Request
I would like to register myself Delia Mattis, Founder of Black Lives Matter Enfield, to address the North London Waste Authority Meeting on Thursday 24th June, 2.30pm, under Item 14 - Deputations - on the Agenda.
The points I am intending to make are:
- Institutional and environmental racism - Black Lives Matter Enfield is calling for the plans to expand the Edmonton incinerator to be paused and for the North London Waste Authority to properly consult the people of Enfield. We believe it is racist planning that determines where these incinerators are allowed to exist. Incinerators are three times more likely to be built in deprived areas which are more likely to have a racially diverse population like Edmonton which is around 60% black, brown or other racial or ethnic group.
- Ella Kissi Debrah died in 2013, she lived near the South Circular Road in Lewisham, south London and the recent coroner’s ruling that air pollution made a material contribution to her death, has sent shock waves through the black community in Enfield. Edmonton is already polluted from the North Circular Road, the expanded incinerator on top of this will make matters worse in terms of vehicles on the North Circular travelling to and from the plant as well as burning more rubbish.
- Health Inequality - Covid-19 has disproportionately affected Black and Brown communities. In Edmonton covid mortality rate is 40% higher than England average according to ONS statistics and is one of most deprived areas of UK, those in power should be choosing to break cycles of inequality and injustice not lock them in by building an even larger incinerator at the same site.
- Experts are now linking air pollution to Covid 19 deaths. The ONS has published a report on the link between long-term exposure to dirty air, severe symptoms of COVID-19 and a greater risk to deaths. This gives even more reason for black communities to oppose the plans
Kind regards
Ms Delia Mattis
Telesha Reid
Mrs Stalla Simonin
Response
14 July 2021
1b Berol House, 25 Ashley Road Tottenham Hale N17 9LJ
enquiries@nlwa.com
nlwa.gov.uk
Ms Delia Mattis Via email
Dear Ms Mattis,
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 claimed that the NLHPP is the product of a racist planning system. In
particular, you said that incinerators are three times more likely to be built in deprived areas
with a higher BAME population.
As a public servant, NLWA is committed to protecting the health and quality of life for all our
communities. This is reflected in the care with which the NLHPP was planned and is being delivered.
The North London Heat and Power Project (NLHPP) was subject to extensive public consultation and a
rigorous, independent Development Consent Order (DCO) process, which resulted in the Planning
Inspectorate recommending the project for approval and the Secretary of State accepting this
recommendation and granting consent in 2017.
The NLHPP is being built now in line with the DCO consent. We emphasise that the project will
enhance the quality of life for north London’s residents, including those who live nearest the
site. It will provide a safe and hygienic waste management service for over two million people.
Although this fundamental point is often taken for granted, facilities like ours keep waste off
the streets and ensure it is disposed of in a safe and efficient way. The COVID-19 pandemic has
reinforced the vital importance of this essential service, which our facility will safeguard for
another generation.
Enfield Council has a vision for Edmonton as a home for high quality industrial activity,
providing skilled jobs and attracting modern business. The need to promote a green recovery from
the COVID pandemic reinforces this. Our new facility contributes significantly to this vision.
During construction we’re creating apprenticeships and training opportunities for young people in
Enfield, when other opportunities have been reducing. We’re delivering at least 100 life-changing apprenticeships
across the build phase. We’ve already appointed 13 apprentices, 8 from Enfield, in roles ranging
from construction to engineering and business administration. We’re also providing a training
programme, helping local people without work to get back into employment. So far we’ve trained 34
people through our project, equipping them with vital skills to get a head start in the
construction sector. We’re proud to be offering at least 225 placements throughout construction.
In your deputation you referenced a planning application for a facility in Cambridgeshire that was
refused by the Secretary of State. I would like to clarify that this decision did not relate to
the socioeconomic composition of the area. The proposals for an energy from waste plant in Wisbech, Cambridgeshire, were refused by the Secretary of State on the grounds that the plant would
negatively impact the visibility of a designated heritage site, the Denny Abbey Complex.
The Secretary of State’s decision explicitly noted the environmental, economic and waste management
benefits that a new facility could offer the area. However, it was determined that the benef its
were outweighed by the heritage impact. The context is therefore very different to the NLHPP.
In your deputation you said that NLWA had made little effort to engage the local community
regarding the NLHPP, particular people from a BAME background.
NLWA consulted extensively with the local community prior to submitting the DCO application. Its
engagement continues now that the project has entered construction.
