Environmental groups based in north London and more widely are continuing their campaign against the planned new Edmonton Incinerator or "Energy-from-Waste" project. Recent letters sent to Enfield Council and to a Spanish firm bidding for the construction project have challenged the council to provide evidence that it is subjecting the project to adequate scrutiny and have asked the engineering firm to withdraw its bid in order to protect its reputation as a company committed to reducing greenhouse gas emissions and promoting the circular economy.
"Dear Ian Davis"
The Enfield letter, sent on behalf of ten groups based in the borough and more than 60 residents, was sent to the council's chief executive, Ian Davis.
The letter sets out "compelling evidence" that the incinerator project should not go ahead. It requests information about how Enfield Council is sourcing independent information and applying adequate scrutiny to the project and asks whether there are financial incentives in place that stand to benefit Enfield council if this project goes ahead.
The writers begin their list of reasons for opposition by accusing the North London Waste Authority of making false claims about the amount of greenhouse gases that the new plant will produce. They say that at 700,000 tonnes of CO2 a year it will be 25 times greater than the Authority is claiming, and that its projected lifetime extends well past the legally imposed deadline for reaching net zero.
Other arguments set out in the letter concern:
- The availability of several much less carbon-intensive technologies for providing heat and power
- The Committee on Climate Change's finding that proliferation of incinerators in the UK is a "key challenge" in addressing climate change and not part of the climate solution (as claimed by the NLWA)
- Updated estimates of the emissions profile of incineration versus landfill as a waste solution
- Uncertainty about the realistic scope for carbon capture and storage
- Identified incineration overcapacity in London
- Value for money considerations
- Public health considerations
- The failure of the NLWA to meet recycling targets - recycling rates in the area have actually been falling.
Concluding their letter, the writers say they
"... hope you can give us confidence that you are doing everything in your power to guarantee the best outcome for both current and future Enfield residents. We are confident that some independent research will lead you to the same conclusions as us, that there is real merit for a pause and review of the incinerator expansion ."
"Dear José Manuel Entrecanales "
The second letter was sent to the chairman and CEO of the Spanish engineering company Acciona, which is the sole remaining firm bidding for the contract to build the new incinerator. It calls on Acciona to withdraw its bid.
The author is north London environmental campaigner Carina Millstone, writing on behalf of a large number of north London, national and international groups, who, she says, represent "the concerned public, political organisations, trade unions, environmental and social activists, doctors, political representatives, UK- and EU-based civil society organisations, and many others".
The letter refers to the Spanish company's public commitments to reducing greenhouse gases by avoiding the use of virgin material and external fossil-based energy, prioritising resource reduction, and using renewable and recycled materials with a view to ‘giving new life to waste', saying that "these goals are vital to slowing climate and ecological system breakdown'.
According to the letter, the Edmonton project is at odds with these goals.
"The project undercuts ‘sustainable regeneration’, since EfW plants permanently destroy materials, releasing greenhouse gases and toxic emissions into the atmosphere, and perpetuating the extraction and use of virgin materials."
By withdrawing, the writer argues, Acciona would protect its reputation and send a signal that it is serious about its climate change ambitions.
Carina Millstone includes the same list of serious objections to the project as appears in the letter to Enfield Council. She concludes by asking Acciona to reply by 6th September stating whether or not it intends to proceed with the bid for the project
Full text of letter to Ian Davis
Full text of letter to Ian Davis
Dear Ian Davis,
We, the undersigned groups & individuals representing a broad spectrum of Enfield residents, want to express our strong opposition to the expansion of the Edmonton incinerator. We do not believe the decision to proceed has been made with Enfield residents’ best interests as priority. And we feel that the large body of compelling evidence opposing the expansion is routinely ignored both by Enfield Council Leadership and NLWA. The North London Waste Authority (NLWA) provides the same outdated, under-researched, biased perspectives that astonishingly, go as far as claiming incineration is part of the ‘climate solution’.
Below we have provided a summary of the reasons explaining why this project should not go ahead. We ask you to consider these as part of developing a more informed view. We would like to know how Enfield Council is sourcing independent information and applying adequate scrutiny to this project and the NLWA in general? We would also like to better understand whether there are financial incentives in place that stand to benefit Enfield council if this project goes ahead and what these are?
