‘NORTH LONDON WASTE AUTHORITY

REPORT TITLE: CONSULTATIONS AND POLICY UPDATE

REPORT OF: HEAD OF OPERATIONS

FOR SUBMISSION TO: DATE: AUTHORITY MEETING 28 September 2017

SUMMARY OF REPORT:

This report provides the regular update on consultations and policy issues which have the potential to impact on Authority operations or activities. The report is principally focussed on one issue for this meeting, namely the consultation draft London Environment Strategy of the London Mayor. The report sets out key aspects of the consultation draft document for Member consideration and recommends authority is delegated to submit a formal response.

The Deputy Mayor for Environment and Energy will give a presentation to the meeting.

The report also notes a response to the GLA’s Environment Committee and planning matters that may affect the Authority’s principal place of business in Tottenham Hale.

RECOMMENDATION: The Authority is recommended to delegate authority to the Head of Operations, in consultation with the Chair and Vice Chairs to submit a response on behalf of the Authority to the draft London Environment Strategy.

SIGNED: ______Head of Operations

DATE: 18 September 2017 1. PURPOSE AND STRUCTURE OF REPORT

1.1 The Consultations and Policy Update report is a regular report which provides an update for Members on consultations and policy issues that are relevant to the Authority such that the proposals have the potential to affect the Authority’s operations and/or costs. The report additionally seeks approval for responses where appropriate.

1.2 This report is principally concerned with the Mayor of London’s consultation draft Environment Strategy. It also notes planning matters that may affect the Authority’s principal place of business in Tottenham Hale.

2. THE MAYOR OF LONDON’S ENVIRONMENT STRATEGY

2.1 As reported at the June Authority meeting the Greater London Authority (GLA) has a duty to develop a capital wide environment strategy, the London Environment Strategy (LES). The Authority will also have a duty to be in general conformity with the waste elements of the LES. The long term implications of the aims, objectives and implementation of the LES for the capital and its residents, workers and visitors were also noted at the last Authority meeting.

2.2 Authority officers had attended a pre-consultation LES ‘strategic engagement workshop’ with the GLA but also concluded that it may provide a helpful addition to the dialogue on the LES if the Authority provided further input at the pre-consultation stage. Following approval at the June Authority meeting the Head of Operations was delegated to submit representations to the London Mayor in consultation with the Chair, concerning the issues that the Authority considered of greatest importance in the expected LES. The Chair subsequently sent a letter to the Deputy Mayor for Environment and Energy which is included as Appendix 1 to this report.

2.3 The following points which were made in the Chair’s letter are incorporated into the consultation draft LES:

2.3.1 A commitment to a circular economy approach for the capital – Chapter 10 of the consultation draft LES sets out measures for a transition to a low carbon circular economy. 2.3.2 Integration of businesses within the scope of the LES – The contribution of the business community is incorporated throughout the document, although it is not clear if or how the European programmes of Extended Producer Responsibility (or post-Brexit equivalents) might contribute to driving the circular economy forward in London. Officers are also enquiring about the calculations of recycling target achievement to understand how much businesses will contribute towards the achievement of the municipal recycling target for the capital or how businesses might be incentivised to do more.

2.3.3 Clarity is provided about the retention of the Emissions Performance Standard, which will be retained alongside tonnage based recycling targets and the Carbon Intensity Floor. Proposal 7.3.2a sets out that waste authorities are expected to demonstrate how they meet the greenhouse gas Emissions Performance Standard (EPS). Proposal 7.3.2b states that “Waste authorities much demonstrate how solutions generating energy from waste meet the carbon intensity floor (CIF), or put in place demonstrable steps to meet it in the short-term.” It is expected that the proposed Energy Recovery Facility at the EcoPark will be able to achieve the CIF when the proposed local heat network is fully operational. 2.3.4 A commitment to behaviour change including communications to increase recycling and reduce waste. This will be delivered by working with the London Waste and Recycling Board (LWARB) and Resource London, waste authorities and other relevant parties. The Mayor will support campaigns including Recycle for London, Love Food Hate Waste and Trifocal to help Londoners and businesses to reduce waste. The take-up of recycling services by local residents and businesses will be critical to the achievement of LES recycling targets. 2.3.5 There is also mention of recycling scheme standardisation to make recycling systems easier to understand if residents move around the capital. This is a matter for the constituent borough councils in the first instance. 2.3.6 Explicit links are made with the London Plan and specifically to the need for regional self-sufficiency in managing London’s waste within the capital. The consultation draft LES also sets out a number of areas in which the Mayor expects the new London Plan to contain additional new policies and proposals to further protect the environment.

