What this document is
The State A / State B economic model for Collier County: what the County pays under the current system and under the CSA, and what it receives — shown as separate flows.
- State A is $88.50/ton blended disposal plus a post-closure obligation through ~2033 and a pending expansion capital decision.
- State B: $6.60M Year-1 Beneficiation Fee at Phase Initial; a Circular Royalty™ of $7.92M in Year 2 growing to ~$395M gross over 30 years.
- Two independent gross transactions, reported separately; zero County capital.
Collier County, Florida
Economic Impact Report
State A commits capital to landfill expansion and carries a post-closure liability — State B converts the same volume into a 30-year royalty return.
Introduction and Decision Summary
Introduction and Decision Summary
This EIR quantifies the fiscal, economic, and structural delta between two defined states for Collier County's manufacturing feedstock system over a 30-year horizon.
State A is the continuation of current operations: all manufacturing feedstock disposed at the Collier County Landfill at White Lake Blvd, operated by Waste Management, Inc., under the county's existing rate schedule. Cost trajectory continues under annual rate escalation and capital reinvestment pressure. No alternative destination contracted. Landfill expansion capital decision pending.
State B is ACM deployment under the Carbotura Circular Supply Agreement: manufacturing feedstock diverted to the ACM facility at Phase Initial (200 TPD), Phase Medium (400 TPD), and Phase Expanded (800 TPD). Beneficiation Fee obligation begins at Phase Initial COD; Circular Royalty™ receipts begin at Month 13. All State B values sourced exclusively from the Proposal EIR Input Block.
Neither State A nor State B is re-diagnosed here. This document computes the delta only.
| Decision Item | State A | State B | Source Type |
|---|---|---|---|
| Annual disposal cost (Phase Expanded volume — 264,000 TPY) | ~$23,364,000/yr Modeled | N/A — replaced by Beneficiation Fee | Modeled |
| Year 1 — Beneficiation Fee paid → Carbotura | $0 | $26,400,000 (Phase Expanded) Derived | Derived |
| Year 1 — Circular Royalty™ received → Community | $0 | $0 (pre-royalty period) | Standard |
| Year 2 — Circular Royalty™ received → Community | $0 | $31,680,000 (Phase Expanded) Derived | Derived |
| Year 30 — Circular Royalty™ received → Community | $0 | $77,996,000 (Phase Expanded) Derived | Derived |
| Community capital obligation | Landfill expansion: $73M–$400M if committed (ESTIMATED) | $0 — 100% Carbotura-financed | Standard |
| Key data gaps | FWDC composition allocation (MODELED) · Total system TPD (ESTIMATED) · Site candidate (PROVISIONAL) · Exogenesis™ eligibility (SUBJECT TO STUDY) | Est/Modeled | |
| Decision deadline | Before BCC commits expansion engineering capital — timing driven by BCC staff analysis return (post March 2025 directive) | Estimated | |
| Cost of delay (per year without CSA at Phase Expanded) | Royalty receipts not started: ~$31.7M/yr (Year 2 rate); escalating annually. Additionally: avoided disposal not realized; expansion capex window remains open | Derived | |
Beneficiation Fee and Circular Royalty™ are shown as independent transactions in separate rows. They are never netted. The Beneficiation Fee flows Community → Carbotura. The Circular Royalty™ flows Carbotura → Community. Both are separate financial effects of the CSA per the Separate Transaction Principle.
County fiscal effects — Beneficiation Fee (TMC Fee) obligations and Circular Royalty™ receipts (independent transactions) — and regional economic impact are distinct categories and must not be combined in any table, chart, or analytical statement in this document. Fiscal effects are contractual per-ton cash flows under the CSA. Regional economic impact (employment, GDP contribution) reflects broader economic activity from facility operation. Both categories appear separately throughout this EIR.
NAICS classification note: ACM is permitted only under manufacturing NAICS codes 325180, 325998, 327992, 331110, 331314, and 331492 (US Sector 31–33). Solid waste codes (562212 / 562213 / 562219 / 562920) are expressly excluded. Both parties commit to the RPT pathway; the endpoint is categorical — manufacturing classification across all permitting, licensing, and regulatory contexts. Interim bridging authorities may apply during the transition.