- Climate Emergency
- Carbon emissions - According to the IPCC Carbon Inventories, burning 1 tonne of waste will emit 1 tonne of CO2. This means the new incinerator will emit 700,000 tonnes/CO2 a year. The NLWA apply some disingenuous (and outdated) carbon accounting to claim that it will only have a carbon footprint of 28,000 tonnes/year. THIS IS FALSE. Full calculations are explained here. Please also consider, the lifetime of the new incinerator spans well beyond the UK’s legislated net zero 2050 goal.
- NLWA justifies the project on the basis that it will generate heat and electricity which will displace energy produced by fossil fuels. The UK now draws 42% of its grid electricity from renewable sources such as offshore wind—significantly more than five years ago, when plans were drawn up for the new incinerator. Incinerator energy is 4x more carbon-intensive than grid power and 23x more than solar or wind. Additionally, heat pumps have become a substantially lower-carbon solution than incineration-based domestic heating systems.
- The Committee on Climate Change's (CCC) 6th Carbon Budget (Dec 2020), identified the proliferation of incinerators in the UK as a key challenge in addressing climate change (not part of the climate solution as NLWA lead you to believe). The decarbonisation ambition identified in the budget has been enshrined in legislation (78% reduction in emissions by 2035 compared to 1990 levels). Key policy recommendations to UK government include:
- 'To prevent a major increase (in emissions), either a substantial fraction – potentially a majority – of the EfW plant pipeline will have to remain unbuilt, EfW fleet utilisation rates will have to fall, or else carbon capture and storage (CCS) will need to be installed on plants from the mid/late-2020s onwards to mitigate the additional emissions.'
- Information provided by the NLWA requested under Environmental Information Regulations (EIR) shows that the proposed incinerator does not follow the CCC’s advice, and therefore runs contrary to the new national, legally enshrined emissions reduction target. At this stage, any plan for CCS is hypothetical, unproven, un-costed and deferred to some unknown future point in time which will hamper the legally mandated emissions reduction targets set by the government. Specifically, the EIR shows that the new incinerator will not be ‘CCS ready’, rather, it will be designed so as to ‘not preclude’ future CCS retrofit. The new incinerator is not in an area confirmed to have CO2 infrastructure available. Quite the opposite: the government has not allocated any funding for this in its plans to 2030 (and not provided any information on future funding intentions). In the EIR, NLWA states that “The likelihood that CCUS will be economically viable depends greatly on establishing a shared ‘infrastructure hub’ in Greater London and the south east of England for carbon dioxide transport, intermediate storage and shipment to a long-term storage facility. This is expected to take considerable time’.
- NLWA continually justify this project claiming that they are diverting waste from landfill which has a higher carbon footprint than incineration. Incineration is worse than landfill when it comes to emissions, and will be getting worse over time. This is because from a greenhouse perspective, it is preferable to store plastics rather than burn them (reducing plastics being of course the best approach). Moreover, the primary source of methane in landfill is from organic waste. This is no longer a valid argument given the Environment Bill’s proposed ban on organic waste to both incineration and landfill by 2030.
- Overcapacity
- According to a recent assessment, EfW annual overcapacity will reach 15 million tonnes in England and 1.3 million tonnes in London by 2035. The North London Waste Authority has not updated its waste projections since 2015, despite sustained calls for it to do so and evidence that total waste arising is already 150,000 tonnes below annual projected levels. This is based on a 30% recycling rate which is legislated to be 65% by 2035. Furthermore, the Environment Bill will prevent organic waste from going to landfill and incineration by 2030, the plastic packaging tax of £200 per tonne, which will come into force on 1 April 2022 and extended producer responsibility for packaging waste as of 2023/24 will further reduce the amount of residual waste. In summary, the changed legislative landscape does not warrant a larger incinerator.
- The Mayor has also released his forecast that London faces a surplus of 950,000 tonnes of EfW capacity if recycling targets are met by 2030 even if the Edmonton incinerator is NOT built. There are 3 incinerators with surplus overcapacity within 40 miles of Enfield (Cory 2, Rivenhall and Basildon), there is no need to build this incinerator.
- Value for money
- Uncosted CCS plans alongside both regional and national incineration overcapacity and reduced residual waste arisings pose a serious financial risk that this plant will become a stranded asset.
