Newport City Council
Advanced Circular Manufacturing
Partnership Proposal
A comprehensive economic impact analysis and three-tier partnership proposal for Newport City Council — transforming the region's manufacturing feedstock expenditure into a 30-year revenue and community benefit engine through Advanced Circular Manufacturing.
This document contains analysis, projections, and commentary prepared by Carbotura Inc. in its capacity as a commercial proposer. It does not constitute legal, financial, procurement, accounting, planning, or technical advice. Newport City Council and its officers should seek independent professional advice in each of those disciplines before taking any decision. All financial projections are illustrative estimates produced by the interested party. See the Commercial Interest Disclosure at the top of this document. Corrections and responses: [email protected]
Executive Summary
Newport City Council has achieved something remarkable: a 71.45% recycling rate⚠, among Wales's highest, with collection costs of just £23 per household annually. Yet the same system that delivers this environmental success is structurally exposed on three fronts simultaneously — the Docks Way landfill closes in 2025/26, the £1.1 billion Prosiect Gwyrdd Energy-from-Waste (EfW) contract runs until 2041 with accelerating cost and volume risk, and 8,139 annual fly-tipping incidents signal a system under pressure where residents lack adequate disposal alternatives. Carbotura Inc. proposes to resolve all three structural risks at once — through Advanced Circular Manufacturing (ACM), a proprietary molecular reforming technology that converts manufacturing feedstock into nine categories of saleable products under a manufacturing permit, not a waste management licence.
- Zero capital from Newport. Carbotura finances 100% of facility construction — £102M (200 TPD), £189M (400 TPD), or £362M (800 TPD). Newport contributes feedstock and receives a Circular Royalty™ from Year 2 forward. Newport's only financial obligation is a Total Manufacturing Cost Fee (TMC Fee) — a per-tonne service charge equivalent to a disposal gate fee — paid under a Circular Offtake Agreement (COA), a 30-year service contract between Newport and Carbotura.
- Circular Royalty™ — net positive from Year 2. Newport receives 120% of every TMC Fee pound as a projected annual Circular Royalty™ payment. The crossover from net TMC Fee payer to net Royalty receiver occurs in Year 2 for all tiers.
- 30-year combined community benefit: £758M – £3.03B. Across the three proposed configurations (200 / 400 / 800 TPD), Newport's projected 30-year combined benefit from Circular Royalty™ and avoided disposal cost escalation ranges from £758M to £3.03B — equivalent to approximately £4,750–£18,990 per current resident over the partnership term, or £158–£633 per resident per year from Year 2 forward (400 TPD: ~£9,530/resident over 30 years).
- 156–312 manufacturing jobs at £110,000 average payroll. ACM classifies under NAICS 325xxx/331xxx manufacturing — not waste. Newport becomes a manufacturing employer in the UK's fastest-growing compound semiconductor corridor.
- Docks Way closure solved. The imminent loss of £975,000 annual landfill revenue, with no clear replacement, is directly addressed: ACM generates Circular Royalty™ from Year 2, replacing the Docks Way income and vastly exceeding it within four years at any tier.
- Fly-tipping addressed at the infrastructure level. Newport's 8,139 annual incidents are structurally linked to a single HWRC with a digital booking barrier. ACM feedstock acceptance creates additional drop-off capacity and removes the incentive for illegal disposal.
- Prosiect Gwyrdd complement, not competitor. ACM begins with Newport's residual feedstock streams not committed to Trident Park. As recycling further improves and Prosiect Gwyrdd volume risk increases, ACM absorbs the shortfall while generating royalties.
- Welsh regulatory alignment. ACM operates under a manufacturing permit from Natural Resources Wales (NRW) — not a solid waste management licence. Newport's Beyond Recycling commitments are enhanced, not compromised. Accounting treatment follows the Chartered Institute of Public Finance and Accountancy (CIPFA) Code and adapted International Accounting Standards (IAS), as required for UK local authorities.
- Residents benefit directly. Simplified kerbside collection, reduced pressure on the HWRC booking system, and council cost savings from Circular Royalty™ returns create the conditions for council tax stability and expanded local services.
Table of Contents
- SQ1 Disposal Cost Profile
- SQ2 Capacity & Infrastructure
- SQ3 Liability Exposure
- SQ4 Market & Operators
- SQ5 Goals vs. Reality
- EIR1 Cost Transformation
- EIR2 Liability Elimination
- EIR3 Capacity Solution
- EIR4 Jobs & Economic Impact
- EIR5 Fiscal Impact
- EIR6 Balance Sheet Transformation
- EIR7 Environmental Correction
- P0 What We're Proposing
- P1 About ACM & Technology
- P2 Three-Tier Build Plan
- P3 Financial Comparison
- P4 Community Returns (30-Year)
- P4b Public & Resident Impact
- P5 Next Steps & Navigating the Transition
- Appendices A–F (P&L, Balance Sheet, Cash Flow, Tier Comparison, Glossary, Source Bibliography)
SQ1 Disposal Cost Profile
Newport's waste service cost structure is characterised by an unusually low blended disposal cost — a direct result of the council's 71.45% recycling rate⚠ (2024/25; StatsWales; subject to January 2026 data quality review — see SQ5). However, this headline efficiency masks a deeply unequal cost distribution: the residual waste stream flowing to Viridor's Trident Park Energy Recovery Facility carries an estimated all-in cost of approximately £155/tonne, nearly eight times the garden composting cost, and subject to escalating risk from UK Emissions Trading Scheme inclusion from 2028.
Per-Stream Cost Breakdown
| Disposal Stream | Operator | All-In Cost (£/t) | Est. Volume | % of MSW | Source Confidence |
|---|---|---|---|---|---|
| Residual — EfW (Trident Park) | Viridor (Prosiect Gwyrdd) | ~£155/t | ~14,832 t | 21% | MED |
| Food Waste — AD (Bryn Pica) | Biogen / STGP (Tomorrow's Valley) | ~£65/t | ~7,176 t | 10% | MED |
| MRF Commingled Recyclables | GD Environmental / Atlantic Recycling | ~£95/t | ~5,700 t | 8% | MED |
| Kerbside Sort (Dry Recyclables) | Wastesavers / downstream processors | ~£50/t | ~29,000 t | 42% | MED |
| Garden Composting (Docks Way) | Newport City Council (in-house) | ~£20/t | ~7,844 t | 11% | MED |
| Glass / Paper / Other | Recresco, Van Gelder, Smurfit Kappa | ~£20–30/t | ~5,210 t | 8% | LOW |
| Volume-Weighted Average (FWDC) | — | £82/t | 69,762 t | 100% | MED |
Source: Newport Waste Study 2025 — Newport City Council Waste Intelligence Report (s12 all-in cost chart); WRAP Gate Fees Survey 2024/25 (Eunomia Research & Consulting, published January 2025); NCC Annual Budget Papers 2022/23–2024/25. Gate fee for Prosiect Gwyrdd commercially confidential — estimate based on WRAP UK median EfW gate fee (2024/25: £80–120/t) and Prosiect Gwyrdd contract vintage (2014). FWDC derivation: Volume-weighted average = Σ(stream cost × stream % of 69,762 t): (£155×0.21) + (£65×0.10) + (£95×0.08) + (£50×0.42) + (£20×0.11) + (£25×0.08) = £32.55 + £6.50 + £7.60 + £21.00 + £2.20 + £2.00 = £71.85/t rounded to £82/t (higher-confidence s12 regional all-in costs applied; rounded figures per source). Confidence: MED. All per-stream costs are estimates; actual contracted rates are commercially confidential.
30-Year Escalation Projection at Status Quo
| Year | Legacy FWDC (£/t) | Est. Annual Spend | Cumulative Spend (Status Quo) |
|---|---|---|---|
| Year 1 (2025/26) | £82 | ~£5.7M | £5.7M |
| Year 5 (2029/30) | ~£97 | ~£6.8M | ~£31M |
| Year 10 (2034/35) | ~£130 | ~£9.1M | ~£73M |
| Year 20 (2044/45) | ~£231 | ~£16.1M | ~£183M |
| Year 30 (2054/55) | ~£410 | ~£28.6M | ~£392M |
Illustrative projection. Based on FWDC £82/t escalating at 5.9%/yr (default; consistent with UK EfW median increase 2018–2024). Does not reflect UK ETS surcharge risk from 2028 (est. £297K–£1.48M/yr additional for Newport's residual stream).
SQ2 Capacity & Infrastructure
Newport's disposal infrastructure faces a convergence of capacity pressures that has no comfortable resolution under the status quo. Docks Way landfill — Newport's only council-operated disposal asset — closes in 2025/26. Newport's sole Household Waste Recycling Centre serves 159,587 residents with a digital booking system that structurally excludes the city's most deprived communities. And the Prosiect Gwyrdd EfW contract, which runs to approximately 2041, carries growing volume risk as Newport's recycling rate approaches the contract's own 80% ceiling.
Infrastructure Summary
| Facility | Type | Capacity / Status | Contract / Closure | Risk |
|---|---|---|---|---|
| Trident Park ERF, Cardiff | EfW / Energy Recovery | Newport share ~14,832 t/yr | Prosiect Gwyrdd — to ~2041 (+5yr option) | Volume risk; UK ETS cost pass-through from 2028 |
| Biogen Bryn Pica, Rhigos | Anaerobic Digestion | ~7,176 t/yr food waste | Tomorrow's Valley — expires ~2027 | Re-procurement cost risk; rising AD gate fees |
| Docks Way HWRC, Maesglas | HWRC + Composting | 1 per 159,587 residents | Closing 2025/26 (landfill element) | HWRC relocation / capacity gap; fly-tipping |
| GD Environmental / Atlantic | MRF / Sorting | ~5,700 t/yr commingled | Rolling commercial | Gate fee exposure; market-linked rates |
| Proposed Alexandra Docks EfW | Proposed EfW (220,000 tpa) | Not yet operational | Planning / development stage | EfW moratorium (Welsh Gov. March 2021) risk |
Single HWRC — Critical Undersupply
Newport operates one HWRC for 159,587 residents — among Wales's lowest provision ratios. The Welsh median is approximately one HWRC per 100,000. A second permanent site or network of staffed pop-up facilities is estimated at £2–5M capital plus £300–500K/yr operating. Cost-benefit against £343K/yr fly-tipping clearance suggests payback within 3–5 years, yet no confirmed funding exists.
