Economic Impact Report

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.

Three things this document says
  1. State A is $88.50/ton blended disposal plus a post-closure obligation through ~2033 and a pending expansion capital decision.
  2. 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.
  3. Two independent gross transactions, reported separately; zero County capital.
Carbotura · Circular Advantage Program · Economic Impact Report

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.

Document: Stage 1 Economic Impact Report Prepared for: Collier County Board of County Commissioners Date: May 2026 Basis: State A from the Feedstock System Assessment; State B from the Proposal EIR Input Block; FWDC MODELED, all else ESTIMATED

Introduction and Decision Summary

Section 1

Introduction and Decision Summary

§1.1 — What This Report Measures

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.

§1.2 — Decision Summary Table
Analysis Basis Under the CSA, Collier County pays the Beneficiation Fee and receives the Circular Royalty™. The Exogenesis™ Royalty (a $50/ton bonus stream from landfill remediation, available under the CSA when a qualifying legacy landfill exists) is described in Proposal §4.1. Both streams are reported as separate transactions per the Separate Transaction Principle (MR §4.8).
Decision ItemState AState BSource 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.

§1.3 — Fiscal vs. Regional Economic Separation

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

Section 2

State A Baseline

Source: Waste Study §§1–4. Registry-locked values. No new diagnosis in this section.

§2.1 — Feedstock Volume and Disposition
StreamAnnual Vol (TPY)Daily (TPD)DispositionOperator
Residential MSW~197,000 Est~597Collier County LandfillWM
Commercial MSW~138,000 Est~418Collier County LandfillWM
Yard Waste / Biomass~66,000 Est~200Landfill + compostingWM / County
C&D Debris~49,500 Est~150WM C&D Landfill (co-located)WM
WWTP Biosolids~26,400 Est~80Landfill ($79.25/ton FY26)Collier County PUD
Other / Specialty~18,100 Est~55VariousCounty / WM
Total System~495,000 Est~1,500Single destination — White Lake Blvd
§2.2 — State A Cost Structure
StreamFY26 Tipping FeeAnnual Cost (addressable volume)Source Type
Residential MSW (~197,000 TPY addressable)$88.20/ton$17,375,000Verified
Commercial MSW (~67,000 TPY of 138K in Phase Exp.)$90.35/ton~$6,053,000Verified
Biosolids (26,400 TPY)$79.25/ton$2,092,000Verified
Blended FWDC (Phase Expanded 264,000 TPY)~$88.50/ton~$23,364,000Modeled
Annual escalation (residential FY25→FY26)+4.5% YOYCompounds annually under county rate scheduleVerified

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.

§2.3 — State A Cost Trajectory (Three Mechanisms)
  1. 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.
  2. 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.
  3. No competitive alternatives market. Closest private landfill ~2.5 hours away, 135% premium. WM operations contract (since 1995) operates without competitive constraint.
§2.4 — State A Environmental and Structural Position
  • 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

Section 3

State B Deployment Baseline

All State B values sourced from Proposal EIR Input Block only. No independent derivation.

§3.1 — Inherited Flags Declaration

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.

§3.2 — Deployment Configuration
PhaseTPDModulesAnnual Feedstock (TPY)% IMMEDIATE StreamCOD
Phase Initial200266,000 Derived20%T0 + 24 months
Phase Medium4004132,000 Derived39%T0 + 42 months
Phase Expanded8008264,000 Derived79%T0 + 60 months

Module verification: 200 TPD ÷ 100 = 2 modules ✓ · 800 TPD ÷ 100 = 8 modules ✓ · Topology: Single-Site, truck-served.