2.4 However, there are some points in the Chair’s letter that the Authority might seek to be expanded upon in the final LES: 2.4.1 The importance of waste infrastructure is mentioned; it appears that support for infrastructure will be delivered primarily through London Plan requirements and the work of the London Waste and Recycling Board. Officers are seeking a better understanding of the GLA’s assessment of the scale of the need and the direct steps needed to deliver the step-changes sought by the Mayor. 2.4.2 Similarly, it will be necessary for officers to engage further with GLA counterparts to develop a more detailed picture of the scope of the test of “general conformity” and it will be applied in practice. 2.4.3 Finally, officers believe that it would be helpful to all if links to other Mayoral strategies could be more explicitly referenced so that any new service developments can readily consider these from the outset.

3. KEY ASPECTS OF THE CONSULTATION DRAFT LONDON ENVIRONMENT STRATEGY

3.1 On 11 August the Mayor of London launched the consultation on his draft LES which runs until 17 November. The LES integrates six different environmental policy areas into one document with the aim of protecting and improving London’s environment and protecting the health of Londoners. From cleaning up London’s air to improving green spaces in the city and cutting carbon emissions, the LES sets the long-term ambition for making London cleaner and greener in the light of anticipated population and housing growth in the capital. The LES covers a period of 33 years from 2017 – 2050.

3.2 The following sections of this report provide a summary of the key aspects of the LES which are relevant to NLWA. It is anticipated that constituent boroughs will be responding separately and will be commenting upon a broader range of issues than NLWA.

3.3 The most relevant and important section of the LES for NLWA is Chapter 7 about ‘Waste’. Key points to note are: 3.3.1 A Mayoral aim for London to become zero waste by 2026 which means no biodegradable or recyclable waste going to landfill by that date and by 2030 65% of London’s municipal solid waste (MSW) to be recycled. 3.3.2 The Mayor wants waste authorities to collectively achieve a 50% local authority collected waste (LACW) recycling target by 2025 and aspire to achieve 60% by 2030. 3.3.3 Landfill and incineration are “undesirable” although the role of energy- from-waste is acknowledged in managing London’s non-recyclable municipal waste. The LES states that London will have sufficient incineration capacity to manage non-recyclable municipal waste once the new Edmonton and Beddington Lane energy recovery facilities are built. 3.3.4 Effective recycling is reported as able to give local authorities a reliable high value income stream which can be used to help offset costs associated with service improvements. 3.3.5 Waste prevention is prioritised in the LES and the document notes that the LES will take a circular approach to London’s use of resources that designs out waste, keeps materials in use at their highest value for as long as possible and minimises environmental impact. The two priorities for waste prevention in the LES are reducing food waste and single use packaging because “they offer the biggest opportunity for change.”

3.3.6 The LES notes that waste authorities in performing their waste functions, need to show how they are “acting in general conformity with the municipal waste provisions” of the LES but that general conformity only applies to local authority collected waste (LACW) activities and that acting in conformity cannot bring excessive additional costs to waste authorities. The Mayor also has the power to direct a waste authority where he considers their waste activities to be detrimental to implementing the municipal waste provisions in the LES. The Mayor has no power of direction over businesses or private waste management companies. A series of London Mayoral expectations of waste authorities is included in this Chapter – see Table 1 below.

Table 1 – Waste Authority Expectations

The Mayor expects waste authorities to deliver the following in order to show they are acting in general conformity with the LES’s municipal waste management policies and proposals. They should:

1. produce a waste management strategy or plan setting out how their waste activities will: o help move waste up the waste hierarchy o provide local economic, social and environmental benefits from improved waste management o make a meaningful contribution to meeting the Mayor’s targets.

