Residual in London and the South East Where is it going to go…?

October 2018 FULL REPORT

Residual Waste in London and the South East

INTRODUCTION

In 2017, London and the South East generated just under 10 Million tonnes (“Mt”) of Residual Waste, exporting circa 1.7Mt as Refuse Derived Fuel (“RDF”) to Europe – a greater dependence on the export market than the rest of the UK. At the same time securing planning consent for new Energy from Waste (“EfW”) facilities is particularly challenging (as evidenced by the recent refusals of EfW developments in West Sussex and Cambridgeshire). By the end of 2019 there could be a total of just 3 remaining Non-Hazardous across the south coast from Hampshire to Kent. When combined with the potential impact of Brexit on RDF exports, there is greater uncertainty with respect to the adequacy of future Residual capacity in this market than any other in the UK. This report therefore considers in detail the future for Residual Waste in London and the South East through to 2025, with a particular emphasis on the availability of local capacity. In this report Residual Waste is defined as non-hazardous, solid, combustible mixed waste which remains after activities and is capable of being processed alongside Residual Household Waste. The Environment Agency term of Household, Industrial and Commercial (“HIC”) is wider and relates to all solid non-hazardous permitted to be landfilled in a Non-Hazardous Landfill. This report has been derived primarily from Environment Agency data, Tolvik’s own market knowledge and through confidential discussions with the major landfill operators in the area - Biffa, FCC, Veolia and Viridor. We are grateful for their assistance. Where we have used commercially sensitive information in the preparation of the report we have aggregated the data so as to maintain confidentiality. Copies of this report can be downloaded via www.tolvik.com together with a 6-page summary extract. Third parties are entitled to freely use the contents of the report, subject to appropriately acknowledging its source.

CONTENTS

1. LONDON AND THE SOUTH EAST ...... 3

2. RESIDUAL WASTE PROJECTIONS ...... 4

3. EFW CAPACITY ...... 6

4. RDF EXPORTS AND OTHER RESIDUAL WASTE TREATMENTS ...... 9

5. RESIDUAL WASTE TO LANDFILL ...... 11

6. LANDFILL CAPACITY ...... 13

7. SUMMARY OF ANALYSIS AND IMPLICATIONS ...... 23

APPENDIX 1: DATA TABLES ...... 25

APPENDIX 2: GLOSSARY ...... 27

APPENDIX 3: WASTE PLANNING OVERVIEW ...... 28

APPENDIX 4: DATA SOURCES ...... 29

Front Cover Image: Waste Transfer Courtesy: Veolia

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Residual Waste in London and the South East

1. LONDON AND THE SOUTH EAST

Figure 1: London and the South East

For the purposes of this report, London and the South East is defined as the area shaded green in Figure 1. It is comprised of London and South East regions (excluding Isle of Wight) together with the southern portion of the Eastern region including Cambridgeshire, which has historically received significant tonnages of waste from London and the South East. It is estimated that in 2017 the total tonnage of Residual Waste generated in London and the South East was 9.88Mt – around 35% of the total generated in the UK as a whole.

Residual Residual Treatment Waste Sources Waste Mt Mt Residual Waste Treatment - 2017 UK EfW 4.19

1.72 LACW 5.86 RDF Export 36% EfW 42% RDF Export MBT Impact 0.26 MBT Co- 0.13 Co-Incineration C&I Landfill Landfill - L & SE 3.38 4.02 Waste 1% Landfill - Outside 0.20 3% 18% Total 9.88 Total 9.88

Figure 2: 2017 Residual Waste in London and the South East

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Residual Waste in London and the South East

2. RESIDUAL WASTE PROJECTIONS

2.1 Assumptions

In this report Residual Waste tonnages have been projected under three scenarios – Limited Intervention, Central and Circular Economy (“CE”) Target. These have been informed by Tolvik’s own in-house analysis and our 2017 review of third-party Residual Waste projections/reports on behalf of the Environmental Services Association (“ESA Report”)(a). The scenarios assume a linear annual improvement towards the 2035 recycling targets set out in Figure 3, resulting in the average recycling rates in 2025 being modelled as shown.

England Household Waste Municipal - like C&I Waste Scenario Recycling Rate Recycling Rate 2025 2035 2025 2035 Limited Intervention 46.7% 50.0% 61.5% 62.5% Central 49.0% 55.0% 62.0% 65.0% CE Target 51.4% 60.0% 65.0% 70.0%

Figure 3: Recycling Rate Assumptions

In projecting Household Waste recycling rates, the national recycling rates set out in Figure 3 have been applied and the performance of each local authority assumed to be relative to their 2016/17 recycling performance – i.e. low performing local authorities will remain low performing – rather than all local authorities achieving the same recycling rate. It has also been assumed that the recycling performance for any single local authority will be capped at 65%. The principle driver for Household Waste arisings has been assumed to be the projected number of households which, the Office of National Statistics projects, will grow in London and the South East by an average 1.23% pa through to 2025. This growth has been offset in Figure 4 by the assumed effects of resource efficiency (reduced waste production per household) on the arisings of waste per household. For C&I Waste, the assumed driver is GDP. However, as regional GDP projections are not generally available this report has used extrapolated national GDP growth projections compiled by HM Treasury(b) for the period to 2022 and adjusted at a regional level based on historic (2010-2016) GVA trends. Projections assume a GDP growth rate of 1.7% pa for the UK as a whole; the significantly higher historic growth rates seen in London and the South East means that this report assumes 2.04% p.a. headline growth for the region through to 2025. These have then been offset by the resource efficiency assumptions set out in Figure 4.

Limited Central CE Target Intervention

Growth in # Households to 2025 1.23% Household Reduction in Avge Waste per Household (0.25)% (0.50)% (0.75)% Waste Net Growth to 2025 0.98% 0.73% 0.48% GDP Growth 2.04% Municipal - like C&I Resource Efficiency (1.00)% (1.00)% (1.50)% Waste Net Growth to 2025 1.04% 1.04% 0.54%

Figure 4: Waste Growth Assumptions for London and the South East

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Residual Waste in London and the South East

2.2 Projections

Residual Waste in London and South East 11.0

10.0

9.0

8.0 Mt

7.0

6.0

5.0 2017 2018 2019 2020 2021 2022 2023 2024 2025

Limited Intervention Central CE Target

Limited Central CE Target Mt Intervention

Residual LACW 5.86 2017 Residual Municipal - like C&I Waste 4.02 Total Residual Waste 9.88 Residual LACW 5.97 5.81 5.67 2020 Residual Municipal - like C&I Waste 4.08 4.08 3.85 Total Residual Waste 10.05 9.89 9.51 Residual LACW 6.04 5.69 5.38 2025 Residual Municipal - like C&I Waste 4.27 4.21 3.71 Total Residual Waste 10.31 9.90 9.09

Figure 5: Projected Residual Waste in London and the South East

In Figure 5, in the Central scenario, the drivers for growth in waste arisings are projected to be sufficient to offset the impact of modest increases in recycling. As a result, the projected tonnage of Residual Waste remains broadly unchanged from 2017. Meanwhile, a modest rise in Residual Waste is projected in the Limited Intervention scenario and an 8% decline in the CE Target scenario.

