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HARINGEY LABOUR CLIMATE ACTION
DEPUTATION PRESENTATION TO NLWA AGM, 24 JUNE 2021
We are here with other deputations to call for a pause and review of the new incinerator.
We welcome the Ecopark proposals. And we accept that we currently need to incinerate SOME residual waste.
But things have moved on significantly since this scheme and DCO application were formulated in 2015 - there’s now growing evidence that in its current form it’s no longer environmentally or financially sustainable. It has to adapt.
Pause and review isn’t a climb-down, it’s an opportunity. An opportunity to update the proposals in line with major advances in technology and policies since 2015 and, importantly, to build in flexibility, as these continue to rapidly evolve, to future proof it. Yes, there will be short term costs. But these could avoid the cost of a potential stranded asset in the long term.
And realistic, better, options, do exist.
I’ll briefly outline some changing circumstances that necessitate review. Other deputations will cover these in more detail. I’ll then note some interventions by prominent experts and politicians.
Over-capacity: We now have the contradiction of more incinerators on board (in Herts and Essex) alongside projected reductions in residual waste through new technologies and regulations. The mayor’s office predicts a surplus capacity of 950,000 tonnes for London.
Recycling: The Waste Authority offers admirable support for reducing residual waste. Unfortunately there is widespread evidence that the incentive to feed incinerators detracts from this. Edmonton already incinerates recyclables contained in ‘black bag’ waste, including high carbon plastics. New tried and tested material recovery facilities could extract this.
Flexibility and future proofing: The number of treatment streams in the proposed plant has reduced from 5 to 2, preventing the flexibility it needs to reduce incineration just as emerging regulations and technologies reduce residual waste. The Authority proposes importing waste if local supplies reduce, instead of lower carbon alternatives.
Carbon: Since 2015 we’ve seen major advances in renewable energy and in the energy efficiency of buildings, and a lower carbon grid. And the Climate Change Committee has recommended Carbon Capture for all incinerators, while incineration could well be included in the next Carbon Trading round to meet the government’s new obligations. So EfW can no longer be claimed to be a low carbon or cost-effective option.
Air quality; There is currently no evidence that incinerator emissions are safe for the surrounding socially and environmentally deprived Edmonton community.
Local economy; The circular economy offers more long-term sustainable investment in local training and jobs than incineration.
Cost: Pause and review would enable future-proofing measures, including more waste streams, advanced material recovery facilities, carbon capture and renewable energy alternatives for the Decentralised Energy Network. Long term savings would outweigh the short-term costs.
And most importantly, the Climate and Ecological Emergencies. We simply can’t afford any compromises on waste reduction or carbon emissions – even our most ambitious efforts may not be good enough.
Our case is backed by many prominent experts and politicians. Labour MP’s who have expressed concern include Daniel Zeichner, Stephen Doughty, Darren Jones, Alex Sobell, Sharon Hodgson, Kate Osamor (Edmonton), who in 2020 called for “an immediate pause and review”, and Alan Whitehead, Shadow Minister for Energy and the Green New Deal, who recently said “the age of incinerators is over”
Sadiq Khan has said “I have been clear London is facing a climate emergency and will continue to oppose new incineration in London”
Defra, has warned that further investment in incineration could hinder developments in recycling, Research from WRAP in Wales has shown that 75% of their residual waste could have been recycled.
Wales has set limits on household waste incineration up to 2025, with none sent to landfill or incinerators by 2050
Recent parliamentary debates have called for a halt to EfW investment and for an incineration tax. This February the government said it would consider this in the long term if Environment Bill targets were not met.
So let’s not go against the flow. Let’s pause and review. Let’s redesign the proposals to accommodate new developments, for the benefit of our boroughs and our planet.
Response
4 July 2021
1b Berol House, 25 Ashley Road Tottenham Hale N17 9LJ
enquiries@nlwa.com
nlwa.gov.uk
Ms Helen Mayer Via email
Dear Ms Mayer,
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 asked that NLWA pauses and reviews 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 for
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. This couldn’t be further from the truth. In fact, 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 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.
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. In fact, the NLHPP is the most cost-
effective solution for treating north London’s waste in the future.
Not building the NLHPP would result in the 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.
In your deputation you suggested that a number of MPs and experts oppose incineration and that
there have been advances in technology and policy
NLWA would like to reassure you that the NLHPP aligns with sustainable waste policies and
represents the most advanced technology for managing residual waste.
The NLHPP fully aligns with the waste hierarchy, which is set by the European Union’s 2008 Waste
Framework Directive and enshrined in UK law. The waste hierarchy is clear that – after waste
prevention, reuse and recycling – energy recovery is the preferred solution for managing non-
recyclable waste. Landfill is established unequivocally as the most damaging option for the
environment.
In 2020, a number of prominent parliamentarians in the All-Party Parliamentary Sustainable
Resources Group, signed a report ‘No Time To Waste’, concluding that ERFs with heat offtake are
the most advanced and sustainable solution for managing non-recyclable waste as the UK transitions
to a Net Zero economy.
The report states: “By sending the [residual] waste to EfW [energy from waste facilities], it is
pushed up the waste hierarchy, diverted away from environmentally damaging landfill, and can
support the UK’s heat and power needs. At the same time, it helps to maintain a clean and hygienic
waste service; something the public has come to expect; the need for which has been reinforced
during the COVID crisis”. The NLHPP is an exemplar of this approach.
Our facility will be the first of its kind in the UK to be fitted with the most modern
specifications, using the world’s best technology to capture and carefully filters emissions,
making it one the safest and cleanest in the country.
In your deputation you stated that the Mayor’s office has forecast surplus capacity in north
London, and claimed the NLHPP will treat waste outside north London.
