Carbotura · Circular Advantage Program
Salt Lake County, Utah
Circular Advantage Proposal
A 30-year BOO agreement converts Salt Lake County's 400–2,000 TPD feedstock into a net revenue-positive position from Year 2, with zero public capex.
Authority Commitment Qualification
Eight Commitments · One Engagement
Four items are required. One item is subject to Waste Characterization Study. Three optional items signal Public Authority offtake election.
4 REQUIRED · ALL ELECTED
1 SUBJECT TO STUDY (Exogenesis™)
3 OPTIONAL · 0 ELECTED
01REQUIRED
Commit feedstock
All designated waste streams legally assigned to Carbotura via CSA · disposal liability removed from Authority balance sheet.
Salt Lake County: ~2,000 TPD addressable; Phase Initial 400 TPD / 146,000 TPY
02REQUIRED
Commit land
Manufacturing Site deed transferred to Carbotura · registered title.
UT: deed via Salt Lake County Recorder (Utah Code §57-1)
03REQUIRED
Commit tax abatements
Local strategic investor instrument · qualifying tax relief · condition precedent to CSA execution.
UT: county strategic investor designation / Utah Enterprise Zone incentives
04REQUIRED
Receive royalty stream
Circular Royalty™ · paid by Carbotura TO the Authority · never combined with Fee.
Separate transactions per MR §4.8 · US GAAP / GASB · ~$17.52M/yr (Opt A Yr 2) or ~$14.6M/yr (Opt B Yr 2)
05OPTIONAL · SUBJECT TO STUDY
Exogenesis™ landfill mining (option)
Exogenesis™ Programme · APS · fully electric fleet · $50/ton royalty TO the Authority · land restored. Subject to Waste Characterization Study and mutual agreement — structured option for discussion.
Salt Lake Valley Landfill (SLVL), Magna UT — county's primary active MSW landfill · closure TBD · Waste Characterization Study required
Section 0
What This Means
Circular Royalty™
OUTFLOW ↑
Fee: $100/ton Yr 1 · +2.5%/yr · ~$14.6M/yr
Fee: $100/ton Yr 1 · +2.5%/yr · ~$14.6M/yr
INFLOW ↓
Circular Royalty™: 120% from Month 13 · +1pp/yr
~$21.02M/yr Year 2 → ~$43.1M/yr Year 30
Circular Royalty™: 120% from Month 13 · +1pp/yr
~$21.02M/yr Year 2 → ~$43.1M/yr Year 30
OUTFLOW ↑
$0 Fee · site deed at signing
(Salt Lake County Recorder · UT §57-1)
$0 Fee · site deed at signing
(Salt Lake County Recorder · UT §57-1)
INFLOW ↓
r Year 2
r Year 2
Exogenesis™ Option · Subject to Study
SLVL, Magna UT
IF ELECTED ↑
Landfill deeded at signing (if study confirms)
Landfill deeded at signing (if study confirms)
IF ELECTED ↓
$50/ton · ~$3.65M/yr from Year 6
Subject to Waste Characterization Study
$50/ton · ~$3.65M/yr from Year 6
Subject to Waste Characterization Study
Three election paths · one Circular Supply Agreement. Salt Lake County may elect the CSA at CSA execution. The Exogenesis™ Option (Salt Lake Valley Landfill, Magna UT) is a structured option for discussion — activation requires Waste Characterization Study and mutual agreement. All streams reported as separate transactions per MR §4.8.
The five decision-relevant facts in this Proposal.
1 — Disposal Liability Converted to Income Instrument
Salt Lake County currently spends approximately $40M/year across its two-landfill system with a $0 return. The Circular Advantage Proposal converts that disposal spend — starting at 400 TPD — into a Circular Supply Agreement that generates a Circular Royalty™ from Month 13. At steady state, the royalty exceeds the Beneficiation Fee on a per-ton basis by design, producing a net positive fiscal position for the county.
2 — Zero Public Capex. Zero Debt.
Carbotura constructs, owns, and operates the ACM facility under a Build-Own-Operate (BOO) structure. Salt Lake County makes no capital contribution, incurs no construction debt, and carries no operating liability. The county's sole financial obligation under the CSA is the Beneficiation Fee per ton delivered. The $247.5M Phase Initial facility is 100% Carbotura-financed.
