Towards a genuinely low-waste strategy for north London

Enfield Climate Action Forum: Suggested responses to North London Waste Authority consultation on draft North London Joint Waste Strategy

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Q1. Which of the following best describes your response?

Responding as an individual

Q2. If you are providing the official response of an organisation, group or business, or as an elected representative of a constituency, please provide details of this.

Name of organisation / group / constituency

​Q3. Do you live in any of the following London Boroughs? If you are providing the official response of an organisation, group or business, or as an elected representative of a constituency, please tell us which area you are based in or represent.

Enfield

Q4. Which of these best describes how your rubbish and recycling is collected?

I put it outside my home for collection

Email address added

Priority 1: Supporting the reduction in household waste by promoting prevention, repair and reuse

Q5. How high a priority should we give to the following actions to support the reduction in household waste by promoting prevention, repair and reuse? (Priority 1)

Q5.1 Low

Q5.2 High

Q5.3 Low

Q5.4 High

Q5.5 Low

Q6. Do you have any other comments on how we propose to support the reduction in household waste by promoting prevention, repair and reuse?

Set up or fund the setting up of reuse shops, at least one in each member borough in RRCs and shopping areas.

Set up or fund the setting up of repair shops in all member boroughs, coordinated with existing initiatives, so that each borough has a repair shop available at least 1 day per week.

Fund repair events where residents can learn how to repair/repurpose certain items, such as www.fixingfactory.org in Camden.

Priority 2: Improving and maximising recycling

Q7. How high a priority should we give to the following actions to improve and maximise recycling (Priority 2)?

Q7.1 Low

Q7.2 High

Q7.3 Low

Q7.4 Low

Q8. Do you have any other comments on how we propose to improve and maximise recycling?

Sort dry recycling with contamination and residual waste to remove recyclable materials for recycling.  For this acquire or adapt existing mixed waste sorting machinery.

Provide more collection points in each borough, especially close to flats, prioritise food waste.

Priority 3:   Reducing the environmental impact of disposal, where there is no option to prevent or reuse waste

Q9. How high a priority should we give to the following actions aimed at reducing the environmental impact of disposal, where there is no option to prevent or reuse waste. (Priority 3)?

Q9.1-Q9.3   High for 1 and 2; Low for 3.

Q10.    Do you have any other comments on how we propose to reduce the environmental impact of waste disposal?

Please do not waste council taxpayers' money on carbon capture and storage technology. The priority at this time should be to reduce greenhouse gas emissions, rather than trying to remove them, especially as the ability to do so cost effectively is unproven.

It would be better to use this money on equipment to recover recyclable/re-usable materials from our black bin waste and contaminated dry recycling. 

Priority 4:   Delivering collaborative, community-focused services which provide value for money and maximise social value

Q11.    How high a priority should we give to the following actions aimed at delivering collaborative, community-focussed services which provide value for money and maximise social value (Priority 4)?

Q11.1-Q11.4   Low for 11.1 and 11.3; High for 11.2 and 11.4

Q12.    Do you have any other comments on how we propose to deliver collaborative, community-focused services which provide value for money and maximise social value?

Implement workplace democracy and workers should be represented on the Board. Salaries to include bonuses dependent on the extent of reduced waste incinerated and increased waste recycled.

You should ensure councils have an equal range of recycling points in each borough for items outside the household waste streams, e.g. clothing, batteries, electrical, DIY etc.

You should ensure councils have adequate shared recycling facilities for households above shops and in blocks of flats.

Q13. How could we effectively engage with residents in future to seek feedback on our progress delivering this strategy?

NLWA has no direct communication channels to residents. Communication with residents are best done by Councils, eg electronic and paper newsletters, with regular information and advice from NLWA on reducing waste and increasing recycling.

Q14. Do you have any further comments on the draft strategy?

The top priority should be to reduce incineration, so as to reduce emissions and increase the materials that are recovered from waste for reuse.

Do not continue communication /outreach as done in the past, as it has not resulted in waste reduction or recycling increase.

To track progress, publish the annual total amount of emissions from NLWA/LEL incineration, without deductions for set-off or reduced by estimates of how much of the emissions are from non-fossil fuel sources.

Q15. Do you have any further comments on anything related to the consultation?

Q16. We want to make sure that all residents are able to access our services as easily as possible. Do you (or other people you know) experience any difficulties using our waste services? Please select all that apply

Many people living in flats have no recycling facilities.

Q17. If you answered yes to the previous question, please explain the barriers e.g. what services you (or others) have difficulties with, and what would overcome these.

The incinerator at the heart of north London's waste strategy

The North London Waste Authority's consultation on a new strategy for dealing with waste scarcely mentions the large new incinerator under construction in Edmonton, which environmental campaigners say is unjustified on both environmental and economic grounds

On behalf of the seven boroughs, the NLWA is currently in the process of building a massive new waste incinerator in Edmonton, to replace the somewhat smaller and now ageing incinerator that you'll see as you travel towards Walthamstow along the North Circular. Strangely, the subject of incineration scarcely features in the draft strategy (the word "incineration" occurs only twice, as does the word "incinerator"), in spite of the extremely high cost of construction, which will be paid for by north London council tax payers.