State A Baseline
State A Baseline
Source: Waste Study §§1–4. Registry-locked values. No new diagnosis in this section.
| Stream | Annual Vol (TPY) | Daily (TPD) | Disposition | Operator |
|---|---|---|---|---|
| Residential MSW | ~197,000 Est | ~597 | Collier County Landfill | WM |
| Commercial MSW | ~138,000 Est | ~418 | Collier County Landfill | WM |
| Yard Waste / Biomass | ~66,000 Est | ~200 | Landfill + composting | WM / County |
| C&D Debris | ~49,500 Est | ~150 | WM C&D Landfill (co-located) | WM |
| WWTP Biosolids | ~26,400 Est | ~80 | Landfill ($79.25/ton FY26) | Collier County PUD |
| Other / Specialty | ~18,100 Est | ~55 | Various | County / WM |
| Total System | ~495,000 Est | ~1,500 | Single destination — White Lake Blvd | |
| Stream | FY26 Tipping Fee | Annual Cost (addressable volume) | Source Type |
|---|---|---|---|
| Residential MSW (~197,000 TPY addressable) | $88.20/ton | $17,375,000 | Verified |
| Commercial MSW (~67,000 TPY of 138K in Phase Exp.) | $90.35/ton | ~$6,053,000 | Verified |
| Biosolids (26,400 TPY) | $79.25/ton | $2,092,000 | Verified |
| Blended FWDC (Phase Expanded 264,000 TPY) | ~$88.50/ton | ~$23,364,000 | Modeled |
| Annual escalation (residential FY25→FY26) | +4.5% YOY | Compounds annually under county rate schedule | Verified |
No WTE/RRF in county; zero combusted tons (FDEP 2020). Out-of-county disposal premium: 135% above in-county cost (SCS Engineers, March 2025). No competitive disposal alternatives in county.
- Annual rate schedule escalation. FY2026 residential MSW rose 4.5% from FY2025. Each annual rate resolution compounds the disposal cost basis under no-action. Planning basis escalation: 2.5%/yr conservative.
- Capital reinvestment pressure. Southern expansion (~$73M) or eastern expansion (up to $400M) would introduce debt service per ton, further elevating the effective disposal cost. Deep injection well ($1.5M/yr savings) illustrates ongoing capital intensity.
- No competitive alternatives market. Closest private landfill ~2.5 hours away, 135% premium. WM operations contract (since 1995) operates without competitive constraint.
- Collier County Landfill: 310.97 acres, Class I MSW. 40.75 acres closed, 9.1 acres temporarily capped, 132.15 acres active. Capacity through ~2059.
- No PFAS treatment at landfill. Leachate managed via Class I deep injection well (3,000 ft depth, operational February 2022).
- Immokalee Landfill: closed 2003, unlined. Active FDEP post-closure obligation through ~2033. Environmental liability acknowledged by BCC March 2025.
- Aquifer sensitivity: 96% of county drinking water from Floridan Aquifer. Leachate management is a structural operational cost regardless of expansion path.
- LFGTE facility on-site (6.5 MW, 120+ wells). Hydrogen from conversion is internal facility power — not an external product or revenue item.
State B Deployment Baseline
State B Deployment Baseline
All State B values sourced from Proposal EIR Input Block only. No independent derivation.
Six confidence flags inherited (see Inherited Flags Block, above). Most consequential for this section: FWDC is MODELED; site candidate is PROVISIONAL; total system TPD is ESTIMATED. All three flags propagate to delta calculations in §4 and are labeled at the figure level throughout.
| Phase | TPD | Modules | Annual Feedstock (TPY) | % IMMEDIATE Stream | COD |
|---|---|---|---|---|---|
| Phase Initial | 200 | 2 | 66,000 Derived | 20% | T0 + 24 months |
| Phase Medium | 400 | 4 | 132,000 Derived | 39% | T0 + 42 months |
| Phase Expanded | 800 | 8 | 264,000 Derived | 79% | T0 + 60 months |
Module verification: 200 TPD ÷ 100 = 2 modules ✓ · 800 TPD ÷ 100 = 8 modules ✓ · Topology: Single-Site, truck-served.
| Term | Value | Source Type |
|---|---|---|
| Beneficiation Fee (TMC Fee) — base | $100.00/ton · +2.5%/yr | Verified |
| Circular Royalty™ base rate | 120% of that year's Beneficiation Fee | Standard |
| Royalty formula | (1.20 + 0.01·(y−2)) × $100 × 1.025^(y−2) per ton | Standard |
| Royalty payment lag | 13 months after corresponding Beneficiation Fee payment | Always |
| Year 2 royalty/ton | $120.00 | Derived |
| Year 10 royalty/ton | $155.96 | Derived |
| Year 30 royalty/ton | $295.44 | Derived |
| Parent Performance Guarantee | 18-month guarantee on all SPV payment obligations · Carbotura, Inc. | Standard |
| Community capital obligation | $0 | Standard |
| CSA term | 30-year minimum from Phase Initial COD + perpetual continuation | Standard |
Residual stream fraction (non-addressable at Phase Expanded): estimated ~35% of total system generation (~525 TPD) continues to White Lake Blvd landfill at current rates. This residual fraction carries continuing disposal cost obligations under State B at the existing rate schedule.