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Residual Waste in London and the South East

3. EFW CAPACITY

3.1 2017 Residual Waste Inputs

Figure 6 details those EfWs which were operational in London and the South East in 2017. Residual Waste inputs to these facilities totalled 3.99Mt. Further details can be found in Appendix 1.

Inputs (ktpa) EfW Location 2016 2017 1 Riverside Bexley 753 746 2 Edmonton Enfield 548 511 3 Allington Kent 513 484 4 SELCHP Lewisham 448 446 5 Lakeside Slough 436 456 6 Greatmoor Buckinghamshire 267 291 7 Ardley Oxfordshire 304 286 8 Newhaven East Sussex 233 223 9 Marchwood Southampton 204 202 10 Portsmouth Portsmouth 204 202 11 Chineham Hampshire 98 93 12 Lancing West Sussex 33 33 13 Milton Keynes ACT Milton Keynes - 17 Total to EfWs in London and South East 4,041 3,991 “Exports” of Residual Waste from London and the 132 267 South East to Severnside, South Gloucestershire Other “Exports” of Residual Waste from London 11 36 and the South East to EfWs Less: “Imports” of Residual Waste from outside (85) (109) London and the South East Total to EfWs 4,100 4,185

Figure 6: Total Residual Waste Inputs into EfWs in London and the South East Source: WDI(1), Tolvik(2)

In order to establish the overall tonnage of Residual Waste generated and sent to EfWs in 2017 in London and the South East (rather than the tonnage which was processed), the headline figure has been adjusted to reflect:

◆ 0.11Mt of Residual Waste generated outside London and the South East sent to the identified EfWs as listed in Figure 6;

◆ 0.30Mt Residual Waste arising in London and South East sent to EfWs further afield – including 0.27Mt transported by rail to Severnside EfW near Bristol.

As a result, it is estimated that in 2017 4.19Mt of Residual Waste arising in London and the South East was sent to UK EfWs.

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Residual Waste in London and the South East

3.2 EfWs in Operation or Construction (“Certain” EfWs)

Based on the figures in Appendix 1, the total Operational Capacity (being the expected Residual Waste throughput as compared to the consented capacity) at “Certain” EfWs in London and the South East is currently 5.31Mt. This is comprised of 4.39Mt of capacity at EfW plants currently fully operational (Figure A1, which includes 0.30Mt of capacity at Severnside identified for Residual Waste arising in London) and 0.93Mt of capacity at EfWs currently in construction (Figure A3). Using 2016 and 2017 data as a guide, if it is assumed that Residual Waste from outside London and the South East processed in these plants is 0.10Mt, then the projected EfW capacity “available” to Residual Waste in London and the South East is 5.21Mt.

Figure 7: Kemsley EfW under construction Source: WTI

3.3 EfWs in Development (“Additional” EfWs)

Figure 8 lists EfW development projects in London and the South East with a projected power output in excess of 5MW for which it is understood conventional EfW technology is proposed. Gasification projects which are not yet in construction have been excluded, on the basis that no gasification/pyrolysis plants in development in London and the South East currently have access to support under the Contracts for Difference mechanism. Headline Known As Location Operator Capacity Status (ktpa) Nationally Significant Infrastructure Project Riverside EP Bexley Cory 650 (“NSIP”) Awaiting planning consent for revised stack Rivenhall Essex Gent Fairhead 595 height Rookery South Central Beds Covanta/Veolia 585 Consented - subject to Judicial Review Kemsley North Kent WTI 390 NSIP Project Rye House Hertfordshire Veolia 320 Secretary of State call in, decision awaited Multifuel Slough SSE 300 Announced intention to develop in May 18 Tilbury Green Thurrock ESB 250 Phase 1 complete Power Edmonton North London NLWA 180 Consented Kemsley K3 – Kent WTI 109 NSIP Project optimised

Figure 8: “Additional” EfWs Source: Renewable Energy Planning Database(d), Tolvik analysis

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Residual Waste in London and the South East

Three scenarios have been developed with respect to “Additional” EfW capacity in London and the South East. They reflect recent sector experience of construction delays, with an assumed total period to takeover of 4 years (although allowance has been made for waste inputs during the commissioning phase).

It is estimated in the Central EfW construction scenario that 1.41Mt of “Additional” EfW capacity could be operational in London and the South East by 2025. In the Low scenario the figure is 1.09Mt whilst in the High scenario the figure is 2.06Mt.

As Figure 9 shows, this points to considerable uncertainty in the projections of additional EfW capacity – but in all cases the potential effects of any additional EfW projects on the market will be delayed until at least 2022.

Additional EfW Capacity in London and South East 2.5

2.0

1.5

1.0

0.5 Additional Additional Capacity Mtpa

0.0 2018 2019 2020 2021 2022 2023 2024 2025

High Central Low

Figure 9: Projected Additional EfW Capacity in London and the South East

There is increasing discussion with respect to the potential to load Residual Waste onto trains in London and the South East in order to transport it to other markets where accessing new EfW capacity is potentially easier. Whilst this remains a possibility, in practice there are significant complexities and costs in developing new rail transfer infrastructure and securing track access etc, particularly in the congested London and the South East rail network.

To date all such rail transport of Residual Waste from London and the South East has been underpinned by local authority contracts offering both scale and longevity and this report assumes that no additional rail transfer facilities will be developed in the period to 2025.

