What this document is
The action instrument. This brief distils the Waste Study, the Circular Supply Proposal and the Economic Impact Report into a single decision frame for Edinburgh City Council. It states the capacity position, the Circular Supply Agreement structure, the illustrative economics, what delay costs, and one call to action: execute the LOI/MOU. No new figures are introduced here.
- Edinburgh City Council has ~780 TPD of addressable manufacturing feedstock committed to long-term disposal under the Millerhill EfW contract, with Regional Edinburgh landfill transitioning to closure by end-2027 under Scotland’s BMW ban. The exposure is a capacity and cost-escalation position, not a one-off price question.
- Carbotura offers a single commercial structure — the Circular Supply Agreement: a Beneficiation Fee (TMC Fee) paid by the Council on delivered feedstock, and a Circular Royalty™ paid by Carbotura from product revenues. There is no election to make, and the two flows are reported as separate transactions and never netted.
- Under the CSA the facility is privately financed on a Build-Own-Operate basis: zero Council capital cost, zero construction debt, and a Circular Royalty™ beginning 13 months after the corresponding Beneficiation Fee payment and escalating for the full 30-year Term. All figures GBP; IFRS / UK GAAP.
Millerhill EfW contract expires ~2040–41 — Edinburgh has no confirmed successor for 145 TPD of contracted residual MSW
The Millerhill EfW contract Joint Committee Agreement — signed October 2016 with FCC Environment (UK) — commits approximately 145 TPD of Edinburgh's contracted residual MSW to the Millerhill Recycling & Energy Recovery Centre (MRERC) through approximately 2040–41. When that contract expires, Edinburgh has no confirmed successor infrastructure for that volume. Working backward from 2040, the latest a Waste Study can be authorised and still have Phase Expanded ACM infrastructure operational before the contract horizon is approximately 2032–33. The recommended authorisation date is 2026. Every year of delay compresses that buffer and cannot be recovered.
Edinburgh City Council generates approximately ~780 TPD of manufacturing feedstock annually. Of that, approximately 145 TPD flows to Millerhill Recycling & Energy Recovery Centre (MRERC), operated by FCC Environment. The remaining stream — recycling, organics, and non-contracted fractions — is the immediate feedstock universe for Phase Initial.
Carbotura's ACM facility converts residual waste streams into synthetic graphite, graphene compounds, and recovered minerals using the MCR process — anoxic, oxygen-free, no combustion. Zero Council capital cost. Zero construction debt. Zero operating liability. Edinburgh's sole financial obligation, under the Circular Supply Agreement (CSA), is the Beneficiation Fee (TMC Fee) on delivered feedstock. From 13 months after corresponding Beneficiation Fee payment, the Circular Royalty™ returns more than was paid.
Phase Initial at 300 TPD can be commissioned and operational before the Millerhill EfW contract expires. Phase Expanded at 1,000 TPD addresses Edinburgh's full addressable feedstock ceiling. The CSA structure does not require engaging FCC Environment on the existing MRERC contract — Phase Initial draws from non-contracted volumes; Phase Expanded phases in as the Regional Edinburgh landfill approaches its end-2027 closure.
Five structural facts for Edinburgh City Council
The FCC Environment's Millerhill Recycling & Energy Recovery Centre (MRERC) contract absorbs 145 TPD of residual MSW through ~2040–41. Edinburgh has no confirmed infrastructure for that volume after contract expiry. The latest a Waste Study can be authorised and still have Phase Expanded operational before 2040 is approximately 2032–33. Every year of inaction forecloses one year of buffer. Authorising in 2026 preserves the maximum window.
Edinburgh's financial exposure is limited to the Beneficiation Fee — a per-tonne Beneficiation Fee set below Edinburgh's verified blended disposal cost. No construction debt, no planning expenditure for infrastructure the Council does not own, no operating liability. The 30-year CSA is a Carbotura obligation backed by step-in rights and a Parent Performance Guarantee.
Year 1 Beneficiation Fee at Phase Initial (300 TPD): approximately £33.7M. Year 2 Circular Royalty™: approximately £40.8M. Gross cost displacement is quantified separately; both flows are reported independently. At steady state, the Circular Royalty™ is designed to exceed the Beneficiation Fee on a per-tonne basis.
The Regional Edinburgh landfill has been identified as a qualifying Exogenesis™ Royalty candidate — converting accumulated legacy landfill material into a structured dual-stream payment alongside the primary CSA. Subject to Waste Characterization Study confirmation. Stacks alongside the Circular Royalty™ as a CSA add-on — does not alter primary CSA commercial terms.
The Scottish Government's Beyond Recycling strategy and circular economy targets require progressive diversion from landfill and combustion. ACM operating under manufacturing classification (SIC Sector C) produces materials — synthetic graphite, graphene compounds, recovered minerals — that enter industrial supply chains rather than being combusted. Edinburgh's ACM pathway is compliant with Scotland's post-WTE strategic direction and avoids long-term dependency on combustion-based ERF capacity.
The Council's CWB Plan judges economic activity against five pillars: Spending, Employment, Land and Property, Inclusive Ownership, and Finance. This project's strongest fit is Finance — the Circular Royalty™ is new, recurring revenue the Council controls and can direct through its own budget-setting and Participatory Budgeting processes — plus Employment (~175 permanent local jobs) and Land and Property (already-designated brownfield/clean-energy site). See the full pillar-by-pillar read, including an honest account of where the fit is weaker, in Community Benefits.
One commercial structure for Edinburgh City Council
Carbotura offers a single commercial structure for this and every engagement: the Circular Supply Agreement (CSA) — Beneficiation Fee (TMC Fee) paid by the Council on delivered feedstock, and Circular Royalty™ paid by Carbotura from product revenues. There is no election to make. A universal Exogenesis™ bonus stacks alongside the Circular Royalty™.
Beneficiation Fee (TMC Fee) + Circular Royalty™
- Beneficiation Fee: £100/tonne planning basis · 2.5%/yr escalator
- Circular Royalty™: 120% of the current-year Beneficiation Fee, +1pp/yr
- Royalty commencement: 13 months after corresponding Beneficiation Fee payment after corresponding Beneficiation Fee payment (rolling monthly)
- 30-year CSA term · perpetual continuation language
- Parent Performance Guarantee · Zero Council capex
- Regulatory Predicate Transition (RPT) required
- IFRS / UK GAAP accounting treatment
The Regional Edinburgh landfill has been identified as a qualifying Exogenesis™ Royalty candidate — converting accumulated legacy landfill material into a structured dual-stream payment alongside the primary CSA. This converts a legacy disposal liability into a royalty-generating instrument without altering primary CSA terms.
Stacks alongside the Circular Royalty™. Subject to Waste Characterization Study confirmation.
Subject to Waste Characterization Study confirmationKey figures at a glance
2.5%/yr escalator
+£5.95M Community Surplus (differential, not netted)
no successor confirmed
No public construction debt
The Circular Supply Agreement (CSA)
| Feature | The CSA · Beneficiation Fee (TMC Fee) + Circular Royalty™ |
|---|---|
| Circular Royalty™ | ✓ Included |
| Beneficiation Fee | ✓ £100/t · 2.5%/yr |
| Royalty commencement | 13 months after corresponding Beneficiation Fee payment after corresponding Beneficiation Fee payment (rolling monthly) |
| Exogenesis™ Royalty (Regional Edinburgh landfill) | ✓ Available — subject to Waste Characterization Study confirmation |
| Millerhill EfW contract successor | ✓ Phase Expanded absorbs contracted stream at contract expiry |
| Parent Performance Guarantee | ✓ Included |