Carbotura · Circular Advantage Program
Salt Lake County, Utah
Feedstock System Assessment
Salt Lake County's ~2,000 TPD manufacturing feedstock flows to two landfills — Trans-Jordan reaches capacity ~2033 with no in-county replacement.
Section 0
What This Means
Five diagnostic findings for decision-makers.
Finding 1 — Constrained Disposal Horizon
Salt Lake County operates approximately 2,000 TPD (730,000 tpy) of manufacturing feedstock across a two-landfill system. The Trans-Jordan Landfill — serving ~500,000 residents across seven southern-valley cities — carries approximately eight years of remaining capacity, with closure projected around 2032–2033. No new MSW landfill is planned within county limits; planning authorities have confirmed there is no available land and no regulatory pathway for an in-county replacement.
Finding 2 — Cost Escalation at Closure
Upon Trans-Jordan's closure, member-city disposal costs are projected to increase three to four times as feedstock transfers to Bayview Landfill in Utah County via two new transfer stations (Sandy, open 2025; South Jordan, planned 2032). The Salt Lake Valley Landfill (SLVL), co-owned by Salt Lake County and Salt Lake City, operates at a commercial gate rate of $36/ton (verified, 2025). Total fully-weighted disposal cost (FWDC) across the county system is estimated at $55/ton, among the lowest in the Western US — a position that will not be sustained past the Trans-Jordan transition.
Finding 3 — Legacy Liability
The North Temple Landfill — a 770-acre closed site operated 1959–1979 in northwest Salt Lake City — remains under active Utah DEQ remediation, with contaminated groundwater extending more than 900 feet off-site. This represents an ongoing liability and a potential future Urban & Landfill Mining opportunity under the Carbotura Exogenesis™ Protocol.
Finding 4 — Renewable Feedstock Characteristics
Unlike a geological resource, the county's manufacturing feedstock stream is perpetually renewable — structurally stable or growing with Utah's population, which has expanded at approximately 1.5% annually over the past decade, among the highest growth rates in the US. This Throughput Reliability is a material differentiator in UNFC G-axis classification and provides durable collateral basis for a 30-year Circular Supply Agreement.
Finding 5 — Zero Royalty Return
Every ton of manufacturing feedstock currently disposed generates $0 return to the county or member cities. The existing disposal system converts public expenditure into landfill volume, with no income instrument and no mechanism to recover value from the 730,000 tpy urban mine. The balance sheet character of the feedstock stream — disposal liability — is structural, not inherent. It can be inverted.
Section 1
Feedstock Profile
Stream characterisation, UNFC classification, and access conditions.
§1.1 ACM Capability Finding
ACM is capable of processing every material stream Salt Lake County generates. Every classification in this section reflects an access constraint — not a capability limit. The barrier to any stream is contractual, logistical, or regulatory — never technical.
§1.2 Feedstock Volume Table
| Stream | Annual Volume (tpy) | Daily (TPD) | Current Disposition | Operator | Access Classification | ACM Phase |
|---|---|---|---|---|---|---|
| Residential MSW (post-diversion) | ~328,500 | ~900 | SLVL (north valley); Trans-Jordan (south valley); Bayview/transfer (future) | Salt Lake County Solid Waste / Trans-Jordan Cities | IMMEDIATE | Phase Initial → Expanded |
| Commercial & industrial MSW | ~219,000 | ~600 | Transfer stations → SLVL / Trans-Jordan | Waste Management of Utah; Republic Services of Utah | IMMEDIATE | Phase Initial → Expanded |
| Construction feedstock (mixed C&D) | ~109,500 | ~300 | Mountain View Landfill (inert); SLVL (mixed loads) | Waste Management of Utah / Private haulers | IMMEDIATE | Phase Medium → Expanded |
| Municipal biosolids (CVWRF + SLC WRF) | ~65,700 | ~180 | Class B land application; partial landfill co-disposal | CVWRF Joint Enterprise; SLC Public Utilities | CONDITIONAL | Phase Medium |
| Non-composted green waste | ~7,300 | ~20 | SLVL / Trans-Jordan (mixed with general feedstock) | Various haulers | IMMEDIATE | Phase Initial |
| Total Addressable | ~730,000 | ~2,000 | ESTIMATED — Carbotura standard parameters applied to Salt Lake County per-capita generation data. Term Sheet phase verification verification required. | |||
All volumes ESTIMATED from Salt Lake County planning data and Utah DEQ waste characterisation studies. Source type: MODELED. Contract audit required during Term Sheet phase verification stage.
§1.3 Phase Initial Priority Feedstocks
Two streams carry no contract barrier and represent the highest-certainty Phase Initial feedstock basis:
Priority A · Residential MSW
~900 TPD
County and city-operated curbside collection routed to SLVL and Trans-Jordan. No third-party private contract barrier. Immediately accessible via municipal Circular Supply Agreement.
Priority B · Commercial MSW
~600 TPD
Commercial loads routed through Republic Services and Waste Management transfer stations to county landfills. Access subject to hauler contract terms; route-level agreements standard.
§1.4 Full ACM Feedstock Capability
ACM processes the complete feedstock spectrum generated by Salt Lake County: mixed municipal feedstock, commercial and industrial fractions, construction and demolition material, putrescible organics, textiles, multi-layer packaging, and municipal biosolids. Plastics (all resin codes), paper, metals, glass, wood, and inert fines are all processable without stream pre-separation. Biosolids access requires a separate engagement with CVWRF and SLC Public Utilities — classified as Conditional pending commercial engagement.
