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SLWP boroughs will continue to oppose Viridor’s plans to treat more waste at the Beddington ERF 

14 September 2023

The four South London Waste Partnership (SLWP) boroughs have submitted a joint response to an Environment Agency (EA) consultation in which they robustly object to an application by Viridor to treat more waste at the Beddington Energy Recovery Facility (ERF). 

Members of the SLWP Joint Committee met with senior representatives from the EA on 12 September 2023 to present their concerns – which centre around operational deliverability, emissions and the fundamental fact that additional waste treatment capacity is not required in the region. In both the joint consultation response and the meeting, the SLWP boroughs call on the EA to reevaluate the information provided by Viridor, to reconsider their decision and to reject Viridor’s application.

Andrea Keys, Partnership Director for the SLWP, said:

“The first round of the EA’s consultation into this application attracted more than 500 responses from members of the public, local authorities and other public bodies such as the Greater London Authority (GLA) and the SLWP expressing concerns about the planned intensification of the Beddington ERF. Despite this, the EA has indicated that they plan to give Viridor the green light.

“The four SLWP boroughs stand united in their opposition to this application and will continue to make that opposition clear to the EA at every opportunity. The boroughs remain optimistic that the EA will reconsider their ‘minded to issue’ decision and will reject this application for additional waste treatment capacity that is not needed and not wanted.” 

Residents and other interested parties have until Friday 15 September to review the consultation documents and submit their responses via the EA’s consultation hub.

A copy of the joint response submitted by the SLWP boroughs to the EA can be found below: 

The four South London Waste Partnership (SLWP) boroughs continue to strongly oppose Viridor’s application to treat more waste at the Beddington Energy Recovery Facility (ERF). The SLWP’s response to the first round of consultation was submitted to the EA on 22 November 2022 and published in the partnership’s website. The four partner boroughs made it clear that they strongly objected to Viridor’s permit variation application. A number of concerns were raised in relation to operational deliverability and emissions. The boroughs also put forward a compelling argument that there is not sufficient local or regional demand for this additional waste treatment capacity. 

On 21 July 2023, the EA published a Draft Decision Document, along with other supporting materials, in which it responded to the points raised in the first round of consultation. Having carefully reviewed these documents, it is clear that the SLWP boroughs’ concerns have not been addressed.

Under operational deliverability, the SLWP’s concerns centred on how the additional waste and associated on-site vehicle movements would be managed in the ERF’s tipping hall and bunker; both are relatively compact for a facility of this size and already operate at full capacity during peak times. 

Viridor has provided further information on how the ‘small number of additional vehicles arriving on site’ will be managed through scheduled arrival times. The EA has taken Viridor’s claims at face value and without verification and has concluded that it is ‘satisfied that there is sufficient space for the additional 1 vehicle per hour to be able to deposit their waste in the tipping hall.’ The SLWP boroughs would like to see more evidence of how the EA has reached that conclusion as the information provided by Viridor is far too simplistic.

Viridor states that ‘Currently, around 7 waste deliveries are received each hour’ and that that the capacity increase would only lead to ‘1 additional vehicle per hour’. Both of those figures are based on 24-hour averages. That is not how the facility operates in practice; there are times of day when it is extremely busy and times of day when it is very quiet. Viridor themselves reference the ‘dynamic supply and demand of waste’. In addition, Viridor’s calculations are based on the payload of an RCV (refuse collection vehicle). In reality, this additional waste is going to come from further afield so will be delivered in much larger articulated haulage vehicles, resulting in fewer additional vehicle movements than suggested, but much greater peaks and troughs of waste being delivered to site, adding to the operational challenges.

Before reaching a conclusion, it is essential that the EA demands more detailed, real-life modelling to be carried out to determine the impact of these additional deliveries on site operations. 

The lack of detailed modelling also means that it is impossible to accurately predict the real-world impact on the waste bunker. Viridor claims that the current bunker capacity (4,194 tonnes) will be sufficient due to the increased throughput of waste. The EA agrees. But again, this decision has been based on an overly-simplified model of one additional RCV delivering 4 additional tonnes of waste every hour, 365 days a year. As explained above, that is not how the additional waste will be delivered in the real world. It is far more likely that the c.96 additional tonnes of waste per day will be delivered in 4-5 articulated HGVs that could, theoretically, arrive on site at the same time. 

In addition, the EA, again, appears to be taking at face value the fact that the ERF will be able to achieve the higher throughput of waste in the furnace as modelled by Viridor. This relies on there being a substantial reduction in the calorific value (CV) of the waste being received at the site. Whilst this may well happen in the future, as national policy changes see less plastic waste in the residual waste stream, we can’t be certain of that and to allow additional capacity based on those uncertain assumptions would be careless.    

