"This summer’s extreme weather events show we are unquestionably facing life-changing climate change. Now is the time for NLWA itself to change."
Stop the Edmonton Incinerator Now, August 2023
The North London Waste Authority's consultation on a new strategy for dealing with waste fails to mention the large new incinerator under construction in Edmonton, which environmental campaigners say is unjustified on both environmental and economic grounds
Environmental campaigners say that a survey of residents being carried out by the North London Waste Authority (NLWA) is "disingenuous box-ticking" that ignores the consequences of building a giant new incinerator in Edmonton.
The survey, part of the preparation for drawing up a new North London Joint Waste Strategy, completely fails to mention the construction by the waste authority of a massive new incinerator in Edmonton, which, according to the Stop the Edmonton Incinerator Now (StEIN) coalition, "for decades to come" will not only contribute to climate change by emiting greenhouse gases equivalent to an additional 250,000 diesel cars on the road, but also "lock residents into a hugely expensive throw-it-away waste system".
An advanced sorting facility "would provide a vital revenue boost for the seven north London councils"
By choosing to build a large and "unnecessary" incinerator when there is already surplus waste incineration capacity in London, NLWA are, they say, pursuing a policy that runs counter to progress towards a low-waste circular economy - one where the maximum quantity of material is reused instead of being destroyed by burning.
An example of a facility for separating out recyclable materials from a mixed waste stream. StEIN are urging the North London Waste Authority to install a facility of this type
Instead of building a huge incinerator that will require large quantities of "feedstock" (ie waste) for several decades, the waste authority could, say the campaigners, install a state-of-the-art recycling facility, which would separate out plastics and other recyclables. The much smaller residual amount of truly non-recyclable material could then be sent to an existing incinerator elsewhere in London.
Dr Rembrandt Koppelaar, an environmental economist who is a member of StEIN, has calculated the economic benefits of pre-sorting:
"An advanced sorting facility would remove an estimated 48% of residual waste just by recovering organics for biogas and digestate for compost. It would extract a further 22% for recycling, which would also provide a vital revenue boost for the seven north London councils."
"Locked into carbon-intensive heat contracts with no redress"
Another aspect of NLWA's strategy which could hamper efforts to cut greenhouse gas emissions (and cause severe road congestion during construction) is their plan to pipe heat from the incinerator through an underground network to provide district heating to homes in Enfield and Haringey boroughs. The need to supply the heat network will create a disincentive to NLWA pursuing its important task of reducing the amount of waste produced by households and encourage it to burn materials that could be reused or recycled.
StEIN member and former Enfield councillor Vicki Pite comments:
"Plans to deliver heat from the incinerator in Edmonton to new housing in Enfield and Haringey will make it difficult for NLWA to turn off the incinerator. The data shows they will need to import waste to maintain the incinerator—and supply residents’ heat. Environmental groups in Enfield are concerned about the massive road disruption planned over several years to lay 23 kilometres of pipework, and Haringey residents are waking up to the same risk. Moreover, residents will be locked into carbon-intensive heat contracts with no redress, although low-carbon alternatives are available."
"Adjusting the waste management approach and forecasts in line with the evidence"
StEIN also accuses the waste authority of using seriously flawed data to justify the incinerator project. They point to multiple errors, including overestimating the amount of black bag waste produced by households, which has been falling rather than rising. As regards greenhouse gas emissions - the crucial factor in the fight against climate change and global heating - they say NLWA are still refusing to correct their greatly understated figures for the amount of carbon that running the plant at full capacity would put into the atmosphere - the method the waste authority uses to calculate this is, they say, discredited.
As regards the new Joint Waste Strategy, StEIN want it to commit NLWA to “doing all it can to reduce waste and to manage the far smaller amount of waste at the highest possible level of the waste hierarchy” while “continuously and publicly updating data on waste collected and recycled, monitoring progress against targets, and adjusting its waste management approach and forecasts in line with the evidence”. Only then can the strategy enable NLWA to pursue the national target of halving residual waste by 2042 (compared to 2019) and London’s target of recycling 65% of it by 2030, while minimising CO2 emissions.