2. offer the Mayor’s minimum level of household recycling service provision

3. make best use of local waste sites identified in local waste plans

4. support the phase out of fossil fuel waste transport and boost uptake of low or zero emission alternatives

5. use Recycle for London messaging in local awareness raising activities to ensure a consistent reduce, reuse, recycle message is delivered across London

6. demonstrate how they will, or have put in place positive changes to improve recycling performance identified through Resource London’s borough support programme

7. publicly notify its intention to tender a waste contract at the same time as notifying the Mayor. This would be a chance for waste authorities considering new services to consider joint procurement options. These can provide better value for money on ‘like for like’ services and achieve service harmonisation across borough boundaries

8. procure waste and recycling services that maximise local economic, environmental and social benefits through demonstrating how they will deliver the Mayor’s Responsible Procurement Policy

9. carry out any other relevant activity supporting the Mayor’s policies and targets

3.4 Other aspects of the LES may impact indirectly on NLWA. These include: 3.4.1 An aim to reduce the amount and impact of freight transport - the Mayor has set a number of targets to cut emissions and reduce the amount of freight movement in central London. This includes reducing construction traffic by 5% by 2020 and reducing the number of freight trips during the morning peak by 10% by 2026. 3.4.2 A desire to reduce the environmental impact of commercial transport, including waste transport, in London – an example is provided about the reduction in deliveries to retailers on Regent Street. By consolidating deliveries amongst the different shops on the street, transport movements have been reduced by 77%. Proposal 7.2.2a of the LES states that: “The Mayor will support efforts to consolidate commercially collected waste services to improve recycling performance, reduce congestion, improve the public realm and improve air quality.” 3.4.3 A desire to prevent or reduce the emissions from Non-Road Mobile Machinery (NRMM) is also articulated within the LES. The Mayor’s planning powers are currently being used to create an NRMM Low Emission Zone with minimum emission standards. The Mayor also wants stronger enforcement powers to ensure that these standards are consistently met across London and has asked the government to legislate to provide these. The LES additionally references the possible inclusion of NRMM emissions standards within environmental permits. Construction NRMM for the North London Heat and Power Project could be impacted by any changing requirements in this regard. 3.4.4 Regarding energy production in the capital the LES notes that in order for London to become zero carbon by 2050 that the energy system will need to move away from using natural gas to being fuelled more from MSW renewable energy and the heat that is waste from industrial and commercial processes. 3.4.5 The Mayor has also committed to buying clean energy generated across the city, using it to power GLA and TfL facilities. The Licence Lite project will deliver on this Mayoral manifesto commitment. The project will acquire an Ofgem junior electricity supply licence to buy locally generated low carbon electricity at a higher price than the generators would otherwise receive from the wholesale market and sell to GLA group facilities. Licence Lite aims to be operational by autumn 2017.

4. NLWA RESPONSE

4.1 The Deputy Mayor for Environment and Energy will give a presentation to the September Authority meeting so that a discussion can take place with Authority Members that will inform the Authority’s final response. This will also allow time for discussion with borough colleagues. Accordingly, this section of the report notes the direct LES consultation questions on waste and introduces some themes for a proposed Authority response to the consultation.

4.2 The LES consultation asks six questions about waste: 1. Do you agree that the Mayor’s policies and proposals will effectively help Londoners and businesses to recycle more? 2. Do you support the Mayor’s ambition to ensure food waste and the six main recyclable materials (glass, cans, paper, card, plastic bottles and mixed plastics) are collected consistently across London? 3. Do you think the Mayor should set borough specific household waste recycling targets? 4. What needs to happen to tackle poor recycling performance in flats? 5. What are the most effective measures to reduce single-use packaging in London such as water bottles and coffee cups? 6. Please provide any further comments on the policies and programmes mentioned in this chapter.

4.3 The Authority response may also touch upon other themes contained in the LES such as air quality, green infrastructure, climate change and the transition to a low carbon economy where this might help reduce our waste stream or provide more beneficial uses for it. Similarly, the development of other Mayoral strategies (e.g. for transport and planning) will also be of importance to the Authority, and a response to the LES might touch upon these where they overlap.

5. GLA ENVIRONMENT COMMITTEE INVESTIGATION INTO LONDON’S WASTE MANAGEMENT

5.1 On 30th June the GLA Environment Committee asked for contributions to its investigation into the position of London’s waste management, particularly waste reduction and the circular economy, recycling potential and the role of energy recovery facilities in managing residual wastes.

5.2 The Chair submitted a response that signposted pre-existing NLWA responses to relevant consultations and other public-domain information. The response is attached as Appendix 2.

