Request
I would like to register the following residents of Chingford, to attend the North London Waste Authority meeting on 24 June, 2.30 pm under Item 7 - Deputations - on the agenda.
Betty Hales
Nadia Amara
We speak as mothers and grandmothers about our frustrations and concerns and also as members of Chingford and Wood Green Constituency Labour Party, which adopted the policy we wish to argue for.
Betty Hales will address the meeting on our behalf. The points she will be raising are:
The initial decision to replace the current incinerator with a bigger one was made before the recent raising of public and scientific awareness about the considerable disadvantages and dangers of incineration as a solution to waste disposal. The initial consultation was not sufficiently comprehensive or extensive to allow all local residents to make their views known and subsequent submissions to the committee, including our own, raising issues of concern and asking for a pause in the process to allow for it to be reconsidered have not been taken sufficiently seriously. In fact they have been met with derision and rudeness. We are appalled, in particular, at the seeming lack of accountability of the NLWA and its intransigence on this issue, even in the face of official Labour Party policy being against Incineration.
Over the last few years, it has become obvious, from our own experience, that the volume of household 'black sack' waste has reduced considerably so the need for a bigger incinerator is even less clear now than it was when this project was first proposed. Surely, the need to constantly feed the furnace will result in increased importation of waste from a larger area, increasing traffic pollution, and reduce the incentive to increase and improve recycling. This project is extremely expensive and potentially not the right choice. Therefore, we believe that to pause and reconsider while there is still time would be the responsible course of action on the part of the NLWA, a sign of strong leadership, not weakness.
I look forward to hearing from you.
With best wishes
Nadia Amara
Response
14 July 2021
1b Berol House, 25 Ashley Road Tottenham Hale N17 9LJ
enquiries@nlwa.com
nlwa.gov.uk
Ms Betty Hales Via email
Dear Ms Hales,
Thank you for taking the time to raise your deputation to the North London Waste Authority (NLWA)
meeting on Thursday 24 June 2021.
I appreciate you bringing forward your views in relation to the North London Heat and Power Project
(NLHPP) and setting out the issues you wanted to draw to Members’ attention. The Authority Members
take seriously their responsibility to protect public services, public health, and the environment,
and these matters have been carefully considered in developing the NLHPP.
As promised in the meeting, I would like to take this opportunity to respond in writing and assure
you that all aspects of the NLHPP are thoroughly considered by the Authority and have been tested
and approved through an independent public inquiry process. This letter provides more detailed
information on the project in relation to the topics you have raised.
In your deputation you asked that NLWA pauses and reviews the NLHPP
NLWA has carefully considered all the issues you raised in your deputation. The NLHPP is a vital
infrastructure project which supports our aim to increase recycling and stop waste from rotting in
landfill. To delay the project would undermine our efforts to tackle the Climate Emergency and
reach Net Zero, both of which are at the forefront of discussions for COP26 this year. No other
option works at the scale we require, and none offer the same compelling financial, social and
environmental benefits. For these reasons we cannot pause the Project.
The impacts of not building the NLHPP would be detrimental to north London residents and also in
our efforts to tackle the Climate Emergency. It would deny north London’s residents state of the
art recycling facilities. It would deny residents a safe, clean and low-carbon solution for
managing their waste in the Climate Emergency. It would deny hundreds of life changing apprenticeship and training
opportunities for local people. And it would deny local homes and businesses the chance to benefit
from low-carbon heating and hot water.
The Project has already been thoroughly reviewed and all the considerations raised by deputations
have been carefully considered over many years. The decision to proceed with the Project followed
several years of comprehensive environmental analysis, as well as an extensive two-stage public
consultation, and careful consideration of the alternative options. As part of the DCO process,
NLWA undertook a full Environmental Statement for the project, which entailed 2,000 pages of
careful analysis of a range of environmental, social and technological factors. This Statement was
subject to an Examination in Public and recommended for approval by the Planning Inspectorate.
