Request
Can you please tell me what is your process for treating and disposing of APCRs air polution control residues?
And how much do you pay per tonne to treat, or stabilise the APCR. Truck fee landfill gate fee and landfill tax and any other fees associated with disposal of APCR .
Response
Good afternoon,
Further to our email acknowledging your request for an internal review (reference 2026-267), our response is as follows.
We can confirm that we hold some of the information you have requested.
You requested: An internal review of the Authority’s decision to withhold specific financial data regarding the treatment and disposal of Air Pollution Control Residues (APCR). Specifically, you requested:
- The total annual tonnage of APCR produced by NLWA energy-from-waste facilities for the last five reporting years.
- The total annual expenditure for APCR treatment and disposal over the same period.
- The contracted operators responsible for APCR treatment and disposal.
- The duration and total value of the current APCR treatment contract.
Our response: The Authority has carried out an internal review in line with regulation and consulted the ICO. A presumption in favour of disclosure has been applied as required by EIR 12(2).
- 1. Total Annual Tonnage of APCR Produced: We can confirm that a total of 13,617 tonnes were exported between January 2025 and December 2025. We cannot disclose detailed or disaggregated APCR tonnage (e.g. breakdowns by process, batch, treatment route, or operational intervals), as this level of granularity could be used to infer cost structures.
- 2. The total annual expenditure for APCR treatment and disposal over the same period.
This information is withheld in accordance with Regulation 12(5)(e) of the Environmental Information Regulations 2004. Disclosure would allow calculation of the unit rate per tonne, reveal supplier pricing, and undermine the Authority’s negotiating position in future procurement exercises. The public interest in maintaining fair competition and protecting public money outweighs the benefits of disclosure in this instance.
Duration and Total Value of the Relevant Contract(s)
3a. Contract Duration
3 years.
3b. Total Contract Value
Response: Withheld under EIR 12(5)(e)
The contract value is withheld as revealing the contract value would allow derivation of unit rates when paired with tonnage, reveal pricing strategy, margins, and commercial constructs of the contracted supplier, and detrimentally impact LondonEnergy’s and NLWA’s commercial interests by weakening future competitive tendering,
The ICO has confirmed that total contract values in narrow, specialist markets (such as hazardous APCR treatment) often qualify for protection under EIR 12(5)(e) where disclosure would materially affect commercial stakeholders and distort future procurement competition.
The public interest in protecting NLWA’s commercial position outweighs the public interest in disclosing sensitive financial detail.
The public interest in transparency has been considered. However, the public interest in maintaining fair competition and protecting the public purse during specialist procurement outweighs the interest in disclosure at this time.
If you are not content with the outcome of the review, you may complain to the Information Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, or via their online portal. The Information Commissioner will not usually accept complaints before a review has been completed.
Website: https://ico.org.uk
Kind Regards,
North London Waste Authority