§3.3 — Economic Terms (State B)
TermValueSource Type
Beneficiation Fee (TMC Fee) — base$100.00/ton · +2.5%/yrVerified
Circular Royalty™ base rate120% of that year's Beneficiation FeeStandard
Royalty formula(1.20 + 0.01·(y−2)) × $100 × 1.025^(y−2) per tonStandard
Royalty payment lag13 months after corresponding Beneficiation Fee paymentAlways
Year 2 royalty/ton$120.00Derived
Year 10 royalty/ton$155.96Derived
Year 30 royalty/ton$295.44Derived
Parent Performance Guarantee18-month guarantee on all SPV payment obligations · Carbotura, Inc.Standard
Community capital obligation$0Standard
CSA term30-year minimum from Phase Initial COD + perpetual continuationStandard
§3.4 — Residual Obligations

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.

Residual Volume — Planning Basis Estimated Phase Expanded (800 TPD) diverts approximately 53% of estimated total system generation (~1,500 TPD). Remaining ~700 TPD continues to State A disposal unless additional ACM phases or conditional streams are activated. Residual cost is modeled at current FY26 blended rate (~$88.50/ton escalating 2.5%/yr). This is a planning-basis estimate; actual residual fraction depends on verified total system tonnage.
§3.5 — Timeline Anchoring
MilestoneDate (from T0)
Phase Initial CODT0 + 24 months
First Beneficiation Fee paymentT0 + 24 months (Month 1 of operations)
First Circular Royalty™ paymentT0 + 37 months (13 months after first fee)
Phase Expanded full operationsT0 + 60 months
CSA term end (30yr minimum)T0 + ~54 years (30 years from Phase Initial COD)
Non-Renewal Notice windowT0 + ~52 years (Year 28 minimum notice window)
Perpetual continuationYear 30+ unless Non-Renewal Notice served
§3.6 — Phase Delta Map: State A → State B

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 → State B — Phase Delta
State A — Current System
Collier County Landfill
Active MSW · 310.97 ac · WM operated · ~$88.50/ton blended · Capacity ~2059
Immokalee Transfer / Closed Landfill
Closed 2003 · Unlined · Active env. liability · Transfer station only
North County Water Reclamation Facility
WWTP · County-operated · Biosolids to landfill $79.25/ton
South County Water Reclamation Facility
WWTP · County-operated · Biosolids to landfill · Part of 40.1 MGD system
State B — With Carbotura
P1 — ACM Facility: RRBP / White Lake SW Parcels
Priority 1 candidate · Single-Site · 200→800 TPD · Adjacent to existing landfill · Provisional

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

Section 4

Delta Analysis

Three Canonical Required Statements "Gross cost displacement is quantified separately from Circular Royalty™ cash flow. Both are independent financial effects of the CSA."

"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."
§4.1 — Three Delta Components
  1. 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.
  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.
  3. 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.
§4.1 — Phase-by-Phase Comparative

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.

§4.3 — Pre-Royalty Period Separation Year 1 and post-Month 13 periods have materially different fiscal characteristics. They must not be combined. In Year 1, Collier County pays the Beneficiation Fee ($100.00/ton · $6.6M at Phase Initial · $26.4M at Phase Expanded) and receives zero Circular Royalty™ — this is the pre-royalty period unique to the CSA. Post-Month 13: Circular Royalty™ payments begin at $120.00/ton and ramp to full run-rate on a rolling monthly basis. The royalty exceeds the Beneficiation Fee by $17.50/ton in Year 2; that spread compounds as the royalty multiplier escalates +1 percentage point per year. The Exogenesis™ Royalty bonus stream, where elected, begins on its own schedule when the Exogenesis™ Programme is activated; it is independent of the pre-royalty period of the primary CSA.
§4.4 — 30-Year Gross Cost Displacement (Phase Expanded · 264,000 TPY) Estimated

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.

YearEst. FWDC/ton (2.5%/yr)Gross Displacement/tonAnnual 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.