- There is now only one company (Acciona) bidding for the construction contract. You can read about this here. We have written to the remaining lead contractor- and I attach the letter for your information. Additionally, we have written to the Competition and Markets Authority, as it seems extremely possible that the 3 shortlisted contractors were working together, and the process may therefore not have been competitive. See an FoI request made in the Spring here, which suggests 'nominal' involvement from CNIM who have since pulled out. Furthermore, Acciona have in the past worked in a Consortium with HZI (the third contractor) on EfW contracts which raises question as to whether there was ever a competitive bidding process for this project. This raises serious questions over value for money. What is Enfield Council doing to ensure that council tax payers get value for money?
- Social justice
- EfW plants in the UK are three times more likely to be sited in the most deprived areas, such as Edmonton, whose racially diverse population has experienced a Covid mortality rate that is 40% higher than the national average. A growing body of scientific evidence links long-term exposure to air pollution with a greater risk of serious medical conditions and premature death, including from infectious diseases. Incinerators are a proven source of air pollution.
- The CRPE has already identified that Upper Edmonton has a major deficit in green space with just 0.28 hectares per 1,000 residents when the local standard for public park provision is 2.37 hectares per 1,000 residents this amounts to a deficit the size of 60 football pitches. Imagine what kind of positive green space can be put in place for the benefit of Edmonton residents instead of a new, larger incinerator.
- Public health
- Incinerators emit a wealth of dioxins, NOx and particulate matter which have proven to be damaging to health. NLWA continually quotes a single scientific paper to justify that incinerators are not a risk to public health. Any scientist knows that the full spectrum of scientific research must be evaluated before conclusions can be reached. I would like to draw your attention to a systematic review of 93 scientific papers in 2020 that looked at the health effects of waste incinerators. The paper concluded, “Despite technological advancements...adverse health outcomes in populations near waste incinerators, including cancers and reproductive dysfunction, have been demonstrated in primary studies”. I’m also aware that NLWA defer to the fact that PHE advises that, “modern, well run and regulated municipal waste incinerators are not a significant risk to public health”. It is a common fact that regulations take some time to catch up with the latest science and this is absolutely the case here. What is Enfield doing to ensure that the precautionary principle is being applied?. The reality is there are limited long term studies on the impact of incinerators on public health and there is a severe lack of monitoring of ultrafine particulate matter. Please watch this webinar of scientists presenting their research on the impact of waste incinerators on human health. What is Enfield doing to monitor the long term impact of the incinerator on its residents?
- Barriers to a circular economy
- The NLWA has consistently failed to meet national and city recycling targets by a significant margin although it has a statutory duty to “have regard” to national and city strategies. Recycling and composting rates have been decreasing for more than five years—from 33% in 2013/14 to 30% in 2018/19—despite targets of 45% by 2015 and 50% by 2020. Between 2014/15 and 2018/19, the amounts of waste that were recycled and composted decreased by 6% and 14%, respectively.
Thank-you for taking the time to read this. We also would like to draw your attention to a video of the 13 deputations opposing the project at the recent NLWA AGM (many provided by Enfield residents). We look forward to your response to our questions and we hope you can give us confidence that you are doing everything in your power to guarantee the best outcome for both current and future Enfield residents. We are confident that some independent research will lead you to the same conclusions as us, that there is real merit for a pause and review of the incinerator expansion.
Sincerely,
Individuals:
Mary Anderson (EN1)
Steve Hennessy (EN1)
Eirwen (EN3 )
Aurora Yaacov (N13)
Charles Fletcher (N13)
Parus Shah (EN3)
Jane Fricker (EN1)
Helen Karamallakis (N18 )
Victoria Pite (EN2)
Kleo Karamallakis (N18)
Zoey (N14)
Susan Bonici (N18)
Sophia Davis (N18)
Cathy Donegan (N21)
Skevos Loizou (N18)
Basil Clarke (N13)
Stalla simonin (N18 )
Julia Inch (EN2)
Ian inch (EN2)
Catherine Ejumotan (N18)
Bill Linton (N13)
Isobel Whittaker (EN1)
Anne-Marie Burn (EN1 )
Ann Fahey (N21)
Anissa Jade Connor (EN1 )
Anna Courcha (N18 )
Roció Vigueras Villar (N9 )
Brenda O’Neill (N21)
Kevin Connor (EN1)
