Deputation request from Ben Griffith, Islington Environmental Emergency Alliance in support of calls for a pause in the new incinerator project and an independent expert review

14 July 2021

1b Berol House, 25 Ashley Road Tottenham Hale N17 9LJ

enquiries@nlwa.com

nlwa.gov.uk

Mr Ben Griffith Via email

 

Dear Mr Griffith,

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 responsibilities in protecting public services, public health, and the 

environment and have carefully considered these aspects 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 said you are concerned about the expansion of the energy from waste facility 

in Edmonton. You said this will contribute to surplus energy from waste capacity that is developing 

in London and the South East.

I would like to clarify that NLWA is not expanding the existing plant. It is investing in a new, 

world- class Energy Recovery Facility (ERF) which will provide combined heat and power and use the 

best technology of any UK facility to clean emissions. It is a vital asset for tackling the Climate 

Emergency, managing residual waste safely and efficiently, and diverting waste from landfill. The 

ERF is one of a range of facilities being built as part of the NLHPP. This includes a new Resource 

Recovery Facility with capacity to manage up to 135,000 tonnes of recyclable material every year, 

as well as the first ever public reuse and recycling centre at the site.

With regard to energy from waste capacity, the Mayor of London’s Environment Strategy states on 

page 281: “modelling suggests that if London achieves the reduction and recycling targets set out 

in this strategy, it will have sufficient capacity to manage London’s non-recyclable municipal 

waste, once the new Edmonton and Beddington Lane facilities are operational”. The NLHPP is clearly 

an important part of London’s future waste infrastructure. The Mayor’s position aligns with the 

Need Assessment undertaken for the NLHPP as part of the Development Consent Order application.

In your deputation you claimed that waste arisings in north London are lower than forecast in the 

Development Consent Order Need Assessment. You also said that the new incinerator will be too 

large, except in the ‘worst case scenario’ for recycling.

Thank you for your question about waste forecasting. This is a topic that NLWA takes very 

seriously, and I would like to reassure you that real life data aligns with the Need Assessment 

forecasts. The waste forecasts carried out for the NLHPP anticipated residual tonnages between 

582,000 to 663,000 tonnes in 2019/20. Actual arisings were around 581,000 tonnes.

For 2020/21, the waste forecasts suggest a range of 567,000 to 661,000 tonnes for residual waste. 

Actual arisings were 570,394 tonnes.

I would like to clarify that the capacity of the ERF is not based on a ‘worst case scenario’ for 

recycling. NLWA submitted forecasts of demand for the new ERF as part of the Development Consent 

Order (DCO) application. A set of recycling scenarios were applied to overall forecast waste arisings and NLWA submitted that an ERF with capacity to treat 700,000 tonnes of residual waste per annum was 

appropriate for north London’s future requirements, having regard to the Authority’s statutory 

duty. More information is online here via the Need Assessment produced for the DCO.

In the Examining Report for the DCO application, the Planning Inspector stated: “I conclude that 

the design capacity of the proposed ERF is reasonable taking the forecasts into account, and 

particularly the very substantial uncertainties involved in looking over 35 years into the future”.

NLWA has a duty to provide appropriate capacity to manage north London’s residual waste, now and in 

the future. There are significant risks with not providing suitable capacity. Most significantly, 

it could mean disposing of our residents’ residual waste via landfill which would have significant 

environmental and financial consequences.

In your deputation you said that you are concerned about the impact the NLHPP will have on climate 

change.

The NLHPP is an important asset that will help tackle the Climate Emergency. 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 caref ully 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 the All Party Parliament Sustainable

Resource Group in its 2020 report “No Time to Waste”. The report was signed by a range of prominent 

parliamentarians from a range of parties.

In your deputation you said that NLWA should commission an independent review into the alternative 

options for residual waste disposal. You said that this should include a review of facilities that 

can extract plastics from black bag waste, as used in the Netherlands.