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Residual Waste in London and the South East

4. RDF EXPORTS AND OTHER RESIDUAL WASTE TREATMENTS

4.1 RDF Exports

It is estimated that in 2017, 1.72Mt of RDF was exported from London and the South East – around 54% of the 3.35Mt in total exported from England. This is broadly identical to the estimate for 2016. Significant tonnages are exported from London and the South East, particularly via the ports of Felixstowe, Tilbury, Dover and Purfleet to the Netherlands and Germany. Data for the first 7 months of 2018 suggest overall RDF exports from England are down by 8% on the same period in 2017 – reflecting the effects of a tightening Residual Waste market in Europe (so reducing European EfW operators’ dependency on UK imports) and signs that European EfW operators are also looking, in the run up to Brexit, to diversify into new sources of international waste supply – e.g. Italy. At the time of writing this report the potential implications for trade movements post Brexit are wide and varied as the UK Government is deep in negotiations with Brussels. For RDF exports from London and the South East, in the near to medium term, the most likely short-term impact will be driven by road transport logistics and customs arrangements rather than macro-economic factors. It is expected that any reduction in lorry movements caused by reduced UK imports and/or hold ups at UK borders will impact those exported goods, such as RDF exports, that rely on regular, reliable and cost-effective return loads. In the longer-term economic factors, potentially including a 6.5% tariff on RDF exports under World Trade Organisation rules, changes to the exchange rate and macro movements in the overall balance of trade between the UK and Europe, could impact on the RDF export market. In this report, for illustrative purposes, two post-Brexit scenarios have been adopted:

◆ Limited disruption - based solely upon the impact of logistics challenges which may result from Brexit. This has been modelled on the basis of an assumed 25% reduction in RDF exports by 2021 (the year of the expiry of the proposed Brexit transition period) and beyond to 1.29Mt. This is effectively an extension of the current 8% reduction in exports from England seen in the past year.

◆ Significant disruption - a long term impact arising from severe disruption to RDF exports post Brexit. This has been modelled as a 75% reduction in exports by 2021 and beyond to 0.43Mt - as it assumes that only those RDF exports committed on medium to long term contracts continue to be exported.

4.2 Mechanical Biological Treatment (“MBT”) Impact

In 2017 there were 6 standalone MBT facilities in London and the South East as well as a pre-treatment facility in Milton Keynes.

ktpa 2017 Inputs 2017 Outputs Mass Loss % Mass Loss

MBT Impact 1,337 1,076 260 19.4%

Figure 10: Total Inputs and Outputs - MBTs in London and the South East Source: WDI(1)

In 2017 total inputs to MBTs in London and the South East are estimated to have been around 1.33Mt and outputs were 1.07Mt; the corresponding “effect” of MBT on the Residual Waste market in 2017 is therefore estimated to have been c. 0.26Mt. Without a policy change in the UK which directly drives the beneficial use of MBT (e.g. restriction on to landfill – which seems unlikely), it is projected that MBT capacity in London and the South East will not be fully utilised and that the net effect of MBT on the Residual Waste market will remain unchanged from 2017 levels. If any of the MBT facilities were to close, as has been seen elsewhere in the UK then this would “release” additional tonnages of Residual Waste into the market.

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Residual Waste in London and the South East

4.3 Co-Incineration

In 2017 it is estimated that 0.13Mt of Residual Waste was sent to cement kilns in London and the South East. Whilst there is the potential for an expansion in demand from cement kilns, particularly if operators wish to reduce their reliance on fossil fuels, in practice over the last few years the use of alternative fuels has declined modestly. It has therefore been assumed for London and the South East that the total tonnage of Residual Waste sent to cement kilns will remain at 0.13Mt. Some commentators have identified the potential for specific biomass facilities to convert to a Residual Waste feedstock. Given a shortfall in regional biomass capacity, in Tolvik’s opinion the probability that any facilities in London and the South East will elect to convert is immaterially low.

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Residual Waste in London and the South East

5. RESIDUAL WASTE TO LANDFILL

5.1 Scenarios

As set out in Figure 11, three scenarios for the tonnage of Residual Waste to landfill in London and the South East have been developed. The projections under each scenario being based on the compound effect of three different factors, produce a particularly wide range of outcomes. As such the High Tonnage and Low Tonnage scenarios have been deliberately selected, for illustrative purposes, as “boundary” conditions. The Low Tonnage scenario could be described as an optimist’s scenario (high recycling rates, RDF exports hold up well post Brexit and a strong pipeline of additional EfW capacity is developed). In which case the High Tonnage could similarly be regarded as a pessimist’s scenario. Tolvik expects that the Central scenario will be the one around which the most likely set of outcomes through to 2025 will result.

Residual Waste Reduction in RDF Additional EfW Landfill Scenario Projection Scenario exports by 2021 Capacity

Low Tonnage CE Target 25.0% High Central Central 37.5% Central High Tonnage Limited Intervention 75.0% Low

Figure 11: Residual Waste Scenarios

5.2 Projected Residual Waste to Landfill

The impact of these assumptions underpinning each scenario on the tonnage of Residual Waste to landfill in London and the South East are shown in Figure 12. For consistency, Figure 12 also assumes that (as at present) that 4% of landfilled Residual Waste (generally arising at the boundary of London and the South East) continues to be sent to landfills outside London and the South East.

Residual Waste to Landfill in London and the South East 4.5 4.0 3.5 3.0 2.5 2.0

Mtpa 1.5 1.0 0.5 0.0 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Low Tonnage Central High Tonnage

Figure 12: Scenarios for Residual Waste to Landfill in London and the South East

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Residual Waste in London and the South East

In the Central scenario, the tonnage of Residual Waste to landfill in London and the South East falls from the current 3.38Mt to 1.94Mt in 2025 – a 43% reduction.

Mt Low Central High

Total Residual Waste (Figure 5) 9.09 9.90 10.31 Certain EfW (Section 3.2) (5.21) Additional EfW (Section 3.3) (2.06) (1.41) (1.09) RDF Exports (Section 4.1) (1.29) (0.86) (0.43) MBT Impact (Section 4.2) (0.26) Co-Incineration (Section 4.3) (0.13) Landfill outside London & South East (0.01) (0.09) (0.14) Landfill in London & South East 0.13 1.94 3.05

Figure 13: 2025 Scenarios for Residual Waste to Landfill in London and the South East

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Residual Waste in London and the South East

6. LANDFILL CAPACITY

6.1 Background

There is little debate in the UK that landfill has a role to play in bridging the gap between the tonnage of Residual Waste generated and the capacity to treat it. In 2017 3.58Mt of Residual Waste generated in London and the South East was sent to landfill of which 3.38Mt (Figure A2) was landfilled locally and just 0.20Mt transported to landfills outside London and the South East. Environment Agency data classifies landfill inputs as HIC, Hazardous and Inert. Residual Waste is a subset of HIC, and as Figure 14 shows, over the last 5 years the tonnages of Residual Waste disposed in landfill in London and the South East have declined by 6.6% pa. At the same time, the tonnages of those elements of HIC which are not regarded as Residual Waste have remained broadly level at around 1.17Mt. Currently on average they account for 29% of all HIC inputs, although there is significant variation between individual landfill sites – in part due to the markets they serve and due to the differing classifications used by operators for waste which is fundamentally the same. It is beyond the scope of this report to undertake a detailed assessment of these differences and instead high-level assumptions, informed by Tolvik’s work on the ESA Report(a), have been applied. In 2017 the total tonnage of HIC landfilled in London and the South East was 4.75Mt - 3.38Mt of Residual Waste and 1.37Mt of other HIC.

