Request
We would like to register Aurora Yaacov to address the North London Waste Authority Meeting on Thursday 24 June, 2.30pm, under Item 14 - Deputations - on the Agenda.
She is speaking on behalf of a coalition of interests, each representative of a large constituency: Upper Edmonton residents (REACT), local trade unions (NEU, Unite Community) special interest and civil society groups, Labour councillors and members, XR Enfield. All Enfield residents. The points she is intending to make concern:
Failure to engage sufficiently with residents
Residents are unaware, for instance, that waste will be imported into Enfield from other places. Residents are generally unaware of the very nature of incineration i.e. that carbon-based waste is burnt (just like gas, coal and oil) and carbon dioxide is produced; 700,000 tonnes of it each year. Yet this figure isn’t published because it is offset against the carbon dioxide that might have been emitted had gas been burnt for the district heat network. The energy generated from incinerators is neither renewable nor low carbon and certainly not green; to pretend otherwise is to mislead the public. Pause and review would give time for a full and proper public information campaign followed by genuine consultation.
Q1: Is the NLWA confident that the proposed incinerator has the support of directly affected communities, residents of North London and of their MPs, today?
Precautionary Principle
A nine-year-old girl's fatal asthma attack(1) has now been linked to illegally high levels of air pollution. Evidence at home and abroad, using improved bioassay methodologies which can detect the very smallest, ultrafine, particles, are revealing microparticles in the toenails of children and in other plant, animal and human organs, correlated with proximity to an incinerator(2 ). Not, therefore attributable to other sources such as vehicular movements (which are, in any case, scheduled to increase with the import of waste from beyond the NLWA(3)). The current Edmonton incinerator emits some 1.8 billion PM 2.5per second(4) . There is no commercially available equipment to accurately monitor or to completely filter the emissions of ultrafine particulate matter and incinerator operators are not required to monitor where the pollution lands. The DHSC(5) reports that “Studies have not identified a threshold concentration below which there is no association between exposure to particulate air pollution and adverse human health and DEFRA, similarly records “There is no safe level for particulate matter (PM10, PM2.5)” (6) Employing the precautionary principle, pausing and reviewing the evidence, could prevent many premature deaths each year.
Q2: Can the NLWA assure residents living in the path of the plumes that the proposed incinerator will not undermine efforts to improve local air quality and health?
A stranded asset
The NLWA estimates that constructing the incinerator runs upwards of £600 million; with oncosts and risk contingencies bringing it to more than £1bn, approaching double the original estimate. The NLWA’s commitment to installing Carbon Capture and Storage (CCS) has not been costed and the councils’ will bear all these unknown costs(7)
Incineration is 20th century technology and improvements in recycling, waste management and consumption will render the incinerator redundant, a stranded asset, before the end of its operational life; the costs to the 7 authorities sunk. Most certainly so if the Authorities are serious about reaching their 2030 recycling targets. Targets reached already by some authorities in the UK and by no mean unrealistic. The plant is oversized. At least 50% and probably 85% of its capacity would not be used over its lifetime. Not all the money spent to date will be lost, because much of it is investment in the infrastructure necessary for more functions beyond incineration, such as Resource Recovery and the Reuse and Recycling Centre. A pause, and review of the full cost is possible and would reveal that there are much less costly and more sustainable solutions to waste management. Not to do so will cost far more: environmentally, socially and economically.
Q3: Is the NLWA confident that the business case for the proposed incinerator holds true today and over its lifespan and that it will not lock North London -and the UK-into the economic system that has created the climate and ecological emergencies?
Aurora Yaacov, Southgate CLP EnCaf [Enfield Climate Action Forum https://www.encaf.org
Vivien Giladi, Enfield Nth CLP Unite Community Socialist Health Association Enfield Health and Wellbeing Board
Dr Bernard Regan, Enfield North CLP NEU
Grace Coiffic-kamali Chair REACT [ Residents of Edmonton Angel Community Together https://reactedmonton.org ]
Cllr Yasemin Brett, Southgate CLP Unite Community Enfield, Political Education Officer
Francis Sealey Director at GlobalNet21 and Author of Global Public Square EnCaf [Enfield Climate Action Forum https://www.encaf.org/ ]
Maria McCaul Chair Unite Community, Enfield
References:
1 https://www.theguardian.com/environment/2020/dec/16/girls-death-contributed-to-by-air-pollution-coroner-rules-in-landmark-case
2 Biomonitoring of Metals in Children Living in an Urban Area and Close to Waste Incinerators: https://www ncbi.nlm nih.gov/pmc/articles/PMC7143875/
3 http://www northlondonheatandpower.london/faqs/future-proofing/what-happens-when-recycling-rates-increase-and-there-s-less-nonrecyclable-waste-to-treat/ http://www northlondonheatandpower.london/faqs/future-proofing/is-it-big-enough-to-meet-current-and-future-waste-needs/
4 https://ukwin.org.uk/files/particulates/PRG Particulates Matter December 2019.pdf
5 https://ukwin.org.uk/files/particulates/PRG Particulates Matter December 2019.pdf
6 Source: DEFRA, PHE and Local Government Association, Air Quality: A Briefing for Directors of Public Health (DEFRA, March 2017)
7 Information obtained under Environmental Information Regulations (EIR) shows that this plan has not been costed
Response
14 July 2021
1b Berol House, 25 Ashley Road Tottenham Hale N17 9LJ
enquiries@nlwa.com
nlwa.gov.uk
Ms Aurora Yaacov By email
Dear Ms Yaacov,
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 requested that NLWA Members pause and review the NLHPP.
