Deputation request from Helen Mayer, Haringey Labour Climate Action to call for a pause and review of the new incinerator

4 July 2021

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

enquiries@nlwa.com

nlwa.gov.uk

Ms Helen Mayer Via email

Dear Ms Mayer,

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 pauses and reviews the NLHPP

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 massively undermine our efforts to tackle 

the Climate Emergency and reach Net Zero, both of which are 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 benefits. For these reasons we cannot pause the Project.

In your deputation you claimed that there is growing evidence that energy from waste is no longer 

environmentally sustainable. This couldn’t be further from the truth. In fact, NLHPP aligns with 

international, national, regional and local policies on waste management and climate change. The 

Committee on Climate Change (CCC) recently confirmed in its Sixth Carbon Budget that facilities 

like our ERF should be the principal disposal route as the UK transitions to Net Zero. In addition, 

the CCC highlights the importance of low-carbon district heat networks in achieving Net Zero.

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 lifechanging 

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.

You also suggested that the NLHPP is not financially viable. In fact, the NLHPP is the most cost-

effective solution for treating north London’s waste in the future.

Not building the NLHPP would result in the waste going to landfill, which has been costed at an 

additional £15 million to £26 million per annum from 2027. This would be an unacceptable cost 

increase for our residents and undermine our efforts to tackle the Climate Emergency.

In your deputation you suggested that a number of MPs and experts oppose incineration and that 

there have been advances in technology and policy

NLWA would like to reassure you that the NLHPP aligns with sustainable waste policies and 

represents the most advanced technology for managing residual waste.

The NLHPP fully aligns with the waste hierarchy, which is set by the  European Union’s 2008 Waste 

Framework Directive and enshrined in UK law. The waste hierarchy is clear that – after waste 

prevention, reuse and recycling – energy recovery is the preferred solution for managing non- 

recyclable waste. Landfill is established unequivocally as the most damaging option for the 

environment.

In 2020, a number of prominent parliamentarians in the All-Party Parliamentary Sustainable 

Resources Group, signed a report ‘No Time To Waste’, concluding that ERFs with heat offtake are 

the most advanced and sustainable solution for managing non-recyclable waste as the UK transitions 

to a Net Zero economy.

The report states: “By sending the [residual] waste to EfW [energy from waste facilities], it is 

pushed up the waste hierarchy, diverted away from environmentally damaging landfill, and can 

support the UK’s heat and power needs. At the same time, it helps to maintain a clean and hygienic 

waste service; something the public has come to expect; the need for which has been reinforced 

during the COVID crisis”. The NLHPP is an exemplar of this approach.

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 one the safest and cleanest in the country.

In your deputation you stated that the Mayor’s office has forecast surplus capacity in north 

London, and claimed the NLHPP will treat waste outside north London.

The Mayor of London’s Environment Strategy is very clear that the NLHPP is required to provide 

residual waste capacity in the future, along with three other energy from waste facilities in 

London. To clarify, the Mayor’s Environment Strategy states, on page 284, that:

“Modelling suggests that if London achieves the reduction and recycling targets set out in this 

strategy, it will have sufficient EfW [energy from waste] capacity to manage London’s 

non-recyclable municipal waste, once the new Edmonton and Beddington Lane facilities are 

operational”.

The new Energy Recovery Facility has not been designed to accept waste from other areas. It has 

been responsibly designed to accommodate a range of residual waste arisings in north London. NLWA 

is clear that this is an appropriate way to plan essential services for two million people.

In your deputation you claimed that incineration hinders recycling rates

NLWA is committed to boosting recycling in north London and the NLHPP will compete with landfill, 

not recycling. Across the EU and the UK, some of the highest recycling regions use EfW plants to 

manage residual waste. The eight local authorities which have achieved recycling rates at 60 per 

cent or higher in the UK are located in Surrey, Oxfordshire, Hertfordshire, Essex, Gloucestershire and 

Yorkshire, where they use energy recovery facilities to treat their residual waste.

The independent think tank Policy Connect has categorically rejected the claim that EfW hinders 

recycling, stating that there is simply no evidence to back it up.

