Forum topic: 'Dirtier than coal': Does north London really need a new 700,000 tonne incinerator?

Questioning the need and sensibility of the proposed new incinerator in Edmonton continues, and not least from Enfield resident Georgia Elliot-Smith, who as well as taking HMG to court on the wider issue of incineration has been talking to Islington councillors about some of the related issues. The position has been reported in the Islington Gazette, copied here word for word. I've added my own thoughts on the NLWA spokespersons “real world evidence” at the end.
'Dirtier than coal': Does north London really need a new 700,000 tonne incinerator?
Islington's eco chief Rowena Champion has promised to “see what she can do” to provide updated figures on whether it’s still really necessary to build a new 700,000 tonne capacity incinerator to burn north London’s waste.
In 2017 the government gave the North London Waste Authority (NLWA) permission to rebuild the Edmonton incinerator.
But four years on, London mayor Sadiq Khan says the capital has no need for another incinerator, and eco campaigners are questioning the viability of the giant £1.2bn "energy from waste" plant in the wake of the government declaring a climate emergency two years ago.
At a meeting on waste strategy organised by the North Islington Labour party this week, XR campaigner Georgia Elliott-Smith, asked Cllr Champion whether any new waste projection figures have been compiled in the past five years to demonstrate the need for a 700,000 tonne capacity incinerator, and whether the NLWA is banking on failing to meet recycling targets.
Islington’s eco chief, Cllr Champion, is one of 14 councillors who sit on the NLWA’s board, from Islington, Hackney, Camden, Barnet, Haringey, Enfield and Waltham Forest councils, which will pay for and own the incinerator if work to build it starts next year.
Ms Elliott-Smith said: “We frequently address the NLWA with our question and yet we are brushed away with comments from Cllr Loakes [NLWA chair] with statements such as ‘We have constantly reappraised our position’, or ‘We have constantly reviewed this incinerator plan’.
“And yet the planned capacity is exactly the same as when the consent order was achieved, based on the plans and statistics pre-2016.
“Since then the council declared a climate emergency. Since then all of the waste capacity data has been shown to be inaccurate. Your capacity is based on climbing waste capacities in London, but in fact waste has reduced in London.
"We now have new waste policies and regulations coming in, and higher recycling targets, meaning that the residual waste going to the incinerator will decrease."
Cllr Champion replied: “It's probably not surprising to you to explain that I don’t know the detailed figures.
“If you wanted to email me I can see what I can do.
“It is constantly reviewed."
London currently has five incinerators with a capacity to burn 3m tonnes of waste, and according to London Assembly member, Nicky Gavron, who also spoke at the meeting: “You have a situation now where by 2030 if we reach our [recycling] targets we will have a million tonnes of surplus capacity."
About 80,000 tonnes of plastics which could be recycled are believed to be incinerated in north London each year, both because of contaminated recycling and the fact that there is no pre-sorting of residual waste before it is incinerated.
Ms Elliott-Smith added: "One of the fundamental things I find disturbing is 60 per cent of what goes in is recyclable, because of no pre-sorting before burning.
"A very large proportion, increasing every year, is made up of plastics, and we know burning mixed plastics is incredibly polluting. It’s dirtier than burning coal.
"We wouldn't tolerate a coal station in Edmonton so it doesn’t make sense to transport waste to Edmonton to burn it."
The NLWA purports its “energy from waste" project is "eco-friendly", and boasts it will generate enough energy from burning rubbish in the incinerator to heat 127,000 homes.
The authority would not confirm whether any new waste forecasts have been carried out since 2016 - but their response does not seem to suggest any have been.
A spokesperson said: "When the plans were put forward for the new facilities in Edmonton, there was public consultation on the evidence of the need for the facilities including waste forecasts.
"After public consultation there was a formal process under the Planning Act 2008 to consider the development.
"The Planning Inspector recommended granting consent for the facility – his report said, 'I conclude that the design capacity of the proposed ERF is reasonable'.
"The Secretary of State for Business, Energy and Industrial Strategy gave approval to the facility.
"For 2019/20 the forecasts estimated that waste would be in the range 582,000 tonnes per year to 663,000 tonnes. In fact the reported waste was 581,000 tonnes.
"So suggestions that the forecasts are excessive clearly don’t match up with real world evidence."
Source: https://www.islingtongazette.co.uk/news/nlwa-pushed-for-new-waste-incineration-forecasts-7848450
Published: 11:09 AM March 31, 2021 Updated: 11:53 AM March 31, 2021

Karl adds: the 2019/20 figures quoted by the NLWA indeed do show that the actual residual figure is pretty much bang on with the lower extreme of the forecast (581,000 tonnes vs 582,000 tonnes). What the quote doesn’t say is that the forecast was based on the then target recycling rate being achieved. Seeking to achieve 50%, the recycling outcome was however only 26.8%, the result being an awful lot more residual waste being left over than had been planned, and hence available for incineration. The difference is about 150,000 tonnes. If you ignore that 150,000 tonnes than yes, the figures are in line. That’s “Real world evidence” for you, but which world is unclear.
Note the recycling targets now being proposed in the waste plan (NLWP) by the seven councils are greater than those used when planning the incinerator.