The new incinerator is, however, very much at the heart of NLWA's future operational strategy, as it is intended to be a nice little earner, designed to send waste heat along an extensive network of pipework to various parts of Enfield borough.

So what's the problem? There are several, including:

• The fact that heat from the incinerator will bring in money will act as a perverse incentive: rather than conserving and recycling materials, which is vitally important for environmental reasons, NLWA will gain financially by burning, and thus destroying, valuable materials, which means that they won't be working as hard as they ought to maximise recycling.
• Though the new incinerator should be significantly "cleaner" in terms of emissions of toxic materials that the current plant, its chimney will still be creating a plume of pollution over densely populated areas.
• Residents connected to the heat network will effectively be tied to using it for decades to come, when there will undoubtedly be much cheaper options available.
• Last but not least, the new incinerator will be emitting huge amounts of greenhouse gases for decades to come, when the future of human life on earth is dependent on rapid reductions in such emissions. And if, for any reason, the incinerator is out of service, NLWA have built themselves a CO2-emitting gas-powered heat plant to back it up - at the very time when we are supposed to be phasing out gas! To get round this key problem with the incinerator (having only recently admitted that the problem exists), the NLWA is suggesting the introduction at some future date of carbon capture and storage technology to redue emissions. However, this technology is as yet unproven to operate at the scale required.

Excerpt from Stop the Edmonton Incinerator Now (StEIN) input

The StEIN coalition is issuing this survey response to ensure that decision-makers who are charged with accelerating the transition away from the linear economy do not overlook the two key obstacles to a more circular economy in North London—neither of which is explicitly mentioned in the survey—namely: 

1. the construction of a waste incinerator in Edmonton, which threatens to lock residents into a socially unjust, carbon-intensive, uneconomic, take–make–waste system for decades to come
2. the failure to install an advanced sorting facility to extract plastics and other recyclables, including compostables, from the waste stream prior to incineration. Such a facility would allow NLWA to: slash CO2 emissions, as material extraction drives down the amount of waste to be incinerated
   • turbocharge recycling, as extracted materials are fed into recycling streams, bringing national and municipal targets back within reach while accelerating the transition to a circular economy
   • secure value for money, as reducing residual waste dramatically lessens how much incineration capacity is required, boosting recycling grows income streams, and slashing CO2 emissions significantly cuts costs of incineration under the UK Emissions Trading Scheme.

These two obstacles have created a yawning gap between North London’s approach to waste management, on the one hand, and municipal and national waste targets, on the other. The gap is reflected in North London’s abysmal recycling rate, which has been trending downwards since 2015. NLWA recycled 28.4% of our household waste in 2021/22 although the previous Joint Waste Strategy set targets of 45% by 2015 and 50% by 2020. The gap yawns even wider because North London lacks a coordinated reuse and repair strategy, although cities like Manchester have demonstrated what can be achieved when one is in place. The fact that NLWA has been operating without a waste strategy since the previous one expired in 2020 may partly explain why no progress has been made in achieving agreed targets.

The new Joint Waste Strategy must whip North London into shape. It needs to support NLWA in closing the gap while complying with the priorities highlighted in the survey, such as minimising the carbon impact of disposal. In particular, the Strategy must enable NLWA to meet—or at least strive for—established milestones on the transition path, including the national government’s target of halving residual waste by 2042 (compared to 2019) and the London Environment Strategy target of recycling 65% of it by 2030 (as reflected in the 2022 North London Waste Plan). Given the urgency behind these ambitious goals, the new Joint Waste Strategy must 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
• 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.

Such a Joint Waste Strategy is certain to identify the above-mentioned obstacles to a circular economy. It would no doubt demonstrate that NLWA can fulfil its vision in line with its stated principles only if it installs an advanced sorting facility and urgently reviews its decision to build a 700,000-tonne incinerator to treat an already insufficient, rapidly shrinking feedstock, instead of sending North London’s truly residual (nonrecyclable) waste to commercial incinerators. A Strategy that aims to halve residual waste, achieve recycling targets, and minimise CO2 emissions can leave no space for an “I’ve started, so I’ll finish” approach.

The following sections broadly respond to the NLWA survey’s seven questions (Q1–Q7), presenting details that decision-makers should consider in drafting the new North London Joint Waste Strategy and in developing policies and activities designed to accelerate the shift towards a circular economy.

1. Top priority for the Joint Waste Strategy: minimising the carbon impact by installing an advanced sorting facility to extract recyclables from the incineration waste stream (Q1)
2. Residents’ views on implementing the waste hierarchy (Q2, Q4, Q5)
3. Actions from the national government (Q3)
4. Urgently needed NLWA actions to tackle the climate and ecological crisis (Q6)
5. Recommendations for the North London Joint Waste Strategy (Q7)

Download the full StEIN response to the consultation