"Not just a box ticking exercise"
PGC invited NLWA to comment on the StEIN press release and survey response. They replied that it would "not be right" to discuss StEIN's survey response at this time, but did send some comments on the press release.
NLWA denied that the survey is just a box-ticking exercise, since it allows residents to raise any issues they want.
NLWA said that they had responded to and dealt with the issues raised in the press release "numerous times over the years" and had recently responded to deputations from StEIN members which cover many of these points (including the alternatives considered, such as pre-sorting facilities). They provided links to two of these responses.
NLWA accused StEIN of including a factually inaccurate statement in the press release by stating that the Mayor of London had concluded that London will have excess incineration capacity even if the new Edmonton plant is not built. They say that, on the contrary, the Mayor's Environment Strategy "makes clear that London’s incineration capacity is dependent on the completion of the Edmonton facility". [Note: I since publishing this item, I have received convincing evidence that NLWA were aware in late 2021 that this was no longer the case and that building the new Edmonton incinerator would create a massive amount of unneeded capacity - see this post in the forums for more detail.]
You can read the full comments sent by NLWA further down the page, as well as a full version of the StEIN press release and their submission to the NLWA survey.
The NLWA survey runs until 15th September and can be accessed at www.nlwa.gov.uk/news/have-your-say-how-reduce-north-londons-waste.
Read the full press release by Stop the Edmonton Incinerator Now (StEIN)
“LOW WASTE” SURVEY OBSCURES KEY OBSTACLES TO CIRCULAR ECONOMY
Full text of press release issued by Stop the Edmonton Incinerator Now (StEIN) on 21st August 2023
North London Waste Authority survey called out as “disingenuous box-ticking” by StEIN coalition- Survey omits carbon impact of failure to install sorting facility and construction of new incinerator
- Yawning gap: NLWA’s approach undermines municipal, national waste reduction and recycling targets
- Coalition calls on NLWA to publish sorting study, corrected forecasts, costs, risks, incinerator emissions
London, 21 August 2023—In response to the North London Waste Authority (NLWA) survey on residents’ waste disposal priorities, the Stop the Edmonton Incinerator Now (StEIN) coalition is urging decision-makers to address two “key obstacles” to North London’s transition to a low-waste, circular economy. Through the more efficient use of materials, circular economy strategies can help to reduce global greenhouse gas emissions to combat climate change and achieve net zero by 2050.
The results of the “Towards a Low Waste North London” survey are to inform the design of a new North London Joint Waste Strategy. NLWA has been operating without a strategy since the previous one expired in 2020. In 2021/22, the most recent year for which official data are available, the recycling rate in North London dropped to 28.4%, far below the previous strategy’s targets of 45% by 2015 and 50% by 2020.
The total amount of waste also declined over the period, discrediting NLWA projections—and associated plans—that it would significantly increase.
StEIN founder Carina Millstone said: “We welcome efforts to feed residents’ views on waste disposal into the design of a sorely needed Joint Waste Strategy. As it stands, however, this survey is no more than a disingenuous box-ticking exercise to help NLWA appear inclusive and responsive to residents’ priorities. If the survey were really meant to help North London shift towards a low-waste economy, it wouldn’t deliberately exclude the two most significant barriers to that transition, while pointlessly asking respondents to rank government initiatives that are already underway.
In its survey response, StEIN identifies the two key obstacles to a circular economy in North London as:
1) the failure to install a sorting facility, which could extract plastics and other recyclables from the waste stream prior to incineration, thereby:
- slashing CO2 emissions
- turbocharging recycling
- dramatically reducing the amount of residual (truly non-recyclable) waste, in line with government requirements
- securing value for money for council taxpayers, including by increasing recycling revenue
2) the construction of an unnecessary waste incinerator in Edmonton, which is due to lock residents into a hugely expensive throw-it-away waste system for decades to come, while emitting as much CO2 as 250,000 additional diesel cars on the roads, undermining ULEZ benefits.
Millstone enumerated the coalition’s demands: “We urgently call on NLWA to make available all the relevant details so that council taxpayers can submit informed responses to the survey and, subsequently, to the consultation on the Joint Waste Strategy.
