Northern Ireland
Combined Circular Supply Proposal — Northern Ireland

1. One site, eleven agreements. A central Advanced Circular Manufacturing site on the M1 corridor near Craigavon/Portadown. Each of the 11 councils signs its own Circular Supply Agreement (CSA), 30-year minimum term, continuing perpetually unless a 24-month Non-Renewal Notice is served.
2. Four years to full capacity. One 400 TPD unit is added each year, reaching 1,600 TPD in Year 4: enough for all 500,832 tonnes of council residual, with 14% headroom.
3. Two payment flows per council, never netted. Each council pays a Beneficiation Fee on its delivered tonnes and receives a Circular Royalty™ on the same tonnes. Independent transactions, reported separately and in full.
4. A condition precedent on an operating facility. Each CSA requires an operating facility meeting our stated claims and standards. Until that is satisfied, the council is not held to performance.
5. Zero council capital. Carbotura finances, owns and operates at every stage, and carries all permitting work at its own cost.

DAERA’s 2024/25 council data puts total local authority collected municipal waste at 1,010,410 tonnes. After reuse, recycling and composting, the residual is 500,832 tonnes. That residual is what this proposal is sized against, council by council.

Residual = total collected minus reused, recycled and composted, from DAERA’s 2024/25 data tables. It includes some separately collected wood sent to energy recovery. Haul distances are straight-line, council centre to the Craigavon area, and are indicative only. DAERA’s 2025/26 figures are due in November 2026.

The stream should shrink, and the sizing allows for it. The Climate Change Act (Northern Ireland) 2022 sets a 70% recycling target for 2030; Northern Ireland is at 50.4% (53.0% in the latest quarter). At 70%, council residual would be about 300,000 tonnes. Each council’s Minimum Annual Feedstock Volume is set in its Term Sheet against its own recycling path, so no council contracts for tonnes it cannot deliver. Capacity the councils no longer need can take commercial and industrial material.

No candidate site has been identified or assessed. Siting is a Joint Working Group item and would follow authorisation. The M1 corridor near Craigavon/Portadown is the starting point because it is central to all 11 councils and connected to Belfast, Newry, Dungannon and the west. Areas worth examining:

• Mandeville, Craigavon. About 99 acres held by Invest NI, most of it unused; needs servicing and zoning in the council’s development plan.
• Halfpenny Valley, Lurgan. About 22 usable acres, unserviced, minutes from the M1.
• Charlestown Road, Portadown. About 10 usable acres, unserviced.
• Granville, Dungannon (M1 Junction 15). An expansion area; current availability to be confirmed.

At 1,600 TPD the process sits inside one building, below the 2,000 TPD building maximum, on roughly 8–12 hectares. Site figures are ESTIMATED; areas and acreages come from press reports and must be checked against Invest NI’s property listings.

One structure, signed eleven times. Each council executes its own Circular Supply Agreement and delivers its own stream. Ownership of and liability for the material transfer to Carbotura on delivery. Carbotura does not purchase the material; the CSA transfers it, and Carbotura pays a royalty on what is delivered and processed.

The Beneficiation Fee and the Circular Royalty™ are independent transactions, reported separately and in full, and never netted. No table in this package carries a combined or net column. The fee is set in US dollars and shown in sterling at the Bank of England rate of 2 November 2026 (£1 = US$1.3416).

Deployment is modular. Each year one more 400 TPD unit — four 100 TPD modules — enters service in the same building. During the ramp every council delivers the same share of its residual, so each council’s fee and royalty grow together; the Joint Working Group may instead phase councils in as their current contracts end.

Annual totals at that year’s escalated rates, accrual basis. Year 4 capacity is 584,000 t/yr; council residual fills 86% of it. Carbotura capital in US dollars: US$75M for the first module and US$55M for each additional module, US$900M in total. Figures ILLUSTRATIVE.

Every council receives its own Circular Royalty™ on its own tonnes, and pays its own Beneficiation Fee. Nothing is pooled.