With an Enfield resident having recently taken HMG to court over waste disposal, specifically incineration, long running activism in this space has reached dizzy heights, but it’s not restricted to Enfield and campaigners in other boroughs are active in bringing waste related issues to the attention of their own councillors. In support of their effort, the chair of PWA recently supplied some background data on the NLWA (“waste authority”) and how their tendency to think very big on our preponderance to generate waste has influenced key decisions both over the years, and presently. He concludes by posing the question whether the NLWA is adding anything of value to our lives.

(The 15 year NLWP, rapidly approaching an equivalent 15 years in its preparation, remains with the 7 boroughs who are making further amendments to the 114 Main Modifications they concluded were required following its rough ride at the 2019 public examination and which were themselves mauled at a subsequent consultation, before its planned resubmission to the independent inspector.)

THE NORTH LONDON WASTE AUTHORITY’S USE OF THE NORTH LONDON WASTE PLAN

XR’s recent questions to Rowena Champion (North London Waste Authority (NLWA) member for Islington) centred on the NLWA’s failure to publish updated waste projections for several years.
Whilst this paper doesn’t claim that waste forecasting is easy, it’s worth spending some time in examining NLWA’s record in producing waste projections whose combined inaccuracy and inflexibility have calcified North London’s waste planning for more than a decade. It has not, as might be expected, commissioned these to support the objectively identified waste needs of the seven North London member boroughs which it was established to serve. On the contrary, it has used them to force its own agenda into successive North London Waste Plans (NLWP).
A waste plan is a land use document prepared by planners which reach evidence-based conclusions about future needs. Its function is not to start with predetermined objectives and work backwards to satisfy them.
So it should examine waste collection data, estimate future waste ‘arisings’ in the light of trends in waste and many other factors (including relevant regulatory and technological changes), look at the capacity of existing waste treatment facilities to handle future estimates, and reach conclusions on what, if any, new facilities are needed.
A waste authority is plainly a most important stakeholder and consultee in this process. It does not, however, own the plan.
From 2008 onwards, inflated NLWA projections purported to support an oversized and inflexible 30-year waste contract procurement (the authority abandoned this in 2013 at a cost of some £40m). Only one council, Enfield, sought independent advice on a contract worth £4-4.5bn. The advice highlighted the flaws which eventually led to the procurement’s failure.
Now, further inflated projections purport to support an oversized incinerator, proposed, as we shall see, on the basis of a study whose validity was very heavily qualified by the consultants who prepared it. Whether individual councils undertook independent analysis remains unknown.
The 2015 Eunomia Waste Study informed the planning application (Development Consent Order – DCO) and examination in public (EiP) for the new Edmonton plant:
• Eunomia included heavy caveats on the paucity and unreliability of data as basis for reliable forecasting – please see the Appendix.
• The NLWA’s misrepresentation of these caveats is beyond astounding: The model was developed based on …. a robust analysis of historical trends and a robust set of assumptions about what will happen to these trends in the future.
• The calculations and other assumptions used to develop the supporting spreadsheet work show all the signs of having been worked to produce a predetermined result, ie the planned 700/- tpa capacity of the new facility. The unrealistic economic forecasts (3% compound annual growth over 30 years) and the accompanying waste forecasts projected from the early 2020s through to 2050 are of schoolboy ‘I’ve got to put something in so here goes’ standard.
Yet the Inspector at the EiP for the Edmonton proposals, supported by the GLA and the N London boroughs (and, it can be assumed, DEFRA), accepted the Eunomia figures. The GLA’s submission to the EiP stated at para 10:
… it is the understanding of GLA officers that the N London waste planners, in developing the NLWP have been working closely with the NLWA … it is known that the NLWP is supportive of the approach being taken and the NLWP reflects the projections for waste growth provided by NLWA.
The Inspector’s report, and the GLA’s comments, indicate an assumption that the NLWP (‘working closely with the NLWA’) would unhesitatingly rubber-stamp the waste forecasts, although the plant capacity was significantly larger than the amount of waste that could be expected to be produced in the area.

It is fair to say that, for the purposes of the DCO, all parties regarded the NLWP not as an evidence-based objective plan for almost a quarter of London, but as no more than an extension of the NLWA. Its absorption into that distorted role has fundamentally compromised its validity as objective regional planning based on sound evidence.

