Request
Dear Cllr Clyde Loakes (Chair NLWA)
NLHPP (North London Heat and Power Project) in Edmonton
I am writing on behalf of seven Enfield Councillors, listed below, who wish to make a deputation to the NLWA at their meeting on 25th June 2020, seeking a pause and independent review of the procurement of the Edmonton ERF (incinerator).
Our view is that radically changed circumstances locally, nationally and internationally since the ERF was planned mean that the proposed ERF is neither fit for purpose nor economically viable. We make the modest request for an independent review of the terms of the procurement of the ERF before proceeding further and before it is too late.
Edmonton is amongst the 10% most deprived areas of London and the UK with extreme health inequalities.
We have concluded that a smaller ERF designed to deal with non-recyclable waste from the 7 authorities only should be on the table, with interim capacity to deal with some recyclable waste whilst recycling levels improve and over dependency on plastics declines.
There are many changed circumstances that point to a need to delay the implementation of the Energy Recovery Facility (ERF).
One of them is simply that MPs and constituents are becoming much more aware of the significance of incineration and its contribution, as an oxidising process, to CO2 emissions which we are legally and ethically committed to cutting. Offsetting and “like for like” strategies on emissions are not enough.
We feel sure that residents of Edmonton, and Enfield, were not aware that the NLWA intends to
• import, and burn, waste to Edmonton from beyond the boundaries of the seven North London boroughs with concomitant HGV movements and pollution in an area already gridlocked at peak times
• continue to burn waste that can be recycled
Post Covid 19 Will See A Financial Depression Of Incalculable Depth
• Councils will be strapped for cash, reserves plundered for Covid 19, managing a debt, with interest, for the biggest Energy Recovery Facility in Europe.
• Lowered consumption by families desperate to make ends meet and therefore much reduced waste; lowered economic output and reduced commercial waste will mean even more import of waste to Edmonton from areas beyond London adding incrementally over time to HGV movements, pollution and other environmental impacts.
The Public Has Woken Up To The Impact Of Plastic Waste On Our Land And Oceans With A Quiet Revolution On How We Consume Plastic Products
• With the change in attitude, improved plastics technology means more and more plastic is recyclable
• Less and less plastic is used for packaging
• Consequently, there will be less non-recyclable fuel for the Energy Recovery Facility and even more waste will need to be imported.
Legislation, Policy And Guidance Have Totally Changed The National Landscape Since The Decisions On The NLHPP (North London Heat And Power Project) Were as Agreed
• Parliament has passed The Climate Emergency Act 2019.
• The seven North London councils and the GLA have declared an environment and climate emergency (Enfield in 2019)
• Government Resources and Waste Strategy 2019 published, which will see
o A tax on plastic packaging
o A consideration of the need for an incineration tax
• Government policy A Green Future: Our 25 Year Plan to Improve the Environment published in 2018
• Green New Deal
o 6 of the 7 north London councils are Labour controlled. The 2019 Labour manifesto, the “Green Industrial Revolution” is clear “Whenever public money is invested in an energy generation project, the public sector will take a stake and return profits to the public”.
o Dr Alan Whitehead MP, Shadow Minister for Energy and the Green New Deal, said in a parliamentary debate on Feb 11 2020 about Waste Incineration Facilities that “we need to understand why, in an era of zero-carbon ambitions for our economy, the idea of granting permission for such enormous plants to deal with our waste is still being contemplated”.
And finally, extant plans take no account of the many relevant changes in the last decade or the changes now envisaged. The outdated (2009) North London Joint Waste Strategy won’t be replaced until the policies of central government are developed, and the implications for waste management after ceasing to be part of the EU are better understood (NLWA Feb 2020 meeting). The North London Waste Plan collapsed last November at its Examination in Public and the revision was delayed indefinitely because of Covid 19.
Deputation
Cllr Vicki Pite cllr.vicki.pite@enfield.gov.uk Chase ward, Enfield Nth
Cllr Yasemin Brett cllr.yasemin.brett@enfield.gov.uk Bowes ward, Southgate
Response
Dear Councillor Pite,
I am writing to you regarding your deputation to the North London Waste Authority (NLWA) meeting on Thursday 25 June 2020 given on behalf of Councillor Brett, Councillor Akpinar, Councillor Gunawardena, Councillor Brown and Councillor Orhan. This was in relation to the North London Heat and Power Project (NLHPP). I would like to thank you for joining the meeting and setting out the issues you wanted to draw to Members’ attention.
Following a thorough review of the proposed project, including the points raised in the deputations, I am letting you know that Members unanimously approved the start of procurement for the new Energy Recovery Facility (ERF). As promised in the meeting, we are responding in writing to each deputation. I have outlined the key points you raised and provided a response for each below, to advise you of Members’ understanding of these issues in making their decision.
