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									To the Waltham Forest Cabinet and Councillors Residents Against Pollution – a statement of our concerns
Introduction In January 2008, around twenty Waltham Forest residents participated in a consultation workshop on the North London Waste Plan. A number of us were from the Blackhorse Lane area, and were so concerned by what we learned, that we decided to establish ourselves as a local campaign group. We leafleted and knocked on doors on just a few streets in the Blackhorse Lane area, and organised a meeting in February of forty local residents, to which we invited the North London Waste Plan consultants. We understand that seven London boroughs are proposing a new plan for waste disposal in North London and different sites are being looked at to build new waste facilities. Of the six potential new sites proposed, four are along the Lea Valley: two of these are in Waltham Forest, including the Blackhorse Lane industrial estate, and a third site borders on Waltham Forest. However, the Lea Valley already bears the brunt of waste disposal in North London (see attached maps from the consultation “Issues and Options” document, http://www.nlwp.net/downloads/NLWP%20Issues%20&%20Options%20report.pdf ; pg26 „Map 1 Existing Waste Facilities Located in North London’; pg36 „Map 2 Strategic Employment Locations in North London Suitable for Recycling and WasteTreatment as Identified in the Early Alterations to the London Plan [Table 4A.7]’ ). We know at the moment that “nothing is ruled in and nothing is ruled out” regarding the type of waste disposal facilities. We know that the council has made a commitment to improve recycling. However, we also know that there is a national turn towards incineration (euphemistically called “Energy from Waste [EfW]”) instead of landfill. We therefore believe that, unless we campaign now to stop it, the new plans are likely to include either a new incinerator in North London or an expansion of the Edm onton incinerator (or both). We are aware that this is the beginning of a two-year process and that no decisions have yet been made. However, we do not wish to have our genuine concerns dismissed on the basis that “nothing has been decided”. Our point is that we want our concerns to be heard and taken into account before the decision is made. Local residents must be part of the decision-making process. We have also become aware that, separate to the North London Waste Plan, decisions have been made regarding the North London Joint Waste Strategy, a separate but parallel process which plans for the disposal of household and commercial waste in North London. We have had some difficulty finding out exactly what has been agreed to, but it looks to us (from published council documents) that a decision may have been made to expand the Edmonton incinerator. This was the “preferred option” of five in the document voted on at the Waltham Forest Cabinet meeting held on the 22nd of July 2008. We therefore have three main areas of concern: 1. Blackhorse Lane – not just an industrial area, but a residential and ‘regeneration’ area Blackhorse Lane is designated an industrial area for planning purposes, which is one reason why it is being considered as a waste disposal site. It is, however, also a residential area, with a higher than average proportion of children and people with limiting long-term illness. Several new, large-scale, high-density housing projects are under development in the vicinity, which will make the area considerably more densely populated. Instead of improving local amenities to cater for the increased population (eg additional parks, libraries, or leisure facilities) which would help to improve the health of residents, proposals are to site a waste disposal facility, possibly an incinerator, there. Is this not at odds with the regeneration plans which were so well publicised by the council, but which now seem to have gone quiet, and which made no mention of a waste disposal site? Certainly it is difficult to see how a waste disposal site serving all of North London

fits in with the council’s plans, as described by Cllr Loakes, to make Blackhorse Lane a “thriving, more attractive part of the borough”. Additionally, we are concerned about Waltham Forest as a whole. Why should the Lea Valley bear the brunt of North London’s waste disposal? Why should the burden not be spread more fairly? There may be industrial areas here but it is also densely populated. We should stress that this is not a case of NIMBY-ism. Potentially-polluting waste disposal facilities should not be sited in any residential area. 2. No more incineration There is already one incinerator in North London, the Edmonton incinerator. In 2002, after a campaign by Greenpeace, the government turned down a plan to massively extend it. So why is it acceptable to consider expansion or even an extra incinerator now? Because of the pressure on landfill sites and the need to reduce carbon emissions, the government is championing incinerators. They call it “energy from waste” because burning rubbish can be used to generate electricity. What we ought to do with rubbish poses a serious problem but we should unequivocally reject incinerators. The rush to incinerate is a dangerous, short-cut solution to much bigger environmental problems, which puts profit before health and reduces the chance of developing safer alternatives. The risks Hundreds of infant deaths a year are linked to pollution emitted from public waste incinerators. Studies have shown higher rates of adult and childhood cancers and birth defects. Incinerators have been shown to pollute over a 15-mile area. They emit:  fine particulates, which can increase mortality rates from all causes, including heart disease and lung cancer.  toxic metals, which accumulate in the body and are implicated in a range of problems in children, including autism and attention deficit hyperactivity disorder.  cancer-causing chemicals. Incinerators have safety measures in place to avoid accidents, but these ignore the effect of airborne chemicals, which can cause illnesses over a long period of time. Additionally, incinerators reduce waste to ash, which is toxic and easily wind borne. The majority of incinerators are sited in poor areas. The myths Incinerators do not solve the problem of landfill. They reduce rubbish to ash, which is 30 to 50% of its original volume, and this still has to be buried in landfill sites. Incinerators release lots of CO2. Electricity-generating incinerators emit 33% more CO2 than gas power stations, but 40% less than coal power stations. However, the technology in fossil-fuel stations is changing. It is predicted that by 2020 incinerators will emit 78% more CO2 than gas power stations and only 5% less than coal power stations. Incinerators can discourage recycling and waste reduction as they need a minimum amount of rubbish to operate. There is evidence that councils are reducing recycling and waste reduction schemes to meet demand.