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The London Plan uses ‘apportionment’ for waste projections. This involves projecting waste ‘arisings’ for London and allocating this total across all boroughs based on an agreed formula. The 7 N London boroughs pool their resulting apportionments and treat them as one.
However, such is the sway that NLWA appears to exercise over its members that, to justify the regional over-capacity of the new plant, the forecast waste arisings for the 7 North London boroughs, as stated in the NLWP 2019, were nearly 40% above the apportionment figures.
The GLA’s support for the Edmonton proposals meant that it endorsed the inflated figures; its final submission to the 2019 NLWP misleadingly described as ‘ambition’ what was in reality the boroughs’ forced adherence to these inflated forecasts:
The Mayor welcomes the ambition [sic] of the NLWP to exceed the apportionment targets.
It ignored the nonsensical conclusion inherent in its support that, if every borough shared this ‘ambition’, London would be saddled with waste treatment over-capacity of some 3 billion tpa!
Unsurprisingly, the Inspector for the NLWP, having seen the sharp divergence from the forecasts as illustrated in the chart below, rejected these projections as unjustified and unsupported by evidence. (The Councils are still entangled in this Gordian knot.)
The chart shows the Eunomia projections for NLWA plotted against the subsequent reality – a 13% divergence in a few years. (This and following tables are from PWA submission to NLWP – March 2019)

The North London Joint Waste Strategy 2009 (NLJWS) was drafted by the NLWA and the 7 boroughs. Its yearly Annual Monitoring Report (AMR) shows that, in spite of charts such as the above, important sections of the text haven’t altered one jot throughout the past decade (2009 onwards) during which the trend in waste has been down:
The continued increases in population and the number of households in London suggest that the amount of waste generated is likely to grow over the remaining period of this Strategy.
Successive AMRs have repeated this nonsense. Yet the last decade has shown that, as far as N London is concerned, waste has declined whilst the population and the number of households have increased by some 20%.

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Those who have come only recently to examining the functions and behaviour of the NLWA should note that its objective in 2019 to inject a grandiose scheme into a regional waste plan of limited stated capacity (ie the seven boroughs’ local waste data) mirrors its behaviour earlier in the 2010s.
In the 2012 NLWP, which the Inspector threw out as illegal, its attitude was much the same. Then, it sought to inject a 30-year waste contract procurement exercise into a 15-year plan, and left the councils to manufacture a justification.
Self-serving overestimates of waste arisings characterised that plan in the same way. See below the same divergence between projections and reality. (Just before the NLWP EiP in 2012 – so after the egregious inaccuracy illustrated below – the boroughs cut long-term projections by a colossal 20%!)

The two charts have a horrible similarity.
The debate surrounding the new incinerator has concentrated on emissions and the availability of practical and environmentally beneficial alternatives to incineration. However, consideration of the issues raised in this short paper, especially the farce surrounding the NLWP’s 14 years of attempting to accommodate the NLWA cuckoo within a nest limited by local waste data, should surely alert members and campaigners alike to question not only the whole basis for the project, but the point of the NLWA’s existence.

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Appendix - THE CAVEATS IN EUNOMIA’S WASTE STUDY FOR NLWA

The study was commissioned from consultants Eunomia as the basis for NLWA’s DCO application for the new Edmonton incinerator.
We draw your attention once more to the NLWA’s own public presentation of the Eunomia study:
The model was developed based on …. a robust [sic] analysis of historical trends and a robust [sic] set of assumptions about what will happen to these trends in the future.
Please look at the caveats below, taken verbatim from the Eunomia Study, and then reconsider the NLWA’s comments.
• ... It is worth re-emphasising, however, that given the paucity of historical data there is limited scope for making accurate predictions,
• ... We would not normally advise forecasting for more than a very small number of years into the future on this basis [ie the paucity of historical data mentioned above]. The use of this type of analysis for long-term projections remains questionable and open to challenge
• ... One limitation of this type of analysis is the number of historical data points which are available
• ... Although the quality of data has been steadily improving since 2000 (although vagaries remain), the time series for the datasets used are relatively short and the quality of data in the early years is questionable.
• ... There is also a danger in over-complicating matters with spurious levels of detail; detail which in and of itself is based on relatively high-level sampling and assumptions.
• ... to account for what we would speculate is the cumulative effect of waste prevention and minimisation measures
• ... Forecasting C&I [Commercial & Industrial] waste volumes for future years is notoriously difficult due to the distinct lack of data on historic and current volumes.
• ... the analysis of a number of alternative scenarios show that waste arisings could vary significantly depending on the assumption made

Pinkham Way Alliance
May 2021.

Small but nonetheless good news from the latest waste position. The best outcome is to produce less waste rather than worrying about what the authorities will do with any resultant. Waste years align with tax years and the latest North London 2022/23 forecast for residual (black bin) waste, including about 6 months of actual data, is down year on year. North London’s dry mixed recycling (blue bin) is also forecast to fall. As is the norm, NLWA had originally expected both would rise.