The Mayor of London’s Environment Strategy is very clear that the NLHPP is required to provide
residual waste capacity in the future, along with three other energy from waste facilities in
London. To clarify, the Mayor’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”.
The new Energy Recovery Facility has not been designed to accept waste from other areas. It has
been responsibly designed to accommodate a range of residual waste arisings in north London. NLWA
is clear that this is an appropriate way to plan essential services for two million people.
In your deputation you claimed that incineration hinders recycling rates
NLWA is committed to boosting recycling in north London and the NLHPP will compete with landfill,
not recycling. Across the EU and the UK, some of the highest recycling regions use EfW plants to
manage residual waste. The eight local authorities which have achieved recycling rates at 60 per
cent or higher in the UK are located in Surrey, Oxfordshire, Hertfordshire, Essex, Gloucestershire and
Yorkshire, where they use energy recovery facilities to treat their residual waste.
The independent think tank Policy Connect has categorically rejected the claim that EfW hinders
recycling, stating that there is simply no evidence to back it up.
The NLHPP will help boost recycling rates by providing a brand-new Resource Recovery Facility with
capacity to manage up to 135,000 tonnes of recyclable materials every year and a public Reuse and
Recycling Centre, enabling north Londoners to bring their recycling direct to the EcoPark for the
first time ever. They will be part of an extensive network of centres across north London which are
available to residents to recycle more of their waste.
In your deputation you claimed that Energy from Waste can’t be low carbon
NLWA is committed to tackling the Climate Emergency and the NLHPP is an important asset in
achieving greenhouse gas reductions. 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 also exemplifies the
sustainable waste management approach advocated by Policy Connect report referenced above.
In your deputation you raised concerns about emissions from the Energy Recovery Facility being
unsafe.
A common misunderstanding about energy from waste facilities is that they are a major source of
pollution and therefore have a significant impact on public health. The scientific evidence clearly
contradicts this point. Studies from world leading health experts, including Imperial College
London, have concluded that modern facilities have an exceedingly small impact on pollution and
present an extremely low risk to public health. This position is supported by Public Health England
– the Government’s independent health advisors.
NLWA’s top priority is to protect our residents’ health. NLWA is investing in the world’s best
technology to control emissions from our new Energy Recovery Facility (ERF) – including
particulates and nitrogen oxides. The Authority is using a higher class of technology than any
other UK facility and, as a result, the new ERF will be the safest and cleanest in the UK.
Emissions will be well within the stringent safety limits set by the Environment Agency and NLWA is
proud to be serving its communities in this way.
The emissions control technology will be so effective that, for the vast majority of the year, the
ERF is expected to have effectively no impact on local concentrations of pollution. Other sources
will vastly outweigh the clean and modern facility – including road transport and wood fires in
people’s homes. As you said, Edmonton in particular suffers from the impacts of the North Circular,
with road transport being the biggest single biggest cause of local pollution.
In your deputation you stated that other facilities can extract plastics at a lower cost to
incineration
Thank you for raising the issue of alternatives in your deputation. This is something the
Authority has considered carefully over many years and it welcomes the opportunity to provide more
information in this response.
The Authority is familiar with suggestions that certain technologies can extract significant
volumes of recycling from residual waste. The technology which is most often cited is Mechanical
Biological Treatment (MBT). Advocates of this approach may be unaware that the process still requires an
energy from waste plant. The requirement to build two facilities is unlikely to lead to lower
costs for boroughs and taxpayers, or better environmental outcomes.
Moreover, MBT plants have not been deployed at the scale required in north London. None have
operated at design capacity in the UK. When used even on a much smaller scale, recycling outcomes
have been low and the majority of waste has needed to be burnt.
This is not to say that there is a lack of innovation in managing north London’s waste.
LondonEnergy Ltd is the company owned by NLWA who are responsible for managing waste on the
Authority’s behalf . They are shortly to begin operating a “picking line” within an existing facility which
will allow volumes of residual waste to be sorted to extract recycling where possible. This could
allow some thousands of tonnes of waste to be recycled which would otherwise be sent to the energy
from waste f acility. This is a very positive development and is a further evidence of constructive
action to reduce residual waste, but it does not change the need for a facilities provided for in
the North London Heat and Power Project.
In addition, the new Resource Recovery Facility at Edmonton EcoPark will have capacity to manage
135,000 tonnes of recyclable material every year, including metals, plastic and wood. This will
help boost recycling rates in north London, but again it does not replace the need for the new
Energy Recovery Facility.
The Authority runs an award-winning waste prevention programme which saves 10,000 tonnes of
resources going to waste each year and sets a benchmark in London for waste prevention and
recycling. We run a number of ground-breaking initiatives and activities including:
• One of the most extensive recycling collection services in the country, accepting the widest
possible range of materials
• The largest network of Household Waste Recycling Centres in London enabling residents the
greatest opportunity to recycle their waste, resulting in 72% of materials being recycled
• 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
• Over £93,000 was awarded to boroughs to trial interventions aimed at combatting recycling
contamination or increasing dry recycling
• £60,000 in funding to community groups as part of NLWA’s Waste Prevention Community Fund
• 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.
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 stated that an incineration tax could come into effect in the future
An incineration tax has not been introduced by the UK Government for energy recovery and it is not
proposed in the Environment Bill. In contrast, landfill continues to be subject to an escalating
tax every year, due to it being the least sustainable method of waste management.
NLWA serves over two million residents. Even with action to reduce residual waste there will be a
substantial volume of such waste to manage in the future. An incineration tax would only have the
effect of increasing costs to boroughs and council taxpayers, without providing a more
environmentally responsible solution for residual waste management.
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
