In a recent message to its supporters the Pinkham Way Alliance (PWA) provided an update on its continuing fight on two fronts: on the one hand, it is still campaigning to prevent, or at any rate minimise, the development of Pinkham Wood; on the other hand, it continues to oppose what it considers overly grandiose plans by the North London Waste Authority for future waste incinerator capacity.
Pinkham Wood
The land referred to as Pinkham Wood is adjacent to the Pinkham Way section of the North Circular and many years ago was the site of Friern Barnet Sewage Works. PWA campaigning was a very significant factor in the abandonment in 2013 of the planned construction of a large waste processing plant on this Borough Grade 1 Site of Importance for Nature Conservation. However, because of ambiguities about the planning status of this land, this did not rule out the possibility of the site being built on to provide some sort of industrial or other commercial capacity.
Haringey Council is currently considering what planning designation the site should have in future. The PWA has submitted a detailed input (available on the PWA website), which has been supported by over 1100 members of the public. Stephen Brice, the PWA Chair, has summed it up as follows:
- that the Council, through their advisors, had produced no evidence of continuing need for employment designation on the Pinkham Way site - rather, the comments pointed the other way,
- that any proposal for developing the site would anyway meet several serious constraints,
- that Pinkham Way's value as a nature conservation site is increasingly apparent, and now recognised by the Council's own advisor, who called it ' ... a rare resource for Haringey ..of high ecological value ... '
The planned new incinerator at Edmonton
Subsequent to its abandonment of its plan for a large waste processing facility on Pinkham Way, the North London Waste Authority announced its intention of replacing the current Edmonton Incinerator (also adjacent to the North Circular and currently known as the "Edmonton Eco-Park") with a more modern, larger incinerator on a neighbouring site - the plan is referred to as the NLWA North London Heat and Power Project. As well as processing waste and generating electricity, the new plant would be a source of hot water used to heat new housing at Meridian Water and New Southgate.
The Pinkham Way Alliance has serious misgivings about this proposal, as is clear from a list of questions they have posed to the North London Waste Authority (reproduced at the end of this article). Among the many points they make is
- the fact that the amount of waste the new plant would need to burn is not compatible with existing targets for increasing the proportion of waste which is recycled and with the principles of the "waste hierarchy"
- the probability that the Authority would want to "import" waste to keep the incinerator working - which is against existing policy
- the questionable business assumptions, in particular in relation to future energy costs.
As they have been arguing for years now, the PWA believes that waste processing capacity should be built up incrementally, in response to actual requirements. They clearly believe that the waste authority is working to an internally generated expansionist agenda, leading to "misguided overprovision for waste management". The Authority's submission to the new North London Waste Plan "displays a one-sided championing of an unlimited waste land bank that discredits the Authority as a reasonable, responsible public body".
A second group that is unhappy about the Edmonton proposals is Enfield Green Party. They view incineration as a wasteful and dangerous process which releases toxins into the atmosphere and destroys materials that might be used again. If there are "residuals" (ie non-recyclable waste) that do need processing, the method used should be anaerobic digestion, pyrolysis or the "Norfolk Solution", which is to use the waste to make bricks and road surfacing material.
The Greens too are concerned about the risk of perverse economic incentives not to maximise recycling. They say:
We believe that it's important that the incinerator should always be seen as a last resort. The NLWA should therefore avoid any arrangements that discourage reductions in the volumes to be burnt. Specifically:
- NLWA should avoid any heat supply commitments that require greater volumes to be burnt than the most optimistic plausible volumes.
- NLWA should commit to keeping the incinerator under public control for its whole life. A private owner would be bound to see it as a source of profit and thus seek to increase the throughput. [Source: Enfield Green Party submission re new Edmonton incinerator]
The second phase of consultation on the plans for Edmonton runs from 18 May until 30 June.
Pinkham Way Alliance comments on North London Waste Authority plans for a new incinerator at Edmonton
January 2015
Pinkham Way Alliance is pleased to have the opportunity to comment on the North London Waste Authority’s future plans for the Edmonton site. We would appreciate your answers to the specific questions that we have asked (in bold italics).
Strategic issues
You fall back on the North London Joint Waste Strategy as underpinning your proposals. However, the NLJWS expires in 2020, whereas your proposed ERF plant will not be built till some years later, and your proposal anticipates three decades ahead and beyond. Therefore
How is the Authority’s proposal consistent with any up-to-date strategy agreed by the North London authorities?
The Waste Hierarchy is central to the waste policies of the EU, the Mayor of London, the NLWS and the evolving North London Waste Plan, with a recycling target of 50% by the year 2020. Yet your proposal assumes that the North London authorities will not achieve a recycling level beyond 35-40% even by year 2051, and it is silent on the anticipated impact of higher-level waste management methods in the hierarchy - waste prevention and re-use – on the forecasts for residual waste.
How is the scale and timing of your proposal consistent with the Waste Hierarchy aspirations to which you and the North London Councils are committed?
The quantities of waste managed in your proposal exceed North London’s apportionment, which is the amount agreed on a London-wide basis by the Mayor of London, taking into account the quantities of waste produced and manageable by all the London authorities.
What is the benefit for North London’s inhabitants in managing more waste than is necessary in North London?
Eunomia’s reservations on data
Eunomia’s caveats on data reliability could not have been stronger. ‘Best available data’ is exactly what it says it is; ‘best’, as the Authority knows, is relative, it is not an indication of fitness for purpose. We are surprised, therefore, at the lack of flexibility in the Authority’s capacity decision on for the new EfW facility.