§4.5 — 30-Year Circular Royalty™ Table (Phase Expanded · 264,000 TPY) Derived
Year Royalty Rate Fee/ton Royalty/ton → Community Annual Royalty Received Excess Over Fee/ton
Year 1Pre-royalty$100.00$0$0(−$100.00)
Year 2120%$102.50$120.00$31,680,000+$17.50
Year 5123%$110.38$132.46$34,969,000+$22.08
Year 10128%$124.89$155.96$41,173,000+$31.07
Year 15133%$141.30$183.34$48,402,000+$42.04
Year 20138%$160.54$216.11$57,053,000+$55.57
Year 25143%$180.87$252.34$66,618,000+$71.47
Year 30148%$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.

Phase Cost Comparison — State A vs. State B Annual Fee Obligation
State A disposal cost (grey) vs. State B Beneficiation Fee (blue). Phase Expanded · 264,000 TPY Estimated
Source: State A — FY26 Rate Resolution 2025-184 projected at 2.5%/yr · State B — Proposal EIR Input Block · All MODELED / DERIVED
Three-Item Gross Fiscal Chart · Phase Expanded (800 TPD · 264,000 TPY)
Avoided Disposal (amber) · Beneficiation Fee paid (red, negative) · Circular Royalty™ received (emerald, Year 2+). All gross. No net line.
All items shown gross · No net position line · Separate Transaction Principle (MR §4.8) · Phase Expanded 800 TPD Estimated
Source: Proposal EIR Input Block · Registry §E · Waste Study §3.1

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

Section 5

System-Level Impact

§5.1 — Employment Delta
Regional Economic Effects — Not County Fiscal Receipts Employment and economic impact figures in §5.1 are regional economic effects from ACM facility operations. They are not county fiscal receipts under the CSA and must not be combined with Beneficiation Fee obligations or Circular Royalty™ receipts in any financial summary.
MetricState A DeltaState B (Phase Expanded)Source
Direct FTE employment0 new manufacturing jobs~200 FTE EstCarbotura standard parameters × 2 (800 TPD baseline)
Indirect / induced jobs0~600 jobs EstScaled from standard 400 TPD baseline
Annual economic impact$0 new manufacturing~$64M+/year EstCarbotura standard × scale
NAICS classificationNAICS 562212 (solid waste)NAICS 31–33 manufacturing (six codes)RPT §1.4
§5.2 — Environmental Delta (Designed-For Basis)
MetricState AState B (Phase Expanded) — Designed For
Carbon impactLandfill methane (LFG captured at 6.5 MW LFGTE); ongoing carbon obligation−3,044 to −3,132 tons CO₂e/day designed reduction Est
30-year carbonLandfill methane baseline continues~34M tons CO₂e designed reduction Est
Water recoveryDeep 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 ModeGrid-dependentGrid-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.

§5.3 — PFAS Structural Delta

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.

§5.4 — No-Fallback Analysis
No-Fallback State for Collier County If the CSA is not executed and the landfill expansion capital is committed, Collier County faces a 30–50 year lock-in to the expanded disposal system with no structured exit until the expanded capacity is exhausted. The last new municipal landfill in Florida opened in 1998 (Sarasota County) — no new siting is realistically available. Out-of-county disposal is 135% more expensive and requires long hauls on congested corridors. The no-fallback analysis confirms: the only structural alternative to expanded landfill dependency is a manufacturing CSA executed before the expansion capital commitment.

Risk and Sensitivity

Section 6

Risk and Sensitivity

§6.1 — Risk Register
RiskDriverBearerMitigationResidual
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
§6.2 — Feedstock Variability ±20%
ScenarioAssumed VolumePhase Expanded Annual Royalty (Year 2)Annual Fee (Year 2)
Base case264,000 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%.

