Deputation request from Councillor Emma Best AM, Londonwide Assembly Member & Endlebury Ward Councillor (Waltham Forest)

14 July 2021

1b Berol House, 25 Ashley Road Tottenham Hale N17 9LJ
enquiries@nlwa.com
nlwa.gov.uk

Councillor Emma Best Via email
 

Dear Councillor Best,

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
inf ormation on the project in relation to the topics you have raised.

In your deputation you asked that NLWA pause and review the NLHPP

The NLHPP is a vital infrastructure project which supports our aim to increase recycling and stop 
waste from rotting in landfill. To delay the NLHPP would massively undermine our efforts to tackle 
the Climate Emergency and reach Net Zero, both of which are at the forefront of discussions f or 
COP26 this year. 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.

In your deputation you claimed that there is growing evidence that energy from waste is no longer 
environmentally sustainable.

On the contrary, NLHPP aligns with international, national, regional and local policies on waste management and climate change. The Committee on Climate Change (CCC) recently confirmed in its Sixth Carbon Budget that facilities like our ERF should be the principal disposal route as the UK transitions to Net Zero. In addition, the CCC highlights the importance of 
low-carbon district heat networks in achieving Net Zero.

The impacts of not building the NLHPP would be detrimental to north London residents and also in 
our efforts to tackle the Climate Emergency. 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 life changing 
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.

The Project 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. As part of the DCO process, 
NLWA undertook a full Environmental Statement for the project, which entailed 2,000 pages of 
careful analysis of a range of environmental, social and technological factors. This Statement was 
subject to an Examination in Public and recommended for approval by the Planning Inspectorate.
You also suggested that the NLHPP is not financially viable. I would like to clarify that the NLHPP 
is the most cost-effective solution for treating north London’s waste in the future. The Authority 
keeps under review the successful and cost-effective delivery of the project. The comparator – if the 
project did not proceed – is against disposal of waste through third party capacity. Waste disposal 
rates in the market are higher than for a facility which would be funded and owned by the Authority 
and operated by LondonEnergy Ltd. In addition, transporting waste out of the north London area 
would impose a transport cost and would mean abdicating responsibility for being self-sufficient in 
terms of waste management.

Not building the NLHPP could result in north London’s residual waste going to landfill, which has 
been costed at an additional £15 million to £26 million per annum from 2027. This would be an 
unacceptable cost increase for our residents and undermine our efforts to tackle the Climate 
Emergency.

Alongside the delivery of the NLHPP, NLWA continues to deliver it’s award-winning waste prevention 
programme including ground-breaking initiatives and activities. We have just announced significant 
investment in a new trial to recycle north London’s old mattresses which is expected to extract 700 
mattresses from the waste stream each week, and are trialling at a new facility in Wembley an 
innovative picking line to extract even more material from waste, which would otherwise be sent to 
landfill.

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. Biffa’s new County Durham plant uses the world’s most advanced technology to 
recycle the equivalent of 1.3bn plastic bottles a year.

In your deputation you suggested that the Mayor of London is opposed to the Project.

Our Project is included in the Mayor of London’s Environmental Strategy and was consented by the Rt 
Honourable Greg Clark MP who was the Secretary of State in 2017 following a rigorous Development 
Consent Order process.

The Mayor of London’s Environment Strategy states, on page 284, that:
“Modelling suggests that if London achieves the reduction and recycling targets set out in this 
strategy, it will have sufficient EfW [energy from waste] capacity to manage London’s 
non-recyclable municipal waste, once the new Edmonton and Beddington Lane facilities are 
operational”.

You may also be aware that, in 2020, a number of prominent MPs in the All-Party Parliamentary 
Sustainable Resources Group signed a report ‘No Time To Waste’, concluding that ERFs with heat
offtake, like the NLHPP, are the most advanced and sustainable solution for managing 
non-recyclable waste as the UK transitions to a Net Zero economy.

The Committee for Climate Change (CCC) which advises UK Government on policy making is clear in its 
Sixth Carbon Budget that facilities like our ERF should be the principal disposal route as the UK 
transitions to Net Zero. In addition, the CCC highlights the importance of low-carbon district heat 
networks in achieving Net Zero. The NLHPP will deliver one of the largest district heat networks in 
London, providing low carbon heating and hot water to 10,000 local homes.

