Deputation request from Dr Edward Tranah, local resident relating to the proposed re-build of the Edmonton EcoPark

14 July 2021
1b Berol House, 25 Ashley Road Tottenham Hale N17 9LJ
enquiries@nlwa.com
nlwa.gov.uk
Dr Edward Tranah Via email

Dear Dr Tranah,

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 suggested that the replacement Energy Recovery Facility will be responsible 
for around 700,000 tonnes of CO2 every year.

NLWA shares your concern about carbon emissions, and it is for this reason that we are investing in 
a world-class Energy Recovery Facility which will minimise the carbon impact of our residents’ 
waste.

Our residents’ waste contains carbon and we have a statutory duty to manage its disposal. The 
Authority has chosen, after careful consideration of the options, to do so in way that best 
protects the environment and contributes to tackling the Climate Emergency.

In your deputation you suggested that our new facility will be responsible for 700,000 tonnes of 
CO2 every year. However, this is misleading in understanding the carbon impact of north London’s 
waste. Following a Carbon Impact Screening of the Project, it is predicted that the net carbon 
impact of the ERF will be around 28,000 tonnes of CO2e each year. This calculation has been 
developed using the standards set by the Intergovernmental Panel on Climate Change (IPCC) 
(Guidelines for National Greenhouse Gas Inventories – 2006) and DEFRA (Energy Recovery for Residual 
Waste - A carbon- based modelling approach – February 2014).

The net carbon impact of the ERF is so low because it will provide low carbon power for the 
country’s national grid, extract metals for recycling, and generate heating for thousands of local 
homes and businesses.

The NLHPP aligns with the Climate Change Committee’s (CCC) route map for Net Zero. The CCC has 
called for all landfilling of biodegradable waste to end by the mid-2020s. The Mayor of London has 
a similar target. Building the NLHPP will ensure that none of north London’s waste ends up rotting 
in landfill.

Our Energy Recovery Facility (ERF) will be more carbon efficient than the majority of UK 
facilities. This is a result of the Authority’s decision to build a facility capable of generating 
combined heat and power. Crucially, our facility will provide heating and hot water to thousands of 
local homes in Edmonton, as well as electricity. Last year the All Party Parliamentary Sustainable 
Resource Group concluded that, within overall sustainable approaches, the best way of dealing with 
residual waste is through energy from waste plants which maximise heat and power benefits. Our ERF 
is an exemplar of this approach. The report is available online here.

We are proud to be building a facility which is expected to meet and exceed the Mayor of London’s 
Carbon Intensity Floor, which is designed to ensure that energy from waste facilities are more 
carbon efficient than the energy sources they replace – namely gas power stations.
As a result of the Authority’s careful planning and application of the very best technology, our 
ERF will save up to 215,000 tonnes of CO2e every year compared to landfill.

In your deputation you criticised NLWA for burning plastic and recyclable waste at the Edmonton 
EcoPark. You said that residual waste cannot be accurately called ‘non-recyclable’.

NLWA welcomes your enthusiasm for recycling and I would like to be clear that no separately 
collected recycling is sent directly to our energy recovery facility. The material is sent to 
specialist Materials Recovery Facility in Edmonton where it is carefully sorted so it can be 
repurposed into new items.

Some recycling is too contaminated to recycle and needs to be treated via energy recovery. As a 
public waste authority, NLWA does its upmost to combat this issue and encourage residents to 
recycle correctly. Ours is the most extensive programme of activity of any London waste authority, 
and includes high impact campaigns like ‘#BinYourNappy’ which is helping to save whole lorry loads 
of recycling from being discarded.

Residual waste may contain materials which could have been recycled. However, it is not viable or 
safe to rummage through bin bags to pick out materials. In any event, this material is often 
heavily contaminated and unsuitable for recycling. Instead we focus on separate recycling 
collections at the kerbside. This in in line with UK Government policies.

