissions per container carried by road are around five times those of those of sea transport. We calculate that the additional road transport cost in carbon of transport form Rosyth instead of Grangemouth is about 0.1Mt CO2 per annum. Over the 20 year life of the facility this would amount to 2Mt CO2, compared with one fifth the amount (0.4Mt CO 2) for sea transport. Excess carbon emission for locating at Rosyth rather than Grangemouth is therefore 1.6 Mt CO2, exactly equal to the claimed savings (p21) of transferring non-existent containers from road to sea! There are many other assertions in this document with which we could take issue, but as the main premise for carbon emission reduction is so clearly flawed, we will not challenge them at this stage.

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Carbon Balance response  
Carbon Balance response  

Community Council's response on Babcock's Carbon Balance document.