In your deputation you claimed that residents are unaware of the project and that inadequate 
consultation was carried out.

Thank you for speaking about public consultation in your deputation. NLWA is committed to public 
consultation, and this was a crucial part of developing our plans for the NLHPP. An extensive two- 
stage consultation process was held across all seven north London boroughs, as part of developing 
the rigorous application for a Development Consent Order (DCO). The Secretary of State would not 
have given consent for the Project to go ahead, had NLWA not passed stringent measures to evidence 
that the local community had been involved in the process.

Local residents, community groups and other stakeholders across all seven north London boroughs 
were invited to give their feedback on the project. This included 15 events, several meetings with 
community and statutory stakeholders, a series of newsletters to 28,000 properties, adverts in the 
north London press, leaflets in every council building and 80 libraries across north London, as 
well as a dedicated website, email and phone line.

The feedback we received during the consultation materially shaped and informed our final 
proposals. This includes the design of EcoPark House, the size of the viewing platform, and the 
decision to bring forward one chimney stack instead of two.

The DCO was submitted to the Planning Inspectorate in October 2015 and following a public enquiry 
the Project was given consent by the Secretary of State for Business Energy and Industrial 
Strategy, The Rt Hon Greg Clark, in February 2017. The full consultation report and appendices are 
available on the NLHPP website here.

We continue to engage with our stakeholders through a number of channels to update them and 
increase awareness. We issue newsletters to up to 28,000 homes and businesses with community 
updates and provide construction update newsletters to 19,000 homes and business regularly. Prior 
to the COVID-19 pandemic we held roadshow events in local community hubs to share information about 
the Project and answer any questions that local people had.  We also have a dedicated website with 
the latest news and information about the project including a section for Frequently Ask Questions.

In your deputation you raised concerns over ‘spiralling’ costs from £600m to £1.2bn.
I would like to reassure you that the Project costs have not ‘spiralled’.
NLWA has always been clear that details of the final cost would be determined between 2017 and 
2020, after the public consultation for the Development Consent Order has finished and the final 
designs were decided.

A root and branch cost review was carried out for the Project in 2019, in line with best practice 
on major infrastructure projects.

Leading experts in engineering, architecture and waste modelling established a robust and 
comprehensive cost estimate of £1.2bn in 2019 prices, which provides a solid basis on which 
boroughs and NLWA can finance this vital project for the residents of north London. The Authority 
used an indicative cost for the project through the consenting process of £650m, however the 2019 
comprehensive cost estimate now includes the Energy Recovery Facility, as well as the Resource 
Recovery Facility, EcoPark House, utility diversions, risk contingencies, project management and 
technical support.

We are committed to delivering the Project at the lowest cost for our residents. Last year the 
Project earned favourable borrowing rates from the Government, as a result of a competitive bid to 
borrow £100m at reduced interest rates. This achievement was based on a rigorous value for money exercise, following HM Treasury guidelines, which validated the project’s extensive environmental and financial benefits for north London’s residents. This assessment demonstrated that the project will achieve major greenhouse gas savings compared to sending north London’s waste to landfill or 
third- party energy from waste facilities.

In your deputation you stated that there is no evidence that the current facility needs replacing.

The case for replacing the NLHPP is set out at length in the Development Consent Order (DCO) 
documentation which was approved by the Secretary of State in 2017.

The existing facility is the oldest of its type in London and has served north London for nearly 50 
years. Whilst it has diverted more than 21 million tonnes of waste during this time, it is reaching 
the end of its operational life. Therefore, the NLHPP will safeguard a sustainable future for 
north London.

Our facility is fully aligned with tackling the Climate Emergency declared by the seven north 
London boroughs. The new facility will generate combined heat and power, enabling one of the 
largest district heat networks in London, providing low carbon heating and hot water to 10,000 
local homes. The Committee for Climate Change (CCC) has confirmed in its Sixth Carbon Budget the 
importance of low-carbon district heat networks in achieving Net Zero.

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