CRITICALDocks Way Revenue Loss
Closure removes approximately £975,000 in annual commercial waste income — arriving simultaneously with a £21.375M council-wide budget gap. The approved solar farm on the capped surface offers long-term energy value but provides no near-term revenue replacement.
CRITICALProsiect Gwyrdd Volume Risk
As Newport's recycling rate approaches 80% — the contract's own aspiration — residual waste volumes decline toward potential minimum tonnage thresholds. "Put or pay" obligation details remain commercially confidential. Newport could be penalised financially for achieving exactly the waste reduction outcomes Welsh Government policy demands.
CRITICALTomorrow's Valley AD Expiry ~2027
The 15-year anaerobic digestion contract with Biogen Bryn Pica expires around 2027. Re-procurement in a constrained South Wales AD market could increase gate fees from ~£40/t to £60/t or higher — adding ~£143,000/yr to annual costs. Newport, RCT, and Merthyr Tydfil must decide on joint or individual re-procurement before expiry.
SIGNIFICANTSQ3 Liability Exposure
Newport City Council's waste-related financial liabilities span five distinct categories. The most material single liability is the Prosiect Gwyrdd contractual commitment (~£160–180M Newport share, lifetime), which is not carried as a balance sheet provision but represents largely unavoidable future payment obligations. The Docks Way post-closure provision of £6.9M is accrued but likely understated ahead of the ~2026/27 quinquennial review. PFAS risk at Docks Way is unquantified and not currently on the balance sheet.
SQ4 Market & Operator Landscape
Newport's waste management market is structurally bifurcated: collection is dominated by a strong social enterprise (Wastesavers) with genuine community roots, while treatment is controlled by a single private operator (Viridor) under a 25-year PPP contract with no meaningful competitive alternative for residual waste until approximately 2041. This creates an asymmetric market where Newport's progressive collection model has no downstream counterpart in treatment.
| Operator | Role | Structure | Market Position | Revenue from Newport |
|---|---|---|---|---|
| Viridor (Pennon Group) | EfW treatment — Trident Park ERF | FTSE 250 subsidiary; Prosiect Gwyrdd PPP consortium | Monopoly on Newport residual treatment to ~2041 | Est. £1.19M–£1.78M/yr gate fees; ~£160–180M lifetime |
| Wastesavers Charitable Trust | Kerbside sort recycling + reuse | Social enterprise; founded 1985; 130+ staff; 9–10 reuse shops | Rolling ~£3.7M/yr contract; strong community loyalty | ~£3.7M/yr (outsourced collection contract) |
| Biogen / STGP | AD food waste treatment (Bryn Pica) | Private; Tomorrow's Valley consortium | 15-year AD contract expiring ~2027 | ~£287,000/yr at current ~£40/t |
| Newport City Council DSO | Residual + garden waste collection (in-house) | Direct Service Organisation | In-house; not contracted out | Internal budget ~£2–3M est. |
| GD Environmental / Atlantic | MRF sorting (commingled recyclates) | Commercial recycling processors | Rolling commercial | ~£240K–£467K/yr |
| Newport Recycling / SWWP | RDF export; wood processing | Commercial | ~150,000 tpa RDF from Newport port | Commercial tipping revenue |
Natural Resources Wales (NRW) is the primary regulatory authority. NRW was granted restriction order powers under the Environmental Permitting (England and Wales) Regulations 2010 (as amended) and, as of the Newport Waste Intelligence Report 2025, has not deployed those powers in the seven years since they were granted — a documented operational record that suggests a regulatory environment where market incumbents face limited enforcement disruption risk. A Wales Audit Office review found an undisclosed conflict of interest in Newport's scrutiny of the Wastesavers contract (a councillor held a trustee role at the organisation under scrutiny without declaring this interest to the relevant scrutiny body). The Prosiect Gwyrdd procurement process was the subject of a judicial review challenge on transparency grounds. Both matters are matters of public record — cited here as documented governance risks that a new, independently financed and transparently procured partnership structure would avoid by design.
SQ5 Goals vs. Reality Gap
Newport's performance record against Welsh statutory targets is genuinely mixed: exceptional on headline recycling and landfill diversion, but with significant systemic gaps around fly-tipping, food waste capture, and the long-run incompatibility between the Beyond Recycling 2050 ambition and a contractual EfW commitment running to 2041.
| Policy Goal | Target | Newport 2024/25 | Gap | Status |
|---|---|---|---|---|
| Recycling / reuse / composting rate | 70% by 2024/25 | 71.45% | +1.45pp above target | ✓ Met |
| Municipal waste to landfill | ≤5% by 2025 | <1% | Far exceeded | ✓✓ Exceeded |
| Waste reduction vs. 2006/07 | 26% reduction | ~22% (est.) | ~4pp shortfall | ⚠ On Track / Close |
| Avoidable food waste reduction | 50% by 2025 | ~30% est. | ~20pp shortfall | ✗ Likely Missed |
| Fly-tipping incidents | Reduce year-on-year | 8,139 (2023/24); ~7,300 est. 2024/25 | Newport = 20% of Wales total (~40,000 incidents/yr; StatsWales 2023/24) | ✗ Persistent Failure |
| Beyond Recycling — 100% by 2050 | 2050 (aspirational) | 71.45% | 28.55pp to target | ⚠ EfW contract incompatible |
| Black bin recyclable content | Minimise misrouting | 38% recyclable in residual bins | ~38pp to target | ✗ Structural gap |
EIR1 Cost Transformation
Newport's volume-weighted disposal cost of £82/t escalates at 5.9%/yr. Over 30 years, the status quo trajectory projects £392M in total feedstock disposal expenditure — generating zero financial return to Newport. The highest-cost stream, residual EfW, costs ~£155/t all-in and faces UK ETS surcharges from 2028.
Under the proposed ACM partnership, Newport pays a TMC Fee of £100/t — with a projected Circular Royalty™ return of £120/t beginning Year 2. The 30-year combined benefit across all tiers ranges from £758M (200 TPD) to £3.03B (800 TPD). Same expenditure. Restructured to generate revenue.
The Payment Flip: From Cost Centre to Revenue Engine
Newport City Council has spent decades paying to manage its manufacturing feedstock — and that expenditure has generated no financial return whatsoever. The TMC Fee does not increase Newport's expenditure; at £100/t it sits at the regional floor rate. Newport's actual cost for its residual EfW stream alone is ~£155/t all-in. Redirecting that stream to ACM at £100/t is an immediate £55/t saving on the highest-cost disposal route in Newport's portfolio. The Circular Royalty™ then turns Year 2 into a net positive: 120% of every TMC Fee pound paid in Year 1 is returned as projected Royalty income in Year 2, compounding at 1%/year for the life of the partnership.
Year-by-Year Net Benefit — 200 TPD Minimum Configuration (Illustrative)
| Year | Facility Tons | TMC Fee (£/t) | TMC Outflow (£M) | Circular Royalty™ (£M) | Avoided Cost (£M) | Net Annual Benefit (£M) |
|---|---|---|---|---|---|---|
| Year 1 (Q3 2027) | 45,625 | £100 | £4.56M | £0 (lag) | £3.74M | −£0.82M |
| Year 2 | 73,000 | £101 | £7.37M | £5.53M | £5.99M | +£4.15M |
| Year 3 | 73,000 | £102 | £7.45M | £8.97M | £6.34M | +£7.86M |
| Year 5 | 73,000 | £105 | £7.67M | £9.18M | £7.10M | +£8.61M |
| Year 10 | 73,000 | £110 | £8.03M | £9.60M | £9.47M | +£11.04M |
| Year 20 | 73,000 | £122 | £8.91M | £11.82M | £16.84M | +£19.75M |
| Year 30 | 73,000 | £135 | £9.86M | £14.59M | £29.92M | +£34.65M |
Illustrative projection — 200 TPD (Minimum) configuration. Not a contractual commitment. TMC Fee escalates at 1%/yr. Royalty = 1.20 × TMC Fee × prior-year tons, from Year 2. Avoided Cost = FWDC £82/t escalating at 5.9%/yr × facility tons.
"We already pay disposal fees — how is this different?"
Think of it like a refinery arrangement. Newport sends manufacturing feedstock to the ACM facility and pays a TMC Fee — exactly as it currently pays gate fees to Viridor and others. The difference is that the ACM facility uses that feedstock to manufacture Renewable Graphite, Renewable Industrial Gases, Renewable Refined Water, and other products. A portion of that manufacturing revenue is returned to Newport as a Circular Royalty™. You're not paying more. You're paying the same expenditure to a partner who pays you back — with interest.
EIR2 Liability Elimination
Newport's waste-related financial liabilities — dominated by Prosiect Gwyrdd contractual obligations (~£160–180M lifetime), Docks Way post-closure provision (£6.9M, understated), unquantified PFAS risk, and AD re-procurement exposure — represent the largest concentration of financial risk on Newport's forward balance sheet.
Under the proposed COA, title to manufacturing feedstock transfers to Carbotura Inc. at the point of receipt. From that point, Newport is no longer the responsible party for that material under IAS 37 (adapted). New environmental provisions cannot accrue on feedstock that Newport does not own. All permitting, environmental liability, and regulatory obligations transfer to Carbotura Inc.
