In response to an application made by Viridor South London Limited to vary environmental permit EPR/GP3305LN/V003.
Merton Council has reviewed Viridor’s permit variation application carefully and has reached the view that we strongly object to the request made by Viridor to increase the maximum capacity of the Beddington Energy Recovery Facility (ERF).
We remain certain that the ERF is an environmentally sustainable, cost-effective and safe way of treating household residual waste under the existing permit. The ERF has delivered significant benefits to the borough in terms of carbon reduction and savings. However, approving this permit variation would see the facility expand significantly in excess of its original scale and purpose to serve local residents.
We have set out below our six key reasons for objecting to this permit variation application, and we call on the Environment Agency to refuse Viridor’s request to increase the volume of waste treated at the Beddington facility.
1.Traffic movement and local air quality
The proposed increase in waste directly delivered into the Beddington facility is not derived from the South London Waste Partnership Boroughs domestic waste, and as such all new / additional waste will be delivered through merchant contracts directly delivering into Beddington by commercial heavy goods vehicle. This will, in turn, increase pollution and reduce air quality at a time when the Mayor of London is extending the ULEZ zone to include this very area to reduce air pollution.
2. Waste volume and demand
The Beddington Energy Recovery Facility (ERF) was built primarily to service the needs of the SLWP boroughs. A 25-year residual waste treatment contract was awarded to Viridor in 2012 on the understanding that they would build and operate a facility capable of processing up to 302,500 tonnes of waste per annum. The majority of that capacity was to be used to treat residual waste collected from households in the four SLWP boroughs. The boroughs accepted that the remaining capacity would be used for ‘third party waste’ and that this was necessary, in order to make the facility commercially viable. At a time when the only other viable option was landfill, this was an acceptable compromise in return for the significant benefits that the Beddington ERF would bring to the SLWP boroughs, both in terms of cost savings and carbon reduction.
However, Viridor would now like to treat significantly more, third party waste at the facility than was originally planned. In October 2020 (just 18 months after the facility entered into full operation), Viridor made an application to increase capacity by 15%, to 347,422 tonnes per annum (tpa). The EA considered this to be a minor variation and in December 2020 granted the applications, without any consultation. Viridor is now asking the EA for permission to increase treatment capacity again, by a further 10% to 382,286 tpa. These relatively minor variations have a cumulative effect and if this latest application is granted, it would result in the facility processing 26% more waste than it was originally permitted for a significant and unacceptable increase.
3. Sufficient waste treatment capacity
Aside from a temporary increase in waste during 2020/21 (caused by the COVID-19 pandemic lockdowns) the amount of residual waste the SLWP boroughs generate, and sends to the Beddington ERF, has been on a steady downward trend for many years. This means that Viridor already has additional capacity for third party waste, without any increase in the facility’s overall capacity.
During the planning phase for the Beddington ERF, Viridor informed local people that the facility would be designed to treat just over 300,000 tonnes of waste; there was no mention at the time of potential future increases. Residents of the SLWP region, and Beddington and surrounding areas in particular, are now asking why they should bear the brunt of more waste being trucked in from across London and further afield when the residual waste treatment needs of their boroughs are already being met.
There is also a strong argument that at a regional level, the additional capacity that Viridor is seeking is not needed. The London Mayor’s analysis of future waste treatment capacity requirements in London suggests that, “If London achieves the Mayor’s reduction and recycling targets, it will have sufficient energy from waste capacity to manage London’s non-recyclable municipal waste” (The London Plan, March 2021). This modelling predates the approval of the very significant second energy from waste facility at Belvedere (with a capacity of 655,000 tpa). In addition, Viridor themselves have just acquired the rights to develop the Thameside ERF at Tilbury (with a capacity of 350,000 tpa) and an ERF is currently under construction at Rivenhall in Essex (with a capacity of 595,000 tpa). So regionally, an additional 1.6m tpa of treatment capacity is going to come on stream in the near future. Legitimate questions therefore exist as to whether additional energy from waste capacity is required at Beddington; the London Mayor would presumably argue that it is not, and we would agree with that conclusion.
5. Operational deliverability
At an operational level we would question the Beddington ERF’s ability to manage a 10% increase in waste volume. In the permit variation application submission, Viridor has explained in detail how the ERF’s combustion control systems will be changed to allow an increase in the processing capacity from 19.83 tonnes per hour to 21.82 tonnes per hour. But questions still remain as to how all this additional material will be physically received at the site, and then how it will be managed in the waste bunker prior to treatment.
The bunker plays a key role in the receipt and pre-treatment of waste, not only ensuring there is sufficient capacity to receive waste in a controlled, permitted and covered area, but it is also key to ensuring a homogenised mix of waste is then processed through the facility. The bunker was not designed to receive 382,286 tonnes of waste. There are already times during the year when the Beddington ERF waste receipt areas operate at maximum capacity. There are also times when the waste bunker is full and Viridor are required to use the controlled overspill area in the tipping hall. Whilst there are safe operational mitigation measures in place to deal with times when the bunker is at maximum capacity, these operational measures are already in regular use. It is difficult to see how the operator can demonstrate safe receipt of an additional 10% of waste with further operational measures alone.
Any additional pressure on the Beddington ERF’s waste receipt areas also has the potential to have knock-on effects for our waste collection crews (three of the four SLWP boroughs make direct deliveries of residual waste to the facility). Any disruption or temporary cessation of the receipt of waste at the ERF due to overcapacity issues could in turn disrupt local waste collection services, with potentially serious consequences. We also have concerns about the ability of the local road network to cope with the additional traffic movements. Whilst we note that the EA does not consider the wider issue of increased vehicle movements as a reason for objection, the boroughs are nonetheless concerned about the impact these will have on local air quality and increased congestion, impacting on our residents and our ability to carry out timely and efficient waste collection operations.
We therefore object to the variation application on the grounds that the operator has not demonstrated that they can carry out the safe and efficient receipt of the additional tonnes sought.
Viridor has not yet been able to meet our expectation that the Beddington ERF should be 100% compliant with its existing environmental permit 100% of the time. We acknowledge that this is a challenging expectation to meet, given the variable nature of waste the facility treats. But we know it is possible: The Beddington ERF recently achieved a 12-month period (2 May 2021 – 3 May 2022) when there were no exceedances of any of the emissions limits. Disappointingly, since 3 May 2022, there have been six occasions when the emissions limits have been breached.
We have set out our reasons for objecting to this permit variation application and we call on the Environment Agency to refuse it.
Merton Council’s consultation response to Environment Agency, ID: ANON-83KQ-PGHH-E