“First, publish the promised NLWA-commissioned assessment of the impact—including on CO2 emissions and recycling—that a sorting facility would have in Edmonton. Second, publish updated waste forecasts for North London, given their huge impact on capacity requirements. Third, we need to see all costs and risks associated with the construction, operation, potential cancelation, and potential early decommissioning of the new Edmonton plant, as well as of the alternatives to building it. And lastly, given publicly available proof that NLWA uses flawed carbon figures, where are the corrected CO2 emissions of the planned incinerator?
Delia Mattis, founder of Black Lives Matter Enfield, said: “NLWA isn’t just deciding to stick with burning loads of recyclables. They’ve also voted to build a new waste incinerator in one of the most deprived areas in the UK. This decision unequivocally entrenches environmental racism. Edmonton’s residents desperately need cleaner air. What they clearly don’t need is highly toxic ultrafine particles pumped out by the incinerator. NLWA must stop treating Edmonton like a sacrifice zone.
Experts have repeatedly highlighted that a sorting facility would help North London achieve elusive waste reduction goals. The much smaller amount of truly unrecyclable waste could then be treated in existing incinerators, as indicated in NLWA’s own alternative waste management scenarios. That would obviate the need for a new incinerator in Edmonton.
Environmental economist Dr Rembrandt Koppelaar assessed the potential benefits of installing a sorting facility: “In North London, an advanced sorting facility would remove an estimated 48% of residual waste just by recovering organics for biogas and digestate for compost. It would extract a further 22% for recycling, which would also provide a vital revenue boost for the seven councils.
Environmental engineer Georgia Elliott-Smith, who previously sued the government for excluding waste incineration from the UK Emissions Trading Scheme, noted: “As Mayor Sadiq Khan’s calculations show, London already has enough waste incineration capacity without an incinerator in Edmonton. It’s high time for NLWA to re-evaluate the plans for a new incinerator in view of the actual waste data.
Elliott-Smith added: “Leaving the incinerator unbuilt could allow for an extension of the Lea Valley nature reserve to provide residents with fresh air, green space, and leisure amenities—not to mention major savings for North London taxpayers if the £1.5 billion ‘Heat and Power’ project is replaced with a low-waste plan.
Former Enfield councillor Vicki Pite underscored the knock-on effects of relying on the incinerator to heat up to 30,000, mostly new homes. Pite said: “Plans to deliver heat from the incinerator in Edmonton to Enfield and Haringey will make it difficult for NLWA to turn off the incinerator. The data shows they will need to import waste to maintain the incinerator—and supply residents’ heat. Environmental groups in Enfield are concerned about the massive road disruption planned over several years to lay 23 km of pipework, and Haringey residents are waking up to the same risk. Moreover, residents will be locked into carbon-intensive heat contracts with no redress, although low-carbon alternatives are available.
Millstone asked: “What’s the point of developing a low-waste strategy for North London while simultaneously spending millions to burn imported, recyclable waste in Edmonton? Where is the leadership on waste? NLWA failed us abysmally on recycling targets. Now they’re spending colossal sums of council taxpayers’ money on a worldview that is no longer credible. NLWA leadership has lost credibility and public support.
The StEIN coalition calls for the new Joint Waste Strategy to commit NLWA to “doing all it can to reduce waste and to manage the far smaller amount of waste at the highest possible level of the waste hierarchy” while “continuously and publicly updating data on waste collected and recycled, monitoring progress against targets, and adjusting its waste management approach and forecasts in line with the evidence”. Only then can the strategy enable NLWA to pursue the national target of halving residual waste by 2042 (compared to 2019) and London’s target of recycling 65% of it by 2030, while minimising CO2 emissions.
Expert evaluation shows that NLWA relies on deeply flawed [estimates of] CO2 emissions for the incinerator, both in its general communications as well as in financial processes such as bond applications. The StEIN coalition continues to call for NLWA to publicly correct the figures by fixing a methodological flaw in the way landfill was assessed and updating a 2013 figure for the avoided carbon intensity associated with power generation (since the National Grid is decarbonising over time).
This summer’s extreme weather events show we are unquestionably facing life-changing climate change. Now is the time for NLWA itself to change.