6. ASHLEY ROAD SOUTH CONSULTATION

6.1 At the February Authority meeting, Members noted the officer response to the planning application for the demolition and redevelopment of the Cannon Factory and Ashley House on Ashley Road adjacent to the Authority’s office in Berol House, Ashley Road. Officers have continued to engage with the redevelopment proposals for Ashley Road South since that time.

6.2 Following the last Authority meeting in June a hybrid planning application HGY/2017/2044, came forward for the redevelopment of Berol House consistent with that part of the overall redevelopment plans for Ashley Road South. The application for full planning permission included retaining Berol House, but replacing a single-storey light-industrial building on the other side of the car park with two buildings of 8-14 storeys providing 156 residential units along with commercial and educational floor-space and various landscaping works. The application for outline planning permission included alterations to Berol House (the Authority’s principal place of business, occupied on a leasehold basis) that would adversely affect NLWA activities and the introduction of 18 residential units in two new storeys on top of Berol House.

6.3 The level of potential disruption could make NLWA’s offices very difficult to work in during construction and development and no longer suitable post redevelopment. Officers have therefore responded with comments on the planning application, objecting to the proposals. Officers will engage positively however on finding solutions to the difficulties of the current application in a way that enables the Authority to continue to operate from Berol House with the minimum of disruption.

7. RECOMMENDATION

7.1 The Authority is recommended to delegate authority to the Head of Operations, in consultation with the Chair and Vice Chairs to submit a response on behalf of the Authority to the draft London Environment Strategy.

8. COMMENTS OF THE LEGAL ADVISER

8.1 The Legal Adviser has been consulted in the preparation of this report and comments have been incorporated.

9. COMMENTS OF THE FINANCIAL ADVISER

9.1 The Financial Adviser has been consulted in the preparation of this report and all comments have been included.

Local Government Act 1972 - Access to Information Documents used: London Environment Strategy, Draft for Public Consultation, Mayor of London, August 2017 – available at https://www.london.gov.uk/WHAT-WE- DO/environment/environment-publications/draft-london- environment-strategy-have-your-say

NLWA Response to LB Haringey consultation on planning applications for Ashley Road South – available at http://www.planningservices.haringey.gov.uk/portal/servlets/ ApplicationSearchServlet by searching using the application reference HGY/2017/2044.

Contact Officers: Andrew Lappage, Head of Operations & Barbara Herridge, External Relations Manager

Unit 1B, Berol House 25 Ashley Road Tottenham Hale N17 9LJ

Tel: 020 8489 5730 Fax: 020 8365 0254 E-mail: [email protected]

Appendix 1

Appendix 2

28 July 2017

By email to: [email protected]

Grace Loseby, Assistant Scrutiny Manager London Assembly Environment Committee City Hall The Queen's Walk London SE1 2AA

Dear Ms Loseby,

Ref: London Assembly Environment Committee investigation into London’s waste management

1. Introduction

1.1. Thank you for providing North London Waste Authority (NLWA) with the opportunity to comment upon the London Assembly Environment Committee’s investigation into London’s waste management, which we understand will have the following three areas of focus:  Waste reduction and the circular economy - how to reduce waste and utilise the circular economy.  Recycling - the potential to develop greater consistency in household recycling and food/organic waste collections between London boroughs.  Energy from waste - the role of energy from waste plants (incinerators and potentially others) in managing residual waste.

2. London Assembly Environment Committee key questions and NLWA response

2.1. We have set out our thoughts thematically, rather than keeping strictly to the Committee’s questions, but we hope nevertheless that our response will be helpful to the Committee.

Clarity about London’s recycling goals

2.2. LWARB’s 2017-20 business plan restates Mayoral ambitions “To reinvigorate London’s recycling efforts so that by 2030 we achieve a 65 per cent recycling rate for the waste from London’s residents and businesses.” As with any target, it will be important that all associated definitions are clear, along with the nature of the contribution towards achieving the target from different organisations (including local authorities) and sectors.