Accrual basis: Year n royalty on Year n tonnage. Cash follows 13 months after each fee payment. Year 1 tonnes are each council’s 29% share of the Year 1 unit. 30-year gross is the sum over the minimum term at escalated rates. The Beneficiation Fee is shown in its own column and is never set against the royalty. Figures ILLUSTRATIVE.

arc21 procures residual treatment for its six councils through a Dynamic Purchasing System, in lots of four years with options to extend four more; new lots started between July 2023 and February 2025. arc21’s application for a residual energy-from-waste facility at Hightown is being re-determined, with a ministerial decision hoped for in early 2027. The North West group and the three independent councils hold their own treatment contracts. We take no position on any of them. Staging over four years exists so that each council can join when its own arrangements allow.

Planning, environmental permitting and classification are Carbotura’s work, at our cost and our risk. There is nothing in that process for any council to file, fund, defend or co-apply on, and no commercial term is contingent on its outcome.

Our filing posture is consistent across jurisdictions: material arrives under its current classification, is processed, and nothing leaves as residual for disposal. Manufacturing classification is what we assert and pursue; we hold no classification instrument in Northern Ireland today and nothing here depends on obtaining one.

On Landfill Tax and carbon pricing. Landfill Tax applies to material disposed to landfill; our understanding is that tonnes processed at a manufacturing site attract none, other than on any residual landfilled, which is designed to be near-zero. Under the Windsor Framework, waste incineration in Northern Ireland falls within the EU Emissions Trading System, which is still being transposed; ACM involves no combustion. Both are stated as our understanding, to be confirmed with HMRC and DAERA, not as settled positions.

One thing: authorise an LOI/MOU and join a Joint Working Group. Councils may join through arc21, the North West group or on their own; each signs for itself.

That is not a commitment to deploy, a procurement award, an exclusivity grant, or a step away from any current contract or application. It opens a working phase in which the stream is characterised, candidate areas are examined with the communities that would host a site, the joining order is agreed, and commercial terms are scoped.

The sequence from there is LOI/MOU execution → Term Sheet → CSA, with the operating-facility condition precedent across it. Nothing binds either party before CSA execution.

All fee and royalty figures in pounds sterling, ILLUSTRATIVE until Term Sheet execution. The Beneficiation Fee is US$150 per tonne, converted at the Bank of England rate of 2 November 2026 (£1 = US$1.3416): £111.81. Sterling figures move with the exchange rate until fixed at Term Sheet. Capital figures are Carbotura’s and are in US dollars, marked US$.

The Circular Royalty™ is computed as Mₙ × BFₙ, where Mₙ = 120% + (n−1) percentage points and BFₙ = £111.81 × 1.025^(n−1). Accrual basis throughout. Accounting standard: CIPFA Code of Practice on Local Authority Accounting (IFRS-based).

Tonnage: DAERA LAC Municipal Waste Data Tables 2024/25 (final, 11 December 2025). Population: NISRA mid-2025 estimates (24 September 2026). Each council’s share of the ramp is pro rata to its residual. No saving is claimed against any council’s contract: no council publishes its residual price per tonne.

ESTIMATED: composition, employment, site requirements, haul distances. NOT IDENTIFIED: any candidate site. TO BE CONFIRMED: Landfill Tax treatment of ACM-processed tonnes; the 2027–28 Landfill Tax rate on gov.uk. Carbotura has no facility at or past Commercial Operation Date; the first is in Pennsylvania, USA, in deployment, with commercial operation targeted for late 2027 to early 2028.

Advanced Circular Manufacturing (ACM)

Industrial manufacturing that uses post-use material streams as feedstock, converting them into specification-grade manufactured commodities. A manufacturing operation, not a waste-management operation, and not combustion in any form.

Circular Supply Agreement (CSA)

The agreement under which ownership of and liability for the material transfer to Carbotura on delivery. The CSA transfers material; it is not a purchase.

Beneficiation Fee (TMC Fee)

The per-tonne Total Material Conversion Fee each council pays. US$150/t (£111.81), escalating 2.5% a year.

Circular Royalty™

The per-tonne royalty Carbotura pays each council on its delivered tonnage, beginning 13 months after Carbotura’s receipt of that council’s first Beneficiation Fee payment. Year 1 is 120% of that year’s Beneficiation Fee, rising one percentage point a year, uncapped.

Minimum Annual Feedstock Volume (MAFV)

The tonnage each council commits to deliver each year, set at Term Sheet against its own recycling path.

Condition precedent

An operating facility meeting Carbotura’s stated claims and standards. Until satisfied, no council is held to performance.