I would like to reassure you that the NLHPP 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.
The project is a vital infrastructure project which supports NLWA and boroughs’ aim to increase
recycling and stop waste from rotting in landfill. 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 risks of delaying the NLHPP are severe. 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 lifechanging 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.
In 2019, the High Court categorically refused a request to judicially review the Government’s
consent f or the NLHPP. We are building the NLHPP in line with the 2017 Development Consent Order
and rapid progress is being made to build a vital community asset for our residents.
In your deputation you raised concerns about the carbon impact of the NLHPP.
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 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 it is impossible to forecast waste volumes decades into the
future. You also said that north London’s waste volumes have been falling year on year.
Thank you for your question about waste forecasts. North London Waste Authority has carried out
thoroughly researched Need Assessment for residual waste capacity, in line with our duty to plan
essential waste services for two million people.
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 North London Heat and Power Project 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”.
Residual waste arisings are in line with forecasts. 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.
In your deputation you said that the NLHPP will contribute to overcapacity of energy from waste
facilities in London.
It may help if I clarify the Mayor of London’s policy position regarding the NLHPP. The Mayor
states on page 281 of his Environment Strategy: “modelling suggests that if London achieves the
reduction and recycling targets set out in this strategy, it will have sufficient capacity to
manage London’s non- recyclable municipal waste, once the new Edmonton and Beddington Lane
facilities are operational”.
The NLHPP is clearly an important part of London’s future waste infrastructure. The Mayor’s
position aligns with the Need Assessment undertaken for the NLHPP as part of the Development
Consent Order application.
NLWA is proud that, as a result of the carefully considered way in which the NLHPP was planned, the
NLHPP is part of the Environment Strategy.
In your deputation you claimed there is a paucity of evidence in relation to the health impacts of
energy from waste facilities. You said the only study to include the Edmonton facility was
published in 2016 and flaws have been pointed out in the methodology. You said other peer reviewed
studies unambiguously document adverse health outcomes and cancer in areas where modern facilities
are operating. You said an Italian study revealed health impacts associated with energy from waste
facilities.
The Authority takes extremely seriously our duty to protect our residents’ health. I would like to
reassure you that the scientific evidence about the safety of modern energy from waste facilities
is not consistent with your deputation.
The clear scientific consensus, based on the overwhelming weight of evidence, is that modern
facilities make an exceedingly small contribution to pollution and do not pose a significant
health risk. The position is made by the following authoritative bodies:
• Public Health England states: “modern, well run and regulated municipal waste incinerators
are not a significant risk to public health.”
• Imperial College London (whose research included our existing facility) concluded in 2019:
“This large national study found no evidence for increased risk of a range of birth outcomes,
including birth weight, preterm delivery and infant mortality, in relation to either MWI emissions
or living near an MWI operating to the current EU waste incinerator regulations in Great Britain”.
It is important to note that the team which conducted this research are world leaders in
environmental epidemiology and it is considered one of the most robust studies ever undertaken on
the impacts of energy from waste facilities.
• The UK’s Institute of Occupational Medicine carried out in 2020 a literature review of 35
scientific papers which examined the health impacts of energy from waste facilities. The report
states: “we conclude that any potential health risks associated with direct emissions from modern,
effectively managed and regulated MSWIs in London are exceedingly low”.
With regard to the Italian study, it is assumed that you are referring to Biomonitoring of Metals
in Children Living in an Urban Area and Close to Waste Incinerators, March 2020, Di Ciaula et. al.
This analysed the impacts of two plants in close proximity to each other, one being a plant for
hospital waste. The context is therefore different to north London and no link has been shown to
that work and our existing and new facilities in north London.
In your deputation you asked that a new public consultation is carried for the NLHPP, including new
information about the project.
NLWA is committed to public consultation, and this was a vital part of the planning process for the
NLHPP. A full public consultation and Examination in Public was undertaken for the NLHPP prior to
the submission of the Development Consent Order application.
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.
The DCO application included a 2,000-page Environmental Statement which fully considered the
environmental and social matters raised in your deputation. The documentation was reviewed by the
independent Planning Inspectorate, which recommended the application for the approval. The
Secretary of State followed this recommendation in 2017. Members continue to consider all the
relevant issues in their decision making for the NLHPP.
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