| Milestone | Date (from T0) |
|---|---|
| Phase Initial COD | T0 + 24 months |
| First Beneficiation Fee payment | T0 + 24 months (Month 1 of operations) |
| First Circular Royalty™ payment | T0 + 37 months (13 months after first fee) |
| Phase Expanded full operations | T0 + 60 months |
| CSA term end (30yr minimum) | T0 + ~54 years (30 years from Phase Initial COD) |
| Non-Renewal Notice window | T0 + ~52 years (Year 28 minimum notice window) |
| Perpetual continuation | Year 30+ unless Non-Renewal Notice served |
Geographic transition from current disposal infrastructure (State A) to ACM deployment at P1 candidate site (State B). State A facilities shown with steel/grey markers. State B ACM site shown as Emerald square. Click any panel item or map marker for details.
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Delta panel available →
State A: Collier County Landfill (blue circle) · Immokalee (amber circle — active liability) · WWTPs (green circles). State B: P1 ACM site (emerald square). Source: Waste Study §6 facilities; Proposal §2.4 site analysis; places_search May 2026. Coordinates estimated where noted.
Delta Analysis
Delta Analysis
"At steady state, the Circular Royalty™ is designed to exceed the Beneficiation Fee on a per-ton basis."
"Circular Royalty™ payments begin 13 months after corresponding Beneficiation Fee payments and ramp to full run-rate on a rolling basis."
- Gross cost displacement. The disposal cost not incurred for feedstock diverted to ACM. Measured as FWDC per ton × annual volume. Independent of royalty receipts. Source: State A §2.2.
- Circular Royalty™ cash flow. Royalty payments received by Collier County from Carbotura beginning Month 13, rolling monthly. Measured as royalty per ton × annual volume. Independent of fee obligations. Source: Proposal EIR Input Block.
- Residual obligation. Disposal cost for non-diverted volume continuing to State A disposition. Measured as remaining volume × State A FWDC. Reduces to zero only at full system addressable deployment.
Beneficiation Fee and Circular Royalty™ shown as separate rows. No Net column. Independent transactions per Separate Transaction Principle.
| Item | Phase Initial (200 TPD · 66K TPY) | Phase Medium (400 TPD · 132K TPY) | Phase Expanded (800 TPD · 264K TPY) |
|---|---|---|---|
| State A disposal cost for this volume | $5,841,000/yr Modeled | $11,682,000/yr | $23,364,000/yr |
| Year 1 Beneficiation Fee paid → Carbotura | ($6,600,000) | ($13,200,000) | ($26,400,000) |
| Year 1 Circular Royalty™ → Community (pre-royalty) | $0 | $0 | $0 |
| Year 2 Beneficiation Fee paid ($102.50/ton) | ($6,765,000) | ($13,530,000) | ($27,060,000) |
| Year 2 Circular Royalty™ → Community ($120.00/ton) | $7,920,000 | $15,840,000 | $31,680,000 |
| Year 10 Beneficiation Fee paid ($124.89/ton) | ($8,243,000) | ($16,485,000) | ($32,971,000) |
| Year 10 Circular Royalty™ → Community ($155.96/ton) | $10,293,000 | $20,587,000 | $41,173,000 |
| Year 30 Beneficiation Fee paid ($204.64/ton) | ($13,506,000) | ($27,012,000) | ($54,025,000) |
| Year 30 Circular Royalty™ → Community ($295.44/ton) | $19,499,000 | $38,998,000 | $77,996,000 |
| Community capital obligation (State B) | $0 | $0 | $0 |
All figures ESTIMATED / DERIVED from locked Registry and Proposal EIR Input Block. No Net column. Beneficiation Fee and Circular Royalty™ are independent transactions.