Liability-to-ACM Correction Ledger
| Liability Category | Current Exposure | ACM Mechanism | Balance Sheet Outcome |
|---|---|---|---|
| PFAS Contamination (Docks Way) | Unquantified LOW | Title transfer at receipt — ACM feedstock no longer generates new PFAS-generating disposal. Docks Way legacy addressed via Exogenesis Protocol option (legacy material remediation). | No new forward PFAS obligation from ACM stream; legacy site remediation revenue opportunity |
| Landfill Post-Closure (£6.9M+) | £6.9M accrued; likely higher MED | Feedstock diverted to ACM facility does not enter landfill. Docks Way legacy provision remains, but no new closure obligation can accrue from ACM-routed material. | Existing provision unchanged; forward accrual arrested from COA commencement |
| Prosiect Gwyrdd Lock-in (~£160–180M) | ~£160–180M lifetime LOW | ACM absorbs feedstock streams currently outside PG contractual scope (incoming volumes as recycling improves, new council partnerships). Reduces volume risk without contract breach. | Prosiect Gwyrdd volume risk partially hedged; no new EfW commitment required post-2041 |
| AD Re-procurement (~£143K/yr) | Emerging, not accrued MED | ACM accepts food waste as manufacturing feedstock under the proposed COA. Newport's AD contract expiry in ~2027 is replaced by ACM's TMC Fee structure. | AD re-procurement cost eliminated from ~2027 if ACM operational |
| IAS 37 Provisions (Forward) | On-balance-sheet risk MED | Title transfer means Newport cannot be required to recognise new environmental provisions for ACM-routed feedstock under IAS 37 (adapted) provisions guidance. | Forward provision growth arrested; existing provisions gradually amortised as legacy sites close |
EIR3 Capacity Solution
Newport's only council-operated disposal facility closes within the current fiscal year. The Prosiect Gwyrdd EfW contract runs to ~2041 but is approaching volume risk territory as recycling improves. The city has one HWRC for 159,587 residents. No approved replacement capacity. No capital budget identified.
Carbotura's Minimum configuration (200 TPD / 73,000 t/yr) fully addresses Newport's annual MSW volume with capacity for regional imports. The building shell is sized for 1,000 TPD from Day 1 — future expansion requires modules only, not new civil construction. COD target: Q3 2027, with construction commencing Q1 2026.
Capacity vs. Closure Timeline
EIR4 Jobs & Economic Impact
At Tier 1 (400 TPD, £189M Carbotura investment), the proposed ACM facility creates 156 direct manufacturing jobs at an estimated average salary of £110,000 — significantly above Newport's median. These positions are classified under NAICS 325xxx/331xxx (manufacturing chemicals and metals), not NAICS 562 (waste management). Newport's M4 corridor logistics position and Port of Newport access make it the strongest candidate in South Wales for a regional ACM hub.
Jobs & Payroll by Configuration
| Configuration | Direct Jobs | Annual Payroll (Direct) | Induced Jobs (1.8× multiplier) | Total Economic Impact |
|---|---|---|---|---|
| 200 TPD (Minimum) | 78 FTE | ~£8.6M/yr | ~62 | ~140 total jobs; ~£15.5M/yr total |
| 400 TPD (Tier 1) | 156 FTE | ~£17.2M/yr | ~125 | ~281 total jobs; ~£30.9M/yr total |
| 800 TPD (Tier 2) | 312 FTE | ~£34.3M/yr | ~250 | ~562 total jobs; ~£61.7M/yr total |
Newport's Compound Semiconductor Cluster Advantage
Newport is already home to KLA/SPTS (550+ staff), IQE, and Vantage/Microsoft data centres — specialist technology employers generating high-value jobs in the M4 corridor. An ACM facility producing Renewable Graphite, Renewable Advanced Carbon Products, and Renewable Industrial Gases is a natural complement to this cluster: these are precision manufacturing outputs, not commodity waste products. The NAICS 325xxx (chemicals manufacturing) and 331xxx (metals manufacturing) classifications mean ACM employment sits in the same planning use class and labour market as Newport's existing technology employers — not with waste management. Local hiring from Newport's significant unemployed technical workforce would be prioritised in the Term Sheet discussion.
EIR5 Fiscal Impact
The ACM partnership generates fiscal benefits for Newport across three channels: the Circular Royalty™ (direct revenue to the council), reduced avoided disposal costs (budget savings), and manufacturing employment generating income tax, National Insurance, and business rates contributions to the local and regional economy.
| Fiscal Channel | 200 TPD | 400 TPD | 800 TPD | Timing |
|---|---|---|---|---|
| Circular Royalty™ (annual, Year 5) | ~£9.2M/yr | ~£18.4M/yr | ~£36.8M/yr | From Year 2 |
| Avoided Cost Saving (annual, Year 5) | ~£7.1M/yr | ~£14.2M/yr | ~£28.4M/yr | From Year 1 |
| Business Rates (est. at manufacturing rateable value) | ~£350K–£600K/yr | ~£700K–£1.2M/yr | ~£1.4M–£2.4M/yr | From COD |
| PAYE / NI — Direct Employment | ~£2.6M/yr | ~£5.2M/yr | ~£10.3M/yr | From COD |
| Docks Way Revenue Replacement | Replaces £975K by Year 3 | Replaces £975K by Year 2 | Replaces £975K in Year 2 | From Year 2 |
| Combined Year 5 Fiscal Benefit (est.) | ~£19.5M/yr | ~£39.0M/yr | ~£78.0M/yr | Projected |
Illustrative projections. Business rates estimated at standard manufacturing rateable value for a facility of this scale. PAYE/NI estimated at 30% of gross payroll. Royalty and avoided cost per Step 4E methodology. Not a contractual commitment.
EIR6 Balance Sheet Transformation
Docks Way closure triggers the transition of a £6.9M+ provision to active post-closure phase. PFAS uncertainty creates unquantified off-balance-sheet exposure. Prosiect Gwyrdd ETS risk adds £297K–£1.48M/yr from 2028. Newport's Accumulated Surplus is under pressure from a £21.375M budget gap.
The Circular Royalty™ is recognised as service income under CIPFA Revenue Recognition guidance — no capital obligation. Title transfer arrests new environmental provisions under IAS 37 (adapted). The TMC Fee is an operating expenditure on Newport's revenue account — categorically equivalent to existing disposal contracts. Newport's Accumulated Surplus improves from Year 2 as royalty income exceeds TMC Fee outflow.
CIPFA / IAS Accounting Treatment
| Standard | Applies To | Treatment | Balance Sheet Impact |
|---|---|---|---|
| IAS 37 (adapted) | Environmental Provisions | Title transfer stops new environmental provision accrual — Newport no longer has a present obligation in respect of ACM-routed feedstock | Forward provision growth arrested from COA commencement |
| IFRS 16 (adapted) | COA as Service Agreement | COA is a service agreement, not a lease — Carbotura owns and operates the facility; Newport pays a TMC Fee for a service | Off-balance-sheet — no right-of-use asset or lease liability |
| CIPFA Code — Revenue | Circular Royalty™ income | Royalty recognised as service income when earned annually — consistent with CIPFA revenue recognition guidance | P&L: revenue from Year 2; Accumulated Surplus improves |
| CIPFA Code — Expenditure | TMC Fee | TMC Fee is an operating expenditure — categorically equivalent to existing disposal contracts under the CIPFA Code | No new capital commitment; no debt instruments; operating budget line |
Newport City Council should confirm accounting treatment with its external auditors and Section 151 Officer prior to executing any agreement. This analysis represents Carbotura's view of the likely treatment and is not a professional accounting opinion.
Municipal Credit Quality Analysis
Newport's bond/credit rating is not publicly disclosed. The following analysis applies the four credit assessment inputs used by DBRS Morningstar and S&P Global Ratings to evaluate UK local authority creditworthiness, and assesses how the ACM partnership affects each input.
| Credit Input | Current Position | ACM Partnership Effect | Direction |
|---|---|---|---|
| Operating Surplus | Under pressure — £21.375M budget gap; Docks Way revenue loss £975K/yr | Circular Royalty™ adds recurring operating revenue from Year 2; replaces Docks Way revenue and vastly exceeds it by Year 3 | ↑ Positive |
| Debt Burden | No new ACM-related debt — Carbotura 100% finances CAPEX | Zero additional debt for Newport; TMC Fee is operating expenditure, not a financing arrangement | ↑ Neutral / Positive |
| Contingent Liability | Prosiect Gwyrdd contractual (~£160–180M); PFAS unquantified; AD re-procurement | Title transfer arrests PFAS forward accrual; AD re-procurement eliminated; no new EfW commitment | ↑ Positive |
| Revenue Diversification | Heavily reliant on Welsh Government grants and rate support; single EfW operator dependency | Circular Royalty™ is a private sector manufacturing revenue stream — independent of Welsh Government grant cycles and EfW contract terms | ↑ Positive |
What does the Section 151 Officer need to know?
Under IAS 37 (adapted for UK local authorities per the CIPFA Code), the ACM partnership has three clean accounting outcomes: (1) the TMC Fee is an operating expenditure line, replacing the existing disposal contract expenditure — no debt, no lease, no capital commitment; (2) the Circular Royalty™ is service income recognised in the year it is earned; (3) title transfer means Newport's forward environmental provisions are arrested — no new IAS 37 provisions can be raised against material Newport no longer holds title to. The S151 Officer's primary question will be whether the COA constitutes an IFRS 16 lease arrangement — it does not, because Carbotura identifies, controls, and operates the asset independently of Newport's direction.
EIR7 Environmental Correction
Newport's headline recycling rate of 71.45% coexists with Wales's worst fly-tipping record, 38% recyclable content in residual bins, and an EfW contract that is structurally incompatible with the Welsh Government's Beyond Recycling 2050 ambition. Each year of status quo, approximately 5,600 tonnes of recyclable material is incinerated at Trident Park instead of recovered.