HIC Inputs to Landfill in London and South East 7.0

6.0

5.0

4.0 Mt 3.0

2.0

1.0

0.0 2012 2013 2014 2015 2016 2017 Residual Waste Other HIC

Figure 14: HIC Inputs to Non-Hazardous Landfill in London and the South East Source: WDI(1)

Excluding double counting of pairs of landfills collectively managed by the same operator (e.g. in which one site closes and the other opens), in 2017 there were 20 operational Non-Hazardous Landfills in London and the South East which accepted more than 20kt of Residual Waste. In total these 20 sites accounted for 99.3% of all Residual Waste inputs. These sites are listed in Appendix 1.

6.2 Declining Operational Landfills

As Figure 15 shows, with the declining tonnage of Residual Waste being landfilled in London and the South East, so the number of operational landfills has correspondingly declined. Furthermore, the reduction in the number of operational landfills has mirrored the decline in Residual Waste inputs – effectively the average tonnage of Residual Waste accepted by each landfill has been broadly unchanged. This is a trend seen across England, not just London and the South East.

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Residual Waste in London and the South East

It is also noted, as reported in Tolvik’s 2011 “The Future of Landfill?”(e) that the trend for average landfill inputs to remain the same through progressive landfill closures was similarly seen across north Europe, as these countries reduced their reliance on landfill.

Landfills in London and South East 120 35

100 30 25 80 20 60 15 40 10

20 5

0 0

Number >20ktpaNumber Accepting Sites of Residual WasteResidual Inputs (2012=100)

Residual Waste Inputs Number of Sites

Figure 15: Operational Non-Hazardous Landfills in London and the South East Source: WDI(1), Tolvik analysis

6.3 Projected Landfill Capacity

A key factor to be considered in this report is whether there is sufficient landfill capacity in London and the South East to meet future requirements. According to the latest available data from the Environment Agency (Appendix 1), as at December 2016 the consented capacity at Non-Hazardous Landfills (primarily engineered for the acceptance of HIC) in London and the South East totalled 71.9million m3. It is important to note that not all this capacity will necessarily become available to the market – for example where the cost of engineering exceeds the revenue which can be generated from gate fees. Starting with this total capacity, it is possible to project the decline in future landfill capacity through to 2025 based on:

◆ The projected tonnages of Residual Waste to landfill in London and the South East under the three scenarios as set out in Figure 12; together with

◆ An assumed 1.17Mtpa of HIC which is not Residual Waste (based on the average over the period 2012 – 2017);

◆ An assumption that no new landfill capacity is consented;

◆ The generally accepted convention that 0.85t of HIC fills 1m3 of landfill capacity. Figure 16 shows the decline in landfill capacity under the three Residual Waste scenarios and the resultant projections for the remaining landfill capacity in 2025 range from 21 – 36 Mm3.

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Residual Waste in London and the South East

Capacity Remaining - HIC Inputs 80.0

70.0

60.0

50.0

40.0

30.0

20.0

10.0

Remaining Mm3 Dec at as Capacity Remaining 0.0 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 Low Tonnage Central High Tonnage

Figure 16: Remaining Capacity at Non-Hazardous Landfills in London and the South East - HIC Inputs only

6.4 “Available” Landfill Capacity

Figure 16 is an over-simplification as, there are a number of other factors which will influence the future “availability” of landfill capacity in London and the South East:

◆ The rate at which landfill capacity is being utilised through the landfilling of inert wastes;

◆ Site specifics. These may include the closure of landfills (particularly to HIC inputs) prior to the exhaustion of the consented capacity – either on commercial grounds or due to planning/permitting constraints and limitations on annual inputs – either practical (e.g. road access) or by consent;

◆ The existing geographical distribution of landfill capacity throughout London and the South East;

◆ Willingness/ability of the market to re-open moth-balled sites/secure extensions to existing consents and/or new consents.

These factors are considered in further detail below.

6.4.1 Landfilling of Inerts

As Figure 17 shows, there has been a 62% increase in the landfilling of inert waste at Non-Hazardous Landfills in London and the South East in the last 5 years – in part due to a number of major infrastructure projects and also due to a reduction in the number of “exempt” sites accepting inert wastes. In 2017 inert wastes into Non- Hazardous Landfills in London and the South East totalled 6.14Mt, down slightly from the peak of 6.58Mt in 2016. Whilst a proportion of inert waste accepted at Non-Hazardous Landfills is generally being used for landfill engineering purposes (e.g. capping), a proportion is disposed and will inevitably utilise consented capacity for HIC waste. Since 2012, total inputs of inert waste (to both Non-Hazardous and inert Landfills) in London and the South East have risen from under 9Mt to around 14Mt, with the proportion being sent to Non-Hazardous Landfills remaining reasonably constant, at 45% of the total. In 2017, 40% of inert waste inputs to Non-Hazardous Landfills were at sites which accepted less than 20kt of Residual Waste; suggesting that this waste was most primarily used for engineering purposes – capping, remediation or completing cells which were not suitable for HIC inputs.

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Residual Waste in London and the South East

Inert Inputs to Landfill in London and South East 16.0 14.0 12.0 10.0 8.0 6.0

Million Tonnes Million 4.0 2.0 0.0 2012 2013 2014 2015 2016 2017 Non Hazardous Landfill Inert Landfill

Figure 17: Inert Waste Inputs into Landfill in London and the South East Source: WDI(1), Tolvik analysis

From discussions with operators it is reasonable to assume that a portion of the consented capacity at Non- Hazardous Landfills will continue to be taken by inert waste. Over the last 5 years the average input of inert waste to Non-Hazardous Landfills in London and the South East has been 5.80Mt. Figure 18 updates Figure 16 on the assumption that 40% of inerts will utilise consented capacity at Non-Hazardous Landfills with the remainder used for engineering purposes. As can be seen, this has a significant impact on the projections of remaining capacity at Non-Hazardous Landfills in London and the South East. As Figure 18 shows, in the High Tonnage scenario landfill capacity is projected to be exhausted in 2025 whilst in the other two scenarios it is very significantly diminished. In all scenarios landfill capacity is projected to be exhausted significantly before 2030.

