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