Last week, the credibility of the NLHPP as being the best option for managing north London’s waste
was reaffirmed when the High Court dismissed the application for a judicial review concerning the
Government’s Emissions Trading Scheme. The plaintiff argued that, if successful, the application
would affect the viability of the NLHPP. NLWA welcomes the decision, because it means that energy
from waste will continue to be excluded from the ETS. The ruling correctly reflects the case of
NLWA that our modern, clean replacement facility remains the most environmentally responsible way
to manage non-recyclable waste.
In your deputation you suggested that there is no evidence that energy from waste facilities are
safe for public health
There is a common misconception that energy recovery facilities have a negative impact on air
quality and therefore pose a significant risk to public health.
PHE is clear that modern, well run and regulated municipal waste incinerators are not a significant
risk to public health. In 2019, PHE reviewed their statement on the basis of a major study by
Imperial College London and their guidance, based on a clear scientific consensus, remains
unchanged.
As a public authority, our key priority is to protect the health of our residents. For this reason,
our facility will be the first of its kind in the UK to be fitted with the most modern
specifications, using the world’s best technology to capture and carefully filters emissions,
making it one of the safest and cleanest in the world.
When air quality and potential health impacts are discussed, it is usually in reference to the
presence of Nitrogen Oxides (NOx) and particulates released into the atmosphere. In relation to
particulates, the ERF will use best-in-class, proven technology for controlling particulates.
Thousands of baghouse filters will be employed to capture particulates, including PM10, PM2.5 and fine particles. This
proven technology has been identified by the UK’s Air Quality Expert Group as being particularly
effective for controlling particulates and ultrafine particles (UFPs). An independent study from
the University of Birmingham in 2016 concluded that, after dispersion and dilution, concentrations
of UFPs are typically indistinguishable from levels that would occur in the absence of an EfW.
In relation to NOx emissions, the ERF will be fitted with a higher level of emission controls than
most other energy from waste plants in the UK. It will be the first in the UK to operate using
Selective Catalytic Reduction (SCR) to reduce NOx emissions to well below the stringent
requirements of the emission limits set by the European Union in the Industrial Emissions Directive
(IED).
The heavily filtered emissions will be released at height from the stack, which ensures that the
pollutants will disperse and dilute in the atmosphere, and therefore be present in exceedingly
small quantities at ground level. For the vast majority of the year, the contribution of the ERF to
NOx at ground level will be effectively zero. It would only be measurable for a few hours a year,
and this will only be at 2% of the relevant air quality standard.
In your deputation you claimed that infant mortality rates in Chingford have increased as a result
of the Edmonton facility
It is inaccurate to claim that the facility in Edmonton is linked to increased infant mortality
rates. This directly contradicts the scientific evidence, which is clear that energy from waste
facilities (EfWs) are not linked to infant mortality, including the existing plant in Edmonton.
A 2019 study by Imperial College London, funded by Public Health England, found no link between
exposure to emissions from EfWs and infant deaths, stillbirth or reduced foetal growth. This is one
of the most robust studies ever undertaken into the health impacts of EfWs. It assessed health
impacts over a seven-year period across a population of 24.5 million people in England and
Scotland. This includes an assessment of 219,486 births. The team of scientists behind the report
have a world- leading reputation as international leaders in environmental epidemiology. The report
is available online here.
In 2019, the same team of academics from Imperial College London published findings on birth
outcomes in infants living close to an EfW. This study included the existing plant in Edmonton. It
found no link between adverse birth outcomes such as effects on birthweight, premature birth,
infant death, or stillbirth, for children born within 10km of EfWs in the UK. The report is
available online here.
In your deputation you stated that residual waste has decreased and so the need for a bigger
facility is unclear
Thank you for sharing your concerns about residual waste arisings. I would like to clarify that
residual waste arisings in north London are in line with the forecasts set out in the Need
Assessment.
• The residual waste forecasts in the Need Assessment suggested that in 2019/20 the volume of
residual waste in north London would be in a range of 582,000 to 663,000 tonnes. The volume of
residual waste produced in 2019/20 was around 581,000 tonnes.