Doris Jiagge (N18 )
Genna Waugh (En1)
Madeleine Burn (EN1)
Alexander Arnott McRae (EN1)
Mike Poku (EN3)
Anna Leech (N21)
Gordon Davies (EN2)
David Beadle (N11 )
Bridget Latter (N9 )
Efe Yeboah (EN1)
Ellie Lewis (N21)
Annika Robinson (N14)
John Rowlands (N14)
Jon Hall (N11 )
Rachael Parker (N11 )
Kristina Apostolova (N14 )
Non Worrall (N13)
Nicola Scott (N13 )
Lauren Weller (En1)
Debra Dean (N9)
Robert Pite (EN2)
Gordon Hutchinson (EN2)
Niki Nicolaou (N14 )
Carmel Miriam Smith (EN2 )
Joseph Bailey (EN1)
Olivia Eken (N9 )
Oliver Pocock (N21 )
Anna Revidiego (EN11)
D Aboah (N18 )
Malcolm Stow (EN3)
Georgia Elliott-Smith (EN2)
Kay Eyers (EN2)
Marie Toman (EN1)
Joanna Sarri (N10 )
Sibel Kazim (N21)
Jenny Godfrey (N13)
Tim Behean (N21)
Helena Dornellas (EN1 )
Full text of letter to ACCIONA
Full text of letter to Acciona Download original PDF version
London, 18 August 2021
José Manuel Entrecanales Domecq
Chairman and CEO
ACCIONA
Avenida de Europa
18. Parque Empresarial
La Moraleja 28108
Alcobendas
Madrid, Spain
by post and by email to , , ,
Dear José Manuel Entrecanales,
I am writing to you on behalf of the undersigned groups—which represent the concerned public, political organisations, trade unions, environmental and social activists, doctors, political representatives, UK- and EU-based civil society organisations, and many others—to call on ACCIONA to withdraw its bid to build a new energy-from-waste (EfW) facility in Edmonton, north London, for the North London Waste Authority.
This urgent request reflects our support for ACCIONA’s ‘sustainable regeneration’ ambitions for the climate, biodiversity, and the circular economy. Indeed, we commend you for your promotion of emission reduction targets and your efforts to reduce greenhouse gases by avoiding the use of virgin material and external fossil-based energy, prioritising resource reduction, and using renewable and recycled materials with a view to ‘giving new life to waste’. These goals are vital to slowing climate and ecological system breakdown.
However, ACCIONA’s active bid to build an EfW plant in Edmonton is at odds with these goals. The project undercuts ‘sustainable regeneration’, since EfW plants permanently destroy materials, releasing greenhouse gases and toxic emissions into the atmosphere, and perpetuating the extraction and use of virgin materials.
By pulling out of the bidding process, ACCIONA would not only protect its reputation as a leader in sustainable approaches, but also send an unmistakable signal to the waste and resource sectors of the UK and other countries, namely that the company is serious about its climate and ecological ambitions. The time to do so is now, given that the two other short-listed companies—CNIM and HZI, ACCIONA’s project partner in Western Australia—have already withdrawn their bids.
As you may be aware, the EfW project faces strong, growing opposition in London and beyond. A London-wide Labour Party conference recently passed a motion for a pause and review of the incinerator plans (which has policy implications for six of the seven local councils in north London). The regional Trades Union Congress, which represents the majority of trade unions in the UK, also passed such a motion. In addition, London’s mayor has agreed to meet with campaigners and cross-party politicians next month to discuss potential alternatives to the Edmonton incinerator. The successful bidder thus runs the risk of delays, cancellation, legal action, and reputational damage, as has been reported in the media.
While we trust you are familiar with the context-specific grounds for the opposition to the Edmonton incinerator project, we would be happy to send you information on the various concerns, including:
- social injustice: EfW plants in the UK are three times more likely to be sited in the most deprived areas, such as Edmonton, whose racially diverse population has experienced a Covid mortality rate that is 40% higher than the national average.1 A growing body of scientific evidence links long-term exposure to air pollution with a greater risk of serious medical conditions and premature death, including from infectious diseases.
- EfW overcapacity: According to a recent assessment, EfW overcapacity will reach 15 million tonnes in England and 1.3 million tonnes in London by 2035.2 The North London Waste Authority has not updated its waste projections since 2015, despite sustained calls for it to do so and evidence that total waste arisings are already 150,000 tonnes below projected levels. Resistance to the project increased when the mayor released his forecast that London faces a surplus of 950,000 tonnes of EfW capacity if recycling targets are met by 2030. The UK Department for Environment, Food and Rural Affairs’ new waste assessment, due out in the coming months, is expected to lead to national and local remodelling, as well as contingency planning for dealing with stranded incineration assets.