§6.3 — FWDC Sensitivity — Sign-Change Threshold
Sign-Change Analysis — Beneficiation Fee vs. FWDC The Beneficiation Fee is governed by the contractual Floor ($100/ton) because the current FWDC (~$88.50/ton) is below $105/ton (Floor + $5). The sign-change threshold — the FWDC level at which the fee derivation shifts from Floor-governed to FWDC-derived — is $105/ton. If the county's actual blended disposal cost rises above $105/ton (which would require residential MSW tipping fees to exceed approximately $93-95/ton at current composition), the Beneficiation Fee begins to track FWDC. This does not worsen the community's position — it means the fee begins to reflect actual disposal cost savings rather than being capped at the Floor. No FWDC scenario moves the fee above the Ceiling ($150/ton) unless the county's actual disposal cost exceeds $155/ton, which would require ~75% rate escalation from current FY26 levels. The Separate Transaction Principle applies regardless of fee level.
§6.4 — Royalty Escalator Sensitivity
ScenarioYear 2 Royalty/tonYear 10 Royalty/tonYear 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.

§6.5 — Timeline Slippage Sensitivity
ScenarioPhase Initial CODFirst Royalty PaymentImpact
On-scheduleT0 + 24 monthsT0 + 37 monthsBase case
6-month slipT0 + 30 monthsT0 + 43 months6 months additional pre-royalty; ~$3.9M foregone royalty (Phase Expanded rate)
12-month slipT0 + 36 monthsT0 + 49 months12 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

Section 7

Decision Window Analysis

§7.1 — Binding Constraints

Two binding constraints govern the Collier County decision window:

  1. 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.
  2. 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.
§7.2 — Decision Window Table
WindowDurationKey ActionConsequence 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.
§7.3 — Irreversibility Mechanism
Specific Irreversibility Instrument — Landfill Expansion Engineering Contract The irreversibility mechanism that closes the Carbotura CSA window is the procurement and award of engineering and permitting services for the southern or eastern landfill expansion — the first contract in the capital commitment sequence. Once awarded, engineering costs are sunk, environmental review is initiated, and the political commitment to the expansion path is effectively locked. The county has been sued before over landfill siting (1990s), meaning any reversal after engineering contract award carries legal and reputational costs that make reversal politically unviable. The LOI/MOU execution is the one prior action that places a structured CSA alternative into the BCC's decision before that engineering contract is awarded.
§7.4 — Optionality Matrix
ActionExpiryIf TakenIf 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

Section 8

Effects Summary

No new figures introduced in this section. All values trace to preceding sections. References note source section.

§8.1 — Fiscal Effects by Period
Separate Transaction Principle — Applies Throughout Beneficiation Fee (Community → Carbotura) and Circular Royalty™ (Carbotura → Community) are shown as separate rows. These are independent transactions. The "Gross Displacement" row is a third independent financial effect (disposal cost not incurred). None of these three rows are netted together in any cell.
Fiscal ItemYear 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

§8.2 — Regional Economic Effects Estimated

Regional economic effects — not county fiscal receipts. Must not be combined with Beneficiation Fee or Circular Royalty™ figures.

EffectState A DeltaState B (Phase Expanded)
Direct manufacturing employment+0+~200 FTE
Indirect / induced employment+0+~600 jobs
Annual regional economic impact$0~$64M+/year
§8.3 — Environmental Effects

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).
§8.4 — Structural Effects
  • 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).
§8.5 — Unresolved Data Gaps
GapFieldImpact on This EIRResolution 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