Capacity Remaining - HIC + Inert Inputs 80.0

70.0

60.0

50.0

40.0

30.0

20.0

10.0

Remaining Mm3 Dec at as Capacity Remaining 0.0 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Low Tonnage Central High Tonnage

Figure 18: Remaining Capacity at Non-Hazardous Landfills in London and the South East - Combined HIC and inert waste inputs

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Residual Waste in London and the South East

6.4.2 Landfill Specifics

Figure 19 details the expected closure dates for the 21 landfills identified in Appendix 1. This information has been generated from a variety of data sources and assumes, where the landfill operator so requires, planning consents will be extended so as to allow for the remaining consented capacity to be filled.

End Date - End Date - Modelled End Landfill Planning Capacity Date Consent 1 Pitsea 2025 2019 2019 2 Westmill 2021 2021 2021 3 Bletchley 2022 Post 2025 Post 2025 4 Rainham 2024 2024 2024 5 Redhill 2030 2025 2025 6 Sutton Courtenay 2030 Post 2025 Post 2025 7 Beddington 2018 2018 2018 Gerrards Cross Closed 2018 8 Springfield Farm Post 2025 Post 2025 Post 2025 9 Brookhurst Wood Closed 2017 10 Calvert Post 2025 Post 2025 Post 2025 11 Waterbeach Post 2025 Post 2025 Post 2025 12 Buckden Post 2025 Post 2025 13 Bellhouse Post 2025 Post 2025 Post 2025 14 Blue Haze 2020 2024 2023 15 Ockendon Post 2025 Post 2025 Post 2025 16 Shelford Post 2025 Post 2025 Post 2025 17 Martells Quarry 2023 2020 2020 18 Greatness 2019 2019 2019 19 Milton 2020 2024 2022 20 Grunty Fen To follow Milton 2025 21 Barling Marsh 2022 2020 2020 Figure 19: Landfill Operational End Dates for the acceptance of HIC Source: Tolvik analysis

Modelling the various constraints on a site-by-site basis, using public data and confidential information provided by landfill operators, the expected “available” capacity each year for disposal of HIC at landfills in London and the South East is shown in Figure 20. As part of the discussions with operators, separate assumptions have also been made regarding inert inputs on a site by site basis. This analysis of “available” capacity has been compared with the projected tonnages of HIC to be landfilled under the three Residual Waste scenarios shown in Figure 12 plus an assumed 1.17Mtpa of non-Residual HIC (as explained in Section 6.3). Figure 20 shows that the potential risk of a shortfall in landfill capacity across London and the South East is more imminent than the analysis in Figure 18 would suggest. Unless existing sites materially increase their HIC inputs on a long-term basis (contrary to current trends where, in general, operators are actively managing remaining capacity), new landfills open and/or waste is transported to landfills outside London and the South East, there is a potential capacity gap in the Central scenario before 2025. It is important to understand that Figure 20 is not suggesting an imminent shortfall in Non-Hazardous Landfill capacity as, unlike EfWs for example, landfill operators can, to a large extent, “flex” HIC inputs to reflect market conditions. By so doing, they exhaust capacity sooner and so bring forward their closure date.

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Residual Waste in London and the South East

HIC Waste to Landfill vs Available Landfill Capacity 6.0

5.0

4.0

3.0 Mt

2.0

1.0

0.0 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 Capacity "Capacity Gap" Low Tonnage Central High Tonnage

Figure 20: HIC to Non-Hazardous landfill under the three scenarios compared with available landfill capacity

A more useful measure is the calculated cumulative shortfall in Non-Hazardous Landfill capacity in London and the South East between 2018 and 2025 under the three scenarios. This is shown in Figure 21 and takes into account the “flexing” of the Non-Hazardous Landfill market to reflect short term capacity mismatches. In the Central scenario, the projected shortfall is 4.66Mt (the area highlighted “Capacity Gap” in Figure 20) whilst in the High Tonnage the figure is 9.75Mt. In the Low Tonnage there no cumulative shortfall is projected.

Low High Mt Central Tonnage Tonnage

Cumulative Shortfall in Capacity - 4.66 9.75

Figure 21: Cumulative shortfall in landfill capacity under the three scenarios 2018-2025

It is to be noted that using the same assumptions as those supporting Figure 20, it is projected that the number of Non-Hazardous Landfills operating in London and the South East will, without the development of additional landfill capacity, fall to 9 by the end of 2025. Significantly, this is consistent with historic trends - the projected decline in landfill numbers in the Central scenario and the expected tonnage of Residual Waste shown in Figure 22 continues the pattern in 2012-2017 as shown in Figure 15.

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Residual Waste in London and the South East

Landfills in London and South East 120 35

100 30 25 80 20 60 15 40 10

20 5

0 0

Number >20ktpaNumber Accepting Sites of Residual WasteResidual Inputs (2012=100)

Residual Waste Inputs Number of Sites

Figure 22: Projected operational Non-Hazardous Landfills in London and the South East

6.4.3 Regional Distribution of Landfill Capacity

Figure 23 indicatively shows the geographic distribution of landfill capacity in London and the South East – and in particular the heavy concentration of consented capacity at sites in Buckinghamshire/Milton Keynes – which account for 45% of the total consented capacity.

Figure 23: Distribution of consented Non-Hazardous Landfill Capacity as at Dec-16 Source: EA(f), Tolvik analysis

The distribution of the 9 landfills projected to remain operational beyond 2025 is shown in Figure 24 together with the projected consented capacity at each.

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Residual Waste in London and the South East

Figure 24: Projected Distribution of consented Non-Hazardous Landfill Capacity as at Dec-25 Source: Tolvik analysis

It is clear from Figure 24 that post 2025 there will be limited Non-Hazardous Landfill capacity in London and the South East to the south of the River Thames. As a result this report also considers, using an identical methodology to previously, the subset of London and the South East shown in green in Figure 25 (referred in short as “South”).