• For 2020/21, the waste forecasts suggest a range of 567,000 to 661,000 tonnes (Low scenario).
Actual arisings were 570,394 tonnes.
It is important that NLWA plans responsibly for society’s needs, and builds infrastructure which
can accommodate a range of future scenarios. In line with our duty, we are building facilities
which we can be confident will deal with the uncertainties of the next 30 to 40 years and provide
the highest environmental standards for that time.
As will always be the case, there are many complexities and challenges involved with forecasting
waste arisings from a quarter of London’s population over a thirty-five-year period. To compound
the challenge, many factors are outside NLWA’s control – including changes to legislation, economic
performance, consumer behaviour and housing stock. This was acknowledged by the Planning Inspector,
who said in his examining report for the NLHPP Development Consent Order (DCO): “I conclude that
the design capacity of the proposed ERF is reasonable taking the forecasts into account, and
particularly the very substantial uncertainties in looking over 35 years into the future”.
In your deputation you suggested that inadequate public consultation has been carried out on the
project
NLWA is committed to public consultation, and this was a vital part of the planning process for the
NLHPP. A two-stage consultation process was held across all seven north London boroughs, as part of
developing the rigorous application for a development consent order (DCO).
Local residents, community groups and other stakeholders were invited to give their feedback on the
project. This included 15 events, several meetings with community and statutory stakeholders, a
series of newsletters to 28,000 properties, adverts in the north London press, leaflets in every
council building and 80 libraries across north London, as well as a dedicated website, email and
phone line.
The feedback we received during the consultation materially shaped and informed our final
proposals. This includes the design of EcoPark House, the size of the viewing platform, and the
decision to bring forward one chimney stack instead of two.
The DCO was submitted to the Planning Inspectorate in October 2015 and following a public enquiry
the Project was given consent by the Secretary of State in February 2017. The full consultation
report and appendices are available on the NLHPP website here.
We have continued to engage with our stakeholders since the Project consultations, through a number
of channels. We issue newsletters to up to 28,000 homes and businesses with community updates and
provide construction update newsletters to 19,000 homes and business regularly. We also provide a dedicated
website with the latest news and information about the project.
In your deputation you stated the Labour party policy is opposed to the NLHPP
I would like to clarify that all of north London’s boroughs support the project, six of which are
Labour- led, and it aligns with the Mayor of London’s Environment Strategy.
In addition, in 2020 a number of prominent Labour MPs, including Dr Alan Whitehead, Alex Sobels,
Kerry McCarthy, Barry Sheerman, Lilian Greenwood and Fleur Anderson, signed a report ‘No Time To
Waste’, concluding that ERFs with heat offtake are the most advanced and sustainable solution for
managing non-recyclable waste as the UK transitions to a Net Zero economy.
The report, published by the independent think tank Policy Connect, concludes that: “By sending the
[residual] waste to EfW [energy from waste facilities], it is pushed up the waste hierarchy,
diverted away from environmentally damaging landfill, and can support the UK’s heat and power
needs. At the same time, it helps to maintain a clean and hygienic waste service; something the
public has come to expect; the need for which has been reinforced during the COVID crisis”. The
NLHPP, which will maximise heat and power benefits, is an exemplar of this approach.
As stated previously, the Mayor of London himself is clear in his Environmental Strategy that the
NLHPP is required to provide residual waste capacity in the future, along with three other energy
from waste facilities in London.
Moreover, the NLHPP aligns with the waste hierarchy, which is set by the European Union’s 2008
Waste Framework Directive and enshrined in UK law. The waste hierarchy is clear that – after waste
prevention, reuse and recycling – energy recovery is the preferred solution for managing non-
recyclable waste. Landfill is established unequivocally as the most damaging option for t he
environment.
If you have any further questions about the Project or require any clarifications, I would be happy
to answer them. You may also find useful the extensive Frequently Asked Questions on our project
website, which cover the themes you raised in your deputation. I would like to thank you again for
your interest in the NLHPP and for submitting your deputation last month.
Yours sincerely,
Cllr Clyde Loakes
Chair, North London Waste Authority