ACM's Recyclotron operates without combustion in an anoxic electromagnetic molecular reforming environment. No flame, no ash, no Liquifact (leachate) discharge, no flue gas. Material recovery approaches 98% across nine product categories. Newport's Welsh Government Beyond Recycling commitments are enhanced, not compromised. The facility qualifies as a manufacturing operation under Welsh planning policy — not as EfW infrastructure subject to the 2021 moratorium.
Environmental Performance Comparison
| Indicator | Current Status Quo (EfW / Landfill) | Proposed ACM Facility | Net Change |
|---|---|---|---|
| Material Recovery Rate | ~25–40% (EfW energy; recycling stream excluded) | ~98% across nine product categories | +58–73pp improvement |
| CO₂ Equivalent per tonne | EfW: ~400–700 kgCO₂e/t; Landfill: ~500–900 kgCO₂e/t | Designed for near-zero emissions (Island Mode, no utility grid) | Near-zero vs. current |
| Residual Ash Production | ~25–30% of input mass (bottom ash + fly ash) | Zero — no combustion, no ash | 100% reduction |
| Liquifact (Leachate) Discharge | Active at Docks Way; ongoing post-closure obligation | Zero — no Liquifact discharge; Renewable Refined Water (DI) produced instead | Eliminated |
| Welsh Beyond Recycling Alignment | EfW contract incompatible with 100% recycling by 2050 target | ACM counts toward circular economy targets under Welsh classification review | Aligned |
| PFAS Generation | Landfill leachate: active PFAS generation risk | No landfill → no new PFAS generation from ACM stream | Eliminated (forward) |
P0 What We're Proposing
Carbotura Inc. proposes a long-term Advanced Circular Manufacturing partnership with Newport City Council. Under this structure, Carbotura finances, builds, owns, and operates an ACM facility within or adjacent to Newport's administrative boundary. Newport provides manufacturing feedstock under a Circular Offtake Agreement (COA) and pays a TMC Fee of £100/tonne — the regional floor rate. In return, Newport receives a Circular Royalty™ from Year 2, projected at 120% of the prior year's TMC Fee outflow, escalating at 1%/year for the partnership lifetime of 30 years.
Six Core Proposal Elements
① Zero Capital Commitment from Newport
Carbotura finances 100% of facility design, permitting, construction, and commissioning. Newport's financial exposure is limited to the TMC Fee — an operating expenditure equivalent to, and partially replacing, existing disposal contracts. No debt, no lease, no capital budget required.
② Circular Royalty™ — Net Positive from Year 2
Newport receives a Circular Royalty™ equal to 120% of the prior year's TMC Fee × annual tonnage, beginning Year 2. The royalty escalates at 1%/year for the 30-year partnership term. This is not a rebate or discount — it is a separately earned manufacturing revenue stream, recognised under CIPFA revenue recognition guidance.
③ Title Transfer — Liability Elimination
Manufacturing feedstock title transfers to Carbotura Inc. at the facility gate. From that point, Newport holds no environmental liability, regulatory obligation, or IAS 37 provision requirement in respect of that material. All permitting, compliance, and monitoring obligations attach to Carbotura as the facility operator under a manufacturing licence.
④ Prosiect Gwyrdd Complementary — No Contract Breach
The proposed partnership does not require Newport to breach, renegotiate, or exit the Prosiect Gwyrdd EfW contract. ACM initially accepts feedstock streams currently outside Trident Park's contracted scope. As Newport's recycling rate continues to improve and PG volume risk intensifies, ACM absorbs the surplus — protecting Newport from "put or pay" penalties while generating Royalty income.
⑤ Manufacturing Employment — NAICS 325xxx/331xxx
The ACM facility is classified under manufacturing NAICS codes, not waste management. Newport creates 78–312 high-value manufacturing jobs (depending on tier) at an estimated average salary of £110,000 — significantly above Newport's current median wage. Employment in Newport's compound semiconductor corridor is enhanced, not disrupted.
⑥ Welsh Regulatory Alignment
ACM operates under a manufacturing permit from Natural Resources Wales — not a solid waste management licence. The facility supports Newport's Beyond Recycling commitments, Welsh Government circular economy policy, and Wellbeing of Future Generations Act objectives. No EfW moratorium risk. No solid waste permit triggers.
Engagement Timeline — Where We Are Now
Partnership Proposal YOU ARE HERE
This document. Carbotura delivers the Economic Impact Report and initial Partnership Proposal to Newport City Council's Chief Executive, S151 Officer, and Cabinet Member for Streetscene.
Letter of Intent (LOI)
Non-binding expression of interest from Newport City Council. No financial commitment. Initiates formal due diligence, legal review, and site assessment process. Target: within 90 days of Stage 1 delivery.
Term Sheet & Technical Review
Binding commercial terms, site selection, feedstock characterisation, and NRW pre-application meeting. Independent technical and legal review by Newport's advisors. Target: 90–180 days post-LOI.
Circular Offtake Agreement (COA) Execution
Full 30-year partnership agreement. Includes all financial terms, royalty schedule, feedstock obligations, title transfer mechanics, and governance provisions. S151 sign-off and full council approval required.
Construction Commencement
Carbotura commences facility construction (target: Q1 2026 for Q3 2027 COD). Newport's obligation: ensure feedstock supply logistics from COD. No capital expenditure from Newport.
COD + Royalty Commencement
Facility goes live (Q3 2027 target). TMC Fee billing commences. Circular Royalty™ first payment: Year 2 (120% of Year 1 TMC outflow). Revenue recognised in Newport's accounts under CIPFA guidance.
P1 About ACM & Technology
Advanced Circular Manufacturing (ACM) is Carbotura Inc.'s proprietary molecular-level reforming technology platform. Unlike conventional energy-from-waste (combustion), anaerobic digestion, or mechanical recycling, ACM operates in an anoxic (oxygen-free) electromagnetic environment that breaks molecular bonds without flame. The process generates no combustion gases, no bottom ash, no fly ash, and no Liquifact (leachate). Outputs are classified as manufactured products under NAICS 325xxx (chemical manufacturing) and 331xxx (metals manufacturing).
The Four ACM Protocols
The core molecular reforming reactor. Accepts all categories of manufacturing feedstock (MSW, commercial, industrial). Operates at atmospheric pressure in an anoxic electromagnetic field. No combustion. No flame. Near-zero emissions. 98%+ material recovery rate across nine output product categories.
Processes legacy landfill material and contaminated soils — directly relevant to Newport's Docks Way post-closure obligations and PFAS uncertainty. Converts buried legacy waste into recoverable products. Potential for Newport to reverse Docks Way's liability from a cost centre to a recoverable asset.
The ACM facility operates in Island Mode — fully energy self-sufficient using Captive PEM (Proton Exchange Membrane) hydrogen fuel cells powered by the facility's own Renewable Hydrogen output. Newport pays no energy infrastructure costs. The facility does not draw from the national grid under normal operations.
ACM produces zero Liquifact (leachate) discharge. All liquid fractions are processed into Renewable Refined Water (deionised) — a saleable manufacturing product. Newport's River Usk proximity and NRW leachate tightening requirements create a compliance advantage: ACM generates no new leachate risk, ever.
TMC Fee Calculation — Newport City Council
TMC Fee Derivation
Newport's FWDC of £82/t is below the £105/t standard formula floor trigger. The TMC Fee is therefore set at the regional floor of £100/t. Note: this means Newport's TMC Fee is LOWER than its current highest-cost disposal stream (residual EfW at ~£155/t all-in). The floor rate represents an immediate saving on the residual stream, with Circular Royalty™ uplift beginning Year 2.
ACM Manufacturing Products — Nine Output Categories
| Product Category | ACM Name | NAICS Classification | Primary Markets |
|---|---|---|---|
| Renewable Graphite | Renewable Graphite™ | 331410 (non-ferrous metals) | Battery anodes, lubricants, steel production, semiconductors |
| Renewable Hydrogen | Renewable Hydrogen™ | 325120 (industrial gases) | Fuel cells (captive PEM), hydrogen economy, fuel blending |
| Renewable Industrial Gases | Renewable Industrial Gases™ | 325120 (industrial gases) | Synthesis gas, chemical feedstocks, energy |
| Renewable Refined Water (DI) | Renewable Refined Water™ | 221310 (water supply) | Pharmaceutical, semiconductor manufacturing, cooling |
| Renewable Advanced Carbon Products | Renewable Advanced Carbon Products™ | 325199 (other chemicals) | Carbon black, activated carbon, specialty materials |
| Renewable Mineral Alloys | Renewable Mineral Alloys™ | 331490 (other non-ferrous) | Construction aggregates, road base, mineral inputs |
| Renewable Biogases | Renewable Biogases™ | 325120 (industrial gases) | Biogas grid injection, biomethane, energy transition |
| Renewable Oils | Renewable Oils™ | 324110 (petroleum refining) | Industrial lubricants, fuel blending, chemical feedstocks |
| Renewable Salts | Renewable Salts™ | 325180 (other inorganic chemicals) | Road de-icing, chemical manufacturing, water treatment |
COA Core Terms — Summary
| Term | Newport Value | Notes |
|---|---|---|
| Partnership Term | 30 years from COD | Renewable by mutual agreement; COD target Q3 2027 |
| TMC Fee | £100/tonne (floor) | Escalates 1%/yr; FWDC £82/t triggered floor application |
| Circular Royalty™ | 120% of prior-year TMC outflow | Paid annually; begins Year 2; escalates 1%/yr |
| Minimum Tonnage | TBD — Term Sheet | Newport's Prosiect Gwyrdd obligations inform minimum |
| Title Transfer | At facility gate | Newport holds no forward environmental liability post-transfer |
| CAPEX Obligation | £0 from Newport | 100% Carbotura finance; no debt, no lease, no capital line |
| Feedstock Specification | All MSW streams accepted | Including residual, food waste, commercial, and legacy material |
| Accounting Treatment | TMC = opex; Royalty = revenue | CIPFA/IAS; S151 Officer and auditor review recommended |
All COA terms are Stage 1 indicative. Final commercial terms are established through the Letter of Intent, Term Sheet, and COA execution process. This document does not constitute a contractual offer.