Figure 25: The South

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Residual Waste in London and the South East

ktpa Rest of London London and the South and the South East South East

UK EfW 2.14 2.05 4.19

RDF Export 0.81 0.90 1.72

MBT Impact 0.04 0.22 0.26

Co-Incineration 0.05 0.08 0.13

Landfill – London & SE 1.46 1.92 3.38

Landfill – Outside - 0.20 0.20

Total Residual Waste 4.50 5.38 9.88

Figure 26: 2017 Baseline – split of Residual Waste destinations

HIC Waste to Landfill in South vs Available Landfill Capacity 2.0

1.6

1.2 Mt 0.8

0.4

0.0 2018 2019 2020 2021 2022 2023 2024 2025 Capacity "Capacity Gap" Low Tonnage Central High Tonnage

Figure 27: HIC to landfill in the South under the three scenarios compared with available landfill capacity

As Figure 28 highlights, there is a significant shortage of consented Non-Hazardous Landfill capacity in the South with a cumulative shortfall of 7.50Mt in the Central scenario – which is greater than that for London and the South East as a whole.

Low High Mt Central Tonnage Tonnage

Cumulative Shortfall in Capacity - South 4.33 7.50 9.85

Figure 28: Cumulative shortfall in landfill capacity under the three scenarios 2018-2025

6.4.4 Planning and Landfill Consents

The planning regime will also influence the future availability of Non-Hazardous Landfill capacity in London and the South East. Whilst landfill operators are typically able to secure extensions of time if required to allow them to fill already consented capacity, proposals for an extension of capacity (either vertically or horizontally) are typically more challenging.

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Residual Waste in London and the South East

Appendix 3 details the current planning policy (as set out in the Waste Local Plan or equivalent) for most of the Waste Planning Authorities within London and the South East. Policy-makers typically assume that recycling rates will continue to rise, additional waste treatment facilities will be developed and that, as a consequence, demand for Non-Hazardous Landfill will continue to decline consistently through 2025 and beyond. As a result, the plans fall into one of two groups:

◆ Sufficient long-term landfill capacity remains - and so there is no requirement in the plan to identify potential new Non-Hazardous Landfill capacity;

◆ Potential shortfall in Non-Hazardous Landfill capacity – in which case there is a mix of potentially (limited) additional capacity at existing sites together with generic policy support for new landfill capacity. The plans do not therefore seem to have fully considered the effects of changes to the core modelling assumptions with regards to the future of the waste market on the availability of Non-Hazardous Landfill capacity in London and the South East.

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Residual Waste in London and the South East

7. SUMMARY OF ANALYSIS AND IMPLICATIONS

This report has considered the final treatment destinations for the 10Mt of Residual Waste generated in London and the South East in 2017, and projects Residual Waste tonnages forward 8 years to 2025. The report has considered the future capacity of EfW in London and the South East by 2025, potential scenarios for flow of RDF Exports to Europe after Brexit and, critically, the available Non-Hazardous Landfill capacity within London and the South East to receive this waste. The key findings are:

◆ The Central scenario assumes modest increases in Household Waste recycling rates, disruption in RDF export leading to a fall in tonnages of 37.5% by 2021 (0.7Mt) and “Additional” EfW capacity of 1.4Mt becomes operational by 2025. In this scenario it is projected that by 2025 there could be a cumulative shortfall of 4.66Mt in Non-Hazardous Landfill capacity across London and the South East.

◆ For the optimist considering a scenario in which there is a progressive increase in recycling through to 2025, RDF exports fall only modestly post Brexit and most planned large scale EfW capacity is developed in London and the South East, existing Non-Hazardous Landfill capacity is likely to last until 2025. The risk of a capacity shortfall post 2025 remains high.

◆ On the other hand, the pessimist could point to the High Tonnage scenario with limited additional EfW capacity, a major reduction in RDF exports and conclude that the capacity shortfall for Non-Hazardous Landfills could be more than double the Central scenario.

◆ Whatever the assumptions, there is little doubt that for the “south” area, (South London, Kent, East & West Sussex, Surrey and Hampshire) the currently available Non-Hazardous Landfill capacity will almost certainly be exhausted before 2025. At least in the short term this will almost certainly necessitate movement of waste from the south, round the M25 to the north of London.

◆ This movement will come at a cost – both economic and environmental. For Local Authorities and companies, the additional costs could be £10-£20 per tonne with the equivalent of at least an additional 20,000 vehicle movements each year. Unlike RDF exports, these are likely to be real additional movements – as vehicles used to transport waste to landfill are likely to be dedicated bulk waste transporters rather than curtain-sided lorries used on a return load to a UK port.

◆ For the reasons set out in Biffa’s “The Reality Gap” Report(c) there will continue to be a need for Non- Hazardous Landfill in London and the South East - to bridge the gap between Residual Waste generated and the capacity available to treat it, to support EfWs (both for the treatment of residues and managing short term EfW downtime) and to provide a disposal option for specialist HIC wastes for which there is no alternative waste management solution.

Given the very real prospect of a shortfall in Non-Hazardous Landfill capacity in London and the South East, what are the potential options available to investors, operators and regulators?

◆ Increase Recycling: A 2025 Household Waste recycling rate 5% higher than that modelled in the Central scenario would reduce the cumulative shortfall in landfill capacity by 1.87Mt (or 40% of the projected shortfall).

◆ Increase exports of RDF to Europe: Given the various uncertainties surrounding RDF exports post Brexit this is unlikely to be a realistic short term option; whether there is a potential for increase in exports in the longer term will be dependent on a number of factors – not least the extent to which the EU successfully implements its Circular Economy package and the corresponding future balance between waste supply and EfW capacity in Northern Europe.

◆ Transport the Residual Waste to elsewhere in the UK: As highlighted in the report, road transport could create significant additional movements on an already busy network and there are real challenges around the delivery of new rail infrastructure. One possible option could be the greater use of sea ports,

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Residual Waste in London and the South East

(possibly substituting RDF exports) providing suitable delivery locations, coastal sea routes and reception points can be identified and that the economics remain viable. Tolvik notes with some interest several recently announced development plans for port based EfW infrastructure in the UK outside London and the South East.

◆ Carefully manage existing consented landfill capacity. There is potential scope for landfill operators to “nurture” existing consented capacity for example by ensuring this is used by HIC waste only. If, the tonnage of inert waste inputs to consented capacity were to be reduced by, say, 10%, the cumulative shortfall in landfill capacity could be reduced by more than 1.0Mt. However, each operator will manage their site to their own best interests rather than those of the market as a whole – and so in practice such an option is likely to be limited in effectiveness.