NLWA has carefully considered the alternative options and a full review has already been 

undertaken. This Alternatives Assessment Report is available on the NLHPP website. It considered 

and rejected the same alternatives that are frequently put to the Authority: landfill; Mechanical 

Biological Treatment (MBT); and gasification. Landfill has an unacceptable impact on the 

environment; and MBT and gasification are small scale and problematic. They both produce a fuel 

which is burnt. Their environmental advantages compared to the NLHPP are uncompelling.

The Authority carried out a further options review after the DCO application was made. The report, 

North London Heat and Power Project Summary Paper on Options, is available on the Authority’s 

website here. It concluded that the NLHPP represents the best solution for north London for a range 

of factors, which together include cost, technological performance, environmental outcomes and 

socioeconomic benefits.

You reference facilities in the Netherlands as a model for NLWA to follow. You did not specify 

individual facilities. However, in previous correspondence you ref erred to a sorting plant in 

Amsterdam. As the Authority pointed out in our earlier response, this facility has not recycled 40% 

of materials. Nor have equivalent facilities elsewhere in the Netherlands. The Amsterdam plant has 

been beset by series issues. Around 10% of the waste is reported to have been successfully 

recycled; the rest burnt. The Municipality of Amsterdam commissioned an investigative report in 

2020, which was highly critical of the plant and its shortcomings.

Notwithstanding these issues, no existing ‘pre-sorting’ plant in the world comes close to being 

able to handle north London’s volumes of waste. Moreover, the Dutch facilities are funded by a 

“polluter pays” tax levied on manufacturers. No such scheme is in place in the UK. The capital, 

operating and maintenance costs of such a plant in north London would instead need to be borne by 

local authorities. This is estimated at between £50 – £100 per tonne, which would add £30 – £60m 

per year to costs for north London’s taxpayers.

This is not to say that there is a lack of innovation in managing north London’s waste. An 

innovative picking line within an existing facility will allow volumes of residual waste to be 

sorted to extract recycling where possible. This is a very positive development, but it does not 

change the need for the facilities provided by the NLHPP.

In your deputation you said that NLWA should work with residents to increase recycling, including 

investment in new recycling facilities. You referenced suggestions that Extinction Rebellion has 

shared with Islington Council, which you claim will significantly increase recycling rates in north 

London.

Thank you for your ongoing enthusiasm for waste prevention and recycling. They are vital issues 

for tackling the Climate Emergency, and we share your commitment to moving towards a circular 

economy in north London.

As you will be aware, NLWA delivers high-impact, extensive campaigns to encourage correct recycling 

from residents. This is coupled with one of the most comprehensive recycling collection services in 

the country, accepting the maximum possible range of items. 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. Bif fa’s new County 

Durham plant uses the world’s most advanced technology to recycle the equivalent of 1.3bn plastic 

bottles a year.

In addition to our award-winning waste prevention programme of activities, we are leading the way 

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 for 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.

NLWA is now building the most significant new public sector recycling infrastructure London has 

seen f or a generation. As part of this £100m investment, we are building a new Resource Recovery 

Facility, with capacity to manage 135,000 tonnes of materials for recycling every year, as well as 

a public Reuse and Recycling Centre. I have referenced above the pioneering approach we are taking 

in an existing facility in the more immediate term.

With regard to Extinction Rebellion’s suggestions on recycling, you will be aware that LB Islington 

has responded in detail to each of them. In summary, while NLWA and boroughs welcome Extinction

Rebellion’s interest and involvement on a key issue, we have to be clear that many of the proposals 

– as well as other initiatives – are already being delivered in north London. For example, in June 

2021 we announced a new mattress recycling scheme, which is expected to recycle 700 mattresses (17 

tonnes) a week. Ultimately we ask that Extinction Rebellion join us in calling for action from 

Government to introduce urgent reforms – including Extended Producer Responsibility and a Deposit

Return Scheme – to achieve the outcomes that our residents, boroughs and the environment deserve.

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