Are we about to lock ourselves into carbon intensive waste disposal?

(c) Jenny Bates / Friends of the Earth

(c) Jenny Bates / Friends of the Earth

The recent changes in recycling and waste collection have brought waste back into the limelight in Camden. However, the decision that is likely to have the biggest impact on our ability to tackle climate change is far less visible. Tomorrow (5 April) the North London Waste Authority, of which Camden is part, will take a decision to move forward with a signficant investment in an energy-from-waste incinerator as part of the redevelopment of Edmonton Eco-Park.

Together with others, I have today written to the two local councillors (Meric Apak and Theo Blackwell) who are on the board of the North London Waste Authority asking them not to lock Camden into such a carbon-dependent route for waste disposal. The detail of that letter is below.

Waste collection might be the most visible element of dealing with our waste, but this is perhaps the most fundamental and we need to ask our representatives to change direction, right now.


We are aware that the Development Consent Order (DCO) for the redevelopment of Edmonton Eco-Park has been granted and that there is a meeting of North London Waste Authority scheduled to take place on 5 April 2017.

We have been concerned for some time that the proposed energy-from-waste incinerator represents a huge investment in what is, to a large extent, a fossil fuel powered plant ( Significant proportions of the waste stream that are plastics (13%) and paper and card (22%). The proportion of energy derived from plastic will be higher that this percentage. Plastic of course is a fossil fuel and should not be considered a renewable energy source. Future policy measures eg a levy on non-returnable plastic bottles could drastically change the proportion of plastic in residual waste and thus jeopardise the efficiency and economics of EFW.)

This will lock North London in to a carbon-dependent route for waste disposal up to and beyond 2050, by which time many local authorities are committed to being “Zero Carbon”. If we are to meet our Paris Climate Treaty obligations, then there is no room for building new high-carbon infrastructure.

We raised this issue in previous consultations and asked for NLWA to attend a public forum where the carbon impacts of the proposed development could be debated, and compared to other routes which might be considered lower carbon.

Regrettably NLWA refused to attend any public forum to discuss this. The carbon modelling report which was produced compared emissions from the EfW plant with land-filling all waste or exporting it as solid fuel. There was – to our knowledge – no comparative carbon modelling of an alternative route involving further recycling, Anaerobic Digestion and MBT, although this route was considered in NLWA documents to meet environmental criteria. Gas produced from AD would be a genuinely renewable fuel and could power a nearby district heating system.

We are also concerned that there are a number of points, including ones raised previously by the GLA in the Planning Team’s assessment and Statement of Common Ground on the developer’s proposals that were not addressed in the Planning Inspector’s assessment, nor seemingly considered by the Secretary of State at DBEIS in the consideration and granting of the DCO.

In our view, there are three issues in particular that raise questions about compliance of the proposed scheme with GLA waste and planning policy and therefore the next steps for NLWA, namely that:

1.    The choice of technology (waste incineration with potential partial future heat network offtake) is out of step with Mayoral policy and technology best practice.

2.    The facility is oversized, meaning that waste will need to be sourced to continue to feed such a large installation and that this will compete against Mayoral ambition on the circular economy and improvement of recycling rates.

3.    At this stage in the development process, the nature of the heat network offtake remains unclear. The applicant has still not determined the size of steam turbines to provide heat to the network, meaning that a robust assessment against the Carbon Intensity Floor cannot be undertaken.

A more detailed supporting explanation for these concerns is appended to this letter.

We recognise that it is late in the day, but we ask the NLWA board members to pause, before committing to huge commercial decisions, and ask whether this is really the best investment for London and the climate. At the very least, the Board should instruct the Authority to model and AD-and-MBT based approach hold a public forum where full carbon modelling can be aired and debated.

We hope that before a point of no return is reached, that for the benefit of all Londoners, that there is serious consideration of the long-term technology and carbon lock-in of such a significant development.

Detailed Comments on Key Issues

1)    Technology Choice

North London Waste Authority’s latest update for their meeting on 5 April suggests that there should be no further debate on the choice of technology for the plant, as this was covered in previous consultation exercises. For the reasons set out below, we do not consider this to be the case. There are important guidelines, in particular on carbon intensity of the currently proposed facility that have not been fully addressed. In our view, if these cannot be satisfactorily delivered by the currently proposed technology choice, then alternatives should be considered.

We note that the applicants own assessment of MBT/AD treatment of waste passed the applicants own environmental testing criteria, but were ruled out due to economic considerations, which were in part based on the attractiveness of heat network offtake enforced through the Lee Valley OAPF.

We also note that the applicants own waste composition figures (NLWA 2009 waste composition), taken from the WRATE and Carbon Intensity Floor modelling: Technical Report (REP005, Issue 3) show that there are significant proportions of the waste stream that are plastics (13%) and paper and card (22%). Plastic of course is a fossil fuel and should not be considered a renewable energy source.

Future policy measures eg a tax on non-returnable plastic bottles could drastically change the proportion of plastic in residual waste and thus jeopardise the efficiency and economics of EFW. While we acknowledge that balancing the calorific value of the waste stream in order to facilitate the incineration process is important, we also feel that more could be done to treat or separate the waste stream on the EcoPark and that by doing this the size of the incineration facility could be reduced and alternative technologies enabled that are more in line with the Mayor’s environmental ambitions and waste strategy.

2)    Facility Size and London Recycling Rates

Recycling rates in London have flattened out and are slowly decreasing in recent years (see data below)

The building of such a large ERF facility (one of the largest in Europe)is likely to compete against Mayoral ambition to raise the recycling rate across London to 65% by 2030. We believe that more can and should be done to extract recyclable components from the waste stream. Prior to the granting of the DCO for the North London Waste facility, GLA indicated that they would like to see further proposals from the applicants around recycling and pre-treatment. We would welcome an update on whether it is now considered that these are in place.

The GLA’s Planning Report of March 2016 noted that:

3)    Heat Network Offtake and Carbon Intensity Floor

The GLA Planning Report of 22 March 2016, stated that  the carbon intensity floor policy (CIF) required by policy 5.17/paragraph 5.85 [of the London Plan] can only be achieved if the ERF’s heat capacity and offtake is secured

In spite of the granting of the DCO, there still remain considerable uncertainties about the nature, timing and sizing of the heat offtake element of the ERF facility. Previous modelling had shown that requirements around CIF levels could be met by the facility, but as above, that these would be dependent on appropriate levels of heat offtake.  The scheme operator/applicant has stated that procurement of steam turbines will be demand led, but uncertainty around the nature of this means that a CIF assessment of what is actually planned is difficult.

We also note that Government guidance on energy generation displaced  by the facility (and therefore the level of CIF) may be refined and that this would drive CIF levels down further, well before 2025. We note that the London Plan is due to be revised in 2017 and that the Government Guidance (DECC, now DBEIS) on marginal generation emissions factors already sets values below the 0.4 level set for CIF by 2025. We also note the GLA’s previous commitment to revise CIF in line with changing Government guidance.

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