◆ Deliver additional Non-Hazardous Landfill capacity. As outlined in this report, present Waste Local Plans suggest only limited potential for the development of additional/new landfill capacity and securing consents for such developments (even if armed with a strong “need” argument) without explicit allocated sites will face potentially significant opposition.

◆ Develop additional EfW capacity. Consider, for example, if there was a “zero landfill” policy across London and the South East in which no Residual Waste is to be landfilled by 2025 (similar to the current Greater London Authority’s policy of working towards not sending any biodegradable waste to landfill by 2026). In the Central scenario 4.7Mt of EfW capacity over and above that currently operational in London and the South East would need to be available. Whilst some of this capacity could potentially continue to be met by RDF export to Europe, any shortfall would need to be through the construction of new EfWs in London and the South East. The modelling in the Low Tonnage scenario assumes a maximum of 2.06Mt of “Additional” EfW capacity by 2025 – less than half that required for a “zero landfill” scenario – putting into context deliverability of such a solution. In practice, it is likely that there will be no single solution, rather that the market will bring forward a range of responses to the potential shortfall in Non-Hazardous Landfill capacity in London and the South East.

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Residual Waste in London and the South East

APPENDIX 1: DATA TABLES

2017: Operational EfWs

Operational Permitted Name Known As Location Operator Capacity (Ktpa)

1 Riverside Facility Riverside Bexley Cory 750 2 EcoPark Energy Centre Edmonton Enfield Council 535 3 Allington Waste Management Facility Allington Kent FCC 486 4 SELCHP ERF SELCHP Lewisham Veolia 447 5 Lakeside EfW Lakeside Slough Lakeside 442 6 Greatmoor EfW Greatmoor Buckinghamshire FCC 279 7 Ardley EfW Facility Ardley Oxfordshire Viridor 292 8 Newhaven ERF Newhaven East Sussex Veolia 234 9 Integra South West ERF Marchwood Southampton Veolia 203 10 Integra South East ERF Portsmouth Portsmouth Veolia 201 11 Integra North ERF Chineham Hampshire Veolia 98 12 Enviropower Ltd, Lancing Lancing West Sussex Enviropower 33 13 Milton Keynes Waste Recovery Park Milton Keynes ACT Milton Keynes Amey 86 Totals 4,086 (1) Severnside Energy Recovery Centre Severnside S.Gloucs Suez 300 Figure A1: Operational EfW Capacity in London and the South East (1) Operational Capacity assumed for Residual Waste from London and the South East

2017: Operational Non-Hazardous Landfills

2016 2017 Void Capacity as Waste Planning Residual Residual Landfill Operator at 31-Dec-16 Authority Waste Input Waste Input (Ktpa) (Ktpa) (Ktpa) 1 Pitsea Essex Veolia 869 544 365 2 Westmill Hertfordshire Biffa 1,812 362 345 3 Bletchley Milton Keynes FCC 12,980 342 317 4 Rainham Havering Veolia 2,703 177 309 5 Redhill Surrey Biffa 4,761 187 262 6 Sutton Courtenay Oxfordshire FCC 4,477 244 240 7 Beddington Sutton Viridor 229 208 206 Gerrards Cross Buckinghamshire 139 232 176 8 Veolia Springfield Farm Buckinghamshire 10,099 0 41 9 Brookhurst Wood West Sussex Biffa 145 205 165 10 Calvert Buckinghamshire FCC 8,814 215 144 11 Waterbeach Cambridgeshire Amey 2,614 174 137 12 Buckden Cambridgeshire FCC 2,938 122 120 13 Bellhouse Essex Enovert 4,555 114 115 14 Blue Haze Hampshire Veolia 1,100 78 105 15 Ockendon Thurrock Veolia 4,266 6 69 16 Shelford Kent Viridor 2,442 91 62 17 Martells Quarry Essex Hinkcroft 139 65 59 18 Greatness Kent Enovert 137 43 41 19 Milton Cambridgeshire FCC 887 61 31 20 Grunty Fen Cambridgeshire FCC 305 0 29 21 Barling Marsh Essex Enovert 202 13 20 Other 5,288 92 23 Total 71,900 3,575 3,380 Figure A2: Operational Non-Hazardous Landfills in London and the South East

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Residual Waste in London and the South East

EfWs in Construction

Operational Permitted Name Known As Location Developer Capacity (Ktpa) 1 Kemsley Park EfW Kemsley Kent WTI 523 2 Beddington Energy Recovery Facility Beddington Lane Croydon Viridor 261 3 Hoddesdon EfW Plant Hoddesdon ACT Hertfordshire AssetGen 86 4 Charlton Lane Eco Park Eco Park ACT Surrey Suez 57 Total 927 Figure A3: EfW Capacity in Construction in London and the South East “Certain” EfWs

Figure A4: “Certain” EfWs in London and the South East (Red= In Operation, Blue = In Construction)

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Residual Waste in London and the South East

Figure A5: Non-Hazardous Landfills in London and the South East

APPENDIX 2: GLOSSARY

ACT Advanced Conversion Technology (i.e. gasification/pyrolysis) APR Annual Performance Reports C&I Commercial and CE Circular Economy EA Environment Agency EfW Energy from Waste HIC Household Industrial and Commercial Wastes kt (pa) ‘000s tonnes (per annum) LACW Local Authority Collected Waste MBT Mechanical Biological Treatment Mt (pa) Million tonnes (per annum) NSIP Nationally Significant Infrastructure Project RDF Refuse Derived Fuel Operational The expected throughput of an EfW based on recent historical performance, and for Capacity newly built EfWs, an assumed 95% of the Headline Capacity Solid, non-hazardous, combustible waste which remains after recycling either treated Residual Waste (in the form of RDF or SRF) or untreated (as “black bag” waste).