With regard to plastic, we work hard locally and nationally to reduce the amount of waste people 
throw in their residual waste bin. We have launched Low Plastic Zones across north London, 
including in Leytonstone, to help businesses and shops cut down on single use plastics. And we 
accept the widest possible range of materials for recycling – including pots, tubs and trays – 
which are not recyclable in some parts of the country.

We are proud that our initiatives to encourage residents to recycle more is helping to 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 in north London 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.

We 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. We are also investing in 
facilities to extract plastic from other types of waste, such as bulky waste. Our Resource Recovery 
Facility will have capacity to manage 135,000 tonnes of recyclable materials every year collected 
by boroughs – we expect this will include thousands of tonnes of plastics.

This local focus is twinned with our leading action 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 f or 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.

In your deputation you asked NLWA to confirm that the emission of particulates from the ERF will 
not have an impact on public health.

NLWA’s first priority is to protect the health of our residents. That is why we are investing in 
the most effective emission control technology available, to make our facility the safest and 
cleanest in the UK.

There is a common misconception that modern energy from waste facilities make significant 
contributions to pollution and have a major impact on public health. But there is no evidence to 
support this.

On the contrary, there is a clear scientific consensus that modern facilities like ours make an 
exceedingly small impact on pollution, and do not present a significant risk to public health. This 
is the unambiguous position of Public Health England, supported by a significant body of scientific 
evidence. This includes research from Imperial College London which studied our facility, and is 
clear that modern facilities cannot be linked to negative infant birth outcomes and infant 
mortality.

Our ERF will make an extremely small contribution to local concentrations of particulates, and 
volumes of pollutants across London. The emissions control technology fitted to the plant will be 
so eff icient that, for the majority of the year, local concentrations of particulates (and NOx) 
are expected to be effectively zero, and only 2% of air quality limits for a f ew hours a year. This is vastly 
outweighed by other sources including road traffic and domestic wood burning. In Enfield, road 
transport is responsible for around 40% of NOx and 30% of particulates. Across London, road 
transport causes 60% of nitrogen oxides and 25% of particulates. These figures are from the GLA’s 
London Atmospheric Emissions Inventory.

The Authority is aware of claims that the ERF will not be able to filter ultrafine particles. This 
is contradicted by independent, peer-reviewed academic research which demonstrates that, on the 
contrary, the ERF will use technology that is extremely effective in filtering ultrafine particles. 
This technology, known as ‘baghouse filters’, has been identified by the UK’s Air Quality Expert 
Group as being particularly effective.

The new ERF in Edmonton will, like the existing plant, use the world’s most advanced technology to 
control particulates.

The efficient filters are able to remove particles that are much smaller than the pore size of 
the fabric. This means that very small particles, known as ‘ultrafine particles’ are captured 
alongside larger particles (ultrafine particles are less than 100 nanometres. A nanometre is one 
thousand-millionth of a metre). The particles are removed by four highly efficient, separate 
mechanisms: impaction; interception; diffusion and electrostatic collection.

The emissions from the ERF that are released into the atmosphere are done so at height, which 
allows them to dilute and disperse in the atmosphere. This is in contrast to other sources, 
including road transport and domestic wood burning, which emit at ground level where people are 
exposed.

In your deputation you said that the NLHPP is being built without the consent of local people.

The NLHPP was brought forward after full public consultation and an Examination in Public. An 
extensive two-stage consultation was carried out for the Project between 2014 – 2015, in line with 
the stringent requirements set for the Development Consent Order (DCO) application .

This included 15 public events, several meetings with community and statutory stakeholders, a series of 
newsletter 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 project website, email and 
phoneline.

If the consultation activities did not meet the high standard required for DCO application, then it 
would have been rejected and not even progressed to its Public Examination phase in the planning 
process.

NLWA continues its wide-reaching engagement on the Project. This includes regular Community Liaison 
Group meetings, newsletters, Twitter and website updates and community roadshows.

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