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The question before north London’s councils is: Will the decision to reverse course be taken now, responsibly, before costs skyrocket, opportunities for a green recovery are lost, and the equivalent of 250,000 diesel cars are added to our roads? Or will the decision be pushed off to the near future? That’s the real call being made.

Environmental campaigners have issued a challenge to the seven borough councils that are funding the North London Heat and Power Project - the construction of a new and larger incinerator to replace the existing facility in Edmonton.

A new article posted on the Stop the Edmonton Incinerator repeats an earlier call for the North London Waste Authority and the councils behind it to pause and review the incinerator project. The campaign's objections to the incinerator are primarily based on the fact that it is designed to emit 700,000 tonnes of carbon dioxide per annum for fifty years, which they see as totally incompatible with the urgent need to reduce greenhouse gas emissions to zero, in order to prevent catastrophic climate change.

However, this particular article concentrates on the financial risks associated with going ahead without reviewing the project. The campaigners argue that there is sufficient time and list a number of reasons, aside from environmental considerations, why the boroughs should do so. And they issue a challenge to councillors:

One north London council could lead the way. One council may be able to set the tone for the new Strategy. By being the first council to reevaluate the Edmonton incinerator plans, that council could potentially persuade the other north London councils to follow suit. This move could be seen—and remembered—as bold and far-sighted.

We have enough time for pause & review of the new Edmonton incinerator

stop the edmonton incineratorThe following information demonstrates that there is indeed sufficient time—in addition to an urgent need—to pause and review the plans for a new energy-from-waste (EfW) incinerator in Edmonton. These points focus on timing, financial impacts, and related considerations. They do not include details on carbon emissions, pollution, health impacts, overcapacity, or other reasons to review the plans, which are covered elsewhere.

