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artists impression of the planned new edmonton incineratorDr Dominic Hogg says that the planned new Edmonton incinerator will be "environmentally disastrous"

If we really think that by burning waste, and thereby emitting more or less all the carbon content of that waste as CO2, that we are doing ‘something green’, then we really are in deep, deep trouble.

Dr Dominic Hogg, 15 April 2022

As part of their continuing efforts to reverse the decision to go ahead with construction of a huge new waste incinerator in Edmonton, the Stop the Edmonton Incinerator campaign have issued a press release drawing on new analysis by environmental and waste consultant Dr Dominic Hogg. Dr Hogg's analysis further undermines the environmental case that the North London Waste Authority (NLWA) has been setting out in support of this expensive and "environmentally disastrous" project.

If the new incinerator, or "energy from waste facility", is built, it will provide useful heat and electrical power, but a downside of incineration is what comes out of the chimney. While the new plant is designed to have better filtration than the current, 50-year old, incinerator, it will still pollute the air with microscopic particulate matter, capable of penetrating both lungs and brain, creating a health hazard for people downwind of its "plume" - in other words a large area of north and north-east London.

Just as important, and from an environmental perspective a key consideration, is its contribution to climate change. When waste is burnt, the carbon it contains combines with oxygen in the air to form the "greenhouse gas" carbon dioxide (CO2). For every tonne of waste that is incinerated approximately one tonne (and sometimes more) of CO2 goes into the atmosphere, where it will remain, adding to global heating which, increasingly rapidly, is making parts of the earth uninhabitable (check out temperatures in China and India this week, if you doubt this).

In order to justify the claim that a new incinerator is "green", the NLWA relies on data that Dr Hogg, and before him other experts, consider to be based on flaws in the methodology used to calculate greenhouse gas emissions from incinerators and one of the alternatives, landfill; and on seriously outdated data about how much carbon dioxide alternative sources of heat and power would emit (their "carbon intensity").

The nub of the carbon intensity issue is that the NLWA is using data about the carbon intensity of alternative types of power generation dating from 2013, while over the past nine years the average carbon intensity of power generation has been falling much faster than previously anticipated, as wind and solar power capacity has been added and coal-fired power stations have been all but completely phased out. And even gas-fired power stations (which have to be phased out too) are much less carbon intensive than incineration.

Dr Hogg says that the figures that the NLWA uses to compare greenhouse gas emissions from incinerators with those from landfill are seriously flawed, concluding that landill actually produces less, not more, CO2 than incineration. However, in his view, both alternatives should be last resorts - increased recycling is the way forward. This can be achieved in two ways: improving sorting of waste by households; and building a modern pre-sorting facility at the Edmonton "Eco-park" - such facilities are able to take in mixed waste and separate out reusable materials, including fossil-derived plastics, so that they are not wasted by being burnt or buried.

Press release issued by the Stop the Edmonton Incinerator Campaign on 19th April


  • New analysis demonstrates CO2 from waste incinerator at least twice as bad for climate as landfill
  • ‘Devastating takedown’ of North London Waste Authority (NLWA) as deceptive or inept
  • NLWA ‘should have’ installed ‘pre-sorting’ facility to cut climate impact, extract plastics, boost recycling
  • Investors warned to ‘steer clear’ of Edmonton incinerator ‘green bonds’, which are ‘simply not green’
  • UK Treasury, UK Municipal Bonds Agency advised not to issue any bonds for waste incinerators

London, 19 April 2022—A new report demonstrates that the North London Waste Authority has been using inaccurate carbon emission figures to misrepresent the planned waste incinerator in Edmonton as ‘part of the climate solution’ and capable of ‘saving’ more than 200,000 tonnes of CO2 per year compared to landfill.

The report, authored by established waste sector expert Dr Dominic Hogg, was released just two weeks after the UN’s climate scientists warned that ‘it’s now or never’ in that CO2 emissions must decline by 2025 to avoid dangerous climate change. Dr Hogg’s analysis debunks NLWA claims by revealing that sending waste to the planned incinerator would actually be far worse for the climate than landfilling it.

‘The net emissions from incineration are double those of landfill,’ finds Dr Hogg. He also shows that the Edmonton incinerator’s climate impact would increase over the years: ‘by the time the facility nears the end of its life, its net emissions may be 3.7 times the emissions that would be generated by landfilling the same waste’.

NLWA’s attempts to present landfill as the only alternative to burning waste is similarly greenwash. In one of its own 2021 assessments, NLWA shows that north London’s non-recyclable waste would be sent for incineration elsewhere in London if the Edmonton plant remained unbuilt. Indeed, the Mayor’s forecast indicates that London will have 250,000 tonnes of surplus incineration capacity if recycling targets are met and the Edmonton plant is not built (overcapacity would swell to 950,000 tonnes if it is built).