3 — Hard Decision Window: Trans-Jordan Closure ~2033
The Trans-Jordan Landfill — serving ~500,000 county residents — has approximately eight years of capacity remaining. Upon closure, member-city disposal costs are projected to increase 3–4× as feedstock transfers to Bayview Landfill in Utah County. To commission a Phase Initial ACM facility before closure, the county must authorize a Joint Working Group phase no later than Q4 2026, with construction beginning Q4 2026 and COD Q2 2028. The procurement decision window is now.
4 — 30-Year Revenue Position
At Phase Expanded (2,000 TPD), the Circular Royalty™ grows to approximately $37.7M/year in Year 2, increasing annually through the 30-year CSA term as both the TMC escalator (2.5%/yr) and royalty rate escalator (+1pp/yr) compound. The total royalty position over 30 years at full buildout exceeds $1.8 billion (nominal, undiscounted), against a total TMC obligation of approximately $1.4 billion — a designed net surplus throughout.
5 — Classification Condition Applies
This engagement requires Utah state classification of the ACM facility as a manufacturing operation (NAICS 325180, 325998, 327992, 331110, 331314, 331492). The federal basis is RCRA §1004(27) · 40 CFR §261.2(e). Classification confirmation is a condition precedent to capital commitment. Full terms in §1.0 below.
Section 1
Commercial Structure and Decision Window
Regulatory Predicate Transition (RPT)
Advanced Circular Manufacturing is a manufacturing process, not a waste-management activity. Microwave Catalytic Reforming operates in an anoxic, oxygen-free, sub-atmospheric environment — mechanistically incompatible with combustion or biological degradation. ACM does not fit within the waste domain and does not operate under waste-domain statutes. The Regulatory Predicate Transition (RPT) — also framed as the dewaste pathway — is the coordinated regulatory shift from legacy disposal-predicate statutes onto manufacturing-predicate classifications. 100% elemental recycling of the municipal material stream requires this transition. Manufacturing NAICS 325180 · 325998 · 327992 · 331110 · 331314 · 331492 (6-code ACM set) plus EPA RCRA §1004(27) / 40 CFR §261.2(e) exclusion pathway in the US; ISIC Rev.4 20-25 + UN CPC 89 internationally. In many jurisdictions the required authorities already exist in latent form within existing statutes; in others the transition requires primary-authority amendments. The Joint Working Group phase includes a regulatory engagement workstream to shepherd the RPT alongside site permitting. Both parties commit to the RPT pathway. Carbotura brings the process-classification evidence, regulatory engagement expertise from prior ACM deployments, and the legal-technical framework. The counterparty brings the standing to engage the local regulator, the political mandate for the transition, and — where applicable — legacy statutory authorities that can be re-instrumented for manufacturing use. The endpoint is categorical: manufacturing classification across all permitting, licensing, and regulatory contexts. Interim bridging authorities may apply during the transition.
§1.1 Commercial Structure
The Circular Advantage Program is structured as a 30-year Build-Own-Operate (BOO) agreement between Carbotura, Inc. and Salt Lake County, Utah (the feedstock supplier). The agreement governs:
| Party | Obligation | Duration |
|---|---|---|
| Salt Lake County | Deliver agreed TPD of manufacturing feedstock to the ACM facility gate; pay Beneficiation Fee ($120/ton, +2.5%/yr) per ton delivered | 30 years from COD (CSA term) |
| Carbotura, Inc. | Finance, construct, own, and operate the ACM facility; process all delivered feedstock to manufactured Circular Materials specifications; pay Circular Royalty™ beginning Month 13 at 120% of corresponding Beneficiation Fee | 30 years from COD (BOO term) |
Decision Window — Trans-Jordan Capacity Horizon
Trans-Jordan Landfill reaches capacity approximately 2032–2033. To commission Phase Initial ACM before closure, the county must authorize the Joint Working Group phase no later than Q4 2026. A Phase Initial facility commissioned Q2 2028 provides the county with an operational alternative path at least 4–5 years before the Trans-Jordan capacity cliff. Each quarter of delay compresses the pre-closure operating window and reduces negotiating leverage.
CSA Term
30 yrs
From Phase Initial COD
Counterparty Capex
$0
Zero public capital required
First Royalty
Month 13
Q3 2029 at Phase Initial COD
Phase Initial CapEx
$247.5M
100% Carbotura-financed
§1.5 — CSA Election Framework
At CSA execution, Salt Lake County The Exogenesis™ Option (Salt Lake Valley Landfill, Magna UT) is a structured option for discussion — activation requires Waste Characterization Study, qualifying asset confirmation, and mutual agreement.