- incompatibility with the net-zero carbon target: The most recent figures indicate that the UK’s current EfW capacity will double by 2030, which is expected to lead to a tripling of greenhouse gas emissions from incineration, pushing the UK’s 2035 net-zero pathway target out of reach.3 The Edmonton incinerator, if built, would account for a significant proportion of these emissions. As you undoubtedly know, no financing has been secured for the incinerator to be equipped with carbon capture and storage technology, which remains prohibitively expensive and unproven at scale.
- incompatibility with recycling targets and the circular economy: Truly residual waste arisings are expected to fall in line with national measures that promote waste prevention, reuse and repair, and recycling, as part of the UK’s transition to a circular economy. If the construction of a new incinerator in Edmonton goes ahead and residual waste trends continue, north London’s councils will be contractually incentivised to send recyclables to incineration to keep the plant running at capacity, which would undermine the UK’s 65% recycling target for 2035 as well as the transition to a more circular economy. Moreover, the local councils risk forgoing recycling revenue that would be secured through a genuine shift away from EfW incineration (and landfilling).
- forgone green jobs: In the UK, reuse and repair already generate 15 times more jobs than the waste disposal sector, whose expansion is preventing a green job boom. The Edmonton incinerator would provide a fraction of the jobs that could be secured for local residents if the councils pursued a green post-Covid recovery, in line with what ACCIONA might call sustainable regeneration principles.
This list is not exhaustive—it excludes concerns about the use of heat from EfW incineration despite the availability of significantly less carbon-intensive options,4 as well as growing alarm over the health risks associated with toxic emissions, such as ultrafine particles, dioxins, and NOx.5 Nor does the list cover the implications of a potential incineration tax, carbon charge, or ban on the burning of plastics for the viability of a new EfW incinerator. For more details, please feel free to contact us.
We hope you will take the time to rethink ACCIONA’s strategy in north London and immediately withdraw your bid to build a new EfW plant in Edmonton. Your decision will have lasting consequences for the residents of Edmonton in particular, and the UK more broadly. It could also set a weighty precedent for other companies in the field, one that could help to align the sector with global climate imperatives and ‘give new life to waste’.
We request that you acknowledge receipt of this letter by emailing . We would be grateful if you could write to the same email address to let us know, by 6 September, whether you intend to proceed with or pull out of the tender to build the new EfW facility in Edmonton, north London.
In the meantime, we remain at your disposal for a meeting and look forward to hearing from you. Sincerely,
Carina Millstone on behalf of
Black Lives Matter Enfield
Camden Civic Society
Climate Emergency Camden: Camden Air Action, Camden
Cyclists, Camden Fairtrade Network, Camden for the CEE Bill,
Camden Green Party, Canopy Coalition, Divest Camden,
Friends of the Earth Camden, Hopscotch Women’s Centre,
Plastic Free West Hampstead, Power Up North London,
Transition Towns Camden
Enfield Climate Action Forum (EnCaf)
Enfield People Before Profit
Enfield People’s Theatre
Enfield Stand Up to Racism
Extinction Rebellion (XR): XR Barnet, XR Camden, XR Enfield,
XR Hackney, XR Haringey, XR Islington, XR Waltham
Forest, XR London, XR UK
Friends of the Earth
Global Alliance for Incinerator Alternatives (GAIA)
Greenpeace
Haringey Clean Air Group
Haringey Labour Climate Action (HLCA)
Islington Environmental Emergency Alliance
Islington North Environment Forum (no logo)
Palmers Green Community
Plastics Rebellion
Residents of Enfield Angel Communities Together (no logo)
Sky Rebellion
Stop the Edmonton Incinerator Now
Unite Community Enfield Area Branch
United Kingdom Without Incineration Network (UKWIN)
XR Drummers London
XR Unify
XR Zero Waste
Zero Carbon Campaign
Zero Waste Europe
1 https://www.theguardian.com/environment/2020/jul/31/uk-waste-incinerators-three-times-more-likely-to-be-in-deprived-areas.
2 https://www.xrzerowaste.uk/s/2021-07-16-XRZW-EfW-overcapacity-policy-brief.pdf.
3 https://www.xrzerowaste.uk/s/2021-07-16-XRZW-EfW-overcapacity-policy-brief.pdf.
4 https://www.telegraph.co.uk/business/2021/02/04/energy-waste-plants-face-scrutiny-carbon-emissions/.