NLWA carried out an extensive two-stage consultation in 2014-15, with newsletters sent to 28,000
properties and a series of events held across Enfield and other nearby boroughs. Local feedback
helped to shape the project that is now being built. NLWA continues to engage with local people as
the project enters construction – through newsletters, our Community Liaison Group, regular website
updates (northlondonheatandpower.london) and our Twitter page (@NLHPP). Before Covid-19 The
Authority held roadshows across Edmonton, and it looks forward to doing so again when public health
guidance permits it.
In your deputation you said that Edmonton is already polluted from the North Circular and the
expanded incinerator will make matters worse, both in terms of vehicles on the North Circular and
from burning more waste. You suggested that mortality rates from Covid-19 in Edmonton could be
linked to the existing energy from waste plant – particularly in relation to the emission of
ultrafine particles.
NLWA shares your concern about air quality in north London, but is clear that the existing and
future plants in Edmonton are an extremely small source of pollution and are not linked to the
negative heath outcomes you raised in your deputation.
A common misunderstanding about energy from waste facilities is that they are a major source of
pollution and therefore have a significant impact on public health. The scientific evidence clearly
contradicts this point. Studies from world leading health experts, including Imperial College
London, have concluded that modern facilities have an exceedingly small impact on pollution and
present an extremely low risk to public health. This position is supported by Public Health England
– the Government’s independent health advisors.
The North London Waste Authority’s top priority is to protect our residents’ health. NLWA is
investing in the world’s best technology to control emissions from our new Energy Recovery Facility
(ERF) – including particulates and nitrogen oxides. The Authority is using a higher class of
technology than any other UK facility and, as a result, the new ERF will be the safest and
cleanest in the UK. Emissions will be well within the stringent safety limits set by the
Environment Agency and NLWA is proud to be serving its communities in this way.
The emissions control technology will be so effective that, for the vast majority of the year, the
ERF is expected to have effectively no impact on local concentrations of pollution. Other sources
will vastly outweigh the clean and modern facility – including road transport and wood fires in
people’s ho mes. As you said, Edmonton in particular suffers from the impacts of the North
Circular, with road transport being the biggest single biggest cause of local pollution.
With regard to ultrafine particles, The UK’s Air Quality Expert Group is clear that: “There have
been a number of studies of municipal waste incinerators, which shows highly effective removal of
UFP [ultrafine particles] by their pollution control systems”. The report from the Air Quality
Expert Group is available online here.
In addition, a study by the University of Birmingham states: “after dispersion and dilution, the
levels of UFPs [ultrafine particles] is indistinguishable from those that would occur in the
absence of an incinerator…in some cases, the ultrafine particle concentration in the flue gas may
be below that in the ambient air”.
In your deputation you referenced the findings of a study by the Office for National Statistics
which linked air pollution with Covid-19 deaths.
Air quality continues to be a major issue in London, but it is wrong to claim that our new Energy
Recovery Facility will contribute to the problem and pose a significant risk to health. Our
facility will be the safest and cleanest of its type in the UK, and we’re proud to be serving
north London’s communities in this way. I have provided more information about the clear scientific
guidance in my earlier response.
In your deputation you claimed that the NLHPP is being built to make profit for the incineration
industry.
I would like to reassure you that the NLHPP will be a publicly owned and operated asset. It will
not make profits for the private sector. NLWA’s investment in environmentally responsible
infrastructure will protect public services and drive the local economy recovery from Covid-19.
In your deputation you said that you wanted Councillor Clyde Loakes, Chair of NLWA, to resign his
position
NLWA Members re-elected Councillor Loakes as NLWA Chair on Thursday 24 June. This followed a
ground-breaking year across NLWA’s activities – the full details of which are provided in the NLWA
Annual Report. Some key highlights include:
• £60,000 in funding awarded to innovative local campaigns through the Authority’s Waste
Prevention Community Fund
• Significant investment in a ground-breaking trial to recycle north London’s old mattresses
which is expected to extract 700 mattresses from the waste stream each week
• Hosting the largest ever Waste Prevention Conference, which was panelled by waste sector
leaders and experts, focussing conversations on Extended Producer Responsibility (EPR)
• 1,000 tonnes of nappy waste avoided as a result of NLWA’s reusable nappy scheme
• Launching a major new recycling campaign to curb the problem of contamination, with a purpose
to help change behaviours and put waste in the correct bins
• Major progress made to build a brand-new Resource Recovery Facility as part of the NLHPP,
enabling north Londoner’s to bring their recycling direct to the EcoPark for the first time ever
which is part of our plan to achieve a 50% household recycling rate
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