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Residual Waste in London and the South East

APPENDIX 3: WASTE PLANNING OVERVIEW

Waste Planning Policy / Plan Status Landfill observations Authority The emerging Minerals and Waste Local No need for additional landfill capacity Buckinghamshire Plan submitted for examination in June before 2035 2018, adoption is due 2020

Central and Consultation on draft Joint Minerals and 6 site allocations includes Non- Local Plan (to cover period up to Landfill at Star Works (2017 HIC inputs of Eastern Berkshire 2036) open until October 2018 30ktpa) East Sussex Waste and Minerals Plan (adopted Landfill allowed through a generic policy (including Brighton 2013) covers period to 2030 and Waste but plans do not specifically allocate land and South Downs) and Minerals Sites Plan (adopted 2017) for such development 5 identified existing Non-Hazardous waste Essex and Waste Local Plan was adopted in 2017 Landfills are regarded as sufficient and no Southend and covers period to 2032 new site allocations The Plan does not expect new applications for landfill but landfill allowed through generic policy and an allocation of Minerals and Waste Plan (adopted Hampshire an extension to Squabb Wood (closed 2013) covers the period to 2030 2016). The Plan identifies Purple Haze as a reserve area for Non-Hazardous Landfill if further capacity required Combination of the Waste Core Strategy and Development Management Policies Aside from limited remaining Non- (adopted 2012) and Waste Site Hazardous Landfill capacity at Westmill, Hertfordshire Allocations (adopted 2014) through to report identifies a significant shortfall in 2026. Initial consultation on Waste Local capacity emerging during the plan period Plan released February 2018 Demand for landfill capacity expected to decline due to new EfW developments, so Minerals and Waste Local Plan (adopted Kent the Plan has no specific site allocations 2016) covers the period to 2030 but allows for Non-Hazardous Landfill through a generic policy Sufficient Non-Hazardous Landfill Waste Development Plan Document Milton Keynes capacity to meet the needs of Milton (adopted 2008) through to 2026 Keynes Minerals and Waste Local Plan: Part 1 Core Strategy (adopted 2017) and Part Sufficient Non-Hazardous Landfill Oxfordshire 2 Site Allocations due 2020. Covers capacity at Finmere and Sutton Courtney period to 2031 Original 2008 plan to 2018, but draft No new allocation for landfill as it is Surrey Waste Local Plan due to be adopted in anticipated that existing capacity at 2020 and to run to 2033 Redhill will last until 2030 Plan acknowledges lack of Non- Emerging Minerals and Waste Plan (up West Berkshire Hazardous Landfill capacity and the need to 2036) adoption programmed for 2020 to export Need for more non-inert landfill capacity over and above that catered for in the Waste Local Plan (adopted 2014) West Sussex Plan – only allocating a modest extension covers the period to 2031 to Brookhurst Wood but no new non-inert landfill sites allocated

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Residual Waste in London and the South East

APPENDIX 4: DATA SOURCES

General Background

1. https://data.gov.uk/dataset/dd8629ad-bd32-4db3-a07a-879737964f23/waste-data-interrogator-2017 2. http://www.tolvik.com/wp-content/uploads/Tolvik-UK-EfW-Statistics-2017.pdf 3. https://www.gov.uk/government/statistics/local-authority-collected-waste-management-annual-results

Specific

(a) ESA: UK Residual Waste: 2030 Market Review – November 2017 http://www.esauk.org/application/files/6015/3589/6453/UK_Residual_Waste_Capacity_Gap_Analysis.pdf

(b) HM Treasury: Forecasts for the UK Economy – a comparison of independent forecasts - May 2018 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/707804/PU797 _Forecast_for_the_UK_Economy_May_2018_covers.pdf

(c) Biffa: The Reality Gap (2017) https://www.biffa.co.uk/wp-content/uploads/2015/11/048944_BIFFA_Reality-Gap_2017Single-150817-2.pdf

(d) BEIS: Renewable Energy Planning Database https://www.gov.uk/government/publications/renewable-energy-planning-database-monthly-extract

(e) Tolvik: The Future of Landfill? – December 2011 http://www.tolvik.com/wp-content/uploads/2011_Future_of_Landfill.pdf

(f) Environment Agency: Remaining Landfill Capacity as at December 2016 https://data.gov.uk/dataset/fa667727-256d-4237-8399-904bf62a0451/remaining-landfill-capacity

Waste Planning Links

Buckinghamshire https://www.buckscc.gov.uk/media/4511199/300-mwlp-submission-document.pdf http://documents.hants.gov.uk/environment/JCEBREG18DraftPlanConsultationDocume Central & Eastern Berks ntVersion6June2018.pdf East Sussex (including https://www.eastsussex.gov.uk/environment/planning/ development/mineralsandwaste/ Brighton & South Downs) http://www.essex.gov.uk/Environment%20Planning/Minerals-Waste-Planning- Essex & Southend Team/Planning-Policy/Pages/Waste-Local-Plan.aspx http://documents.hants.gov.uk/mineralsandwaste/HampshireMineralsWastePlanADOPT Hampshire ED.pdf https://www.hertfordshire.gov.uk/services/recycling-waste-and-environment/planning-in- hertfordshire/minerals-and-waste-planning/waste-planning/waste-planning.aspx Hertfordshire https://www.hertfordshire.gov.uk/media-library/documents/environment-and- planning/planning/planning-in-hertfordshire/waste-local-plan/the-waste-site-allocations- document-2.pdf https://www.kent.gov.uk/about-the-council/strategies-and-policies/environment-waste- Kent and-planning-policies/planning-policies/minerals-and-waste-planning-policy https://www.milton-keynes.gov.uk/planning-and-building/planning-policy/waste- Milton Keynes development-plan-document https://www.oxfordshire.gov.uk/residents/environment-and-planning/planning/planning- Oxfordshire policy/minerals-and-waste-policy/core-strategy https://www.surreycc.gov.uk/__data/assets/pdf_file/0004/150484/2017-12-01-Draft- Surrey Waste-Local-Plan-Full-Version_v2_Dec2017.pdf West Berkshire https://info.westberks.gov.uk/mwlp https://www.westsussex.gov.uk/about-the-council/policies-and-reports/environment- West Sussex planning-and-waste-policy-and-reports/minerals-and-waste-policy/waste-local-plan

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CONSULTING

MARKET ANALYSIS

DUE DILIGENCE

Adrian Judge Tolvik Consulting Ltd is a privately-owned specialist provider of independent market analysis and

commercial due diligence and advisory services across the waste and biomass sectors.

Our clients include the UK’s leading waste companies, project finance investors, developers and equity investors.

Chris Jonas This report has been written by Tolvik Consulting Ltd on an independent basis using our knowledge of the current UK waste market and with reference inter alia to various published reports and studies and to our own in-house analysis.

This report has been prepared by Tolvik Consulting Ltd with all reasonable skill, care and diligence as applicable. Whilst we have taken reasonable precautions to check the accuracy of information contained herein, we do not warrant the accuracy of information provided.

Sally Freshwater

Tolvik Consulting Limited, The Old Vicarage, Fairmead, Cam, Dursley, Gloucestershire GL11 5JR

Tel: + 44 (0) 1453 519048 Email: [email protected]

www.tolvik.com