FWDC projected at 2.5%/yr (conservative planning basis — FY25→FY26 actual was 4.5%). Independent of Beneficiation Fee. Separate from Circular Royalty™ receipts per Separate Transaction Principle.
| Year | Est. FWDC/ton (2.5%/yr) | Gross Displacement/ton | Annual Gross Displacement (264K TPY) |
|---|---|---|---|
| Year 1 | $88.50 | $88.50 | $23,364,000 |
| Year 2 | $90.71 | $90.71 | $23,947,000 |
| Year 5 | $97.77 | $97.77 | $25,811,000 |
| Year 10 | $111.07 | $111.07 | $29,322,000 |
| Year 15 | $126.10 | $126.10 | $33,290,000 |
| Year 20 | $143.07 | $143.07 | $37,770,000 |
| Year 25 | $162.34 | $162.34 | $42,858,000 |
| Year 30 | $184.30 | $184.30 | $48,655,000 |
Gross cost displacement is an independent financial effect of the CSA — it is not a royalty receipt and must not be combined with royalty figures in any table or chart.
| Year | Royalty Rate | Fee/ton | Royalty/ton → Community | Annual Royalty Received | Excess Over Fee/ton |
|---|---|---|---|---|---|
| Year 1 | Pre-royalty | $100.00 | $0 | $0 | (−$100.00) |
| Year 2 | 120% | $102.50 | $120.00 | $31,680,000 | +$17.50 |
| Year 5 | 123% | $110.38 | $132.46 | $34,969,000 | +$22.08 |
| Year 10 | 128% | $124.89 | $155.96 | $41,173,000 | +$31.07 |
| Year 15 | 133% | $141.30 | $183.34 | $48,402,000 | +$42.04 |
| Year 20 | 138% | $160.54 | $216.11 | $57,053,000 | +$55.57 |
| Year 25 | 143% | $180.87 | $252.34 | $66,618,000 | +$71.47 |
| Year 30 | 148% | $204.64 | $295.44 | $77,996,000 | +$90.80 |
Royalty figures are amounts received. The royalty is paid 13 months in arrears, so the figure shown for a year is earned on the previous year’s delivered tonnage.
Excess Over Fee/ton column is shown for analytical reference only — it is not a net column combining the transactions. Beneficiation Fee and Circular Royalty™ remain separate transactions per MR §4.8.
Executive Implications — Delta Analysis
- The Year 1 fiscal position is negative under the CSA: the county pays $26.4M in Beneficiation Fee (Phase Expanded) and receives no Circular Royalty™. This is the pre-royalty period — a known, bounded cost that ends at Month 13.
- From Year 2 onward, the Circular Royalty™ exceeds the Beneficiation Fee per ton by design, and the spread compounds annually. By Year 10, the royalty is $31.07/ton above the fee; by Year 30, $90.80/ton above. At Phase Expanded scale, the Year 30 royalty of $78.0M exceeds the fee of $54.0M by $24.0M annually.
- The gross cost displacement (avoided disposal) is a separate, independent financial effect. At Phase Expanded Year 30, $48.7M in disposal cost is not incurred — on top of $78.0M in royalty receipts. Both are consequences of the CSA; neither offsets or is combined with the other.
- Every year of delay in CSA execution is a year of royalty receipts not started. At Phase Expanded Year 2 rates, that delay cost is $31.7M/yr in foregone royalty. The royalty does not recapture lost years — the 30-year clock starts from T0, not from a fixed date.
System-Level Impact
System-Level Impact
| Metric | State A Delta | State B (Phase Expanded) | Source |
|---|---|---|---|
| Direct FTE employment | 0 new manufacturing jobs | ~200 FTE Est | Carbotura standard parameters × 2 (800 TPD baseline) |
| Indirect / induced jobs | 0 | ~600 jobs Est | Scaled from standard 400 TPD baseline |
| Annual economic impact | $0 new manufacturing | ~$64M+/year Est | Carbotura standard × scale |
| NAICS classification | NAICS 562212 (solid waste) | NAICS 31–33 manufacturing (six codes) | RPT §1.4 |
| Metric | State A | State B (Phase Expanded) — Designed For |
|---|---|---|
| Carbon impact | Landfill methane (LFG captured at 6.5 MW LFGTE); ongoing carbon obligation | −3,044 to −3,132 tons CO₂e/day designed reduction Est |
| 30-year carbon | Landfill methane baseline continues | ~34M tons CO₂e designed reduction Est |
| Water recovery | Deep injection well for leachate ($1.5M/yr ops) | 174,000+ gallons ultrapure/day designed recovery |
| Energy (self-powered) | Grid draw for existing operations | ~1,714 MWh/day designed internal generation · near-zero grid draw |
| Material throughput | ~28% recycling credit (LFGTE) | ~90% sold globally · ~100% converted (ACM) |
| Island Mode | Grid-dependent | Grid-independent designed capability, ~5% reserve buffer |
All State B metrics use "designed for" qualifying language per Carbotura standard. These are engineered performance targets at commercial scale, not guaranteed operational outcomes.