2.3. A particularly important factor in relation to definitions of targets is the role of green waste recycling, because of significant differences in its availability in different parts of London and in London as a whole relative to other regions. Attached in Appendix 1 are details of the top 10 waste collection authorities in England for Best Value Performance Indicator (BVPI) 192 (averaging 62.4% combined BVPI 82a and 82b) who get 59.4% of that recycling performance from 82b (most of which is garden waste) compared to 19% in inner London. The Authority has previously commissioned research which showed that a 50% national target translates to 41% in north London purely on the basis of garden waste. Authority officers would happy to provide more information if required.

2.4. The Committee might wish to consider if one way to overcome the recycling disadvantage London has due to a lower level of green waste arisings than some regions relatively might be to change or supplement the historic focus on recycling rates to a measure of residual waste per household.

2.5. Within the above we suggest the Committee looks into the different approaches to apportioning co-collected business or trade waste (i.e. where business waste is co- collected by local authorities in the same vehicles as household waste and the totality of that collected waste then apportioned between the two sources) and unregulated waste/fly tipped wastes and different interpretations in general. It is important that before making comparisons within London and between regions that the data is made as consistent as reasonably possible.

2.6. The Committee may also wish to examine the extent to which the level of economic inequality correlates inversely with recycling rates both on an English regional and national (EU) level.

Collection consistency

2.7. Concern has been expressed that the number of different recycling schemes for householders in the capital might be an obstacle to a relatively mobile population from understanding how to recycle when they move from place to place. Although instinctively consistency should assist with behaviour change, we are not aware of evidence that it delivers any significant benefits. Most of the perceived benefits appear to be based upon self-reported future behaviour of the public, which may be over claimed (see the work on the likely impact of incentives to encourage people to recycle: http://www.eunomia.co.uk/reports-tools/investigating-the-impact-of-recycling-incentive- schemes/). The Committee might wish to examine whether it is empirically true that differing recycling schemes are a significant obstacle to improved recycling rates, or whether poor engagement in recycling by some is primarily caused by other factors.

2.8. There are financial benefits to joining up collections on a sub-regional basis or in (proximate) groupings of authorities that have shown an interest in working together, as demonstrated in South London. Consistency of service design will be driven in these groupings and it may be better for the Mayor to support sub-regional working by groupings of authorities through which consistency will emerge, and then having a debate about a more pan-London consistent approach if the evidence and gains warrant this.

2.9. If greater consistency is believed to be beneficial, the Committee may wish to consider if developing a standardised colour coding system for household recycling in London would be a useful and more achievable change. Given that all boroughs would benefit, the cost of the change for those boroughs that have to make a switch in colour(s) could possibly be funded through the Mayoral precept or with money from a devolved-to-London landfill tax scheme (which NLWA would support).

Recovering Energy from Waste

2.10. The recovery of energy from waste has an important role to play in London’s waste management strategy as there will always be waste which is commercially unviable and/or difficult to recycle, e.g. multi-material products which are difficult to separate for recycling or certain hazardous wastes. Long term product policy is expected to shift us towards using a greater proportion of fully recyclable products but it is important to have an outlet for disposing of the products which are not recyclable.

2.11. A Development Consent Order has been made for a new Energy Recovery Facility at the Edmonton EcoPark, which will deliver reduced emissions and is planned to provide a low carbon heat source for thousands of new homes and business nearby. Further evidence and information from the NLWA perspective is available on our North London Heat and Power Project and from the Lee Valley Heat Network (energetik) websites.

2.12. The current Municipal Waste Strategy for London includes an Emissions Performance Standard and a Carbon Intensity Floor. NLWA supports these and suggests that if they are to be reviewed that this should be done in consultation with London’s waste authorities and waste processors. It will be important, given Mayoral ambitions for decentralised energy (electricity and heat) and the role of waste-fuelled energy recovery facilities in assisting with delivering on these ambitions, that any new EPS and CIF standards are capable of being met with this technology.

Circular economy

2.13. The joint waste disposal authorities’ paper about circular economy opportunities in a post- Brexit environment (as detailed below) is supportive of a move towards a circular economy and NLWA has welcomed the London circular economy roadmap.

2.14. If the Committee hasn’t done so already, it may wish to look at the Parisian model of developing a circular economy in a city e.g. setting up 10 ‘Ressourceries’1; hubs for repair and reuse, (see the Parisian White Paper on the Circular Economy of Greater Paris, available at https://api-site.paris.fr/images/77050). Similarly, the launch of Advance London, the new EU-funded programme to help London’s smaller businesses ‘go circular’ and become more resource efficient that was launched on 25 April is a another good example of a new idea for developing circular economy approaches in a city.

