Environmental campaigners issue new challenges over incinerator 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 The North London Waste Authority (NLWA) provides the same outdated, under-researched, biased perspectives that astonishingly, go as far as claiming incineration is part of the ‘climate solution’.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 The NLWA apply some disingenuous (and outdated) carbon accounting to claim that it will only have a carbon footprint of 28,000 tonnes/year.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 )