  • No construction contract until mid-2022. The North London Waste Authority (NLWA) has selected three (international) bidders and plans to award the contract to build the incinerator itself in Q2 of 2022. Contract execution is to begin at the start of Q3 2022, following a month-long pause (see page 26 of this NLWA tender presentation, which is also pasted below). That means the seven north London councils have a significant window to pause and review the current plans and put the most appropriate solution in place. Ideally, the councils will withdraw support for the incinerator before the contract is signed, in part to avoid the cancellation fee in the contract. Such fees tend to be substantial and typically increase over time (the later the cancellation, the higher the fee).
  • Limited sunk costs to date. At the end of March 2020, the NLWA had entered into contracts totalling just under £23 million on the Edmonton site (see page 25, Section 6: Capital commitments, of the NLWA’s statement of accounts for the year ended 31 March 2020). The majority of these works are necessary regardless of which type of waste management plant is to be established there, including works related to access, sewerage, and the EcoPark area. Similarly, the £100 million resource recovery facility, which is already under construction, is required regardless of whether an incinerator is built.
  • Sunk costs can be written off. Councils will be able to write off a portion of lost costs, even if that process is cumbersome and affects council budgets. Any resulting reduction in a budget is sure to be far smaller than the massive budget spend that would be caused by a stranded asset down the road—the consequence of building an incinerator whose capacity far exceeds the current amount of residual (non-recyclable) waste, while expecting rapid growth in recycling rates, which will significantly slash waste treatment needs in north London (and beyond). Budget concerns are not a reason to ignore the need for a pause and review; in fact, they are a reason for a pause and review. Moreover, fears about the current budget should not outweigh responsible, long-term decision-making.
  • Don’t throw more good money after bad. If the incinerator plans are reconsidered and deemed incompatible with the climate and ecological emergency and associated imperatives, or unjustifiable in the light of developments that have taken shape since the plans were drawn up in 2015, then surely the approach should be to stop throwing more money at it and move on with plans that are compatible with the climate and ecological emergency.
  • The new incinerator itself would be a sunk cost if built. The NLWA estimates that the construction of the incinerator itself will cost £600 million, while associated land purchase, utility, and relocation costs, together with risk contingencies, account for an additional £350 million. Given that the plant would be a stranded asset well before the end of its operational life of at least 50 years, these expenses themselves would effectively be sunk costs if the north London councils are serious about achieving 2030 recycling targets. Since the plant is oversized, at least 50% and probably 85% of its capacity would not be used over its lifetime.
  • The current incinerator is operational until 2027. Given that London will have surplus EfW capacity even if the new Edmonton incinerator is not built, as confirmed by the Mayor’s office (evidence available), and that the councils have legal, practical, and financial reasons to get serious about meeting municipal and national recycling and waste reduction targets by 2030, there is plenty of time to draw up realistic waste management plans that do not involve a new incinerator and that provide solutions for treating north London’s drastically reduced amount of residual waste once the current incinerator is decommissioned. The long-overdue Joint Waste Strategy (JWS), drawn up by the NLWA and its seven constituent councils, is the perfect vehicle for such analysis. The now expired extant JWS was drawn up in a different era, for a different era.
  • Funding. Funding to date has not come through PFI but rather from the Public Works Loan Board (PWLB), which does not get involved in how the money is spent. PWLB funding so far is relatively small and would certainly be dwarfed by the much larger financing required to actually build the plant.
  • One north London council could lead the way. One council may be able to set the tone for the new Strategy. By being the first council to reevaluate the Edmonton incinerator plans, that council could potentially persuade the other north London councils to follow suit. This move could be seen—and remembered—as bold and far-sighted.
  • Pending decisions also require a pause. The following decisions, among others, may have an impact on the viability of EfW incineration, which could have serious financial implications for the councils and taxpayers of north London:
    • UK ETS. A favourable decision in Georgia Elliott-Smith’s legal case against BEIS regarding the exclusion of EfW emissions from the UK Emissions Trading Scheme (which came into force post-Brexit) could very well cause a significant increase in the cost of EfW incineration. The court date is set for April; more details are available here.
    • CO2 tax. If the Government decides to impose a carbon tax, the cost of EfW incineration would increase considerably.
    • COP26. The outcome of the international conference could affect the UK’s overall approach to counting and costing carbon emissions from EfW incineration.
  • Future risk. In view of climate and temperature forecasts, it is difficult to envisage that burning waste - with all its CO2 implications - will be politically acceptable in the not-so-distant future, and certainly not in 2050 (when the incinerator would be only halfway through its operational life). A decision to proceed now would thus place a burden on decision-makers in the not-so-distant future to take a decision to reverse matters, at a time when it will be far more costly to do so. Since incineration contracts stipulate minimum tonnage requirements to ensure the financial viability of the operator, going forward with plans to build the Edmonton incinerator also means agreeing to supply enough waste to keep the plant operating at capacity and emitting the corresponding greenhouse gases into the distant future. The question before north London's councils is: Will the decision to reverse course be taken now, responsibly, before costs skyrocket, opportunities for a green recovery are lost, and the equivalent of 250,000 diesel cars are added to our roads? Or will the decision be pushed off to the near future? That’s the real call being made.

Links

Stop the Edmonton Incinerator website

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Karl Brown's Avatar
Karl Brown posted a reply #5913 01 Mar 2021 16:57
Stop the planned Edmonton incinerator now or leave its required closure for someone else a few years down the line, that’s the decision at the heart of the previous posting. But if it is to be stopped, what are the implications? I've asked the related question– if not incineration, then what – a few times without answer. I don’t know but have drawn up a strawman. Apologies for length but if there are to be considerations other than simply “no incineration” then they’ll need some context.

Firstly, a look at how we got to here.

The existing 500k tpa (tonnes per annum) capacity Edmonton incinerator was deemed to be close to the end of its long life (dying by 2015 by memory) and some alternate waste disposal method was therefore required. The plan was to build a large plant on Pinkham Way to turn black bin waste (“residual”) into fuel briquettes (Solid Recoverable Fuel – SRF). It was described as “an exemplar for modern sustainable waste management”. As well as assuming waste levels would rise relentlessly year on year and so needing to be very large, it was also very costly per tonne, hugely polluting, and involved noticeable contract risk. PWA strongly opposed it, identified numerous issues and the idea ultimately collapsed, as did the wider use of SRF – SRF quickly transpired to be less an exemplar and more a historic waste management technique.