2.15. However, part of the journey towards convincing participants that commitment to a circular economy model is worth the investment is gaining recognition that circular economy approaches can bring about significant economic benefits as well as environmental benefits. We would suggest that the Committee (itself or through the Mayor):  convenes a conference for London’s large employers to investigate how best to bring about a more circular approach to business in London. We would suggest that the conference could include: o ‘business to consumer’ ideas such as TK Maxx’s take-back scheme (http://www.tkmaxx.com/page/giveupclothes) and Marks and Spencer’s ‘Shwopping’ scheme (http://www.marksandspencer.com/s/plan-a- shwopping). The public sector could also be included in this too, as there may be relevant experience here (e.g. http://www.wiseuptowaste.org.uk/reuse/clothes-and-shoes); o ‘business to business’ ideas such as advocated by the Ellen McArthur Foundation; o acts as an advocate for circular economy thinking, perhaps by establishing an information hub, namely a website containing the physical and online locations of hire, repair and second-hand items through which people can search for their nearest location using a postcode locator, so that consumers can easily participate in these activities; and o delivers a communications campaign to promote exchange facilities such as Freegle and Freecycle, other sharing apps and the information hub noted above with the intention of making the concept of reuse appealing to a wider audience.

1 Ressourcerie (Resource store) The term "Ressourcerie ®" is a trademark. Ressourceries use processes to collect waste (bulky waste, non- hazardous industrial waste, etc.) that are designed to preserve the waste product’s original purpose so that it can be recovered primarily through re-use/re-utilisation, and then recycling.  supports the London Waste and Recycling Board (LWaRB) in implementing its 2017 – 2020 business plan and Circular Economy Route Map;

2.16. Finally, the Committee may be interested to note that NLWA held a seminar on the circular economy earlier this year. Analysis and recommendations are included in both NLWA’s own summary of the event and an accompanying consultants’ report.

Behaviour Change Campaigns

2.17. A number of approaches and interventions have been considered for reaching London’s ambitions and targets for managing waste more sustainably. NLWA would like to see a commitment to behaviour change work.

2.18. The work being delivered by Resource London, including recycling communications work, needs to be sustained for the long term if we are to achieve Mayoral ambitions for reduction, reuse and recycling of London’s waste. Both the London Waste and Recycling Board (LWARB) and Resource London in particular need to be adequately resourced for the challenge. The devolution of landfill tax either to the Mayor or to London boroughs could provide this necessary long term support. However, without sustainable funding, and particularly within the current post-Brexit economic climate, it is important to stress that expectations for waste management within the capital will need to be realistic. However, on the basis of sufficient resources in particular we suggest:

 that there is an enhanced commitment to waste prevention measures at the top end of the waste hierarchy;  a commitment to sharing progress monitoring information across the capital such that evaluation work being delivered by Resource London or LWARB is shared with the capital’s waste collection and disposal authorities and in order that the lessons learned at a London wide level can be passed on quickly for local use and vice versa;  that the GLA co-ordinates its resources effectively with waste authorities, with particular regard to the linkages between promotional campaigns on the one hand and enforcement campaigns on the other that focus on wastes in the wrong place (wastes loose in the open or in the wrong bins); and  that there is continued and increased focus on recycling contamination. Desk research by NLWA suggests that authorities which are doing best on tackling recycling contamination have made long term commitments to tackling the issue, have established groups of officers from both operational and communications disciplines to tackle the problem and have been consistent in their follow-up of residents who are contaminating e.g. making sure that they promptly send letters about contamination to residents and follow up with a visit or second warning according to the authority’s own procedures.

The London Plan – the spatial strategy for the capital

2.19. The land use implications of moving waste up the waste hierarchy are significant in that the amount of land required to treat a tonne of waste by energy recovery (incineration) or landfill is significantly smaller than the land required to treat a tonne of waste by composting or recycling, and this is significantly smaller that the land required for repair and reuse. In order to drive forward with a circular economy for the capital it is essential that there is sufficient affordable land for improved resource use.

