Statement from Stop The Edmonton Incinerator Now on 20 October 2019 in response to the NLWA’s statement of 15 October 2019 claiming that the ‘carbon impact of 2 million Londoners could increase if waste facility not replaced.

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First, we are delighted that the NLWA has released a public statement to make the case for the proposed new incinerator: in our prior exchanges with the NLWA, its position was that the new incinerator was a done deal. We are confident that the release of this statement is indicative of an erosion of the consensus within the NLWA in favour of the proposed incinerator.

Moreover, it is striking that the NLWA are now seeking to justify the proposed new incinerator in the context of the climate emergency. This is surely a sign that the NLWA are listening to our concerns as we have been arguing that the proposed new incinerator goes against climate stabilisation and net zero goals. We thank the NLWA for their responsiveness.

Our views are diametrically opposed to those of the NLWA, and our position is that a new incinerator, that would emit greenhouse gases and lock us into the so-called ‘linear’ economy (as opposed to the ‘circular economy’), goes against the Government’s amendments to the Climate Change Act mandating net zero emissions by 2050, as well as against recent new recycling and waste prevention targets and legislation (for example, as most recently set out in the Environment Bill).

Italicised below are the NLWA’s statements, with our position below each statement.

Failure to replace an ageing incinerator in North London with a new energy recovery facility could lead to the same carbon impact as adding 110,000 cars on the road every year, according to a new expert analysis.

The work by engineering consultants Ramboll, which assessed the carbon impact of the new plant in Edmonton, found it will save the equivalent of 215,000 tonnes of carbon dioxide every year – like adding 110,000 cars to the road, compared to the alternative of sending the same amount of waste to landfill.

The new facility is part of the overall drive towards Net Zero by generating up to 78 megawatts of low carbon energy in the form of heat and power, displacing the need for virgin fossil fuel generated power like gas and coal.

Note that we have not yet seen the Ramboll study. However, there are three very important points to make:

First, the extent to which incineration can be deemed a GHG emission saver depends on the carbon intensity of the energy it displaces- it may produce fewer GHGs compared to the energy grid today, but with plans to fully decarbonise the energy grid by 2050 (a target that is likely to be brought forward in the next 30 years, with the Labour party for example committing to net zero by 2030), it will be the case that in the short-term future, energy from incinerators will more carbon intense that the median carbon intensity of the energy grid. Far form ‘displacing the need for virgin fossil fuel generated power like gas and coal’, it will be one of the more polluting energy sources of an energy mix rich in renewables like solar or wind power, whose carbon intensity has been estimated to be 23 times lower than the carbon intensity of incinerator generated energy.[ii] The proposed new incinerator will likely be operational until 2075, 25 years after the net zero target.

Second, it is worth noting that estimates of emissions saved- or generated- through incinerators to not account for displaced emissions generated in the production of new goods, that could instead have been reused or recycled. Inasmuch as much of the ‘waste’ burnt in incinerators is actually preventable, reusable or recyclable, the carbon intensity of the generated energy is underestimated. A true estimate would require a full consequential lifecycle assessment, accounting for ‘unnecessary’ extraction, manufacture, transport etc of resources burnt in the incinerator.

This is what Sandy Martin MP, Shadow Waste Minister (of the same political party of the Labour controlled NLWA) has to say about the issue of energy from incinerators: ‘One of the most disappointing points of the strategy is that it continues to support incineration. “Energy from Waste” is a form of deception – even high calorific plastic is 7 times less efficient as a “fuel” than the fossil fuels it is made from would have been if they had been used to generate electricity directly. Everything going into an incinerator represents far more embedded energy than can be recovered by burning it. For many materials, including plastics, much of that energy can be saved if it is recycled.’ [iii]

Third, while the car comparison is striking, it only holds true while cars emit a certain amount of pollution. While there are targets for the full decarbonisation of cars, with targets for electric cars as early as 2040, 35 or before set by the Government and Labour Party, the proposed new incinerator will in the short-term future be more polluting than transport- not so much ‘removing’ cars from roads but ‘adding’ them.

Plans show North London Waste Authority (NLWA) are incorporating the best available technology for removing NOx from their emissions to help improve air quality in north London.

This sentence seems to imply that BAT for NoX removal is not currently being applied. As concerned local residents,  we would welcome immediate confirmation that the current incinerator poses no risk to public health.  

We further note that despite due regards for pollutant minimisation, pollution limits do get breached with the current incinerator, which should not give us undue confidence that limits will never be breached with the proposed new incinerator. For example, in 2018, as per London Energy Ltd report under the Industrial Emissions Directive Article 55 (2), the monthly daily mean for NOx exceeded the Daily NOx Emissions Limit Value (ELV). Looking forward, it is our understanding that new road vehicles will be expected to achieve zero emissions- and yet the proposed incinerator will be pumping out 328 tons/ year (according the Appendix 1, Volume 2 of the Environmental Statement). Regarding other pollutants, in August 2018 the release of Hydrogen chloride spiked above the ELV.

Further, the release of particulate matter (PM) through incinerator plumes continues to be a cause for grave concern. It was estimated that a staggering 11.3 tonnes of particulate matter was released by the current incinerator last year- this is an absolutely vast quantity, given their size.[iv]This is what DEFRA have to say about particulate matter: ‘Exposure to airborne PM is associated with a range of adverse effects on human health including effects on the respiratory and cardiovascular systems, leading to hospital admissions and mortality. There is increasing evidence that fine (PM2.5) and ultrafine (PM0.1) particulate matter plays a more significant role than previously thought’.[v] We would welcome an estimated projection by the NLWA of PM to be released year-on-year by the proposed new incinerator.