Relevant links:
- NLWA’s “Towards a Low Waste North London” survey: northlondonwaste.commonplace.is/en-GB/proposals/nljwssurvey/step1
- StEIN’s response to NLWA’s “Towards a Low Waste North London” survey: stop-edmonton-incinerator.org/stein-response-to-the-north-london-joint-waste-strategy-survey/
- This press release: stop-edmonton-incinerator.org/press-release-low-waste-survey-obscures-key-obstacles¬to-circular-economy
- Dr Rembrandt Koppelaar, “Waste Prevention and Recycling as the way forward instead of rebuilding the Edmonton incinerator”: static1.squarespace.com/static/5f95667217eb67456f4ebd4e/t/61b10286fc33f625ca60c71b/1638990474397/Poster_North_London_Alternative_plan_recycling_instead_of_incineration.pdf
- Dr Dominic Hogg (founder of the consultancy Eunomia):
- The case for sorting recyclables prior to landfill and incineration, reloop: www.reloopplatform.org/wp-content/uploads/2022/06/D-HOGG-_Reloop_FINAL_June2022-1.pdf
- “Should the NLWA Incinerator be Eligible for Green Bonds?”: www.dominichogg.com/s/Eligibilityof-Incineration-for-Green-Bonds-Final-Version.pdf
- “Should Incineration Attract Finance from Green Bonds?”: www.dominichogg.com/hoggblog/should-incineration-attract-finance-from-green-bonds
- “A Burning Issue”, Environmental Finance (registration required): www.environmental-finance.com/content/analysis/a-burning-issue.html
- Additional StEIN links:
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- “Legal action challenges government funding for Haringey heat networks using incinerated waste”: stop-edmonton-incinerator.org/wp-content/uploads/2022/09/2022-09-22-Press-release-Heat-Scheme.pdf
- “Campaigners issue litany of concerns to aid Gove investigation of NLWA”: stop-edmonton>incinerator.org/wp-content/uploads/2022/06/2022-06-16-Campaigners-expect-Gove-investigators-toscrutinize-concerns-about-NLWA.pdf
- “Edmonton incinerator data ‘grossly misleading’ or sign of ignorance”: stop-edmonton-incinerator.org/wp-content/uploads/2022/04/2022-04-19-worse-than-landfill-press-release-2.pdf
Read the StEIN response to the NLWA survey
Read North London Waste Authority's full comments on the StEIN press release
Thanks again for your enquiry.
Please see our press release about the Joint Waste Strategy, which explains more about the strategy and encourages residents to have their say. It includes quotes from our Chair, Councillor Clyde Loakes, reiterating that this is a genuine listening exercise.
The survey has six free-text questions allowing residents to raise any issues they want to, so we strongly disagree with the suggestion in the press release that the public consultation is just a box-ticking exercise.
We have responded to and dealt with the issues raised in STEIN’s press release numerous times over the years and continue to do so. For example, our Chair recently responded to deputations from STEIN members which cover many of these points (including the alternatives considered, such as pre-sorting facilities). These are on the public record so can be quoted:
- https://www.nlwa.gov.uk/ourauthority/scheme-of-publications/deputation-malcolm-stow-issues-relating-consideration
- https://www.nlwa.gov.uk/ourauthority/scheme-of-publications/deputation-dorothea-hackman-issues-relating-energy-waste
As the listening exercise is still ongoing, it wouldn’t be right for us to discuss or respond to STEIN’s (or any one organisation’s) response at this time. But we will consider their response along with all responses we receive.
We also note the STEIN press release is factually inaccurate when it states London Mayor Sadiq Khan concluded that “London will have excess incineration capacity even if the 700,000-tonne Edmonton plant is not built . . .” We refer to the Mayor of London’s London Environment Strategy, which states on page 284: “Modelling suggests that if London achieves the reduction and recycling targets set out in this strategy, it will have sufficient EFW capacity to manage London’s non-recyclable municipal waste, once the new Edmonton and Beddington Lane facilities are operational (see Objective 7.4).” The statement makes clear that London’s incineration capacity is dependent on the completion of the Edmonton facility.