Appendix A

Sources and Methodology

ItemMethodologyPrimary Source
FWDC derivationWeighted blend: verified FY26 tipping fees × estimated stream composition sharesResolution No. 2025-184, Collier County BCC, Schedule C; FDEP 2020 Collier report (composition basis)
Beneficiation Fee formulaMAX($100, MIN($150, FWDC−$5)); Floor = $100 at current FWDCCarbotura standard parameters CSA v2026.7
Circular Royalty™ formula(1.20 + 0.01·(y−2)) × $100 × 1.025^(y−2) per tonCSA v2026.7; Proposal EIR Input Block
Phase sizing200/400/800 TPD (Architect-confirmed); module count = TPD ÷ 100Registry §H; Proposal §2.1
Environmental performance basisCarbotura standard parameters 400 TPD baseline × phase scale factorCarbotura standard parameters §8
Employment basis100 FTE direct / ~300 indirect at 400 TPD baseline × phase scale factorCarbotura standard parameters §8
Timeline basisCarbotura standard deployment schedule; T0 + 24 months Phase Initial CODMI §Standardized Deployment Timeline
Expansion cost estimatesSCS Engineers presentation to Collier BCC, March 2025Naples Daily News / Yahoo Finance March 5, 2025
Immokalee liability basisFDEP 30-year post-closure rule; closed 2003 → obligation through ~2033Florida DEP post-closure regulations; BCC workshop March 2025 (SCS Engineers)

Glossary Additions

Appendix B

Glossary Additions

Additions to the Waste Study authoritative glossary. See Waste Study Appendix D for base terms.

TermDefinition
Gross Cost DisplacementDisposal 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 FlowsThe 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 PeriodMonths 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 PeriodMonth 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 PeriodYear 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 ModelThe 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 ACurrent system — all manufacturing feedstock to Collier County Landfill, WM operated, under FY26 rate schedule. No ACM. Expansion capital decision pending.
State BACM 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 PrincipleBeneficiation 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™ RoyaltyBonus 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 GAAPUnited States Generally Accepted Accounting Principles — governing accounting standard for this engagement (Florida jurisdiction per Registry §A).
Forward-Looking Statement (Short Form) Projections are based on RevCon™ 3 baseline assumptions and subject to feedstock composition variability, market conditions for manufactured materials, regulatory frameworks, and site-specific factors. Carbotura makes no guarantee of specific financial returns.

Evidence Chain

Appendix C

Evidence Chain

FigureValueSourceType
Phase Expanded TPD / TPY800 TPD / 264,000 TPYArchitect-confirmed intake; Registry §HVerified
Beneficiation Fee Year 1$100.00/tonProposal EIR Input Block; Registry §EVerified
Circular Royalty™ Year 2$120.00/tonProposal EIR Input Block; formula: 1.20 × $100.00Derived
Circular Royalty™ Year 30$295.44/tonProposal EIR Input Block; formula: 1.48 × $100 × 1.025^28Derived
FWDC blended~$88.50/tonFY26 Rate Resolution 2025-184 + composition estimate; Waste Study §3.1Modeled
Phase Initial CODT0 + 24 monthsCarbotura standard deployment schedule; Proposal §6Standard
First royalty paymentT0 + 37 monthsPhase Initial COD + 13-month lag; formula-derivedDerived
Employment — Phase Expanded~200 FTE direct / ~600 indirectCarbotura standard parameters (100 FTE / 400 TPD baseline × 2)Estimated
Expansion cost — southern option~$73M / +29 years capacitySCS Engineers, BCC Workshop March 2025Estimated
Immokalee closure year2003Naples Daily News / Yahoo Finance March 5, 2025; BCC workshop SCS EngineersVerified
Post-closure obligation end~2033FDEP 30-year post-closure rule applied to 2003 closureEstimated
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Indicative reference only — not an offer. All financial figures are Carbotura planning-basis estimates unless marked VERIFIED. FWDC of $88.50/ton is MODELED from Collier County Resolution No. 2025-184, Schedule C (effective 1 October 2025): residential MSW $88.20, commercial MSW $90.35, biosolids $79.25. The Beneficiation Fee of $100/ton and all royalty figures are ESTIMATED on Carbotura standard parameters. The Immokalee landfill (closed 2003, FDEP post-closure obligation through ~2033) is an Exogenesis™ candidate subject to feedstock characterisation. Pricing is available under a Circular Supply Agreement (CSA) or a Circular Materials Offtake Agreement (CMOA) — contact Carbotura. The Beneficiation Fee and the Circular Royalty™ are independent gross transactions and are not netted anywhere in this package.