It is very hard to argue that the proposed new incinerator will do anything other than degrade air quality in North London rather than improve it.

This solution mirrors countries in Germany and Belgium who are renowned for clean and modern facilities which treat waste in a sustainable way, while recycling over 50%.

Current UK recycling targets are 60% by 2030, 65% recycling rates by 2035. The Mayor of London’s target is 65% by 2030. [vi]

Cllr Clyde Loakes, Chair of NLWA says “Failure to build the new facility could result in 700,000 tonnes of our residents’ rubbish going to landfill each year, which would generate the equivalent of an extra 215,000 tonnes of carbon dioxide, the same pollution as putting an extra 110,000 cars on the road. That’s more than every householders’ car in Waltham Forest.

“Dumping rubbish in landfill would also mean thousands more journeys by bin lorries travelling to the landfill site outside London, congesting roads and emitting more pollution.”

As Cllr Loakes is aware with his pioneering Mini Holland scheme, the best way to get cars off the road is to build safe cycle lanes and pedestrian facilities – not building an incinerator!

The Government’s advisers, the Committee for Climate Change is clear there needs to be four times the amount of low carbon power options in the UK to achieve Net Zero.  Modern waste facilities are fully compatible with this. 

The carbon intensity of energy generated from incinerators depends on the composition of waste, especially its plastic content. As mentioned earlier, estimates suggest that with the current waste mix, the carbon intensity of incinerators is comparable to fossil fuels, and 23 times more carbon intense than solar or wind. We have requested from the NLWA year-on-year estimates until 2075 of wastes volumes burnt; emissions generated; energy generated; energy intensity of the energy generated; planned median intensity of the energy grid as we transition towards net zero emissions. Unfortunately, we have not yet received this data.

NWLA looked into the options for dealing with the waste left after recycling and consulted residents on their findings. It was agreed replacing the facility at Edmonton with a brand-new Energy Recovery Facility was the most environmentally beneficial way to deal with the waste.

Despite our requests to the NLWA, we have not seen a comprehensive analysis of the alternatives that were considered. The consultation with residents was minimal and confined to residents living near the proposed incinerator. To our knowledge, no residents outside of Enfield or Waltham Forest were consulted at all, despite the fact the wastes of Hackney, Islington, Camden, Brent, Haringey end up burnt. We also understand the decision was taken prior to the declaration of the climate emergency and the net zero targets.

The carbon analysis confirms the North London Heat and Power Project is crucial to tackling the Climate Emergency declared by the six of north London’s boroughs which make up the NLWA.

The alternative of sending waste to landfill, would cost taxpayers more each year, result in thousands of extra bin-lorry journeys to landfill sites, and be extremely damaging to the environment.

We welcome the declarations of a Climate Emergency across the North London boroughs.

Regarding the alternative of sending waste to landfill, it worth noting that the policy consensus that landfill is environmentally worse than incineration no longer holds, in the context of the immediate imperative of reducing GHGs. Burning wastes, especially plastics, releases GHGs into the atmosphere immediately, something that does not happen in well-managed landfill. The carbon emissions impact of transport will also decline as transport is decarbonised as set out in government targets. We are not advocating for landfill, as we believe efforts must be focused on waste prevention and recycling but are instead suggesting that the NLWA cannot make a climate change argument for incineration over landfill.

Prof Sir Ian Boyd, DEFRA Chief Scientific Advisor said the following to the EFRA Committee of the House of Commons in January 2018: ‘I want to make a more general point about incinerators. If there is one way of quickly extinguishing the value in a material, it is to stick it in an incinerator and burn it. It may give you energy out at the end of the day, but some of those materials, even if they are plastics, with a little ingenuity, can be given more positive value. One thing that worries me is that we are taking these materials, we are putting them in incinerators, we are losing them for ever and we are creating carbon dioxide out of them, which is not a great thing. We could be long-term storing them until we have the innovative technologies to reuse them and turn them into something that is more positively valued. This brings me to a more general point about landfill. Quite rightly, we have had a policy of trying to eliminate landfill in this country, because it has been seen as a major source of greenhouse gas pollution and, to some extent, groundwater pollution. That is because we put biodegradable organics in—food waste, garden waste and things like that. Landfill is a very low-marginal-cost method for storing highly resistant materials like plastics and metals for long periods of time, if we cannot extract the value from them now. This is one caveat I would put around the current direction of travel on landfill. We should not lose sight of the fact that, in a few decades’ time, or maybe a bit longer, we might be mining our landfill sites for the resources they contain. Rather than putting some of those resources into incinerators and losing them for ever, we might want to think differently about the landfill sites.[vii]

Reducing waste is the best way to stop the emissions associated with treating waste. However, anything other than replacing the current facility will have severe consequences for the environment, the Climate Emergency and reaching Net Zero carbon emissions.

We agree with the NLWA that the best approach to waste management is waste prevention, followed by waste recycling. We would prefer to see the considerable public funds committed to the proposed new incinerator, which we understand will be funded through council taxes, go to waste prevention and recycling instead. We would also welcome an update of the projected cost of the proposed incinerator and have been dismayed the NLWA ha hitherto been unable to provide us with an estimate, including how these costs will affect council tax.   Moreover, we believe that waste prevention, recycling activities and the transition to a circular economy (which the NLWA supports) could support the creation of good, ongoing local jobs and business opportunities. To our knowledge, the NLWA has not conducted an analysis of the local wealth and job creation potential of concentrating efforts on waste prevention and recycling over waste management.