2.20. NLWA recommends that some analysis is undertaken regarding the number, type and capacity of waste facilities that are in place at present and the likely recycling rate that is achievable based upon the current facilities and resources. Without appropriate new infrastructure in the capital it is difficult to see that the Strategy targets will be met. Clearly, London is a particularly challenging place for waste infrastructure investment as land costs are high and therefore initial investment and capital costs are high. Accordingly, more certainty about contractual income may be necessary than elsewhere in the country to offset the initial outlay on land and buildings.

2.21. It may also be helpful if the London Plan were to include a clear position on the reasonable capacity of waste storage that is needed at new-build developments for residents (and businesses) to be able to manage their wastes in a way that enables the achievement of any new targets for recycling, residual waste production or other circular economy measures. The pressure to provide sufficient new housing may need to be tempered by ensuring that the housing is not so dense that there is not sufficient space, both within homes and where wastes are put out for collection, so that it is easy and convenient for London households to recycle at the levels required by the Mayor’s expected London Environment Strategy, and for collection frequencies to remain reasonable for waste collection authorities. Any such measure would however need to be preceded by the GLA consulting with waste authorities on the minimum and maximum ‘reasonable’ weekly equivalent waste capacity (for reuse, recycling, composting/AD and recovery or disposal) for different types and sizes of homes.

Other information from NLWA

2.22. Previous responses by NLWA to other public consultations that the Committee may wish to look at are:  NLWA comments on the government’s Industrial Strategy Green Paper, April 2017 (available at: http://nlwa.gov.uk/docs/consultation- responses/beis_industrial_strategy_nlwa_response_6apr2017_web.pdf )

. NLWA and other joint waste disposal authorities’ views on wastes management strategy post Brexit, September 2016 (available at http://nlwa.gov.uk/docs/consultation- responses/brexit---jwdas-position-paper.pdf)

. NLWA response to the EFRA Committee Food Waste Inquiry in England, September 2016 (available at http://nlwa.gov.uk/docs/consultation-responses/efra-inquiry- response-web.pdf)

. NLWA response to the European Commission’s Circular Economy proposals 2015 – response and position paper (available at http://nlwa.gov.uk/docs/consultation- responses/nlwa-response-downloaded-from-eu-website-ie-as-submitted.pdf and http://nlwa.gov.uk/docs/consultation-responses/circular-economy-consultation-position- paper---nlwa-final.pdf )

. NLWA comments on the issues created as a result of the current definitions of reuse and repair as set out in the Defra discussion paper on clarifying the definition of waste reuse and repair in 2015 (available at http://nlwa.gov.uk/docs/consultation- responses/clarifying-the-application-of-the-definition-of-waste-to-re-use-and-repair- nlwa-response-30-01-15.pdf)

. NLWA response to the London Assembly investigation into food waste in the capital 2014 (available at http://nlwa.gov.uk/docs/consultation-responses/london-assembly- investigation-into-food-waste-management-for-web.pdf)

. NLWA response to the publication of the first waste prevention programme for England, December 2013 (available at: http://nlwa.gov.uk/docs/consultation- responses/waste-prevention-programme-for-england_final-submitted.pdf )

. NLWA response to the Mayor of London’s Municipal Waste Management Strategy consultation 2010 (available at http://nlwa.gov.uk/docs/consultation- responses/response_form_for_mws_oct2010_14012011_updated-01032011.doc)

. Other NLWA responses to consultations are available at http://nlwa.gov.uk/consultations/our-responses

If you need any clarification of the above, please let me know.

Yours sincerely

Cllr Clyde Loakes Chair of North London Waste Authority

Appendix 1

Top 10 waste collection authorities in England for Best Value Performance Indicator (BVPI) 192

% Of BVPI 82a + 82b that is BVPI Authority BVPI82a BVPI82b 82b South Oxfordshire District Council 34.5% 31.3% 47.6% East Riding of Yorkshire Council 30.4% 35.6% 53.9% Rochford District Council 26.5% 38.9% 59.5% Vale of White Horse District Council 34.4% 29.9% 46.5% Surrey Heath Borough Council 33.9% 27.9% 45.1% West Oxfordshire District Council 27.7% 33.0% 54.3% Stratford-on-Avon District Council 24.8% 35.7% 59.0% Trafford MBC 24.5% 35.9% 59.5% Three Rivers District Council 27.3% 32.0% 54.0% Stockport MBC 24.3% 35.0% 59.0% Total 28.4% 34.3% 54.7%