Invest in alternatives The main aim should be to re-use and recycle. In North London only 23% of waste is currently recycled. Councils should then invest in environmentally-friendly disposal systems that can deal with remaining waste without incineration. About 94% of public waste can be dealt with by methods other than incineration, such as composting or anaerobic digestion. It is safer to send the remaining 6% to controlled landfill than burning it. Take out the profit motive Waste disposal plants are run by private companies which exist for only one reason: profit. They have no interest in long-term research and investment in safe and environmentally-acceptable alternatives, just short-term solutions that provide a quick profit. How can we trust them to implement appropriate safety measures? London Waste Ltd, the company that owns the Edmonton incinerator, was fined in 1998 for “burning clinical waste of types not permitted”; altogether they were found guilty of 19 separate charges. And we will probably have to pay through the nose to be poisoned. Costs of other projects have rocketed. For example, in Newhaven, Sussex, the costs of one waste disposal site have doubled to £145.7 million just to prepare the site for a new incinerator. The taxpayer is underwriting the costs while the private company, Veolia, will reap all the profits. Nevertheless, councils do have the lawful right to take waste disposal back in-house. We think waste management should be brought back into public control. Reduce waste A huge amount of waste is completely unnecessary. There is a mass of excessive packaging and advertising. Competition between companies leads to enormous waste in duplicated production processes. Most non-disposable goods, such as washing machines and electrical items, are deliberately made with built-in obsolescence. The technology that allows such goods to last for many years exists but they are specifically designed to wear out in a short time so that we are forced to buy them again and again. We know that most of this is not within the council’s control but the council could campaign with local businesses to reduce packaging, advertising, etc, and aim towards a “Zero Waste” strategy. 3. We want a real say We are being consulted in North London. In just six weeks, with one workshop in each borough, we were being “consulted” about something which could potentially threaten the health, and even the lives, of babies, children, and adults in our boroughs. Only a tiny number of local people took part in the consultation simply because no one knew about it. When the regeneration plans for Blackhorse Lane were put out to consultation, glossy brochures were posted through our doors, but in this case the publicity has been extremely poor. Through our own campaigning we have discovered that the vast majority of local residents know nothing about the proposals and, increasingly, when they do, it is because of our campaigning work. We would like to point out the following with regard to the “consultation” which took place: 1) The consultation protocol stated that the intention was to carry out an "inclusive and comprehensive consultation and communication programme that properly engages stakeholders in North London during the work on the JWDPD." There is no definition of the term stakeholder, which is a commonly-used, but vague, government term. Neither is there any list attached stating who the consultants consider to be their stakeholders. We would venture to suggest that we, as concerned local residents, fall within the definition of a stakeholder, yet we were not specifically targeted for consultation.

2) The programme of consultation undertakes to include a virtual launch, with letters being distributed to all stakeholders, announcing the commencement of the plan and the launch of the project website. We were not included in this programme and believe that as stakeholders we should have been. 3) A touring exhibition did take place around the seven boroughs, as promised by the plan, but it was extremely poorly publicised and very few residents were even aware of it. This cannot be called meaningful consultation. 4) The consultants undertook to carry out targeted consultation with “hard to reach” groups. There is no explanation, description, or list of what constitutes a “hard to reach” group. Given that we were not reached through the standard consultation methods, we consider ourselves a hard to reach group, yet we were still not targeted. We would also like to know what efforts have been made to define and consult hard to reach groups. 5) One of the operating principles is that "community involvement is appropriate to the level of planning. We will endeavour to ensure that the consultation arrangements are built on a clear understanding of the needs of the community, and are fit for purpose, taking into account the resources available." We do not think that this project can be said to have understood the needs of the community, given that only minimal efforts to consult with local people have been made. 6) Another of the operating principles is that "the methods used to encourage involvement and participation should be relevant to their experience. A wide range of methods and approaches will be used, tailored to the needs of different groups. This includes those considered 'hard to reach.' For example, at the issues and options stage local proactive outreach work would be carried out in the form of face to face meetings with local interest groups and residents. This would be flexible and particularly focused on groups with a specific local interest in particular sites and with groups who have not engaged with other aspects of the consultation programme." We would like to know what proactive outreach has been done and why we were not included in this. We need answers to these questions, as we believe they lay the process open to challenge on a number of grounds. Additionally, we are very concerned to learn that decisions were made at a Waltham Forest Cabinet meeting in July about the North London Joint Waste Strategy, a separate but parallel process to the consultation on the North London Waste Plan. Whenever we try to find out what is happening, we are told not to worry as it is a different process. It may be technically different, but clearly the two are related to each other. The Strategy makes decisions about household and commercial waste and the Plan makes decisions about potential new sites for all waste; therefore, they are integrally linked. How can we believe that we can successfully influence the Plan, if decisions are made about the Strategy without our involvement whatsoever? We have also had great difficulty finding out exactly what was decided in the July meeting. We request: 1) a meeting between Residents Against Pollution and councillors about the future of Blackhorse Lane 2) a presentation on the science of incinerators to be held with councillors and members of the public. Residents Against Pollution residentsagainstpollution@googlemail.com 07748 534891

References: Thompson & Anthony. The health effects of waste incinerators. 4th Report of the British Society for Ecological Medicine. Pope & Dockery. Health effects of fine particulate air pollution: lines that connect. Journal of the Air and Waste Management Association 56. Warhurst & Watson. Dirty Truths: Incineration and Climate Change. Friends of the Earth Defenders of the Ouse Valley and Estuary Alternatives to incineration.

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