State A: PFAS compounds entering the landfill present ongoing risk given the county's Floridan Aquifer sensitivity (96% of drinking water from groundwater). No PFAS treatment at landfill; leachate disposal via deep injection well does not eliminate PFAS from the waste stream. State B: ACM designed for complete elemental dissociation of PFAS compounds at operating temperatures above 1,200°C via anoxic Microwave Catalytic Reforming. PFAS compounds are eliminated from the feedstock stream, removing the structural groundwater risk pathway for diverted volumes.
Risk and Sensitivity
Risk and Sensitivity
| Risk | Driver | Bearer | Mitigation | Residual |
|---|---|---|---|---|
| FWDC model error | Composition allocation estimated — verified total tipping fees confirm floor governance | Shared — Term Sheet phase verification resolves | Fee at $100/ton Floor regardless of FWDC level; Floor is binding | Low — Floor is contractual |
| Technology performance | RevCon™ 3 basis; commercial scale | Carbotura — BOO isolates community | Parent Performance Guarantee; royalty independent of output performance | None to community |
| Output market risk | Synthetic graphite, graphene compounds, recovered minerals markets may shift | Carbotura — royalty obligation is independent of product pricing | Royalty flows from operating revenues; community royalty is contractually fixed per CSA | Moderate for Carbotura; none to community royalty structure |
| Timeline slippage | Permitting, RPT, site access | Carbotura (construction) / Shared (site) | P1 site co-located with existing SW infrastructure; standard T0+24 schedule | Moderate — delays royalty start |
| WM contract constraints | Franchise / landfill operations contracts may contain notice or exclusivity provisions | Community — legal review during Term Sheet negotiation | CSA is manufacturing supply agreement; Term Sheet phase verification includes contract review | Moderate — legal review required |
| NAICS / classification risk | Regulatory Predicate Transition (RPT) — coordinated shift onto manufacturing predicate | Shared — both parties commit to the RPT pathway | RPT: both parties commit to manufacturing classification (NAICS 31–33) | Low-moderate — RPT: both parties commit to the dewaste pathway |
| Expansion capital commitment | BCC may vote to commit expansion engineering capital before CSA is executed | Community decision risk | Term Sheet phase verification must precede BCC expansion capital vote | High if not acted on |
| Exogenesis™ Waste Characterization Study outcome | Study may determine Immokalee or White Lake Blvd cells do not qualify | Community (foregone bonus royalty) / Carbotura (foregone extraction) | Exogenesis™ is optional bonus — primary CSA is unaffected | Low to primary CSA; Exogenesis™ royalty foregone if no qualifying asset confirmed |
| PFAS regulatory tightening | Stricter federal / state PFAS standards increase landfill compliance costs | Community (State A only) / ACM eliminates PFAS pathway | ACM PFAS elemental dissociation at 1,200°C+ eliminates the regulatory risk for diverted volumes | Residual for non-diverted volume only under State B |
| Competitive procurement requirement | County procurement rules may require public RFP before CSA execution | Community — process design | Structured as manufacturing operations (NAICS 31–33); Term Sheet phase verification determines procurement pathway | Moderate — legal review during Term Sheet negotiation |
| Scenario | Assumed Volume | Phase Expanded Annual Royalty (Year 2) | Annual Fee (Year 2) |
|---|---|---|---|
| Base case | 264,000 TPY (800 TPD) | $31,680,000 | $27,060,000 |
| −20% (211,200 TPY) | 211,200 TPY | $25,344,000 | $21,648,000 |
| +20% (316,800 TPY) | 316,800 TPY | $38,016,000 | $32,472,000 |
Both royalty and fee scale proportionally with volume. Royalty exceeds fee in Year 2+ regardless of volume scenario — structure-determined by the 120% multiplier exceeding 100%.
| Scenario | Year 2 Royalty/ton | Year 10 Royalty/ton | Year 30 Royalty/ton |
|---|---|---|---|
| 0 pp/yr (no multiplier escalation) | $120.00 | $145.08 | $239.55 |
| +1 pp/yr (base case) | $120.00 | $155.96 | $295.44 |
| +2 pp/yr (upside only) | $120.00 | $166.84 | $363.10 |
Even at 0 pp/yr escalation, Year 30 royalty ($239.55/ton) exceeds Year 30 fee ($204.64/ton) by $34.91/ton — the steady-state positive position holds under all multiplier escalator scenarios. +1 pp/yr is the base case per CSA v2026.7.