All waste collection authorities in England Best Value Performance Indicator (BVPI) 82a and b

% Of BVPI 82a + 82b that is Authority BVPI82a BVPI82b BVPI 82b Barking and Dagenham LB 12.3% 6.4% 34.3% Barnet LB 22.0% 14.4% 39.5% Brent LB 22.9% 12.9% 36.0% Camden LB 19.9% 4.3% 17.7% Ealing LB 30.8% 12.1% 28.1% Enfield LB 20.2% 15.5% 43.3% Hackney LB 18.4% 6.0% 24.7% Hammersmith and Fulham LB 20.6% 1.2% 5.5% Haringey LB 25.7% 9.8% 27.7% Harrow LB 19.9% 20.9% 51.2% Havering LB 19.8% 11.8% 37.3% Hillingdon LB 26.1% 18.0% 40.9% Hounslow LB 21.8% 11.7% 34.9% Islington LB 22.1% 6.9% 23.7% Lambeth LB 21.7% 7.0% 24.4% Newham LB 11.9% 2.7% 18.6% Redbridge LB 16.4% 11.1% 40.4% Richmond upon Thames LB 25.7% 14.0% 35.2% Royal Borough of Kensington and Chelsea 23.7% 2.2% 8.5% Waltham Forest LB 22.9% 11.1% 32.7% Wandsworth LB 19.9% 1.1% 5.4% Bexley LB 31.3% 20.6% 39.7% Bromley LB 26.1% 20.1% 43.5% City of London 25.8% 5.0% 16.1% Croydon LB 21.7% 16.1% 42.6% Greenwich LB 20.5% 14.2% 40.9% Lewisham LB 16.9% 1.0% 5.3% Merton LB 25.2% 9.7% 27.7% Royal Borough of Kingston upon Thames 28.0% 15.3% 35.4% Southwark LB 25.8% 8.8% 25.4% Sutton LB 25.7% 8.8% 25.5% Tower Hamlets LB 24.5% 1.8% 6.7% Westminster City Council 16.8% 0.0% 0.2% Inner London 20.8% 4.9% 19.0% Outer London 22.5% 13.3% 37.3% London 21.9% 10.5% 32.4%

Appendix 2 Background to North London Waste Authority (NLWA)

A1 NLWA is the statutory joint waste disposal authority for north London and as such is responsible for the disposal of waste collected by seven north London boroughs. NLWA also arranges for the recycling and composting of waste collected by the seven boroughs where requested and organises the management of reuse and recycling centres (RRCs) where the seven boroughs wish us to do so.

A2 In addition to the operational functions for managing waste, NLWA also works jointly with the north London boroughs to deliver public-facing behaviour-change programmes to encourage waste prevention and recycling. A3 NLWA is the owner of LondonWaste Ltd (LWL), which owns the Edmonton EcoPark in Enfield and which operates the Energy from Waste (EfW) facility and other processes there. A Development Consent Order to redevelop the Edmonton EcoPark was recently made and the Authority now has plans to implement this over the next ten years.

A4 In addition to the facilities at the Edmonton EcoPark, NLWA uses a rail transfer station in Hendon, from which most residual waste is transferred out of London for energy recovery and mixed dry recyclables are bulked up for onward transfer to two third party materials recycling facilities (MRFs) at Bow and Edmonton, a road transfer station at Hornsey Street in Islington doing the same (but all to London destinations and all by road). NLWA also manages eight of the nine reuse and recycling centres in north London. Further information about the Authority can be found on our corporate website at www.nlwa.gov.uk with recent update reports about our activity as follows:  Annual Report – which provides details of our activities in the past year (2016/17) http://nlwa.gov.uk/governance-and-accountability/annual-reports/annual-report-2016- 17/

 Annual Monitoring Report which reports on the recent progress (2015/16, pending WasteDataFlow for 201/17) of the eight north London authorities, NLWA and the seven boroughs in meeting the objectives of the North London Joint Waste Strategy http://nlwa.gov.uk/governance-and-accountability/annual-strategy-monitoring-reports

 Information about our proposals to replace the existing energy-from-waste facility at Edmonton with a new energy-recovery facility can be found here: http://northlondonheatandpower.london/

 Our public-facing website is here: http://www.wiseuptowaste.org.uk/