Exogenesis™ Option — Salt Lake Valley Landfill (SLVL), Magna UT (Subject to Study)
The Salt Lake Valley Landfill is Salt Lake County's primary active MSW landfill. Exogenesis™ activation requires Waste Characterization Study. If elected: all post-closure obligations transfer to Carbotura at CSA execution (GASB 49 extinguishment).
Section 2
Deployment Architecture
§2.1 Phase Configuration
| Phase | Deployed TPD | Modules | Annual Feedstock (tpy) | % of Addressable | COD Target | Source Type |
|---|---|---|---|---|---|---|
| Phase Initial | 400 | 4 × 100 TPD | 146,000 | 20% | Q2 2028 | CARBOTURA STANDARD |
| Phase Medium | 1,000 | 10 × 100 TPD | 365,000 | 50% | Q4 2029 | CARBOTURA STANDARD |
| Phase Expanded | 2,000 | 20 × 100 TPD | 730,000 | 100% | Q2 2031 | CARBOTURA STANDARD |
§2.2 BOO Capital Structure
| Phase | Total CapEx | Equity (20%) | Grant (15%) | Debt (65%) | County Contribution |
|---|---|---|---|---|---|
| Phase Initial (4 modules) | $247,500,000 | $49,500,000 | $37,125,000 | $160,875,000 | $0 |
| Phase Medium (10 modules) | $592,500,000 | $118,500,000 | $88,875,000 | $384,125,000 | $0 |
| Phase Expanded (20 modules) | $1,167,500,000 | $233,500,000 | $175,125,000 | $758,875,000 | $0 |
CapEx: $75M first 100 TPD module + $57.5M per additional 100 TPD module. Capital structure: Equity 20% / Grant 15% / Debt 65% — Carbotura permanently locked parameters. Accounting standard: US GAAP.
§2.3 Feedstock Stream Coverage by Phase
| Stream | Phase Initial | Phase Medium | Phase Expanded | Access Status |
|---|---|---|---|---|
| Residential MSW (~900 TPD) | ✓ INCLUDED | ✓ INCLUDED | ✓ INCLUDED | IMMEDIATE |
| Commercial / Industrial MSW (~600 TPD) | ✓ PARTIAL | ✓ INCLUDED | ✓ INCLUDED | IMMEDIATE |
| Green waste / organics (~20 TPD) | ✓ INCLUDED | ✓ INCLUDED | ✓ INCLUDED | IMMEDIATE |
| C&D feedstock (~300 TPD) | ✓ CONDITIONAL | ✓ CONDITIONAL | CONDITIONAL | |
| Municipal biosolids (~180 TPD) | ✓ CONDITIONAL | ✓ CONDITIONAL | CONDITIONAL |
§2.4 Site Candidate Analysis
Three candidate zones evaluated across Salt Lake County's industrial corridor. Priority 1 is the recommended Phase Initial site basis. All candidates are provisional pending Joint Working Group phase site confirmation.
ACM Site Candidates · Salt Lake County
P1 — Priority
P2
P3
SLVL feedstock
Trans-Jordan feedstock
Site Candidate Summary
| Priority | Zone | Acreage | Zoning | Land Authority | Co-location Advantage | Key Consideration |
|---|---|---|---|---|---|---|
| P1 | West Valley City Industrial Corridor (Hunter / 4000 W) | 15–25 ac | Industrial (M-1/M-2) | Private industrial / West Valley City | ~2 miles from SLVL; direct SR-201/I-80 access; established industrial infrastructure; proximity to WM and Republic Services transfer routes | Site confirmation subject to Joint Working Group phase; West Valley City planning approval |
| P2 | Magna / Saltair Industrial Zone (I-80 west corridor) | 20–35 ac | Industrial (heavy) | Private / Salt Lake County unincorporated | ~2.5 miles from SLVL; I-80 direct access; lower land cost than West Valley City; industrial precedent established | Farther from south-basin Trans-Jordan volumes; county unincorporated zoning process |
| P3 | North Salt Lake Industrial Park (Davis County border) | 10–20 ac | Industrial (light/heavy) | Private / North Salt Lake City | Accessible to WFWRD north-valley volumes; I-15 corridor; potential long-term Phase Expanded northern hub position | ~18 miles from SLVL; ~28 miles from Trans-Jordan; less favourable for Phase Initial south-basin volumes |
Priority 1 Finding
The West Valley City Industrial Corridor (Hunter / 4000 W area) is the recommended Priority 1 ACM site candidate. Proximity to SLVL (~2 miles) minimises feedstock hauling cost and maximises route efficiency for both WM and Republic Services commercial transfer flows. Direct SR-201/I-80 access connects to the south-valley Trans-Jordan corridor via the Bangerter Highway connector (~18 miles). All Phase Initial feedstock volume (400 TPD residential + commercial MSW) is deliverable to this site without intermediate transfer.
