Request
Request for deputation to NLWA from Islington Environmental Emergency Alliance
Making the request: Ben Griffith
The deputation: Caroline Royds - Lindy Sharpe - Jill Ellenby – Richard Gallen - Ben Griffith
One member of deputation to address the NLWA: Ben Griffith
Summary: Islington Environmental Emergency Alliance brings together Islington residents, business owners, subject matter experts, environmental campaigners, religious leaders, organisations and community groups from across the Borough. The purpose of the collaboration is to assist, through constructive challenge and input, Islington Council to meet their objectives for reducing greenhouse gas emissions.
The IEEA has a number of working groups including one on waste. The IEEA waste working group is deeply concerned about the proposed 30 per cent expansion and redevelopment of the north London incinerator, which will operate up to 2060 and maybe beyond, because of
- The exacerbation of air pollution
- The emission of greenhouse gases
- The perpetuation of the linear economy.
There are strong reasons to believe that the proposed 30 per cent expansion lacks a solid rationale
- According to the NLWA’s projections in the Need Assessment, the new incinerator would be much too large except in the worst-case Low Recycling scenario
- Total waste arisings are turning out lower than the projections
- The projections predated the development of economic and political drivers to reduce waste, which have emerged largely in light of the climate emergency
- Surplus incineration capacity is developing across London and the UK.
Just as roads can generate traffic so incinerators can generate waste. We are particularly concerned that the planned incinerator will have surplus capacity and this will undermine efforts to reduce residual waste for reputational, financial, ideological and structural reasons.
Instead of planning for increasing residual waste, the NLWA and the local Councils should aim to drive it down:
- Reduce total waste arisings through developing a circular economy. Arup reported to the London Waste and Recycling Board: ‘A potential reduction of more than 60% in waste arisings can be achieved in less than 30 years. However, a central estimate of approximately 30% waste reduction is likely to be achieved depending on the levels of uptake of circular economy initiatives.’
- Work with residents and businesses to increase recycling by all means possible, eg. by investing in facilities to make it more convenient. We should respect and strive to achieve the London Mayor’s target of 65% recycling of municipal waste by 2030. We must learn from best practice including Wales’s achievement of a 65% recycling rate in 2020 through the Welsh Collections Blueprint.
- Invest in technology to separate recyclables, in particular plastics, from ‘black bag’ waste along the lines of the facilities operating successfully eg in the Netherlands. Overall, the performance of residual waste sorting at present is around 40% when organic recovery is included and could rise to 50%.
We strongly support calls for a pause in the new incinerator project and an independent expert review to develop a strategy to drive down residual waste and identify the most sustainable way to deal with the unavoidable waste that remains.
Response
14 July 2021
1b Berol House, 25 Ashley Road Tottenham Hale N17 9LJ
enquiries@nlwa.com
nlwa.gov.uk
Mr Ben Griffith Via email
Dear Mr Griffith,
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 responsibilities in protecting public services, public health, and the
environment and have carefully considered these aspects 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 you are concerned about the expansion of the energy from waste facility
in Edmonton. You said this will contribute to surplus energy from waste capacity that is developing
in London and the South East.
I would like to clarify that NLWA is not expanding the existing plant. It is investing in a new,
world- class Energy Recovery Facility (ERF) which will provide combined heat and power and use the
best technology of any UK facility to clean emissions. It is a vital asset for tackling the Climate
Emergency, managing residual waste safely and efficiently, and diverting waste from landfill. The
ERF is one of a range of facilities being built as part of the NLHPP. This includes a new Resource
Recovery Facility with capacity to manage up to 135,000 tonnes of recyclable material every year,
as well as the first ever public reuse and recycling centre at the site.
With regard to energy from waste capacity, the Mayor of London’s Environment Strategy states on
page 281: “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.
In your deputation you claimed that waste arisings in north London are lower than forecast in the
Development Consent Order Need Assessment. You also said that the new incinerator will be too
large, except in the ‘worst case scenario’ for recycling.
Thank you for your question about waste forecasting. This is a topic that NLWA takes very
seriously, and I would like to reassure you that real life data aligns with the Need Assessment
forecasts. The waste forecasts carried out for the NLHPP anticipated residual tonnages between
582,000 to 663,000 tonnes in 2019/20. Actual arisings were around 581,000 tonnes.
For 2020/21, the waste forecasts suggest a range of 567,000 to 661,000 tonnes for residual waste.
Actual arisings were 570,394 tonnes.
I would like to clarify that the capacity of the ERF is not based on a ‘worst case scenario’ for
recycling. NLWA submitted forecasts of demand for the new ERF as part of the Development Consent
Order (DCO) application. A set of recycling scenarios were applied to overall forecast waste arisings and NLWA submitted that an ERF with capacity to treat 700,000 tonnes of residual waste per annum was
appropriate for north London’s future requirements, having regard to the Authority’s statutory
duty. More information is online here via the Need Assessment produced for the DCO.
In the Examining Report for the DCO application, the Planning Inspector stated: “I conclude that
the design capacity of the proposed ERF is reasonable taking the forecasts into account, and
particularly the very substantial uncertainties involved in looking over 35 years into the future”.