Why has the Authority not attempted to mitigate the admitted inadequacy and fragility of ‘best available data’, at least to some extent, by a flexible, incremental approach rather than a decision to build maximum capacity near the beginning of the period?
Operating capacity/forecast arisings/recycling rate
We are concerned that the operating capacity of 700,000 tpa, when compared with the forecast arisings for 2051, indicates a recycling rate only a few per cent above the present NLWA figure of c 32%. This present figure is anyway well below some comparable WDAs (Gtr Manchester at 38.25% is but one example), and should be addressed urgently if there is not to be a substantial shortfall in NLJWS aims of 50% by 2020. The plan actually gives the impression that the Authority has given up on any effort to meet these, either by 2020 or in the future.
In the light of this apparent conflict, what is the Authority’s attitude to the 50% recycling target? Where does the target sit in the Authority’s list of priorities?
What financial or strategic assessment has been made of the implications of the central or the high estimates of recycling on the plant’s operation?
Capacity compared with N London apportionment
At its proposed 700k tpa capacity, the new plant would be capable of processing above 100% of the 2036 HHLD Apportionment, and an even higher percentage in earlier years.
London Boroughs have been set an Apportionment target based on regional need and their perceived ability to support the all London target. NLWA operates a pooled Apportionment for seven Boroughs within this total.
There is considerable difference between following the requirements of the Apportionment of the London Plan and seeking sub-Regional self-sufficiency in waste.
Has a strategic or financial assessment been made of the apparent acceptance that sub-regional self-sufficiency is the better route?
Consequences of future shortfall in N London arisings
It is evident from the forecasts that a shortfall in feedstock from N London is possible, especially if the Authority and the Councils approach the 50% recycling target. We assume then that the Authority may be positioning itself as provider of treatment services to third parties. However, anecdotal evidence indicates that the cost of exporting waste to Europe, for instance to Holland, is significantly lower than the cost of local treatment
What evidence does the Authority have of a reliable supply of third party waste of the required quality in the event of a shortfall from the sub-region?
Quality of feedstock for the new plant.
We note the Authority’s comments on the high calorific feed necessary for the size of lines to be installed in the new plant.
How does the Authority reconcile the apparent conflict between this requirement and
- with Policy 2 of the Mayor’s Municipal Waste Strategy, which emphasises ‘cleaner, efficient energy generation from low-carbon waste material’
- with the UK Government pledge to reduce carbon emissions by 80% by 2050, and
- with EU policies and statements about plastic and energy recovery, especially from the previous Environment Commissioner, who said in 2012 “It (plastic) must be responsibly used and recycled from cradle to cradle without escaping a closed loop of responsible treatment at its end of life phase”?
Electricity pricing model
In October 2014, the UK Dept of Energy published projections for the price of oil, as it does every year. Oil is globally traded, and probably the most understood and heavily researched commodity with advanced, liquid markets, where even minute by minute trading is technically analysed. In the preamble, DECC says the following:
Forecasting fossil fuel prices far into the future is extremely challenging, as it depends on a large number of unknowns … DECC has instead generated a set of projections based on estimates of fundamentals and other available evidence that represents a plausible range for future prices … Each set of price projections (across oil, gas and coal) has been subjected to peer review, in which an expert with expertise in the given fuel type provided scrutiny to the methodologies behind the projections.
It is plain that, with input from the International Energy Agency, the Institute of Economic Affairs, leading industry analysts Wood Mackenzie and 8 other financial institutions, DECC could justifiably believe that it had used ‘best available data’.
As at October 2014, the low, central and high forecasts for oil, were $90, $105 and $120 for 2014, and $89, $96 and $122 for 2015.
Three and a half months later, on Friday 23rd January 2015, Brent Crude closed at just under $49 and West Texas at under $46.
DECC also publishes yearly projections of electricity prices.
Has the Authority used the DECC forecasts or any similar projections in any financial assessment made of the operating model of the new plant?
What price scenarios have been assessed?
Will the plant’s financial model be available in the next consultation exercise?
Commercial and Industrial Waste
In the waste forecasting model, we see that NLWA’s share of business waste has fallen by nearly 40% in four years, yet this fall is forecast to be made up, and more, during the next four years:
… in 2012/13 that proportion was around 10% decreasing from 16% in 2009/10. The overall proportion was assumed to increase to approximately 20% by 2018/19 and was held constant for the remainder of the study period
Has the Authority analysed the reasons for the initial sharp fall, and what changes have been made in the present strategy which gives it confidence that it will double market share in the next four years, and retain that gain after that?
If the strategy to rebuild market share is primarily price based, what are the wider implications for other stakeholders?
Land use implications
In view of the many competing uses for land in North London, we are concerned that misguided overprovision for waste management within the sub-region endangers our ability to provide for other uses. In particular, the fact that waste management has the lavishly funded Waste Authority driving its expansion poses a danger to uses such as nature conservation which is left to find its advocacy from voluntary civil society. In particular, the submission to the new North London Waste Plan, written by the Authority’s former Director of Procurement, displays a one-sided championing of an unlimited waste land bank that discredits the Authority as a reasonable, responsible public body.
Will the Authority now withdraw the former Procurement Director’s submission from the new North London Waste Plan, which has now been superseded by the abandonment of the procurement, and to allow the evolution of a fresh approach starting with this consultation on the new Edmonton ERF?
This item was amended on 5 April 2015 by adding Stephen Brice's summary of the PWA submission to Haringey Council. The headline was amended to reflect discussion of the Edmonton incinerator