§2.5 Phase Initial Feedstock Sufficiency
Phase Initial (400 TPD / 146,000 tpy) is fully supportable from immediately accessible streams — residential MSW from county and member-city collection routes — without requiring any conditional-access streams (C&D, biosolids) or third-party hauler renegotiation. The 400 TPD commitment represents approximately 20% of the total addressable county feedstock and is conservatively bounded well within accessible volume.
Section 3
Economic Structure — Beneficiation Fee
FWDC Planning Basis Disclosure
The fully-weighted disposal cost (FWDC) used in this Proposal is $55/ton — an ESTIMATED planning basis derived from the verified SLVL commercial gate rate of $36/ton (saltlakecounty.gov, 2025) plus estimated collection/transport overhead (~$19/ton). Utah's disposal costs are structurally among the lowest in the Western US. FWDC contract audit is a required Joint Working Group phase deliverable. Results may revise this basis upward or downward.
Beneficiation Fee Derivation
Beneficiation Fee Floor/Ceiling formula: MAX($100, MIN($150, FWDC − $5)) = MAX($100, MIN($150, $50)) = $100/ton (formula floor)
Locked Beneficiation Fee: $120/ton (user-specified; above formula floor; reflects Carbotura market-rate manufacturing arrangement pricing)
Locked Beneficiation Fee: $120/ton (user-specified; above formula floor; reflects Carbotura market-rate manufacturing arrangement pricing)
| Parameter | Value | Basis |
|---|---|---|
| FWDC planning basis | $55/ton | ESTIMATED — SLVL gate $36/ton verified + collection overhead ~$19/ton |
| Beneficiation Fee — Year 1 | $120/ton | Locked — Carbotura standard rate |
| Beneficiation Fee escalator | +2.5% / year | Carbotura standard parameters |
| Floor / Ceiling | $100 / $150 | Carbotura standard parameters |
| Year 10 Beneficiation Fee per ton | ~$149.87/ton | Calculated: $120 × 1.025⁹ |
| Year 20 Beneficiation Fee per ton | ~$191.85/ton | Calculated: $120 × 1.025¹⁹ |
| Year 30 Beneficiation Fee per ton | ~$244.60/ton | Calculated: $120 × 1.025²⁹ |
Annual TMC Obligation by Phase
| Phase | TPD | Annual tpy | Year 1 TMC ($120/ton) | Year 5 TMC | Year 10 TMC |
|---|---|---|---|---|---|
| Phase Initial | 400 | 146,000 | $17,520,000 | ~$19,340,000 | ~$21,880,000 |
| Phase Medium | 1,000 | 365,000 | $43,800,000 | ~$48,360,000 | ~$54,700,000 |
| Phase Expanded | 2,000 | 730,000 | $87,600,000 | ~$96,700,000 | ~$109,400,000 |
Section 4
Circular Royalty™
§4.0 — Circular Royalty™
Standard CSA election: Salt Lake County pays Beneficiation Fee; Carbotura pays Circular Royalty™ at 120%, +1pp/yr, from Month 13. Separate transactions, never netted.