The NLHPP will help boost recycling rates by providing a brand-new Resource Recovery Facility with 

capacity to manage up to 135,000 tonnes of recyclable materials every year and a public Reuse and 

Recycling Centre, enabling north Londoners to bring their recycling direct to the EcoPark for the 

first time ever. They will be part of an extensive network of centres across north London which are 

available to residents to recycle more of their waste.

In your deputation you claimed that Energy from Waste can’t be low carbon

NLWA is committed to tackling the Climate Emergency and the NLHPP is an important asset in 

achieving greenhouse gas reductions. 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 carefully 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 Policy Connect report referenced above.

In your deputation you raised concerns about emissions from the Energy Recovery Facility being 

unsafe.

A common misunderstanding about energy from waste facilities is that they are a major source of 

pollution and therefore have a significant impact on public health. The scientific evidence clearly 

contradicts this point. Studies from world leading health experts, including Imperial College 

London, have concluded that modern facilities have an exceedingly small impact on pollution and 

present an extremely low risk to public health. This position is supported by Public Health England 

– the Government’s independent health advisors.

NLWA’s top priority is to protect our residents’ health. NLWA is investing in the world’s best 

technology to control emissions from our new Energy Recovery Facility (ERF) – including 

particulates and nitrogen oxides. The Authority is using a higher class of technology than any 

other UK facility and, as a result, the new ERF will be the safest and cleanest in the UK. 

Emissions will be well within the stringent safety limits set by the Environment Agency and NLWA is 

proud to be serving its communities in this way.

The emissions control technology will be so effective that, for the vast majority of the year, the 

ERF is expected to have effectively no impact on local concentrations of pollution. Other sources 

will vastly outweigh the clean and modern facility – including road transport and wood fires in 

people’s homes. As you said, Edmonton in particular suffers from the impacts of the North Circular, 

with road transport being the biggest single biggest cause of local pollution.

In your deputation you stated that other facilities can extract plastics at a lower cost to 

incineration

Thank you for raising the issue of alternatives in your deputation. This is something the 

Authority has considered carefully over many years and it welcomes the opportunity to provide more 

information in this response.

The Authority is familiar with suggestions that certain technologies can extract significant 

volumes of recycling from residual waste. The technology which is most often cited is Mechanical 

Biological Treatment (MBT). Advocates of this approach may be unaware that the process still requires an 

energy from waste plant. The requirement to build two facilities is unlikely to lead to lower 

costs for boroughs and taxpayers, or better environmental outcomes.

Moreover, MBT plants have not been deployed at the scale required in north London. None have 

operated at design capacity in the UK. When used even on a much smaller scale, recycling outcomes 

have been low and the majority of waste has needed to be burnt.

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

LondonEnergy Ltd is the company owned by NLWA who are responsible for managing waste on the 

Authority’s behalf . They are shortly to begin operating a “picking line” within an existing facility which 

will allow volumes of residual waste to be sorted to extract recycling where possible. This could 

allow some thousands of tonnes of waste to be recycled which would otherwise be sent to the energy 

from waste f acility. This is a very positive development and is a further evidence of constructive 

action to reduce residual waste, but it does not change the need for a facilities provided for in 

the North London Heat and Power Project.

In addition, the new Resource Recovery Facility at Edmonton EcoPark will have capacity to manage 

135,000 tonnes of recyclable material every year, including metals, plastic and wood. This will 

help boost recycling rates in north London, but again it does not replace the need for the new 

Energy Recovery Facility.

The Authority runs an award-winning waste prevention programme which 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 including:

•     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

•     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.

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. Biffa’s new County Durham plant uses the world’s most advanced technology to 

recycle the equivalent of 1.3bn plastic bottles a year.

In your deputation you stated that an incineration tax could come into effect in the future

An incineration tax has not been introduced by the UK Government for energy recovery and it is not 

proposed in the Environment Bill. In contrast, landfill continues to be subject to an escalating 

tax every year, due to it being the least sustainable method of waste management.

NLWA serves over two million residents. Even with action to reduce residual waste there will be a 

substantial volume of such waste to manage in the future. An incineration tax would only have the 

effect of increasing costs to boroughs and council taxpayers, without providing a more 

environmentally responsible solution for residual waste management.

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