Deputation request from Monica Caruso, EnCaf Youth requesting a pause and review for the expansion of the Edmonton energy-from-waste facility

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

Ms Olivia Eken
Via email

Dear Ms Eken,

Thank you for taking the time to raise your deputation to the North London Waste Authority (NLWA)
meeting on Thursday 24 June 2021.

I would like to thank you for submitting your video and setting out the issues you wanted to draw to
Members’ attention.

As promised in the meeting, we are responding in writing to each deputation. I would like to 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. I can also reassure you that Authority
Members take seriously their responsibilities in protecting public services, public health, and the
environment.

Before I address the points raised in your video, I would like to commend you and other members of
Enfield Climate Action Forum for your interest and enthusiasm in environmental and climate issues.
As a public authority, we are committed to tackling the Climate Emergency declared by the seven
north London boroughs and welcome your involvement in discussing these important issues with us.

In your deputation you raised concerns about the expansion of the current facility

It is important to note that we are not ‘expanding’ the existing 1970’s plant. We are investing in a
world-class replacement facility which will operate at the highest standards of environmental
performance to serve our 2 million residents.

We are building a range of facilities at the EcoPark which represents the largest public sector
investment in London’s recycling and waste management infrastructure for decades.

This includes the largest publicly owned Resource Recovery Facility in London, which will boost
recycling across our boroughs. The facility is currently under construction to recycle around 135,000
tonnes of waste that would otherwise be sent to landfill, recovering thousands of tonnes of metal,
plastic, and wood.

Also under construction is a brand new household Reuse and Recycling Centre. This will be the
newest in our extensive network across north London, which are helping to reduce waste and improve
recycling rates. It will be the first facility of its type at the EcoPark.

We are also building a world-class Energy Recovery Facility. It will benefit from the cleanest and
safest emissions control technology of any UK facility. And, by supporting a local heat network, it will
be significantly more carbon efficient than older facilities which only produce electricity. Ours will
provide direct benefit to thousands of local residents in the form of low-carbon heating and hot water.
Compared to landfill, our facility will save up to 215,000 tonnes of CO2e every year.

In your deputation you claimed that energy from waste is not compatible with a sustainable future or a
circular economy

NLWA shares your commitment to tackling the Climate Emergency. The NLHPP is a crucial part of
NLWA’s overall strategy which seeks to minimise waste, increase recycling and recover energy from
waste instead of sending it to landfill.

As well as building a new world-class Energy Recovery Facility, first and foremost as a public authority,
we have a duty to teach and encourage residents about the waste hierarchy and drive the principles
of the circular economy – to reduce waste, increase recycling and prevent landfill. NLWA has the most
extensive waste prevention activity of any waste authority in London and our management strategy
champions the circular economy and sets a benchmark for other waste authorities.

Our award-winning waste prevention programme 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:
• 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
• Our online Waste Prevention Exchange conference, which in 2020 secured the most ever
attendees (215 people)
• 21 Facebook and Instagram Live events through the year, as well as 16 Q&A sessions,
focusing on recycling and waste prevention
• An innovative reusable nappy subsidy of £54.15 per baby – which has resulted in an
estimated 1,000 tonnes of nappy waste being avoided

NLWA’s 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. 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 would welcome your support in spreading the word about these innovative and high impact
initiatives.

None of this removes the need for a responsible plan to manage the non-recyclable waste produced
by two million people. NLWA is building a new Energy Recovery Facility to make sure this waste is
managed in the most environmentally responsible way, to protect the environment and minimise
carbon emissions from our residents’ waste. This is being achieved by using waste a resource to
provide heating and hot water for local homes. The facility is one of a range of assets being built at
the Edmonton EcoPark, which also includes a new public reuse and recycling centre and Resource
Recovery Facility to extract recyclable materials from bulky waste. These facilities are assets for the
environment and north London’s residents, which will all contribute to tackling the Climate
Emergency.

In your deputation you raised concerns about particulates and air quality

NLWA’s key priority is to protect the health of our residents. For this reason, we are building our new
facility with the most modern specifications, using the world’s best technology to capture and carefully
filter emissions, including particulates.

There is a clear scientific consensus including from Public Health England that modern facilities like
ours make an exceedingly small impact on pollution, and do not present a significant risk to public
health.

PHE is clear that modern, well run and regulated municipal waste incinerators are not a significant risk
to public health. In 2019, PHE reviewed their statement on the basis of a major study by Imperial
College London and their guidance, based on a clear scientific consensus, remains unchanged.

When air quality and potential health impacts are discussed, it is usually in reference to the presence of
Nitrogen Oxides (NOx) and particulates released into the atmosphere. In relation to particulates, our
ERF will use best-in-class, proven technology for controlling particulates. Thousands of baghouse
filters will be employed to capture particulates, including PM10, PM2.5 and fine particles. This proven
technology has been identified by the UK’s Air Quality Expert Group as being particularly effective for
controlling particulates and ultrafine particles (UFPs). An independent study from the University of
Birmingham in 2016 concluded that, after dispersion and dilution, concentrations of UFPs are typically
indistinguishable from levels that would occur in the absence of an EfW.

In relation to NOx emissions, the ERF will be fitted with a higher level of emission controls than most
other energy from waste plants in the UK. It will be the first in the UK to operate using Selective
Catalytic Reduction (SCR) to reduce NOx emissions to well below the stringent requirements of the
emission limits set by the European Union in the Industrial Emissions Directive (IED).

The heavily filtered emissions will be released at height from the stack, which ensures that the
pollutants will disperse and dilute in the atmosphere, and therefore be present in exceedingly small
quantities at ground level. For the vast majority of the year, the contribution of the ERF to NOx at
ground level will be effectively zero. It would only be measurable for a few hours a year, and this will
only be at 2% of the relevant air quality standard. 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.

In your deputation you suggested that combined heat and power is not viable

The NLHPP will utilise combined heat and power as recommended by All Party Parliamentary
Sustainable Resource Group as being the best route for achieving Net Zero. More information is
available online here.

As part of a long-term heat supply agreement, the NLHPP is enabling one of the biggest district
heating networks in London, providing low carbon heating and hot water to 10,000 local homes, with
the capacity to supply up to 30,000 more homes across the borough and beyond.

In your deputation you claimed that the NLHPP will create inequalities on BAME communities

As a public authority we are committed to protecting the health and quality of life for all of our
communities in north London. This is reflected in the care with which NLHPP was planned and is
being delivered.

The NLHPP will enhance the quality of life for north London residents, providing a safe and hygienic
waste management service and keeping north London’s waste off the streets. The COVID-19
pandemic has reinforced the vital importance of this essential service, which our facility will safeguard
for another generation.

Enfield Council has a vision for Edmonton as a home for high quality industrial activity, providing
skilled jobs and attracting modern business, which our new facility contributes significantly towards.

During construction we’re creating apprenticeships and training opportunities for young people in
Enfield, Waltham Forest, and Haringey when other opportunities have been reducing. We’re
delivering at least 100 life-changing apprenticeships across the build phase. We’ve already appointed
16 apprentices, 9 from Enfield, in roles ranging from construction to engineering and business
administration. 37.5% of our apprentices are from BAME backgrounds.

We’re also providing a training programme, helping local people without work to get back into
employment. So far, we’ve trained 52 people through our project, of whom 44% have said that they
are from BAME backgrounds, equipping them with vital skills to get a head start in the construction
sector. We’re proud to be offering at least 225 placements throughout construction.

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