In analysing the data used by NLWA, which is based on calculations undertaken by the consultancy Ramboll, Dr Hogg identified a methodological flaw in the way the landfill was assessed, and a failure to update a 2013 figure for the avoided carbon intensity associated with power generation. He concludes that the use of a 2013 figure for an incinerator that is not expected to be operational until 2026 or later ‘is either grossly misleading or reflects a failure to understand what is happening to the UK power generation system’, since the grid alternative is decarbonising rapidly.

Dr Hogg also slams the UK Municipal Bonds Agency (UKMBA) for planning to issue ‘green bonds’ to finance the Edmonton plant. He advises green investors to ‘steer clear of the UKMBA’s debut green bond’ as it is ‘simply not green’ and ‘should not have passed scrutiny by UKMBA’. He adds: ‘The issuance’s inclusion of the Edmonton facility undermines the credibility of the UKMBA’s green bonds, and is particularly damaging since this is the UKMBA’s debut green issue.’

The critique extends beyond the Edmonton plant. Dr Hogg writes: ‘The HM Treasury and UK Government Debt Management Office and the UKMBA should cease any bond issues in support of energy from waste incineration. They should then align their approaches with the view developed under the aegis of the official UK taxonomy’ of sustainable finance activities.

Dr Hogg’s analysis of NLWA data comes after years of campaigning against the planned incinerator, and multiple attemps by Extinction Rebellion and others to prove that the NLWA CO2 figures are invalid. Given that he has more than 30 years of experience campaigning and consulting on environmental issues, his intervention will be difficult to dismiss.

On Twitter, one campaigner called Dr Hogg’s report a ‘devastating takedown of the NLWA incinerator plan’, noting that the £800 million ‘environmentally disastrous’ incinerator project was ‘massively worse’ than councillors who supported it had been told.

This news comes on the heels of the Government’s proposal to halve non-recyclable waste by 2042 (compared to 2019 levels), which corresponds to a recycling rate of 70%–75%. The proposal has already led to calls for two waste incineration projects to be halted – in Dorset and Wiltshire – amid predictions that considerably less waste will be available for incineration. The target is expected to become law by the autumn and will further weaken the basis on which NLWA is building the Edmonton incinerator.


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Karl Brown posted a reply
28 Apr 2022 22:02
Yes, burning waste really can’t be “green”. That said, the EU and UK deemed it better than landfill and are taxing the latter ever more heavily – facilitating fly tipping it seems in so doing - to make incineration the chosen route for residual waste. The NLWA followed that lead.
The statement that there is sufficient incineration capacity within London to meet London’s need is interesting: under London’s net self-sufficiency (NSS) strategy, logic would say if there is enough capacity somewhere then use it / don’t build more. London’s NSS is based on aggregate waste so that a surplus in one waste management type can effectively “offset” a deficit in another. So, someone burns our waste, we process their scrap cars, sort of thing. (Waste miles and actual transport viability of the waste ignored.) If followed across the UK this approach would minimize unnecessary waste management sites / capacity.
North London also has a NSS strategy but here it is not aggregated across all waste types, instead it applies to individual waste types; it is effectively self-sufficiency in intent for each waste type rather than NSS. NLWA have always had a concern that they will not have sufficient capacity to deal with residual waste, hence build your own, and build it very big to remove any risk of going short. It’s not representative of strong management and should fail under a Duty to Cooperate requirement.
But if incinerating our waste elsewhere in London is not practicable neither is landfill likely to be a solution. Non-London counties have been clear they neither want it nor have space for London’s residual waste. No surprises there. So where would we have our landfill site(s)? With the push back we have seen on housing plans on the green belt I imagine plans to bury old mattresses, kids toys, broken plates, used nappies and such in the north of the borough will be less than welcome. I may be wrong.
Yet, “increased recycling is the way forward” isn’t something I would support. Recycling, with its costs of transport, processing and rebuilding into something else is better than landfill or incineration but there are higher levels of the waste hierarchy which are even better, such as reuse, but best of all is not to generate stuff in the first place – fast fashion and equivalent themes spring to mind. Then the embedded carbon doesn’t happen and there is no end waste to get rid of. But that’s a fundamental change in our society, including the inevitable end of neoliberalism and its market driven everything. We shouldn’t be deceived, recycling isn’t the answer and its not up to “us” to provide the solution, this is a government / Big Co issue to address.
In the meantime I’ve yet to see a solution better than accepting what we have placed on a clear reducing trajectory for a decade or so while the big picture gets sorted.