Royalty(m+13) = TMC(m) × Royalty_Rate(m)
| Parameter | Value | Basis |
|---|---|---|
| Base royalty rate (Year 1 TMC basis) | 120% | Carbotura standard parameters |
| Royalty rate escalator | +1 percentage point / year | Carbotura standard parameters |
| Payment lag | 13 months | Carbotura standard parameters |
| Payment basis | Rolling monthly (lagged) | Carbotura standard parameters |
| Year 2 royalty rate | 120% | Calculated |
| Year 10 royalty rate | 128% | Calculated: 120% + 8pp |
| Year 20 royalty rate | 138% | Calculated: 120% + 18pp |
| Year 30 royalty rate | 148% | Calculated: 120% + 28pp |
Fiscal Period Distinction
| Period | Duration | Beneficiation Fee Paid | Royalty Received | Net Position |
|---|---|---|---|---|
| Pre-Royalty Period | Months 1–12 (Year 1) | $17.52M (Phase Initial) | $0 | -$17.52M (transition investment) |
| Royalty Ramp | Month 13 to ~Month 24 | ~$17.96M | Royalty begins; rolling ramp to full run-rate | Transitioning to positive |
| Steady State | Year 2 onward (28 years) | Escalating at 2.5%/yr | Exceeds Beneficiation Fee per-ton by design | Net positive and growing |
Year-by-Year Fiscal Position — Phase Initial (400 TPD / 146,000 tpy)
| Year | Avoided Disposal ($M) |
Beneficiation Fee Paid ($M) |
Royalty Rate | Circular Royalty™ ($M) |
Surplus (Royalty − TMC) |
|---|---|---|---|---|---|
| Year 1 | $8.03 | -$17.52 | $0 | -$17.52M | |
| Year 2 | $8.19 | -$17.96 | 120% | +$21.02 | +$3.06M |
| Year 5 | $8.69 | -$19.34 | 123% | +$23.20 | +$3.86M |
| Year 10 | $9.46 | -$21.88 | 128% | +$27.32 | +$5.44M |
| Year 20 | $11.25 | -$28.01 | 138% | +$37.71 | +$9.70M |
| Year 30 | $13.74 | -$35.53 | 148% | +$53.55 | +$18.02M |
Avoided Disposal = FWDC $55/ton growing at 2%/yr × 146,000 tpy. Beneficiation Fee = $120/ton growing at 2.5%/yr × 146,000 tpy. Royalty = prior year TMC × royalty rate. All values nominal. Source type: CALCULATED from locked Registry parameters.
Gross cost displacement is quantified separately from Circular Royalty™ cash flow. Full net fiscal position reflects both.
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.
Three-Item Gross Fiscal Chart — Phase Initial (Years 1–20)
Gross datasets shown independently — no pre-netting. No net position line.
Avoided Disposal Cost (amber) · Beneficiation Fee Paid (red, negative) · Circular Royalty™ Received (emerald, Year 2+). Phase Initial 400 TPD / 146,000 tpy. All values nominal.
Annual Cash Flow by Phase — Year 2 Steady State
| Phase | Annual tpy | Year 2 TMC Paid | Year 2 Royalty | Year 2 Net Surplus | Net per ton |
|---|---|---|---|---|---|
| Phase Initial (400 TPD) | 146,000 | -$17.96M | +$21.02M | +$3.06M | +$21.00/ton |
| Phase Medium (1,000 TPD) | 365,000 | -$44.90M | +$52.56M | +$7.66M | +$21.00/ton |
| Phase Expanded (2,000 TPD) | 730,000 | -$89.80M | +$105.12M | +$15.32M | +$21.00/ton |
Year 2 net surplus = Royalty received ($144/ton × tpy) minus TMC paid ($123/ton × tpy). Net per ton = +$21 at Year 2; grows to +$109/ton at Year 30. Source type: CALCULATED.
§4.1 — Exogenesis™ Option (Subject to Waste Characterization Study)
Structured Option — Not a Commitment
Exogenesis™ becomes a CSA element only after Waste Characterization Study, qualifying asset confirmation, and mutual agreement.
Potential additive royalty stream. If elected: Salt Lake County deeds Salt Lake Valley Landfill (SLVL, Magna UT) to Carbotura at CSA execution. All post-closure obligations transfer at CSA execution (GASB 49).
| Year | Rate $/ton | Annual (~73,000 tpy indicative) |
|---|---|---|
| 1–5 | $0 | |
| 6 | $50.00 | +$3,650,000 (indicative) |
| 10 | $52.02 | +$3,797,460 |
| 30 | $63.49 | +$4,634,770 |
| 30-yr indicative (if elected) | ~$103M | |
All values INDICATIVE. Subject to Waste Characterization Study. Stacks on the CSA — never netted (MR §4.8).