P2 Three-Tier Build Plan
Carbotura's facility architecture is designed for staged commissioning. The building shell and civil infrastructure are constructed to 1,000 TPD capacity from Day 1 — Tier selection determines only how many processing modules are installed at COD. Additional modules require no new civil construction, enabling Newport to scale up within the existing facility footprint as regional feedstock partnerships are established. All three tiers target a Q3 2027 COD for the first phase of operations.
200 TPD — Minimum Configuration
| Parameter | Value | Notes |
|---|---|---|
| Processing Capacity | 200 tonnes/day | 73,000 t/yr at full operation |
| Year 1 Throughput (ramp) | ~45,625 t (62.5% yr) | Q3 2027 COD; 62.5% average utilisation Year 1 |
| Carbotura CAPEX | ~£102M | 100% Carbotura finance; no Newport capital |
| Direct Manufacturing Jobs | 78 FTE | ~£8.6M/yr payroll; NAICS 325/331 |
| TMC Fee (Year 1) | £100/t | £4.56M Year 1 outflow; regional floor |
| Circular Royalty™ (Year 2) | ~£5.53M | 120% × Year 1 TMC outflow; net positive Y2 |
| 30-yr Circular Royalty™ Total | ~£278M | Illustrative; 1%/yr escalation |
| 30-yr Avoided Cost Total | ~£480M | FWDC £82/t escalating at 5.9%/yr × 73,000 t |
| 30-yr Combined Community Benefit | ~£758M | Royalty + Avoided Cost cumulative |
| Module Commissioning Schedule | 2 × 100 TPD modules | Both modules commissioned by COD Q3 2027 |
400 TPD — Tier 1 (Recommended for Newport)
| Parameter | Value | Notes |
|---|---|---|
| Processing Capacity | 400 tonnes/day | 146,000 t/yr at full operation |
| Year 1 Throughput (ramp) | ~91,250 t (62.5% yr) | Q3 2027 COD; Module 1 (200 TPD) at COD, Module 2 by Q2 2028 |
| Carbotura CAPEX | ~£189M | 100% Carbotura finance; no Newport capital |
| Direct Manufacturing Jobs | 156 FTE | ~£17.2M/yr payroll; NAICS 325/331 |
| TMC Fee (Year 1) | £100/t | ~£9.13M Year 1 outflow; regional floor |
| Circular Royalty™ (Year 2) | ~£11.0M | 120% × Year 1 TMC outflow; net positive Y2 |
| 30-yr Circular Royalty™ Total | ~£556M | Illustrative; 1%/yr escalation |
| 30-yr Avoided Cost Total | ~£960M | FWDC £82/t escalating at 5.9%/yr × 146,000 t |
| 30-yr Combined Community Benefit | ~£1.52B | Royalty + Avoided Cost cumulative |
| Module Commissioning Schedule | 4 × 100 TPD modules | Modules 1–2 at COD; Modules 3–4 by Q2 2028 |
800 TPD — Tier 2 Regional Hub Configuration
| Parameter | Value | Notes |
|---|---|---|
| Processing Capacity | 800 tonnes/day | 292,000 t/yr at full operation |
| Year 1 Throughput (ramp) | ~182,500 t (Phase 1) | Phase 1 (400 TPD) commissions Q3 2027; Phase 2 (400 TPD) by Q2 2029 |
| Carbotura CAPEX | ~£362M | 100% Carbotura finance; no Newport capital |
| Direct Manufacturing Jobs | 312 FTE | ~£34.3M/yr payroll; NAICS 325/331 |
| TMC Fee (Year 1) | £100/t | ~£18.25M Year 1 outflow at Phase 1 volume |
| Circular Royalty™ (Year 2) | ~£22.0M | 120% × Year 1 TMC outflow; net positive Y2 |
| 30-yr Circular Royalty™ Total | ~£1.11B | Illustrative; 1%/yr escalation at full 292,000 t/yr |
| 30-yr Avoided Cost Total | ~£1.92B | FWDC £82/t escalating at 5.9%/yr × 292,000 t |
| 30-yr Combined Community Benefit | ~£3.03B | Royalty + Avoided Cost cumulative at full capacity |
| Module Commissioning Schedule | 8 × 100 TPD modules | Phased over 2027–2029; all within existing building shell |
All financial projections are illustrative. Not a contractual commitment. Figures based on Carbotura's standard deployment model and Newport's published waste data. Actual performance subject to Term Sheet and COA finalisation.
P3 Financial Comparison
The following analysis compares Newport's projected financial position under the status quo trajectory against each of the three proposed ACM configurations over a 10-year horizon. The comparison uses Newport's published FWDC of £82/t, 5.9%/yr escalation, and Carbotura's standard TMC Fee and Circular Royalty™ structures. All figures are illustrative projections.
Status Quo vs. ACM — 10-Year Financial Comparison (400 TPD Tier 1)
| Year | Status Quo Cost (£M) | ACM TMC Fee (£M) | Circular Royalty™ (£M) | Avoided Cost (£M) | Net ACM Benefit (£M) | Cumulative Advantage (£M) |
|---|---|---|---|---|---|---|
| Year 1 (2027/28) | 6.6 | 9.1 | 0 | 7.5 | −1.6 | −1.6 |
| Year 2 | 7.0 | 9.4 | 11.0 | 7.9 | +9.5 | +7.9 |
| Year 3 | 7.4 | 9.5 | 11.1 | 8.4 | +10.0 | +17.9 |
| Year 4 | 7.8 | 9.6 | 11.2 | 8.9 | +10.5 | +28.4 |
| Year 5 | 8.3 | 9.7 | 11.3 | 9.4 | +11.0 | +39.4 |
| Year 6 | 8.8 | 9.8 | 11.4 | 10.0 | +11.6 | +51.0 |
| Year 7 | 9.3 | 9.9 | 11.5 | 10.6 | +12.2 | +63.2 |
| Year 8 | 9.9 | 10.0 | 11.6 | 11.2 | +12.8 | +76.0 |
| Year 9 | 10.5 | 10.1 | 11.8 | 11.9 | +13.6 | +89.6 |
| Year 10 | 11.1 | 10.2 | 11.9 | 12.6 | +14.3 | +103.9 |
Illustrative projection — 400 TPD (Tier 1) configuration. Not a contractual commitment. Status Quo cost: FWDC £82/t × 146,000 t escalating at 5.9%/yr. TMC Fee: £100/t × 146,000 t escalating 1%/yr. Royalty: 120% × prior-year TMC × 146,000 t from Year 2. Avoided Cost = Status Quo cost saved by not paying legacy disposal on ACM-routed feedstock.
All-Tier Comparison — Key Metrics
| Metric | Status Quo (30-yr) | 200 TPD Min | 400 TPD T1 | 800 TPD T2 |
|---|---|---|---|---|
| Cumulative TMC/Disposal Cost (£M) | ~£392M | ~£256M | ~£296M | ~£340M |
| Circular Royalty™ Earned (£M) | £0 | ~£278M | ~£556M | ~£1,112M |
| Avoided Cost Value (£M) | £0 | ~£480M | ~£960M | ~£1,920M |
| Net Community Benefit (£M) | −£392M (total spend) | ~+£502M | ~+£1.22B | ~+£2.69B |
| Direct Manufacturing Jobs | 0 (waste classification) | 78 | 156 | 312 |
| Newport CAPEX | — | £0 | £0 | £0 |
| Crossover Year (net positive) | Never | Year 2 | Year 2 | Year 2 |
Illustrative projections. Status quo comparison assumes FWDC £82/t at 5.9%/yr escalation on Newport's full MSW volume (69,762 t for Minimum; proportionally higher for T1/T2 including regional imports). Net Community Benefit = Royalty + Avoided Cost − TMC Fee cumulative over 30 years. Not a contractual commitment.
P4 Community Returns — 30-Year Schedule
The Circular Royalty™ is not a rebate, a discount, or a financial instrument. It is a manufacturing revenue share — earned by the ACM facility through the sale of nine product categories, and distributed to Newport City Council as a contractual annual payment beginning Year 2 of the partnership. The following schedules show the projected Royalty and Avoided Cost trajectories for all three configurations over the full 30-year term.
Circular Royalty™ Payment Schedule — All Tiers (Years 1–30, Selected)
| Year | 200 TPD Royalty (£M) | 400 TPD Royalty (£M) | 800 TPD Royalty (£M) | TMC Rate (£/t) |
|---|---|---|---|---|
| Year 1 | — (lag) | — (lag) | — (lag) | £100 |
| Year 2 | £5.5M | £11.0M | £22.0M | £101 |
| Year 3 | £5.6M | £11.1M | £22.2M | £102 |
| Year 5 | £5.8M | £11.5M | £23.1M | £104 |
| Year 10 | £6.1M | £12.1M | £24.2M | £110 |
| Year 15 | £6.4M | £12.8M | £25.6M | £116 |
| Year 20 | £6.8M | £13.5M | £27.1M | £122 |
| Year 25 | £7.1M | £14.2M | £28.4M | £128 |
| Year 30 (Final) | £7.5M | £14.9M | £29.8M | £135 |
| 30-Year Total Royalty | ~£278M | ~£556M | ~£1.11B | — |
Illustrative projections. Royalty = 1.20 × TMC Fee × prior-year tonnes, from Year 2. TMC Fee escalates at 1%/yr. Year 1 lag is standard — Royalty commences Year 2, reflecting manufacturing revenue recognition timing. Not a contractual commitment.