Costs relating to the failed exercise were not trivial: goodwill of circa £50m and loans of circa £100m were left on the NLWA balance sheet and much cost can be traced back to the failed plan.

Fixes were made to keep the existing incinerator operating a little longer.

Over this period pressure to reduce reliance on landfill into the shire counties and other out of London areas continued, with HMG imposing ever rising landfill taxes plus a growing reluctance of others to take London’s waste. (Our area, North London, is a bit less than a quarter of London’s total and the issue is London-wide.)

The decision taken was to burn it; build a new Edmonton. NLWA PR at the time indicated this approach could be £900m cheaper than the abandoned Pinkham Way plan.

Here it is worth noting that if a decision is made to incinerate then given the available protected land for waste management at Edmonton the chances of any other north London borough hosting an incinerator would be remote.

To divert again: Local Authority Collected Waste (LACW) is predominantly but not exclusively the household waste we are all familiar with. It makes up less than one third of North London’s total waste. A slightly smaller element is Commercial and Industrial waste (C&I). In waste management terms these two major streams are now seen as pretty much interchangeable.

At the London level the Mayor seeks to ensure, but is not responsible for London’s waste disposal. Based on an agreed formula, the apportionment, boroughs are allocated their share of London’s forecast waste levels in both LACW and C&I. The 7 boroughs of North London pool their individual apportionments into a single lump for collective management. The NLWP (“waste plan”) is there to ensure these waste streams, plus the other streams making up the other roughly one third of total waste, has enough local (land) capacity to manage it, either directly or, under the waste plan’s chosen Net Self Sufficiency strategy, on a sort of “we’ll manage some of your waste if you do the same for some of ours”, basis. That makes sense because the waste industry follows geography, centres of excellence, scale economies and such drivers rather than borough administrative boundaries.

Now things start to get interesting.

North London’s allocated apportionment is actually below its level of generated waste, some other boroughs being consequently greater. A decision not to plan at London’s apportionment level was taken by the seven councils. Instead they intended plan at a higher level of waste –and basically to do so in Enfield. Here lies one of the great mysteries of the story. Why? For example, the West London West Authority followed the apportionment route.

Nor was it to be a little: the intent was to go a full 40% on top of the then apportionment; 40% more than what London identified was required of north London as the basis to determine the capacity of the new Edmonton incinerator.

This chosen approach looks even worse in the latest London Plan, where North London’s apportionment (our local share of London’s total need) has been reduced yet further.

So there has been a decision taken by previous councils, including Enfield, perhaps particularly Enfield, to manage more waste than planning demands. I don’t know why and do not believe we should be happy given that we are collectively paying for such unnecessary capacity to be built and run. Did and does it represent value for money for Enfield’s ratepayers?

Once this not-apportionment decision was made, the actual waste forecasts made by the Mayor as part of the London Plan for use by London councils were also ignored and instead the forecasts underpinning the new Edmonton site were made by the NLWA. Racy in nature they appeared not to take into account what seemed like obvious dampers on waste growth such as housing units getting smaller and so with less space for stuff, people moving to experiences rather than stuff, the cost of materials influencing design mass and hence absolute weight of stuff, and of course climate change impacting business models generally driving less stuff. I criticised the forecast extensively at the time and elapsed time has proved that to be fully justified.


NLWA modelling of waste forecasts for the Edmonton incinerator vs actual outcome. (Vertical axis represents tonnes.)

The NLWA forecast were also taken as base figures for use in the NLWP. That particular exercise hasn’t been going too well.

The subsequent (and now latest) London Plan has an aggregate apportionment for LACW and C&I and a combined recycling target of at least 65% by 2030. That’s a mix of 75% for C&I and 50% for LACW, this latter being by 2025. Note the upside potential to do better in LACW. Large cities worldwide do occasionally hit 70%+ and I have read of 80%+ in Japan, albeit with an impossible to contemplate system of collecting boxes.

And for North London it implies a residual waste disposal need in the order of 470-490k tpa over the decade 2030-2040. (NB. Non-apportioned waste streams being ignored, the private sector deals with those.)

In the absence of any alternate, it suggests a smaller incinerator than is planned, albeit still one of scale.