Section 5
Risk Register
| Risk | Key Driver | Who Bears It | Mitigation | Residual Exposure |
|---|---|---|---|---|
| FWDC verification | Actual FWDC differs from $55/ton planning basis | Both parties (affects relative economics) | Contract audit at Joint Working Group phase; FWDC confirmed before CSA execution | LOW — Royalty economics positive regardless of FWDC level; surplus grows from Year 2 |
| Classification (RPT) | Utah DEQ or municipal authorities classify ACM as solid waste disposal | Shared — Carbotura commits to the RPT pathway; county retains current system | Federal basis RCRA §1004(27) · 40 CFR §261.2(e); Utah DEQ pre-engagement coordination at Joint Working Group phase | MODERATE — mitigated by federal petition; Utah has manufacturing-friendly regulatory climate |
| Technology performance | ACM throughput or Circular Materials yield below specification | Carbotura (BOO operator) | Performance guarantees in CSA; liquidated damages for material underperformance | LOW — Born by Carbotura; county is indemnified against throughput shortfall |
| Timeline slippage | Permitting delays or supply chain constraints push COD beyond Q2 2028 | Carbotura (construction risk) | Carbotura standard deployment schedule with 6-month buffer; pre-permitting begins at Joint Working Group phase | MODERATE — compresses pre-Trans-Jordan operating window; mitigation is early engagement start |
| Third-party contract constraints | Commercial hauler contracts (Republic Services / WM) restrict feedstock routing to ACM | County (sourcing risk) | Identify and map existing collection contracts at Joint Working Group phase; negotiate route agreements in parallel with CSA | LOW to MODERATE — county and city-owned residential routes carry no private contract constraint |
| Competitive procurement | Salt Lake County issues alternative technology RFP; CSA pathway forecloses | Both parties | No active alternative technology RFP identified in public records as of April 2026; authorize Joint Working Group phase to establish exclusive engagement window | MODERATE — risk is highest in RFP pre-award period; mitigation is early CSA term sheet |
| PFAS / emerging contaminants | Utah DEQ or EPA PFAS-in-MSW regulations restrict feedstock access | Regulatory — borne by system | ACM Regenesis™ Protocol is designed to address PFAS destruction; regulatory monitoring at Joint Working Group phase | LOW — ACM PFAS performance is a competitive advantage vs. landfill; no current Utah PFAS-in-MSW prohibition |
Section 6
Deployment Timeline
Carbotura standard deployment schedule. T0 = Q2 2026 (engagement start).
| Milestone | Target Date | Lag from T0 | Notes |
|---|---|---|---|
| Joint Working Group phase Authorization | Q3 2026 | T0 + 1 month | Procurement decision window open now — delay compresses pre-closure margin |
| Joint Working Group phase Complete | Q3 2026 | T0 + 3 months | FWDC audit; site confirmation; CSA term sheet; CCP verification with Utah DEQ |
| Phase Initial Construction Start | Q4 2026 | T0 + 6 months | Site permit; module manufacturing begins |
| Phase Initial COD — 400 TPD Operational | Q2 2028 | T0 + 24 months | ACM facility operational — feedstock supply begins; Beneficiation Fee accrues |
| First Circular Royalty™ Payment | Q3 2029 | T0 + 37 months | 13 months after Phase Initial COD — first royalty remittance to Salt Lake County |
| Phase Medium Full Operations — 1,000 TPD | Q4 2029 | T0 + 42 months | Full south-valley volume integration; conditional stream authorization underway |
| Phase Expanded Full Operations — 2,000 TPD | Q2 2031 | T0 + 60 months | Full county feedstock urban mine operational — 730,000 tpy processed |
| Trans-Jordan Closure (projected) | ~2032–2033 | ~T0 + 72–84 months | ACM Phase Expanded fully operational 12–18 months before Trans-Jordan closure |
| CSA Term End | Q2 2058 | T0 + 30 years (from COD) | 30-year CSA completes; renewal or re-engagement option |
Carbotura standard deployment schedule. Subject to Joint Working Group phase and site confirmation outcomes.