| Scenario | Phase Initial COD | First Royalty Payment | Impact |
|---|---|---|---|
| On-schedule | T0 + 24 months | T0 + 37 months | Base case |
| 6-month slip | T0 + 30 months | T0 + 43 months | 6 months additional pre-royalty; ~$3.9M foregone royalty (Phase Expanded rate) |
| 12-month slip | T0 + 36 months | T0 + 49 months | 12 months additional pre-royalty; ~$7.9M foregone royalty (Phase Expanded rate) |
Royalty figures are amounts received. The royalty is paid 13 months in arrears, so the figure shown for a year is earned on the previous year’s delivered tonnage.
Slippage does not change the contractual royalty rate — it delays the start. The 30-year clock runs from actual Phase Initial COD, not from T0. Slippage reduces total royalty received over any fixed horizon.
Decision Window Analysis
Decision Window Analysis
Two binding constraints govern the Collier County decision window:
- BCC expansion capital commitment. The March 2025 BCC workshop directed staff to return with detailed expansion analysis — both southern ($73M) and eastern ($400M) options. When the BCC votes to commit engineering capital, the CSA alternative for that capacity increment closes structurally. The timeline from workshop directive to BCC capital vote is typically 12–24 months for a project of this scope.
- Term Sheet phase verification lead time. A Term Sheet phase verification requires authorisation, scoping, procurement, and execution — typically 3–6 months. This study must precede the BCC expansion vote to be decision-relevant. The authorisation of Term Sheet phase verification is therefore the near-term decision gate.
| Window | Duration | Key Action | Consequence if Missed |
|---|---|---|---|
| BCC authorises Term Sheet phase verification | Now → before BCC expansion vote | Execute the LOI/MOU — typically 3–6 months to complete | Term Sheet phase verification not available to inform expansion vs. CSA decision |
| CSA execution window | Before expansion engineering contracted | Execute CSA — fixes terms and begins the T0 clock | If expansion engineering contracted, CSA alternative for that capacity closes. Capital lock-in is irreversible. |
| Exogenesis™ add-on window | Before CSA execution | Waste Characterization Study must be complete and add-on incorporated at signing | Exogenesis™ Programme cannot be added retroactively. Post-closure liability transfer opportunity is lost if not elected at CSA execution. |
| Action | Expiry | If Taken | If Not Taken |
|---|---|---|---|
| Execute the LOI/MOU | Before BCC expansion engineering vote | The CSA remains available; expansion alternative remains analysed | BCC proceeds without structured CSA alternative analysis |
| Execute the CSA | Before expansion engineering contract awarded | T0 set; Phase Initial COD in 24 months; royalty in 37 months | $73–$400M expansion capital committed; CSA window closed for that capacity increment |
| Elect Exogenesis™ Royalty | At CSA execution only | Immokalee liability transferred; $50/ton bonus royalty begins post-Exogenesis™ deployment | Post-closure liability remains community-held through ~2033; Exogenesis™ bonus not available retroactively |
| Take no action | N/A | N/A | State A continues; disposal cost escalates annually; expansion capital decision made without CSA alternative; Immokalee liability matures to enforcement |
Executive Implications — Decision Window
- The decision window is not calendar-driven — it is event-driven. It closes when the BCC votes to commit engineering capital to landfill expansion. That vote may occur in 2025 or 2026 based on staff return timelines. Term Sheet phase verification must be authorised before that vote.
- The Exogenesis™ add-on window closes at CSA execution — it cannot be added retroactively. The Immokalee post-closure liability (active, unlined, running through ~2033) transfers to Carbotura only if the Exogenesis™ Programme is elected at signing. Each year without CSA execution is a year of active liability carrying on the county's books.
- If the BCC's primary concern is Year 1 outflow (fee without offsetting royalty),
- The LOI/MOU execution preserves all optionality: it does not commit to the CSA, It is the minimum necessary action to keep the CSA as a viable alternative to the expansion capital decision that follows.