Were we to achieve a 75% recycling level for LACW then a further drop off in implied capacity to about 350k tpa follows.



Now back to the strawman and in the absence of spending a few months on a comprehensive strategy formulation exercise it’s necessary to make some assumptions. For my purposes I’m going to assume:

• We will continue to generate waste;

• The existing incinerator will indeed pack up (but I will come back to that);

• There is no incineration capacity available elsewhere (but I will come back to that also)

• HMG and the shire counties do not change their position on landfill;

• C&I will be included in the position as well as LACW. This wasn’t the case in the original Edmonton consultation, it slipped in later - perhaps something was needed to fill the over-capacity - but on the basis the waste is going to be there it will need to be managed.

• The 7 boroughs and the NLWA do intend to achieve the recycling targets they have been set and include in their own planning documents;

• Heat and power is not a reason for incineration, merely one externality of waste production;

• Climate Change is not fake news, its trajectory is frightening and accelerating.

There is no societal move which will change waste overnight; we are going to be living with the stuff for some years yet. However, a huge push in areas such as the green and particularly circular economy (necessarily HMG rather than individual council driven) could see absolute waste levels drop – dramatically – and recycling levels increase – also dramatically. Given the infrastructure, process and product design such changes imply then with strong commitment these could be fully flying in let’s say 10+ years hence.

Outside of big structural changes, a much more robust recycling approach (industry and user) could be pushed in much earlier time scales; indeed post Brexit HMG is apparently reviewing waste management requirements. I see no reason why an aggressive approach over 1-5 years could not generate noticeable change. (The very long established 50% recycling target set by the North London councils themselves finally made it to about 30% after more than a decade. Did anyone notice a real sustained campaign to boost recycling? Carrots and sticks and the employment of the polluter pays principle surely bring opportunity to improve matters, quickly.

Combining shorter and longer term actions suggests that somewhere between roughly 5 and 15 years out we could have noticeably less waste and within that more recycling and therefore much less residual left to dispose of – ie burn.

Quite recent work by Arup looked specifically at the circular economy opportunity in London. In the decade 2030-2040 it saw a best case of a 60% reduction in levels of waste. Its central scenario was for a 30% reduction with the percentages increasing rapidly in the preceding years in both cases to reach these plateaus. Conversely there is no fall at all in the new incinerator’s planned capacity for decades, or ever. Having fixed capacity when the realistic expectation is of a marked reduction in your input material is a risk.

How much of this work has already been factored into the London Plan and how much could be with determination will be hugely influential on what level of residual waste follows and hence what level of core incineration is implied.

At this same sort of 10+ year’s ahead future time period it seems entirely reasonable to assume politicians can no longer refrain from implementing stringent climate mitigating actions – eg 40+ existing UK incinerators and another 100 being expected, all producing CO2 in large quantities, will come under enormous pressure if the world is burning, flooding, crops failing and so forth in line with typical climate change forecasts and our growing experiences. Instead we will be forced to change how we do things.

Now apply thinking of the widely acknowledged sage Warren Buffett who said that it’s better to be roughly right rather than precisely wrong and because the future is unknowable, it is better trying to figure out what is probable rather than making an explicit forecast.

The best I would say about 30-50 years ahead is that it will be fundamentally different to now. I certainly wouldn’t expect to see a 700k tpa incinerator anywhere and certainly not inside a city. Indeed that difference could realistically happen a lot earlier.

So pulling all this together, rather than planning for capacity plus more being fixed over an expected 50 year life, we are instead looking at a bridging situation of only doing what we need to do until we need to - or are otherwise able to - reduce incineration and then most likely stop it. How long away that inflexion point is then becomes key – 5, 10, 20 or 25 years hence. Over that same period it seems realistic to assume ever more recycling of ever less waste, hence, and once mitigating activity starts to bite, a reducing level of residual waste to burn.