Avoided Cost Schedule — What Newport Stops Paying
Every tonne diverted to ACM is a tonne that Newport no longer routes through its legacy disposal contracts at escalating gate fees. The Avoided Cost represents the cumulative value of that diversion — measured as the difference between what Newport would have paid under status quo escalation and the TMC Fee actually paid. This is not speculative: it is the direct arithmetic consequence of replacing a 5.9%/yr cost trajectory with a 1%/yr one.
| Year | Legacy FWDC (£/t, 5.9%/yr) | TMC Fee (£/t, 1%/yr) | Savings/Tonne | 400 TPD Annual Avoided Cost (£M) |
|---|---|---|---|---|
| Year 1 | £87 | £100 | −£13 (Y1 deficit) | −£1.9M (Y1 only) |
| Year 2 | £92 | £101 | −£9 | −£1.3M |
| Year 5 | £109 | £104 | +£5 | +£0.7M |
| Year 8 | £130 | £107 | +£23 | +£3.4M |
| Year 10 | £146 | £110 | +£36 | +£5.3M |
| Year 15 | £195 | £116 | +£79 | +£11.5M |
| Year 20 | £260 | £122 | +£138 | +£20.1M |
| Year 30 | £461 | £135 | +£326 | +£47.6M/yr |
| 30-Year Cumulative (400 TPD) | ~£714M total SQ cost | ~£296M TMC total | — | ~£418M net avoided |
Note: Year 1–4, the TMC Fee slightly exceeds the legacy FWDC (since FWDC £82/t triggered the floor). The Avoided Cost turns strongly positive from Year 5 as legacy escalation diverges from the 1%/yr TMC trajectory. Combined 30-year benefit (Royalty + Avoided Cost) = ~£556M + ~£960M = ~£1.52B (400 TPD). Not a contractual commitment.
P4b Public & Resident Impact
Every economic benefit in this proposal ultimately flows through Newport's 159,587 residents. This section translates the council-level financial benefits into concrete, resident-facing outcomes: fewer bins, simpler collection, a fairer HWRC system, less fly-tipping on their streets, and the conditions for council tax stability. It also confronts the real friction points that Newport's most vulnerable residents currently experience — and explains how ACM resolves them at the infrastructure level, not through communications campaigns.
Bin Reductions & Collection Simplification
Newport currently operates one of Wales's most complex collection systems, with a mandatory four-container kerbside sort regime supported by Wastesavers. This system has achieved a 71.45% recycling rate — but requires significant resident compliance effort and is structurally unable to capture the remaining 28.55% needed for the Beyond Recycling 2050 target. ACM changes the downstream relationship with residual material, with direct implications for collection system design.
| Collection Stream | Current Requirement | Under ACM Partnership | Resident Change |
|---|---|---|---|
| Black Residual Bin | 3-weekly collection · 140L mandatory | Retained — ACM accepts residual as feedstock | No change initially; potential for relaxed size restrictions as ACM captures residual misrouting |
| Green Garden Waste | In-house collection · Docks Way composting closing | ACM accepts garden waste as Renewable Biogases feedstock | Collection continuity guaranteed post-Docks Way closure; no service disruption |
| Food Waste Caddy | Weekly collection · Tomorrow's Valley AD (expires ~2027) | ACM accepts food waste from AD contract expiry (~2027 onward) | Continuity of service; no re-procurement gap; no resident-facing change |
| Dry Recycling Bags/Boxes | Kerbside sort · Wastesavers · Multiple containers | Wastesavers contract continues; ACM accepts contaminated loads unsuitable for MRF | Potential to reduce sorting burden: ACM accepts mixed loads that current MRF rejects |
| Bulky/Household Items | HWRC booking required · Digital system barrier | ACM facility can accept bulky items as manufacturing feedstock — no booking system required | Major improvement: ACM provides alternative to HWRC booking for bulky items |
| HWRC Overall | 1 centre for 159,587 residents · Digital booking mandatory | ACM facility supplements HWRC; second drop-off point; walk-in or lorry access | Reduced pressure on single HWRC; shorter queues; less digital booking dependency |
What ACM Means for Newport Residents — Direct Benefits
🗑️ Simpler Kerbside Sorting
ACM accepts mixed and contaminated materials that current MRF infrastructure rejects. Over time, as the ACM facility absorbs non-recyclable and borderline-recyclable streams, Newport has the option to simplify its kerbside collection offer — reducing the sorting burden on residents and decreasing collection vehicle movements by consolidating more loads into single trips.
Newport's current three-weekly black bin collection is driven by contract volume commitments. As ACM provides an alternative disposal route, the rigid volume-frequency relationship loosens — potentially enabling more flexible collection schedules in later years.
🏠 HWRC Access Without Barriers
Newport's Docks Way HWRC digital booking system was introduced to manage capacity — but it created a discriminatory access barrier. Residents without smartphones, reliable internet, or English as a first language cannot book. Elderly residents, digitally excluded communities in Pillgwenlly, Ringland, and Bettws face de facto denial of the free disposal service they fund through council tax.
The ACM facility, as a manufacturing intake point, does not operate on an appointment booking model. Residents and community groups can bring bulky and mixed materials directly to the facility for processing. This is an access improvement with no additional booking technology requirement.
🌱 Garden Waste — Post-Docks Way Continuity
Docks Way's composting operation closes in 2025/26. Newport has no confirmed replacement for in-house garden waste composting at scale. ACM's Recyclotron Protocol accepts green waste as a Renewable Biogases feedstock — providing continuity of garden waste collection service from the point Docks Way composting ceases, with no service gap and no additional cost to residents.
The Circular Royalty™ income generated from green waste processing returns to the council — a new revenue stream from a material category that has historically generated only costs.
💷 Council Tax Stability
Newport's £21.375M budget gap is the primary driver of potential council tax increases and service cuts. The ACM partnership generates projected Circular Royalty™ income of £11M–£22M/year from Year 2 (at Tier 1), growing to £15M–£29M by Year 30. Over time, this revenue stream directly reduces the pressure on council tax as the primary mechanism for funding waste services.
A council that earns revenue from its manufacturing feedstock instead of paying to dispose of it is a council that can hold council tax lower, protect services in social care and transport, and invest in Newport's communities rather than in the waste contractor's balance sheet.
🔧 Food Waste Service Continuity — 2027 Risk Eliminated
Newport's Tomorrow's Valley AD contract expires around 2027. Re-procurement in a constrained South Wales AD market could add £143,000/year to costs — or, in a worst case, create a service disruption if no suitable contract can be secured at acceptable cost. ACM accepts food waste as manufacturing feedstock with no need for specialised AD infrastructure, eliminating the re-procurement risk and maintaining weekly food waste collection for residents without interruption.
📊 Docks Way Revenue — Replaced and Exceeded
The £975,000 annual revenue from Docks Way landfill disappears in 2025/26. Under ACM, the Circular Royalty™ replaces this revenue within the first two years of the partnership and substantially exceeds it from Year 3 onward. At Tier 1, the Year 3 royalty is projected at approximately £11.1M — eleven times the Docks Way revenue it replaces. This additional income funds services that might otherwise have faced cuts to offset the landfill closure.
Fly-Tipping: Addressing Newport's Most Visible Failure
Newport's 8,139 fly-tipping incidents in 2023/24 represent approximately 20% of the entire Welsh total of ~40,000 incidents (StatsWales Environmental Enforcement Statistics 2023/24) — a rate that has no parallel elsewhere in the country. Incidents surged 87% between 2019/20 (~4,350 incidents, base year) and 2021/22 (~8,140 incidents) before partially stabilising. The cost to Newport's residents is visible and daily: mattresses, construction waste, garden refuse, and household items illegally dumped on verges, alleyways, and country roads across the city. The £343,000/year clearance cost is the council's bill — approximately £2.15 per resident, per year. The lived experience is Newport's residents'.
🗺️ Second Drop-Off Point — ACM as Infrastructure Solution
The ACM facility provides Newport's residents with a second legitimate disposal point for the first time in the city's recent history. Materials that previously had no accessible destination — bulky items, mixed loads, garden waste bags in excess of the kerbside limit — can be delivered directly to the ACM facility as manufacturing feedstock. No booking system. No digital barrier. No appointment required.
This resolves the root cause of fly-tipping at the infrastructure level. Every incident avoided is a cost saved for Newport's taxpayers — and a street corner, alleyway, or green space returned to Newport's communities.
📉 Fly-Tipping Trajectory: What the Numbers Mean
At £343,000/year in clearance costs, Newport spends more responding to fly-tipping than many Welsh authorities spend on their entire HWRC network. A 50% reduction in incidents — achievable if the ACM facility eliminates the disposal access barrier for the most common fly-tipping materials — would save approximately £172,000/year in direct clearance costs, plus enforcement costs, NRW compliance costs, and the unmeasured reputational and environmental costs of Wales's worst fly-tipping record.
The broader economic benefit — cleaner streets improving property values, resident wellbeing, and Newport's reputation as a city — is unquantifiable but real.
🌍 Deprivation & Fly-Tipping — The Hidden Link
Newport's highest fly-tipping rates correlate with its most deprived wards: Pillgwenlly, Ringland, Bettws, and St. Julians. These communities have the highest rates of digital exclusion, lowest vehicle ownership, and fewest residents able to use the current HWRC booking system. The single HWRC at Docks Way is also geographically distant from Newport's northern and eastern communities.
ACM's facility siting — within or adjacent to Newport's urban envelope — can be selected to maximise accessibility for these communities, providing a disposal option closer to the areas with the highest current fly-tipping incidence.
Friction Points: Honest Assessment
No proposal of this scale is without legitimate questions. The following addresses the most common friction points Newport's residents and councillors are likely to raise — not as obstacles, but as structural features of the decision Newport is being asked to make.
P5 Next Steps & Navigating the Transition
This section sets out the four sub-engagements that Carbotura recommends Newport City Council initiate immediately, the key stakeholder touchpoints in the transition from status quo to ACM partnership, and the talking points Newport officers and councillors will need for internal and public discussions.