Effects Summary
Effects Summary
No new figures introduced in this section. All values trace to preceding sections. References note source section.
| Fiscal Item | Year 1 (Pre-Royalty) | Year 2 (Royalty Active) | Year 10 (Steady-State) | Year 30 |
|---|---|---|---|---|
| Gross Cost Displacement (avoided disposal) → Community (indirect) | $23,364,000 M | $23,947,000 | $29,322,000 | $48,655,000 |
| Beneficiation Fee paid → Carbotura (outflow) | ($26,400,000) | ($27,060,000) | ($32,971,000) | ($54,025,000) |
| Circular Royalty™ received → Community (inflow) | $0 | $31,680,000 | $41,173,000 | $77,996,000 |
Gross displacement row = §4.4 · Beneficiation Fee row = §4.1 · Circular Royalty™ row = §4.5 · All MODELED / DERIVED · Phase Expanded 800 TPD · 264,000 TPY
Regional economic effects — not county fiscal receipts. Must not be combined with Beneficiation Fee or Circular Royalty™ figures.
| Effect | State A Delta | State B (Phase Expanded) |
|---|---|---|
| Direct manufacturing employment | +0 | +~200 FTE |
| Indirect / induced employment | +0 | +~600 jobs |
| Annual regional economic impact | $0 | ~$64M+/year |
Designed-performance basis. Not guaranteed operational outcomes.
- Carbon: designed reduction of 3,044–3,132 tonnes CO₂e/day (Phase Expanded) vs. continued landfill methane and ongoing LFGTE combustion.
- PFAS: complete elemental dissociation designed for diverted streams vs. persistent PFAS in leachate under State A.
- Water: 174,000+ gallons ultrapure water recovered/day designed vs. leachate disposal obligation.
- Material throughput: ~90% sold globally / ~100% converted (ACM) vs. ~28% recycling credit (LFGTE basis).
- Capital commitment: $0 community capital (State B) vs. $73M–$400M expansion (State A path).
- Operational risk: 100% Carbotura-borne (State B) vs. 100% community-borne (State A continuation).
- Post-closure liability (Immokalee): extinguished at CSA execution (if Exogenesis™ elected) vs. active liability through ~2033 (State A).
- Disposal concentration risk: structurally diversified to ACM manufacturing route (State B) vs. 100% single-operator, single-facility dependency (State A).
| Gap | Field | Impact on This EIR | Resolution Path |
|---|---|---|---|
| Feedstock composition breakdown | MSW/biosolids/C&D stream allocation (currently 60/35/5 estimated) | Affects blended FWDC; Floor governance confirmed regardless | FDEP annual tonnage reports; Term Sheet phase verification waste audit |
| Immokalee landfill GASB-equivalent liability quantum | Exact dollar amount of FDEP post-closure obligation | Would quantify the balance sheet benefit of Exogenesis™ add-on; not needed for primary CSA analysis | Collier County CAFR review; FDEP post-closure care cost estimates |
| Closed cell volumes — White Lake Blvd | Extractable mass from 40.75 closed + 9.1 capped acres | Would support Exogenesis™ Royalty quantification; not needed for primary CSA | Waste Characterization Study |
| Site candidate confirmation | RRBP / SW Parcels acreage, PUD entitlement status | P1 site provisional; map and analysis use estimated coordinates | Term Sheet phase verification site analysis; Davidson Engineering PUD review |
| WM contract terms | Exclusivity provisions, notice periods in franchise and landfill operations contracts | May affect transition timeline and feedstock diversion mechanics | Legal review during Term Sheet phase verification stage |
Sources and Methodology
Sources and Methodology
| Item | Methodology | Primary Source |
|---|---|---|
| FWDC derivation | Weighted blend: verified FY26 tipping fees × estimated stream composition shares | Resolution No. 2025-184, Collier County BCC, Schedule C; FDEP 2020 Collier report (composition basis) |
| Beneficiation Fee formula | MAX($100, MIN($150, FWDC−$5)); Floor = $100 at current FWDC | Carbotura standard parameters CSA v2026.7 |
| Circular Royalty™ formula | (1.20 + 0.01·(y−2)) × $100 × 1.025^(y−2) per ton | CSA v2026.7; Proposal EIR Input Block |
| Phase sizing | 200/400/800 TPD (Architect-confirmed); module count = TPD ÷ 100 | Registry §H; Proposal §2.1 |
| Environmental performance basis | Carbotura standard parameters 400 TPD baseline × phase scale factor | Carbotura standard parameters §8 |
| Employment basis | 100 FTE direct / ~300 indirect at 400 TPD baseline × phase scale factor | Carbotura standard parameters §8 |
| Timeline basis | Carbotura standard deployment schedule; T0 + 24 months Phase Initial COD | MI §Standardized Deployment Timeline |
| Expansion cost estimates | SCS Engineers presentation to Collier BCC, March 2025 | Naples Daily News / Yahoo Finance March 5, 2025 |
| Immokalee liability basis | FDEP 30-year post-closure rule; closed 2003 → obligation through ~2033 | Florida DEP post-closure regulations; BCC workshop March 2025 (SCS Engineers) |
Glossary Additions
Glossary Additions
Additions to the Waste Study authoritative glossary. See Waste Study Appendix D for base terms.