Section 7
Community Value Stack
7.1 County Fiscal Effects
| Effect | Phase Initial (Year 2+) | Phase Expanded (Year 2+) | Source Type |
|---|---|---|---|
| Circular Royalty™ received (annual, Year 2) | +$21.02M/yr | +$105.12M/yr | CALCULATED |
| Beneficiation Fee obligation (annual, Year 2) | -$17.96M/yr | -$89.80M/yr | CALCULATED |
| Net annual county surplus (Year 2) | +$3.06M/yr | +$15.32M/yr | CALCULATED |
| Net annual county surplus (Year 10) | +$5.44M/yr | +$27.20M/yr | CALCULATED |
| Net annual county surplus (Year 30) | +$18.02M/yr | +$90.10M/yr | CALCULATED |
| Disposal cost avoided (annual, Year 2, FWDC $55/ton) | $8.19M/yr | $40.94M/yr | MODELED |
| Post-Trans-Jordan cost step-change avoided (~2033) | ~$50–67M/yr avoided (south basin) | N/A (full system alternative) | PROJECTED |
7.2 Regional Economic Effects
| Effect | Phase Initial | Phase Medium | Phase Expanded | Basis |
|---|---|---|---|---|
| Direct manufacturing FTE | 35 | 90 | 155 | Carbotura standard parameters |
| Indirect / induced jobs | 105 | 270 | 465 | 3× direct multiplier |
| Annual economic impact | $18.5M | $46.0M | $92.5M | ESTIMATED — Carbotura standard parameters |
| Property tax (manufacturing classification) | Subject to West Valley City assessment | Grows with facility valuation | DATA GAP — Joint Working Group phase deliverable | |
Executive Fiscal Summary
- From Year 2, Salt Lake County receives more in Circular Royalty™ than it pays in Beneficiation Fee — a net positive position on the county's books. This is not a rebate, subsidy, or discount; it is a manufactured product royalty paid by Carbotura for the right to convert the county's feedstock stream into Circular Materials.
- The balance sheet character of the feedstock stream inverts: what was a disposal liability generating $0 return becomes an income instrument generating tens of millions of dollars annually.
- The post-Trans-Jordan cost escalation (~3–4× for south-valley member cities) is entirely avoided for the volumes committed under the CSA. This is a liability hedge of significant fiscal magnitude for member-city budgets.
- The 30-year nominal royalty position at Phase Expanded exceeds $1.8 billion — against a total TMC obligation of approximately $1.4 billion — a designed net positive of approximately $400M over the CSA term.
Section 8
Why This Works in Salt Lake County
| # | Dimension | Salt Lake County Specifics |
|---|---|---|
| 1 | Volume Alignment | ~2,000 TPD addressable county feedstock — fully supports Phase Initial (400 TPD, 20% capture), Phase Medium (1,000 TPD, 50%), and Phase Expanded (2,000 TPD, 100%) without requiring out-of-county volumes at any phase. Utah's 1.5%/yr population growth provides a growing feedstock base throughout the 30-year CSA term. |
| 2 | Infrastructure Alignment | The West Valley City Priority 1 candidate site sits approximately 2 miles from the Salt Lake Valley Landfill and within 18 miles of Trans-Jordan. Both WM and Republic Services commercial transfer stations are within 3 miles. The SR-201/I-80/Bangerter corridor provides direct feedstock delivery routing from north and south valley alike — no new infrastructure required for Phase Initial operations. |
| 3 | Contract Timing Alignment | Trans-Jordan reaches capacity ~2032–2033 — approximately 8 years from engagement start. The Carbotura standard deployment schedule delivers Phase Initial COD at Q2 2028 and Phase Expanded at Q2 2031 — providing a 1.5–2 year operational cushion before the Trans-Jordan capacity cliff. The decision window is aligned: act now, commission early, avoid the step-change. |
| 4 | Policy Alignment | Utah's manufacturing-friendly regulatory climate and industrial zoning infrastructure in the West Valley / Magna corridor support the Regulatory Predicate Transition (RPT) (§1.0). RCRA §1004(27) · 40 CFR §261.2(e) provides the federal basis; Utah DEQ coordination at Joint Working Group phase stage will establish the state-level manufacturing classification pathway. No Utah regulatory instrument currently classifies Microwave Catalytic Reforming as solid waste treatment. |
| 5 | Regulatory Forcing Function | The Trans-Jordan closure is a hard, non-negotiable capacity deadline — not a soft preference. The absence of any in-county replacement site (confirmed by planning authorities) and the 3–4× cost projection at closure create the strongest possible structural driver for alternative procurement. No in-county alternative technology solution is under active procurement as of April 2026. |