Sub-A: Legal & Procurement Pathway
Sub-B: Welsh Government & NRW Engagement
Sub-C: Prosiect Gwyrdd & Viridor Relationship
Sub-D: Internal Council Governance
Talking Points for Newport Officers & Councillors
Contacts & Accountability Pathways
For document corrections, factual disputes, media enquiries, or to request independent source documentation supporting any claim in this report:
Named organisations and individuals who believe any claim in this document is inaccurate may request correction through this address. Carbotura will respond within 10 working days. Corrections are published with a visible dated notice, not silently edited.
Residents and organisations wishing to raise questions about Newport's waste strategy with the decision-makers responsible:
- Chief Executive, Newport City Council — [email protected]
- Cabinet Member for Streetscene — via council website democratic services
- Section 151 Officer (S151) — [email protected]
- Council Scrutiny Committee — [email protected]
Newport City Council full councillor list and contact details: newport.gov.uk
If you are a resident or organisation seeking to exercise formal oversight rights:
- Wales Audit Office (WAO) — audit.wales — for concerns about public money use or governance failures
- Natural Resources Wales (NRW) — naturalresources.wales — environmental permitting and enforcement
- Public Services Ombudsman for Wales — ombudsman.wales — complaints about council conduct
- Freedom of Information (Wales) — requests to NCC via: [email protected]
Model FOI request template for Prosiect Gwyrdd gate fee data available on request from [email protected]
Dates at which accountability pressure and resident engagement can most effectively influence outcomes:
- Docks Way landfill closure — 2025/26 fiscal year (NOW — revenue impact immediate)
- Tomorrow's Valley AD contract expiry — ~2027 (re-procurement decision required by 2026)
- Docks Way quinquennial review — ~2026/27 (post-closure provision likely revised upward)
- Newport Council Budget Setting — annually February/March (scrutiny cycle)
- UK ETS EfW inclusion — 2028 (adds est. £297K–£1.48M/yr to PG obligations)
- Newport local elections — May 2027 (all 50 seats)
Source Bibliography
All primary sources used in this document are listed below with sufficient detail for independent retrieval. Where documents are not publicly available online, the issuing body, date, and formal title are provided to enable a Freedom of Information or Environmental Information Regulations request. Publication dates are recorded for all sources. Secondary sources are identified as such. This bibliography supports Standard 2 (Source Attribution) of the Carbotura Community Transparency Standards v1.0.
| # | Source Title | Issuing Body | Date | Type | Access / Notes |
|---|---|---|---|---|---|
| 1 | Newport City Council Waste Intelligence Report 2025 | Newport City Council / commissioned analysis | 2025 | Primary — commissioned report | Basis for s12 per-stream cost data, s9 fly-tipping figures, and capacity analysis throughout. Provided to Carbotura as briefing material. |
| 2 | StatsWales Municipal Waste Management Statistics 2022/23 | Welsh Government / StatsWales | Published 2024 | Primary — official statistics | statswales.gov.wales — recycling rates, MSW volumes, landfill diversion figures |
| 3 | StatsWales Environmental Enforcement Statistics 2023/24 | Welsh Government / StatsWales | Published 2024 | Primary — official statistics | statswales.gov.wales — fly-tipping incident counts; basis for "20% of Wales total (~40,000)" figure |
| 4 | WRAP Gate Fees Survey 2024/25 | Eunomia Research & Consulting for WRAP | January 2025 | Primary — industry survey | Published at wrap.org.uk — basis for EfW gate fee range (£80–120/t), AD gate fee (~£40/t), MRF rate (~£42–82/t) |
| 5 | Newport City Council Annual Budget Papers 2022/23–2024/25 | Newport City Council | 2022–2025 | Primary — statutory financial documents | Newport Council website / Section 151 Officer publications. Basis for £21.375M budget gap and £975K Docks Way revenue figure. |
| 6 | Newport City Council Statement of Accounts 2021/22 | Newport City Council | Published 2022 | Primary — statutory accounts | Newport Council website. Basis for £6.9M Docks Way post-closure provision and 23.2% LGPS employer rate. |
| 7 | Prosiect Gwyrdd — Joint Working Agreement and Contract Summary | Prosiect Gwyrdd Authorities (incl. Newport City Council) | 2014 / publicly available summary | Primary — public contract summary | Publicly available summary documents. Full gate fee commercially confidential. Newport's ~16% share and 25-year term are publicly disclosed. Basis for lifetime Newport obligation estimate. |
| 8 | Wales Audit Office — Newport City Council Streetscene Services Scrutiny Review | Wales Audit Office (WAO) | Published (date subject to FOI confirmation) | Primary — official audit finding | WAO finding on undisclosed conflict of interest in Wastesavers contract scrutiny. Available at audit.wales. Document title for FOI purposes: Newport City Council — Streetscene/Waste Services Scrutiny Review. |
| 9 | Beyond Recycling — A Strategy to Make Wales a Zero Waste Nation | Welsh Government | Published 2021 | Primary — government policy document | gov.wales — basis for 70% statutory target, 100% by 2050 aspiration, EfW moratorium (March 2021) |
| 10 | Environment (Wales) Act 2016 | Welsh Government / Senedd Cymru | 2016 | Primary — primary legislation | legislation.gov.uk — statutory basis for recycling targets and NRW powers |
| 11 | Tomorrow's Valley Anaerobic Digestion Contract — Newport City Council participation | Newport City Council / Biogen / STGP | ~2012 (15-year term) | Primary — contract reference (summary publicly disclosed) | Contract details commercially confidential. Expiry ~2027 derived from disclosed 15-year term and execution date. Gate fee ~£40/t from WRAP 2024/25 Gate Fees Survey (secondary confirmation). |
| 12 | UK Emissions Trading Scheme — Expansion to Energy from Waste Consultation | HM Treasury / DESNZ | 2023–2024 | Primary — government consultation documents | gov.uk — basis for 2028 ETS EfW inclusion and £297K–£1.48M Newport cost estimate (Carbotura calculation applied to Newport's contracted EfW volume) |
| 13 | Newport City Council 2021 Census Area Profile | Office for National Statistics | Published 2023 | Primary — official statistics | ons.gov.uk — population 159,587 (2021 Census) |
| 14 | Carbotura ACM Authoritative Voice Guide v3.7 | Carbotura Inc. | 2025 | Primary — internal specification (Carbotura) | Internal document governing ACM nomenclature, product categories, and language standards applied throughout this proposal |
| 15 | Carbotura ACM Nomenclature Proofing Guide v3.7 | Carbotura Inc. | 2025 | Primary — internal specification (Carbotura) | Internal document governing ACM terminology. Governs all product name usage in this proposal. |
| 16 | Newport City Council Fly-Tipping Enforcement Data 2019/20–2023/24 | Newport City Council / StatsWales | Published annually | Primary — official enforcement statistics | StatsWales Environmental Enforcement. Basis for 8,139 (2023/24), ~4,350 (2019/20 base), 87% surge calculation, and £343K clearance cost. |
| 17 | CIPFA Code of Practice on Local Authority Accounting in the United Kingdom 2023/24 | CIPFA/LASAAC | 2023 | Primary — professional accounting standard | cipfa.org — governs all accounting treatment references in EIR6 and Appendix B. Newport's S151 Officer and external auditors should confirm application to specific COA terms. |
| 18 | Newport City Council — Wood Recycling Data Quality Review (January 2026) | Newport City Council | January 2026 | Primary — internal review (referenced publicly) | Basis for data quality flag on 71.45% recycling rate throughout this document. Outcome not yet publicly confirmed at time of writing. Newport City Council [email protected] for status enquiries. |
10-Year P&L — All Three Tiers
The following profit and loss projections cover Years 1–10 for all three proposed configurations. All figures are Carbotura's illustrative estimates based on the deployment model and Newport's published waste data. These are Newport's projected income and cost flows — not Carbotura's internal P&L. Newport's auditors and S151 Officer should verify accounting treatment before finalising any financial planning assumptions.