| Term | Definition |
|---|---|
| Gross Cost Displacement | Disposal cost not incurred for feedstock diverted from State A to ACM under the CSA. Measured as projected FWDC per ton × annual volume. Independent financial effect — never combined with royalty receipts. |
| Per-Ton Fiscal Flows | The gross per-ton amounts flowing independently in each direction under the CSA: Beneficiation Fee (Community → Carbotura) and Circular Royalty™ (Carbotura → Community). Each flows at its own rate, escalates independently, and is reported as a separate transaction. Never netted. |
| Pre-Royalty Period | Months 1–12 under the CSA. Community pays Beneficiation Fee; receives no Circular Royalty™. The pre-royalty period is a structural feature of the CSA. |
| Royalty Ramp Period | Month 13 to approximately Month 24. Rolling Circular Royalty™ payments begin; ramp to full run-rate as corresponding fee payments from Month 1 onward each trigger their lagged royalty payment. |
| Steady-State Period | Year 2 onward. Circular Royalty™ per ton exceeds Beneficiation Fee per ton by design and compounding annually. The spread grows as the royalty multiplier escalates +1 percentage point per year. |
| Delta Model | The analytical framework of this EIR: quantifying the difference between State A (current system continuation) and State B (ACM deployment under CSA) without re-diagnosing either state independently. |
| State A | Current system — all manufacturing feedstock to Collier County Landfill, WM operated, under FY26 rate schedule. No ACM. Expansion capital decision pending. |
| State B | ACM deployment under Carbotura CSA — manufacturing feedstock diverted to ACM facility at P1 site (RRBP, East Naples). Beneficiation Fee begins Phase Initial COD; Circular Royalty™ begins Month 13. |
| Separate Transaction Principle | Beneficiation Fee and Circular Royalty™ are independent payment obligations under the CSA. Never netted, combined, or co-mingled in any table, chart, or sentence. See MR §4.8. |
| Circular Royalty™ | Standard CSA modeled in this EIR. Community pays Beneficiation Fee; receives Circular Royalty™ from Month 13. Formula: (1.20 + 0.01·(y−2)) × $100 × 1.025^(y-2) per ton. See Proposal §4.0. |
| Exogenesis™ Royalty | Bonus stream stacking on the CSA. $50/ton extracted by Exogenesis™, +1%/yr compound. Subject to Waste Characterization Study and qualifying asset confirmation. Not quantified in this EIR. See Proposal §4.1. |
| US GAAP | United States Generally Accepted Accounting Principles — governing accounting standard for this engagement (Florida jurisdiction per Registry §A). |
Evidence Chain
Evidence Chain
| Figure | Value | Source | Type |
|---|---|---|---|
| Phase Expanded TPD / TPY | 800 TPD / 264,000 TPY | Architect-confirmed intake; Registry §H | Verified |
| Beneficiation Fee Year 1 | $100.00/ton | Proposal EIR Input Block; Registry §E | Verified |
| Circular Royalty™ Year 2 | $120.00/ton | Proposal EIR Input Block; formula: 1.20 × $100.00 | Derived |
| Circular Royalty™ Year 30 | $295.44/ton | Proposal EIR Input Block; formula: 1.48 × $100 × 1.025^28 | Derived |
| FWDC blended | ~$88.50/ton | FY26 Rate Resolution 2025-184 + composition estimate; Waste Study §3.1 | Modeled |
| Phase Initial COD | T0 + 24 months | Carbotura standard deployment schedule; Proposal §6 | Standard |
| First royalty payment | T0 + 37 months | Phase Initial COD + 13-month lag; formula-derived | Derived |
| Employment — Phase Expanded | ~200 FTE direct / ~600 indirect | Carbotura standard parameters (100 FTE / 400 TPD baseline × 2) | Estimated |
| Expansion cost — southern option | ~$73M / +29 years capacity | SCS Engineers, BCC Workshop March 2025 | Estimated |
| Immokalee closure year | 2003 | Naples Daily News / Yahoo Finance March 5, 2025; BCC workshop SCS Engineers | Verified |
| Post-closure obligation end | ~2033 | FDEP 30-year post-closure rule applied to 2003 closure | Estimated |