In your deputation you suggested that the NLWA should build a smaller ERF. We want to reassure you that the capacity of our ERF has been carefully planned by examining future waste trends in north London. NLWA’s waste modelling, has been scrutinised by an independent planning inspector. This examined population rises, employment, household income, as well as waste reduction and recycling in the future. The modelling reaffirmed that the ERF needs capacity to treat up to 700,000 tonnes of north London’s non-recyclable waste each year by 2050. A smaller ERF would not be appropriate for tackling the challenge of north London’s non-recyclable waste in the future. Waste experts, including the Greater London Authority (GLA), are clear that the volume of residual waste across London is set to rise. Population increases mean that, while individual households will recycle more and produce less waste, the overall volume will still go up.
In your deputation you alluded to the link between incineration and its contribution to CO2 emissions. Firstly, it is important to remember that each piece of non-recyclable waste produced by our residents contains carbon. Therefore, every method for disposing of this waste generates greenhouse gasses that contribute to climate change. However, our duty in this time of Climate Emergency is to minimise its environmental impact. Landfill is the worst option for the environment as it produces vast quantities of uncontrolled methane emissions, which is at least 25 times stronger than carbon dioxide. Moreover, landfills scar our countryside for generations and produce leachate that can severely pollute water courses. In contrast, our ERF will save the equivalent of 215,000 tonnes of CO2 every year compared to landfill – which is like taking 110,000 cars off the roads every year. More information is available in the carbon impact screening prepared for the Project here. The methodology used in this report follows internationally recognised scientific standards set by the Intergovernmental Panel on Climate Change (IPCC).
In your deputation you claimed that the NLHPP will import waste from beyond the boundaries of the seven north London boroughs which will therefore impact on HGV congestion. The NLHPP is first and foremost a facility for north London that is sized to deal with north London’s residual waste needs. This ensures waste from north London does not need to be sent out of London creating more traffic on the roads and increasing the carbon footprint of the waste. The NLHPP is replacing a facility on the same site which has been operating for 50 years and is reaching the end of its life. We need to replace this facility to meet the Mayor of London’s self-sufficiency targets which requires London to be treating the waste it generates within London’s boundaries, not transporting it across the UK or abroad. Our new facility is recognised by the Mayor of London as a nationally significant piece of infrastructure for net self-sufficiency in London. Accepting waste from third parties, including local businesses and other local authorities, will only be considered if the ERF has spare capacity. This would provide an income stream for north London if, and only if, the needs of north London’s residents are served first. Our waste modelling shows that our residents will produce up to 700,000 tonnes of residual waste by 2050. Our new ERF will have capacity to treat this volume of waste. In your deputation you claimed that in the future waste levels will fall and more plastics will be recycled. Waste experts, including the GLA, predict that the amount of residual waste in north London, and across London, is expected to increase in the future. This is despite higher recycling rates and reduction in waste, which is being driven by initiatives like our Low Plastic Zones. Individual households are expected to reduce their waste and recycle more however, housing growth means there will be more households, which will increase the overall volume of waste. In the same way, business growth will lead to a greater overall volume of waste, despite increasing recycling rates and reduction measures. The GLA is clear that the NLHPP is required for London to manage its own non-recyclable waste in the future. In doing so, the Project will prevent landfilling and its severe environment consequences.
In your deputation you claimed that the NLHPP is not consistent with Labour’s plan for a Green Industrial Revolution. The “Green Industrial Revolution” is clear that “whenever public money is invested in an energy generation project, the public sector takes a stake and profits return to the public”. NLHPP is completely consistent with this as it is funded, developed and owned by the NLWA. This low carbon Project is being constructed in close collaboration with trade unions and with oversight from the Environment Agency and the Greater London Authority (GLA) and like with all projects of this scale it will be subject to thorough and detailed on-going scrutiny. The ERF will generate low-carbon heat and power for up to 127,000 homes which aligns with Labour’s commitment to deliver nearly 90% of electricity and 50% of heat from renewable sources by 2030. In addition, the ERF provides the potential to heat 10,000 homes at Meridian Water, and therefore aligns with Labour’s commitment to “investing in district heat networks using waste heat”. Our Project will provide at least 100 apprenticeships in high-tech science, technology, engineering and maths (STEM) sectors for the future, including engineering and construction and we’re also working with trade unions to ensure that our Project provides well-paid unionised jobs. The NLWA has led the campaign for many years in calling for the Government to make producers responsible for the waste they create. In doing so, we have long supported the objectives of Labour’s Green Industrial Revolution. In your deputation you requested that the NLHPP be paused and independently reviewed. Pausing the Project would post severe environmental and financial risks and would simply not be compatible with our prime responsibility to provide responsible, effective and long-term solutions for our residents. The Project has already been thoroughly reviewed and approved, following several years of comprehensive environmental analysis, as well as an extensive two-stage public consultation, and careful consideration of the alternative options. It is absolutely vital that we progress the Project in line with our timescales and any delay or pause would be incompatible with our efforts to tackle the Climate Emergency. North London’s boroughs set out at length their support for the Project in a detailed letter published in April 2020.
If you have any further questions about the Project or require any clarifications, I would be happy to answer them or arrange a briefing at a suitable time.
Yours sincerely,
Cllr Clyde Loakes
