Request
I am writing to request to make a deputation at the NLWA AGM on the 24th June at 2:30pm. My name is Carina Millstone, and I would like to give the deputation in my personal capacity as an environmental campaigner, parent, and resident of South Chingford.
The deputation concerns the plans to install Carbon Capture and Storage (CCS) on the North London Heat and Power Project (the new Edmonton incineration)
Specifically, and with reference to information provided by the NLWA under EIR, I intend to raise the following points:
1. The Committee on Climate Change's (CCC) 6th Carbon Budget (Dec 2020), identified the proliferation of incinerators in the UK as a key challenge in addressing climate change (not part of the climate solution). Key policy recommendations to UK government include: 'To prevent a major increase (in emissions), either a substantial fraction – potentially a majority – of the EfW plant pipeline will have to remain unbuilt, EfW fleet utilisation rates will have to fall, or else carbon capture and storage (CCS) will need to be installed on plants from the mid/late 2020s onwards to mitigate the additional emissions.' ' For those plants not yet under construction, new energy-from-waste plants (and plant expansions) should only be constructed in areas confirmed to soon have CO2 infrastructure available and should be built 'CCS ready' or with CCS.'
2. Since the 6th Carbon Budget, the decarbonisation ambition identified in the budget has been enshrined in legislation, with the government setting a legally mandated target of 78% reduction in emissions by 2035 compared to 1990 levels.
3. Information provided by the NLWA requested under Environmental Information Regulations (EIR) (https://www.nlwa.gov.uk/ourauthority/scheme-of-publications/request-information-about-potential-carbon-capture-and-storage) show that the proposed incinerator does not follow the CCC’s advice, and therefore runs contrary to the new national, legally enshrined emissions reduction target. Specifically, the EIR shows:
- the new incinerator will not be ‘CCS ready’, rather, it will be designed as to ‘not preclude’ future CCS retrofit.
- The new incinerator is not in an area confirmed to have C02 infrastructure available- quite the opposite: the government has not allocated any funding for this in its plans to 2030 (and not provided any information on future funding intentions)
- ‘The likelihood that CCUS will be economically viable depends greatly on establishing a shared ‘infrastructure hub’ in Greater London and the south east of Page 11 England for carbon dioxide transport, intermediate storage and shipment to a longterm storage facility. This is expected to take considerable time’
- CCS on any future Edmonton incinerator is at least 10 years away - after 2031
It is absolutely clear from the EIR response that building a new incinerator with a hypothetical, unproven, un-costed plan to retrofit it with CCS in over a decade will hamper the legally mandated emissions reduction targets set by the government.
I urge the board of the NLWA, composed of councillors whose local authorities have nearly all declared climate emergencies, to recognise the irreconcilable tension between their continued support for the rebuild and expansion of the Edmonton incinerator and the urgent need to decarbonise our economy.
Thank you for your consideration,
Response
14 July 2021
1b Berol House, 25 Ashley Road Tottenham Hale N17 9LJ
enquiries@nlwa.com
nlwa.gov.uk
Ms Carina Millstone Via email
Dear Ms Millstone,
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 Climate Change Committee had identified energy from waste
facilities as an obstacle to Net Zero
Thank you for your deputation about the Climate Change Committee’s position on the waste sector.
NLWA closely follows the guidance set by the Climate Change Committee (CCC) and we are proud that
the NLHPP is aligned with the CCC’s route map for Net Zero. The CCC’s Sixth Carbon Budget is clear
that no biodegradable waste should be sent to landfill at all by 2040, and zero biodegradable waste
by the mid-2020s. Energy from waste is clearly identified by the CCC as the method for residual
waste management during the Net Zero transition, allied with Carbon Capture, Utilisation and
Storage (CCUS) technology by the 2050s. Low-carbon heat networks are identified as a precondition for Net Zero. Our project will unlock one of the largest in London, providing heating and hot water
to thousands of homes in Edmonton.
The waste sector has achieved the greatest reductions in greenhouse gasses of any part of the
economy. This has arisen principally through the use of energy from waste technology in place of
landfill. This is acknowledged by the CCC.
In its June 2021 Progress Report to Parliament, the CCC states: “Waste sector falls were driven
exclusively by reductions in landfill emissions. Waste emissions fell by 28% from 2009 to 2019, but
this was primarily due to the landfill tax diverting biodegradable waste away from landfill to
other waste treatment, particularly Energy from Waste (EfW) incineration”.
In your deputation you suggested that NLWA’s Energy Recovery Facility is not aligned with the CCC’s
requirement of being ‘CCS ready’
Thank you for your question about carbon capture and storage. NLWA welcomes the opportunity to
clarify the CCC’s guidance in relation to this technology and the energy from waste sector.
The CCC’s Sixth Carbon Budget is clear that energy from waste facilities should be fitted with CCUS
by the 2050s (page 154 of the report). NLWA is designing its facility to not preclude CCUS
technology, in line with this objective.
Further detailed information about NLWA’s early planning for CCUS was provided to you in March
2021. The response is available online here.
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