| 6 | Economics Specificity | The Beneficiation Fee of $120/ton is derived against Salt Lake County's actual verified disposal cost structure (SLVL gate rate $36/ton confirmed; full-system FWDC $55/ton ESTIMATED pending audit). The Circular Royalty™ at $144/ton (Year 2) produces a net surplus of +$21/ton against a TMC of $123/ton. These are not generic parameters — they are specific to this community's cost data and deployment scale. |
Appendix
Appendix A — Data Basis
| Figure | Value | Public Source | Source Type |
|---|---|---|---|
| SLVL commercial gate rate | $36/ton | saltlakecounty.gov/landfill/pricing/ (2025) | VERIFIED |
| FWDC — full system | ~$55/ton | Modeled: $36/ton gate + $19/ton collection overhead | MODELED / ESTIMATED |
| Trans-Jordan capacity horizon | ~8 years (~2033) | Draper Journal, April 2024 | VERIFIED — press |
| Post-closure cost escalation | 3–4× current | Trans-Jordan director, Draper Journal, April 2024 | VERIFIED — press |
| Addressable feedstock volume | ~2,000 TPD | Carbotura standard per-capita parameters; Utah DEQ; SLC Sustainability Dept. 2024 | ESTIMATED |
| Beneficiation Fee | $120/ton | User-specified; Carbotura standard rate | LOCKED |
| Circular Royalty™ parameters | 120% base, +1pp/yr, 13-month lag | Carbotura standard parameters | CORPUS LOCKED |
| CapEx — Phase Initial | $247.5M | $75M first module + 3 × $57.5M; Carbotura standard | CARBOTURA STANDARD |
| Employment parameters | 35 FTE / 105 indirect / $18.5M (Phase Initial) | Carbotura standard parameters | ESTIMATED |
Appendix B — Selective Glossary
- Beneficiation Fee (Total Material Conversion Fee)
- The Beneficiation Fee paid by Salt Lake County per ton of feedstock delivered. $120/ton Year 1, escalating 2.5%/yr. Replaces legacy "tipping fee" or "gate fee."
- Circular Royalty™
- The conversion royalty paid by Carbotura to Salt Lake County at 120% of the corresponding month's Beneficiation Fee, with a 13-month payment lag. Escalates at +1 percentage point per year. At steady state, designed to exceed the Beneficiation Fee per ton.
- Circular Supply Agreement (CSA)
- The 30-year commercial agreement governing feedstock delivery, Beneficiation Fee, Circular Royalty™, and Circular Materials rights. The instrument that converts the county's disposal liability into an income instrument.
- FWDC (Fully-Weighted Disposal Cost)
- Total cost borne per ton of feedstock disposed, including gate fee, collection, transport, and admin. Salt Lake County planning basis: ~$55/ton ESTIMATED. SLVL gate rate component: $36/ton VERIFIED.
- Gross Cost Displacement
- The annual disposal spend that is displaced when feedstock flows to the ACM facility instead of the landfill. Quantified separately from Circular Royalty™ cash flow; both are required for the full net fiscal position calculation.
- Net County Fiscal Position
- The sum of Gross Cost Displacement plus Circular Royalty™ Received minus Beneficiation Fee Paid. Positive from Year 2 at all deployment phases. Grows annually through royalty and TMC escalation compounding.
- Pre-Royalty Period
- Months 1–12 of CSA operations: Beneficiation Fee is paid; no royalty is received. The transition investment required before royalty cash flow begins.
- BOO (Build-Own-Operate)
- Carbotura's financing and operating structure: Carbotura finances, constructs, owns, and operates the ACM facility. Salt Lake County makes no capital contribution, incurs no debt, and bears no operating risk. The county's only financial obligation is the Beneficiation Fee per ton delivered.
- Regulatory Predicate Transition (RPT) (RPT)
- Carbotura's requirement that the ACM facility be classified under manufacturing NAICS codes (325180, 325998, 327992, 331110, 331314, 331492). Federal basis: RCRA §1004(27) · 40 CFR §261.2(e). No capital commitment proceeds without CCP satisfaction.
- Circular Materials
- Manufactured output products of the ACM process: synthetic graphite, recovered metals, engineered aggregates, energy equivalents. Carbotura retains title to all Circular Materials; the county's revenue instrument is the Circular Royalty™, not product revenue.