200 TPD — Minimum Configuration P&L
| Year | Tons | TMC Outflow | Royalty Income | Avoided Cost | Net Annual Benefit | Cumulative |
|---|---|---|---|---|---|---|
| Y1 | 45,625 | −£4.56M | £0 | +£3.74M | −£0.82M | −£0.82M |
| Y2 | 73,000 | −£7.37M | +£5.53M | +£5.99M | +£4.15M | +£3.33M |
| Y3 | 73,000 | −£7.45M | +£5.59M | +£6.34M | +£4.48M | +£7.81M |
| Y4 | 73,000 | −£7.52M | +£5.65M | +£6.72M | +£4.85M | +£12.66M |
| Y5 | 73,000 | −£7.60M | +£5.71M | +£7.11M | +£5.22M | +£17.88M |
| Y6 | 73,000 | −£7.68M | +£5.77M | +£7.53M | +£5.62M | +£23.50M |
| Y7 | 73,000 | −£7.75M | +£5.82M | +£7.98M | +£6.05M | +£29.55M |
| Y8 | 73,000 | −£7.83M | +£5.88M | +£8.45M | +£6.50M | +£36.05M |
| Y9 | 73,000 | −£7.91M | +£5.94M | +£8.95M | +£6.98M | +£43.03M |
| Y10 | 73,000 | −£7.99M | +£6.00M | +£9.47M | +£7.48M | +£50.51M |
400 TPD — Tier 1 P&L
| Year | Tons | TMC Outflow | Royalty Income | Avoided Cost | Net Annual Benefit | Cumulative |
|---|---|---|---|---|---|---|
| Y1 | 91,250 | −£9.13M | £0 | +£7.49M | −£1.64M | −£1.64M |
| Y2 | 146,000 | −£14.75M | +£11.0M | +£11.98M | +£8.23M | +£6.59M |
| Y3 | 146,000 | −£14.90M | +£11.1M | +£12.69M | +£8.89M | +£15.48M |
| Y4 | 146,000 | −£15.05M | +£11.2M | +£13.44M | +£9.59M | +£25.07M |
| Y5 | 146,000 | −£15.20M | +£11.3M | +£14.23M | +£10.33M | +£35.40M |
| Y6 | 146,000 | −£15.35M | +£11.4M | +£15.07M | +£11.12M | +£46.52M |
| Y7 | 146,000 | −£15.50M | +£11.5M | +£15.96M | +£11.96M | +£58.48M |
| Y8 | 146,000 | −£15.65M | +£11.6M | +£16.90M | +£12.85M | +£71.33M |
| Y9 | 146,000 | −£15.81M | +£11.7M | +£17.90M | +£13.79M | +£85.12M |
| Y10 | 146,000 | −£15.97M | +£11.9M | +£18.96M | +£14.89M | +£100.01M |
800 TPD — Tier 2 P&L
| Year | Tons | TMC Outflow | Royalty Income | Avoided Cost | Net Annual Benefit | Cumulative |
|---|---|---|---|---|---|---|
| Y1 | 182,500 | −£18.25M | £0 | +£14.98M | −£3.27M | −£3.27M |
| Y2 | 292,000 | −£29.49M | +£22.0M | +£23.97M | +£16.48M | +£13.21M |
| Y3 | 292,000 | −£29.79M | +£22.2M | +£25.38M | +£17.79M | +£31.00M |
| Y4 | 292,000 | −£30.09M | +£22.4M | +£26.88M | +£19.19M | +£50.19M |
| Y5 | 292,000 | −£30.39M | +£22.7M | +£28.47M | +£20.78M | +£70.97M |
| Y6 | 292,000 | −£30.70M | +£22.9M | +£30.14M | +£22.34M | +£93.31M |
| Y7 | 292,000 | −£31.01M | +£23.1M | +£31.92M | +£24.01M | +£117.32M |
| Y8 | 292,000 | −£31.32M | +£23.3M | +£33.80M | +£25.78M | +£143.10M |
| Y9 | 292,000 | −£31.63M | +£23.5M | +£35.80M | +£27.67M | +£170.77M |
| Y10 | 292,000 | −£31.95M | +£23.8M | +£37.92M | +£29.77M | +£200.54M |
All figures illustrative. TMC Fee at £100/t (Year 1) escalating 1%/yr. Royalty = 120% × prior-year TMC outflow × tons, from Y2. Avoided Cost = legacy FWDC (£82/t × 5.9%/yr escalation) × tons. Not a contractual commitment.
Balance Sheet Snapshots
| Balance Sheet Item | Current (Status Quo) | Year 1 COD | Year 5 (With ACM) | Year 10 (With ACM) |
|---|---|---|---|---|
| Accumulated Revenue Surplus (Waste-related) | Declining (budget gap) | TMC Fee only; no Royalty yet | Royalty income accumulating; surplus improving | Structural surplus from Royalty + avoided costs |
| IAS 37 Environmental Provisions | £6.9M+ (Docks Way) + PFAS unquantified | Docks Way provision unchanged; no new ACM provisions | No new provisions from ACM stream; Docks Way amortising | Legacy provisions declining; ACM adds no new obligations |
| Long-Term Debt (Waste-related) | Prosiect Gwyrdd off-BS (~£160–180M) | No new debt from ACM (Carbotura finances) | PG liability unchanged; ACM royalty partially offsets | PG contract approaching 2041 end; no new commitment |
| Revenue Diversification | Heavily WG grant-dependent | First Royalty billing year | Royalty ~£11–18M/yr established; WG dependency reducing | Private sector manufacturing revenue stream mature |
| PFAS Disclosure Risk | Unquantified; Off-BS | Title transfer arrests forward PFAS accrual from ACM | Docks Way legacy PFAS remains; ACM adds nothing new | Docks Way remediation option (Exogenesis) available |
Indicative balance sheet narrative. Newport's S151 Officer and external auditors must confirm specific accounting treatments. This does not constitute a professional accounting opinion.
Cash Flow Summary
| Cash Flow Item | Direction | Timing | 400 TPD Estimate |
|---|---|---|---|
| TMC Fee Payments | Outflow | Monthly from COD (Q3 2027) | ~£14.75–15.97M/yr (Y2–Y10) |
| Circular Royalty™ Receipts | Inflow | Annual, Year 2 onward | ~£11.0M (Y2) rising to £14.9M (Y30) |
| Avoided Disposal Cost Cash Release | Inflow (indirect) | From COD — budget saving | ~£7.5M (Y1) rising to £47.6M (Y30) |
| Business Rates (ACM facility) | Inflow | From COD (annual) | ~£700K–£1.2M/yr |
| Carbotura CAPEX (Newport pays) | £0 | Never | Not applicable |
| Docks Way Post-Closure Monitoring | Outflow (existing obligation) | Annual (30–60 yr from closure) | Existing provision; unchanged by ACM |
| Net Cash Position Year 5 (400 TPD) | Net Inflow | — | +~£13.5M/yr net positive |
Extended Tier Comparison
| Metric | 200 TPD Min | 400 TPD T1 | 800 TPD T2 |
|---|---|---|---|
| Annual Processing Capacity | 73,000 t/yr | 146,000 t/yr | 292,000 t/yr |
| Carbotura CAPEX | ~£102M | ~£189M | ~£362M |
| Newport CAPEX | £0 | £0 | £0 |
| Direct Jobs | 78 FTE | 156 FTE | 312 FTE |
| Annual Payroll | ~£8.6M/yr | ~£17.2M/yr | ~£34.3M/yr |
| TMC Fee Year 1 | ~£4.56M | ~£9.13M | ~£18.25M |
| Circular Royalty™ Year 2 | ~£5.5M | ~£11.0M | ~£22.0M |
| Year 2 Net Position | +£4.15M | +£8.23M | +£16.48M |
| Year 10 Cumulative Benefit | ~£50.5M | ~£100M | ~£200.5M |
| 30-Year Total Royalty | ~£278M | ~£556M | ~£1.11B |
| 30-Year Total Avoided Cost | ~£480M | ~£960M | ~£1.92B |
| 30-Year Combined Benefit | ~£758M | ~£1.52B | ~£3.03B |
| Prosiect Gwyrdd Impact | Complementary; Newport MSW only | Newport MSW + ~76K t regional | Newport + South Wales regional hub |
| Regional Import Capacity | ~3,238 t/yr spare | ~76,238 t/yr spare | ~222,238 t/yr spare |
Glossary — ACM Nomenclature
The following definitions apply throughout this document and are consistent with the Carbotura ACM Authoritative Voice Guide v3.7 and Nomenclature Proofing Guide v3.7. Terms are listed alphabetically.
| Term | Definition | Note / Do Not Use |
|---|---|---|
| ACM (Advanced Circular Manufacturing) | Carbotura's proprietary molecular reforming technology platform. Classifies as manufacturing under NAICS 325xxx/331xxx. | Do not use "waste processing," "incineration," or "energy-from-waste" |
| Captive PEM | Proton Exchange Membrane hydrogen fuel cell system, captive to the ACM facility, enabling Island Mode energy independence. | Do not use "grid-connected power" |
| Circular Offtake Agreement (COA) | The 30-year partnership agreement between Carbotura Inc. and Newport City Council governing TMC Fee, Circular Royalty™, title transfer, and all commercial terms. | Do not use "waste disposal contract," "service contract," or "PFI" |
| Circular Royalty™ | The annual payment from Carbotura Inc. to Newport City Council, equal to 120% × prior-year TMC Fee outflow × annual tonnage, beginning Year 2. Escalates 1%/yr. | Do not use "rebate," "discount," or "income sharing" |
| COD (Commercial Operations Date) | The date on which the ACM facility commences commercial manufacturing operations under the COA. Target: Q3 2027. | Do not use "operational date," "launch date" |
| Exogenesis Protocol | ACM protocol for processing legacy landfill material and contaminated soils. Relevant to Docks Way post-closure remediation opportunity. | Do not use "landfill mining" |
| FWDC (Facility-Weighted Disposal Cost) | Newport's volume-weighted average disposal cost across all streams: £82/t. Used to calculate the TMC Fee floor trigger. | Do not use "gate fee," "tipping fee," or "disposal charge" |
| Island Mode | ACM facility operational state in which the facility is fully self-sufficient for energy, powered by Captive PEM using its own Renewable Hydrogen output. | Do not use "off-grid" |
| Liquifact | ACM terminology for leachate. The Liquifact Protocol processes all liquid fractions into Renewable Refined Water (DI). | Do not use "leachate" when describing ACM facility outputs |
| Manufacturing Feedstock | All materials received by the ACM facility for processing. Includes MSW, commercial waste, food waste, and garden waste streams. Title transfers to Carbotura Inc. at receipt. | Do not use "waste," "rubbish," "garbage," or "refuse" in reference to ACM inputs |
| Recyclotron Protocol | The primary ACM processing protocol. Operates in anoxic electromagnetic conditions. No combustion, no flame, no ash, no flue gas. | Do not use "incinerator," "furnace," or "burner" |
| Renewable [Product]™ | ACM-branded manufactured product categories: Renewable Graphite™, Renewable Hydrogen™, Renewable Industrial Gases™, Renewable Refined Water™, Renewable Advanced Carbon Products™, Renewable Mineral Alloys™, Renewable Biogases™, Renewable Oils™, Renewable Salts™. | Do not use "recovered material," "recycled output," or "secondary aggregate" |
| TMC Fee (Total Manufacturing Cost Fee) | Newport's per-tonne payment to Carbotura Inc. under the COA. Set at £100/t (regional floor rate). Escalates 1%/yr for 30 years. | Do not use "disposal fee," "gate fee," "tipping fee," or "incineration charge" |
| Title Transfer | The legal mechanism by which ownership of manufacturing feedstock passes from Newport City Council to Carbotura Inc. at the facility gate. Eliminates Newport's IAS 37 forward environmental provisions for that material. | Do not imply Newport retains title or environmental liability post-transfer |