Deputation request from Felicity Premru, North London Trades Union and LESE TUC Environmental Sustainability and Just Transition Network calling for a pause and review of the North London Heat and Power Project

14 July 2021

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

enquiries@nlwa.com

nlwa.gov.uk

Ms Felicity Premru Via email

 

Dear Ms Premru,

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 pause and review the NLHPP on environmental grounds in the 

context of COP26.

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 undermine therefore our efforts to tackle 

the Climate Emergency, which is 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 benef its. For these reasons we cannot pause the Project.

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 life changing 

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.

In your deputation you raised your concerns around air quality, with specific reference to 

particulate pollution.

As a public authority, our key priority is to protect the health of our residents . For this 

reason, 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 the safest 

and cleanest in the country.

There is 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.

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, the 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.

In your deputation you asked how NLWA is engaging with trade unions to create green jobs.

The Project is actively engaging with trade unions to ensure our on-site teams are working in the 

safest environment possible and are treated fairly and equally. We are proud to be registered with 

the National Agreement for the Engineering Construction Industry, which establishes a partnership 

with trade unions to promote positive working practices and cultures. These mean that everyone 

working on the Energy Recovery Facility contract are paid at or above the London Living Wage.

Our Project is a major part of the green recovery in Enfield, and part of Enfield Council’s plan to 

promote high-tech industries and jobs in Edmonton.

We’ve committed to 25% local employment through the unlocking of jobs and apprenticeships for north 

London residents to attract new talent into the construction industry, as well as 10% local 

expenditure across our green infrastructure project.

So far, our job-generating project has created 16 apprenticeships in roles covering quantity 

surveying, ground and civil engineering and business management. Over the course of the Project 

we’ll be creating at least 100 of these opportunities for local young people where they will learn 

first-hand the innovative construction methods that can be used on a project of this size and 

complexity.

A number of our apprentices working to build the new Resource Recovery Facility (RRF) have already 

been involved in a pioneering piling technique which has reduced the embodied carbon of the 

original scheme by between 10-16%. Other apprentices working on the sewer diversion works have been 

involved in a unique approach, resulting in cutting the water required by 65%.

In your deputation you requested that NLWA prioritises reuse, repair and recycling of materials. 

NLWA and north London boroughs share your enthusiasm for reuse, repair and recycling.

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. 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 sets a benchmark in London for waste prevention and 

recycling. We run a number of wide-ranging activities with north London residents including:

•     One of the most extensive recycling collection services in the country, accepting the widest 

possible range of materials

•     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

•     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

•     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, f ocusing 

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

•     A network of RRCs across north London, which recycled 72% of materials. Construction 

commenced on a brand-new centre at the Edmonton EcoPark

In addition to our programme of activities, NLWA has extensive infrastructure across north London 

to support higher recycling rates. This includes Materials Recycling Facilities run by our 

contractors, which sort dry collected recyclables into separate waste streams so they can be made 

into new products. 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 have a 

network of public reuse and recycling centres, including the Barrowell Green Recycling Centre in 

Enfield. The NLHPP will enhance this network of existing infrastructure. We are building a 

brand-new public reuse and recycling centre for the benefit of our residents, enabling them to 

bring their recycling directly to the EcoPark for the first time ever, as part of our drive to 

achieve 50% household recycling rates. We’re also building a new Resource Recovery Facility with 

capacity to manage up to 135,000 tonnes of recyclable materials every year including plastic, wood 

and metal. As part of the NLHPP, a new visitor and education centre is being built known as EcoPark 

House where the local community will be able to learn more about waste management and recycling.

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.

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