NLWA has a duty to provide appropriate capacity to manage north London’s residual waste, now and in
the future. There are significant risks with not providing suitable capacity. Most significantly,
it could mean disposing of our residents’ residual waste via landfill which would have significant
environmental and financial consequences.
In your deputation you said that you are concerned about the impact the NLHPP will have on climate
change.
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 caref ully 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 NLWA should commission an independent review into the alternative
options for residual waste disposal. You said that this should include a review of facilities that
can extract plastics from black bag waste, as used in the Netherlands.
NLWA has carefully considered the alternative options and a full review has already been
undertaken. This Alternatives Assessment Report is available on the NLHPP website. It considered
and rejected the same alternatives that are frequently put to the Authority: landfill; Mechanical
Biological Treatment (MBT); and gasification. Landfill has an unacceptable impact on the
environment; and MBT and gasification are small scale and problematic. They both produce a fuel
which is burnt. Their environmental advantages compared to the NLHPP are uncompelling.
The Authority carried out a further options review after the DCO application was made. The report,
North London Heat and Power Project Summary Paper on Options, is available on the Authority’s
website here. It concluded that the NLHPP represents the best solution for north London for a range
of factors, which together include cost, technological performance, environmental outcomes and
socioeconomic benefits.
You reference facilities in the Netherlands as a model for NLWA to follow. You did not specify
individual facilities. However, in previous correspondence you ref erred to a sorting plant in
Amsterdam. As the Authority pointed out in our earlier response, this facility has not recycled 40%
of materials. Nor have equivalent facilities elsewhere in the Netherlands. The Amsterdam plant has
been beset by series issues. Around 10% of the waste is reported to have been successfully
recycled; the rest burnt. The Municipality of Amsterdam commissioned an investigative report in
2020, which was highly critical of the plant and its shortcomings.
Notwithstanding these issues, no existing ‘pre-sorting’ plant in the world comes close to being
able to handle north London’s volumes of waste. Moreover, the Dutch facilities are funded by a
“polluter pays” tax levied on manufacturers. No such scheme is in place in the UK. The capital,
operating and maintenance costs of such a plant in north London would instead need to be borne by
local authorities. This is estimated at between £50 – £100 per tonne, which would add £30 – £60m
per year to costs for north London’s taxpayers.
This is not to say that there is a lack of innovation in managing north London’s waste. An
innovative picking line within an existing facility will allow volumes of residual waste to be
sorted to extract recycling where possible. This is a very positive development, but it does not
change the need for the facilities provided by the NLHPP.
In your deputation you said that NLWA should work with residents to increase recycling, including
investment in new recycling facilities. You referenced suggestions that Extinction Rebellion has
shared with Islington Council, which you claim will significantly increase recycling rates in north
London.
Thank you for your ongoing enthusiasm for waste prevention and recycling. They are vital issues
for tackling the Climate Emergency, and we share your commitment to moving towards a circular
economy in north London.
As you will be aware, NLWA delivers high-impact, extensive campaigns to encourage correct recycling
from residents. This is coupled with one of the most comprehensive recycling collection services in
the country, accepting the maximum possible range of items. As a result of our efforts to encourage
residents to recycle more, we’re helping shape the process for reuse and recycling of plastics not
only in north London, but across the rest of the UK. The volume of plastic recycling we collect has
enabled our recycling partner Biffa to invest in world-leading recycling technology, which the rest
of the country is now benefitting from. We have ensured that 100% of the plastic, steel and
aluminium which is recycled gets processed in the UK, supporting UK jobs. Bif fa’s new County
Durham plant uses the world’s most advanced technology to recycle the equivalent of 1.3bn plastic
bottles a year.
In addition to our award-winning waste prevention programme of activities, we are leading the way
to call on Government to speed up reforms that will making recycling compulsory and enable more
plastic to be recycled, such as a deposit return scheme for bottles. We also want government to
make producers responsible for their packaging through a “polluter pays” policy called Extended
Producer Responsibility. We would welcome your support in calling for greater action from
Government.
NLWA is now building the most significant new public sector recycling infrastructure London has
seen f or a generation. As part of this £100m investment, we are building a new Resource Recovery
Facility, with capacity to manage 135,000 tonnes of materials for recycling every year, as well as
a public Reuse and Recycling Centre. I have referenced above the pioneering approach we are taking
in an existing facility in the more immediate term.
With regard to Extinction Rebellion’s suggestions on recycling, you will be aware that LB Islington
has responded in detail to each of them. In summary, while NLWA and boroughs welcome Extinction
Rebellion’s interest and involvement on a key issue, we have to be clear that many of the proposals
– as well as other initiatives – are already being delivered in north London. For example, in June
2021 we announced a new mattress recycling scheme, which is expected to recycle 700 mattresses (17
tonnes) a week. Ultimately we ask that Extinction Rebellion join us in calling for action from
Government to introduce urgent reforms – including Extended Producer Responsibility and a Deposit
Return Scheme – to achieve the outcomes that our residents, boroughs and the environment deserve.
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
