Deputation from Annette Baker, Plastic Free Crouch End asking for the NLWA to pause and reflect on the necessity to enlarge the incinerator at Edmonton

14 July 2021
1b Berol House, 25 Ashley Road Tottenham Hale N17 9LJ
enquiries@nlwa.com
nlwa.gov.uk
Ms Annette Baker Via email
 

Dear Ms Baker,

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 said that Wales has placed a moratorium on waste incineration and north 
London should do the same

Thank you for sharing with Members your insights about the Welsh recycling system. Although north 
London already applies many of the measures used in Wales, including separate kerbside collections, 
the context in Wales cannot be directly applied to north London.

Wales has a population density of 151 residents per square metre – in comparison, London has 5,701. 
It is well documented that rural, less dense areas have higher recycling rates than cities, and 
recycling rates in north London are consistent with those in other inner London areas.

The Mayor of London’s Environment Strategy states that the NLHPP is needed in the future, to
provide sufficient waste when the Mayor’s waste prevention and recycling targets have been met. We 
are therefore bringing forward a project which aligns with waste and recycling policies set for 
London.

In your deputation you asked how the NLHPP aligns with efforts to tackle the Climate Emergency

The NLHPP is an important asset that will help tackle the Climate Emergency. Compared to the 
alternative of landfill, the project will save up to 215,000 tonnes of CO2e per annum: equivalent 
to taking 110,000 cars of the road each year. This is a result of NLWA’s carefully considered 
approach which maximises the ERF’s heat and power benefits.

The project aligns with the Climate Change Committee’s Net Zero route map. It also exemplifies the 
sustainable waste management approach advocated by the All Party Parliament Sustainable
Resource Group in its 2020 report “No Time to Waste”. The report was signed by a range of
prominent parliamentarians from a range of parties.

In your deputation you said that burning waste is dangerous to health

I would like to reassure you that NLWA’s first priority is to protect the health of our residents. 
That is why we are investing in the most effective emission control technology available, to make 
our facility the safest and cleanest in the UK.

There is a common misconception that modern energy from waste facilities make significant 
contributions to pollution and have a major impact on public health. But there is no evidence to 
support this.

On the contrary, there is a clear scientific consensus that modern facilities like ours make an 
exceedingly small impact on pollution, and do not present a significant risk to public health. This 
is the unambiguous position of Public Health England, supported by a significant body of scientific 
evidence. This includes research from Imperial College London which studied our facility along with 
others in the UK, and is clear that modern facilities cannot be linked to negative infant birth 
outcomes and infant mortality.

The emissions control technology fitted to the plant will be so efficient that, for the majority of 
the year, local concentrations of particulates and NOx are expected to be effectively zero, and 
only 2%of air quality limits for a f ew hours a year. This is vastly outweighed by other sources 
including road traffic and domestic wood burning. In Enfield, road transport is responsible for 
around 40% of NOx and 30% of particulates. Across London, road transport causes 60% of nitrogen 
oxides and 25% of particulates. These figures are from the GLA’s London Atmospheric Emissions 
Inventory.

In your deputation you said that technology exists to remove recyclable material from residual 
waste at a lower cost to incineration

Thank you for your suggestions on alternative ways to managing residual waste. The Authority has 
carefully considered the alternatives as part of our planning for the NLHPP. It may help if I 
explain why they are not suitable. The technology which is most often cited is Mechanical 
Biological Treatment (MBT). Advocates of this approach may be unaware that the process still 
requires an energy from waste plant. The requirement to build two facilities is unlikely to lead 
to lower costs for boroughs and taxpayers, or better environmental outcomes.

Moreover, MBT plants have not been deployed at the scale required in north London. None have 
operated at design capacity in the UK. When used even on a much smaller scale, recycling outcomes 
have been low and the majority of waste has needed to be burnt.

It has also been suggested to the Authority that it should use Dirty Materials Recycling Facilities 
(D - MRFs) instead of energy recovery. D-MRFs use a combination of hand and machine sorting to 
separate some recyclable materials from residual waste. They do not replace the need for an energy 
recovery facility. Unlike Materials Recovery Facilities (MRF), D-MRFs process residual waste as 
well as separately collected recycling. For this reason, contamination rates are typically much 
higher in D - MRFs and lower volumes of recycling can be extracted. For example, in 2020/21 a D 
-MRF in Brageddie, North Lanarkshire, was reported to have extracted around 3% (6,000 tonnes) of 
processed waste for recycling. The remaining waste is treated in an energy recovery facility. It is 
unclear that this approach, which would require two plants, would provide corresponding 
environmental or financial advantages for north London.

This is not to say that there is a lack of innovation in managing north London’s waste. 
LondonEnergy Ltd is the company owned by NLWA who are responsible for managing waste on the 
Authority’s behalf . They are shortly to begin operating a “picking line” within an existing facility which 
will allow volumes of residual waste to be sorted to extract recycling where possible. This could 
allow some thousands of tonnes of waste to be recycled which would otherwise be sent to the energy 
from waste facility. This is a very positive development and is a further evidence of constructive 
action to reduce residual waste, but it does not change the need for a facilities provided for in 
the North London Heat and Power Project.

In addition, the new Resource Recovery Facility at Edmonton EcoPark will have capacity to manage 
135,000 tonnes of recyclable material every year, including metals, plastic and wood. This will 
help boost recycling rates in north London, but again it does not replace the need for the new Energy 
Recovery Facility.

In your deputation you said that renewable energy should be used instead of energy from waste facilities.
 

The purpose of the new Energy Recovery Facility (ERF) is to manage non-recyclable waste produced by 
around one quarter of north London’s population. The alternative is landfill, not renewable energy.
NLWA’s commitment to building a world-class facility means that, as well as managing non-recyclable 
waste in a saf e and hygienic way, the ERF will produce heat and power for society. This includes 
heating and hot water for thousands of homes in Edmonton. The low-carbon energy will be generated 
at a lower carbon intensity than the source it replaces – namely combined cycle gas turbine power 
plants. The ERF is therefore a low-carbon asset which will contribute to divesting the UK’s energy 
system from virgin fossil fuels.

In your deputation you said that NLWA should pause and rethink the NLHPP.

The NLHPP is a vital infrastructure project which supports our aim to increase recycling and stop 
waste from rotting in landfill. To delay the NLHPP 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.

In your deputation you said that NLWA should spend money on measures to prevent waste and promote 
the circular economy, instead of incineration

Thank you for raising the extremely important issues of waste prevention and recycling. NLWA has a 
wide-ranging programme of activity to prevent waste and promote the circular economy. This includes 
high-impact campaigns as well as capital expenditure on new assets. Our waste prevention measures 
include the country’s first Low Plastic Zones, Stop and Swap online clothes swaps and our Waste 
Prevention Community Fund which empowers innovative local projects. You mentioned reuse shops. Our 
wholly owned company, LondonEnergy, which operates RRCs and the Edmonton EcoPark, runs a Second 
Time Around Reuse Shop which ensures that clothes, furniture and sports equipment, among other 
items, are reused and not thrown away.

With regard to investment in recycling facilities, NLWA is currently bringing forward the most 
significant public sector investment in recycling infrastructure London has seen for a generation. 
This includes a Resource Recovery Facility with capacity to manage around 135,000 tonnes of 
recyclable material every year. The Authority is also building a brand-new public Reuse and 
Recycling Centre to add to its existing network across north London. These assets are part of the 
NLHPP and are being built now at the Edmonton EcoPark.

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