That in turn implies a required small(er) core of incineration capacity with flexibility around it to expand it (for the shorter term) and decrease it (for the medium / longer term) - as well as potentially stopping it altogether (medium / long term) without breaking the bank. And it may be that flexible element is able to be found elsewhere, eg:

• Germany / Netherlands, area where feedstock has been previously sought

• Other London (where I have read sufficient capacity will exist)

This core capacity, noticeably smaller than the 700k tpa being planned, might be salvageable from a temporarily extended section of the existing Edmonton plant. Doubtless a relatively expensive refit of part of an old plant but also very likely going to be so much cheaper than building long term new plant of massive scale. Much will be dependent on the expectation of the inflexion point - many scientists seem to suggest its now.

Note further on the matter of flexibility, the plans for Edmonton are based on two lines of 350,000 tonnes each. There is very little flexibility in that – nothing, 350k tpa or 700k tpa. The existing plant by comparison has five lines.

So there’s the outline of a strawman: we do carry on incinerating but only as part of a green / circular economy plan to hugely reduce it and perhaps ultimately stop it.

The actual strategy steering the boroughs and NLWA, the Joint Waste Strategy (JWS), was first set in 2004, a long time ago when the waste world was certainly different. It expired last year meaning a fresh start is required on a new one.

I’ve also said on several occasions that the contradictions in the very long running NLWP as ever more convoluted efforts are made to manipulate a route in for the otherwise stranded Pinkham Way site, purchased at above market price for a long since unsuccessful plan, will see this it finally fail, most likely this year. That’s an even longer post – best we simply wait and see if I know what I’m talking about.

So here are three orbits all now coming together– a new JWS, a new NLWP, and a pause and reflect of incineration - all interlinked, all dependent one on the other and all on the face of it needing serious work to provide a robust, evidence based and ideally community supporting solution to north London’s waste.

In the 80’ and 90’s there was a phrase, no one got sacked for ordering big blue (IBM). It reflected a no / little personal risk approach by a CEO – frequently a more expensive, too large solution was taken but it followed the herd, it was the route of the easy decision and the pension was safe. With Edmonton I see what is a low risk and non-innovative approach; one following the herd. The parallels with the earlier failed Pinkham Way plan of inflated forecasting, extra capacity, huge long term plant and massive expense are troubling. Pausing and reflecting whether to make this second colossal spend given the real risks associated with the changes since 2015 or thereabouts when the plans were first developed does have a sensible ring to it.

An associated strategy formulation worth its name would also be looking at human resource – leadership and management in particular. Wherever I look, be it the never delivered NLWP, an incinerator set to meet North London’s needs but rapidly of too large a scale for that need, Pinkham Way problems, significant wasted capital, failed targets and more, I don’t see any glowing references falling from this last decade.

But even under this possible scenario of a marked tail off in waste, and residual waste in particular, it will not all disappear which merely gets us back to the original question – if not incineration, then what? UKWIN have looked at the matter and may have answers. Perhaps when levels are quite small landfill does becomes a valid option, or we simply live a life not measured by our levels of stuff and driven by the R’s such as Reduce, Repair, Reuse, Remake, Recycle, Recover.

But 700k tpa capacity looks more and more like it needs rethink with every passing day. If the background intent has always been to support other London and the wider south east that’s a strange secret to keep and a highly unwelcome burden on the residents of Enfield and Chingford.
Karl Brown's Avatar
Karl Brown posted a reply #5922 07 Mar 2021 09:25
A Minimum Guaranteed Tonnage (MGT) is the commitment we will make to the tender-winning operator of a new Edmonton incinerator. Problem is it then needs to be delivered: up to 700k tpa for 30 plus years. When there’s not enough local black bin waste, waste is needed to be shipped in from elsewhere (already assumed for Edmonton) and then blue bin recycling is used to make up the shortfall. This was one of the huge risks identified with NLWA’s failed Pinkham Way project,
Dispatches on Channel4 at 8pm Monday 8 March will explore this phenomena, "Dirty Truth About Your Rubbish". They find a direct correlation between incineration contracts and low recycling outcomes.
This week the Welsh government put a moratorium on new incinerators; last month the business secretary refused permission for a new incinerator including because it would cannibalise recycling; while London’s Mayor refused the last incinerator application before him.
Is a 50 year, £1billion plus commitment to Edmonton a sensible move by the NLWA in the current and expected waste-world? Surely time for a pause and an objective review - while there still is time.