For the reasons stated above, we cannot be certain that the ERF bunker and furnace will be able to cope with these additional deliveries and increased throughput at peak times and the SLWP boroughs call on the EA to reconsider their decision to approve the permit variation application for this reason.

The SLWP also raised concerns about emissions, and the fact that Viridor has not been able to consistently meet our expectation that the Beddington ERF should operate at 100% compliance with its existing Environmental Permit. 

Whilst the SLWP acknowledges that the environmental performance of the Beddington ERF has improved considerably in recent months, the fact of the matter is that there have been 43 exceedances of the emissions limits set by the EA since the facility entered into operation in March 2019. The explanation given by the EA is that these short-lived, minor exceedances do not cause significant harm to the environment or a risk to public health and therefore are not a reason to refuse the application to treat more waste. This relaxed approach to emissions limit exceedances is confusing and concerning for local people who, understandably, believe that one exceedance is one too many. 

It is therefore our strongly held view that the EA should not permit more waste to be treated at the facility as Viridor has not been able to demonstrate compliance with its existing Environment Permit over a prolonged period of time. Regardless of the outcome of this determination process, the SLWP partner boroughs call on the EA to do far more to engage proactively with local residents so they can gain a better understanding of how the ERF is regulated and the EA’s attitude towards exceedances of the emissions limit values. Such open and transparent action by the EA, to the satisfaction of the four partner boroughs and our residents, would reflect the collaboration aspirations and values promoted by the EA via its Chair and social media messaging. 

The final key point raised by the SLWP boroughs during the first phase of the consultation was the fundamental question of whether additional waste treatment capacity is needed. The SLWP has clearly shown that there is insufficient demand for this additional capacity in the local area and as a result the 34,864 tonnes of additional waste to be treated at the Beddington ERF will be transported in from many miles away, going against the core principle that waste should be treated as close to its source as possible. 

The Beddington ERF was built, primarily, to treat residual waste collected from households in Croydon, Kingston, Merton and Sutton. Between 2016/17 and 2022/23, the amount of residual waste collected from homes in those four boroughs has fallen by 19% (from 240,135 tonnes to 195,239 tonnes). This downward trend in SLWP municipal waste being sent to the Beddington ERF means that Viridor already has significant additional headroom for local ‘third party waste’ without any increase in the facility’s overall capacity. 

Even at a regional level, there is a compelling argument that this additional treatment capacity is not required. Modelling conducted by the GLA shows that the residual waste treatment needs of London can be met with existing infrastructure, as long as waste reduction targets are met. An additional 1.6m tonnes per annum of waste treatment capacity is going to come on stream in and around London in the near future. As a result, the concern is that the additional waste destined for the Beddington ERF will travel many miles, from areas of the country that have failed to plan ahead and ensure they can meet their own waste treatment needs. One million residents across the SLWP region are doing a great job of reducing the amount of rubbish they generate. Why should they bear the brunt of other regions’ waste being trucked into the area?

This is a view that was expressed by many respondents to the public consultation, including the SLWP, the GLA, local authorities, councillors and the constituency MP. The response provided by the EA is that local need and regional capacity are not material matters for the consultation; the EA permit variation determination process is focussed purely on whether or not the ERF can treat the additional waste safely, from a technical perspective. 

This  is simply not good enough. Across the UK there is a network of 50+ energy from waste facilities. Most of these are commercially operated, but they do provide a vital public service to the country. It is paramount that the EA takes the wider impact of their decision into consideration when reviewing such applications from private sector operators. Otherwise, waste treatment capacity will only be made available where it suits commercial operators most, and not necessarily where it is best placed in terms of meeting local needs and providing a public service. This is vital if waste is to be treated as close to its source as possible, reducing traffic movements and carbon emissions.

All local authorities are required to have Waste Plans in place. These are important statutory planning documents that safeguard existing waste management sites, create planning policies and designate areas for potential waste management development. They are designed to ensure that regions can be self-sufficient when it comes to managing their waste and that waste is treated as close to its source as possible. 

The value of these Waste Plans is severely undermined if the EA makes significant decisions about treatment capacity at major waste facilities such as the Beddington ERF without paying any regard to them. There is a clear and obvious disconnect between local and national policy and the SLWP calls on the EA to widen the scope of their consultations as a matter of urgency. 

The SLWP boroughs remain certain that the Beddington ERF is an environmentally sustainable, cost-effective and safe way of treating household residual waste. The ERF has delivered significant benefits to the boroughs in terms of carbon reduction and financial savings since it opened in 2019. However, approving this permit variation would see the facility expand significantly in excess of its original scale and purpose and would only serve the needs of communities many miles away. We therefore call on the EA to reconsider its decision, taking into account the wider implications outlined above, and refuse Viridor’s application to treat more waste at the Beddington ERF. 


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