§1.5 UNFC Urban Mining Feedstock Resource Classification
The following classification applies the UNFC Urban Mining Framework (three-axis: E — socio-economic viability; F — project feasibility; G — source uncertainty) to characterise Salt Lake County's manufacturing feedstock as a natural resource asset.
Proven Feedstock Reserve
0TPD
No signed Circular Supply Agreement exists at this stage. Proven Reserve is $0. This tier will be populated upon CSA execution following engagement.
Indicated Feedstock Resource
0TPD
No MOU or LOI formalised at this stage. Indicated Resource is $0. This tier will be populated upon execution of a formal expression of interest or engagement MOU.
Inferred Feedstock Resource
~2,000TPD
Total annual manufacturing feedstock generation: ~730,000 tpy. Source: Utah DEQ solid waste characterisation data; Salt Lake County planning estimates; Carbotura standard per-capita parameters. Status: ESTIMATED.
Elemental Composition Note — UNFC G-Axis Ore Grade
Estimated feedstock elemental profile for Salt Lake County MSW (standard US composition, ESTIMATED basis):
| Component | % by Weight | ACM Relevance | Data Source |
|---|---|---|---|
| Organics / food waste | 28% | Primary carbon feedstock; high calorific contribution | ESTIMATED — US EPA MSW composition data |
| Paper & cardboard | 20% | Carbon fraction; cellulosic feedstock input | ESTIMATED — US EPA / state solid waste reports |
| Plastics (all resin codes) | 18% | High-carbon fraction; significant calorific value ~40 MJ/kg | ESTIMATED — US EPA MSW composition data |
| Metals (ferrous + non-ferrous) | 8% | Circular Materials stream; recoverable via ACM separation | ESTIMATED |
| Glass | 5% | Inorganic fraction; inert product use | ESTIMATED |
| Textiles | 7% | Carbon-containing mixed fraction | ESTIMATED |
| C&D / other inerts / fines | 14% | Inorganic fraction; aggregate Circular Materials | ESTIMATED |
Combined carbon fraction (organics + plastics + paper + textiles): ~73% by weight. Calorific value: ~10–14 MJ/kg (Carbotura standard US MSW basis, ESTIMATED). Community-specific MSW audit required during Term Sheet phase verification stage.
UNFC Classification Summary
| Classification | Volume (TPD) | Volume (tpy) | Basis | Status |
|---|---|---|---|---|
| Proven Feedstock Reserve | 0 | 0 | Signed CSA / imminent commitment | NOT YET FORMALISED |
| Indicated Feedstock Resource | 0 | 0 | MOU / LOI / formal expression of interest | NOT YET FORMALISED |
| Inferred Feedstock Resource | ~2,000 | ~730,000 | Total system generation — Salt Lake County catchment | ESTIMATED |
| Total Urban Mine | ~2,000 | ~730,000 | Full addressable county feedstock universe | ESTIMATED |
Section 2
Logistics and Infrastructure
Current collection infrastructure, transfer points, haul distances, and route convergence.
Salt Lake County operates a dual-basin disposal geography divided by the valley's north–south axis. The northern basin is served primarily by the Salt Lake Valley Landfill at 6030 W California Ave (1300 S) — located approximately 11 miles west of downtown Salt Lake City, directly accessible from the I-80/SR-201 freight corridor. The southern basin is served by Trans-Jordan Landfill at 10473 S Bacchus Hwy in South Jordan, approximately 16 miles south of downtown, with direct access from the Bangerter Highway and I-15 interchange.
| Node | Type | Location | Basin Served | Status |
|---|---|---|---|---|
| Salt Lake Valley Landfill (SLVL) | MSW Landfill + HHW | 6030 W California Ave (1300 S), SLC | North valley + county-wide commercial | ACTIVE |
| Trans-Jordan Landfill | MSW Landfill + HHW + Recycling | 10473 S Bacchus Hwy, South Jordan | South valley (7 member cities) | ACTIVE — ~8 YRS REMAINING |
| Trans-Jordan Sandy Transfer Station | Transfer Station | 8813 S 700 W, Sandy | Central / east valley | ACTIVE — OPENED 2025 |
| WM Salt Lake Commercial Transfer Station | Transfer Station | 3405 W 900 S, SLC | County-wide commercial | ACTIVE |
| Republic Services Transfer Station | Transfer Station | 675 Gladiola St, SLC | County-wide commercial | ACTIVE |
| Central Valley WRF (Biosolids) | WWTP — Biosolids generation | 800 Central Valley Rd, South Salt Lake | Multi-city joint service area | ACTIVE |
| SLC Water Reclamation Facility | WWTP — Biosolids generation | 1365 W 2300 N, SLC | Salt Lake City proper | ACTIVE |
Route convergence for an ACM facility sited in the West Valley City / Magna industrial corridor would intersect natural feedstock flow paths from both basins: the I-80/SR-201 corridor from the east and the Bangerter Highway connector from the south. Haul distances from either landfill to the primary candidate site zone average 3–8 miles — within standard commercial feedstock delivery economics.
Section 3
Cost Structure
Current system cost, operator verification, and trajectory analysis.
§3.1 Current System Cost
| Cost Element | Value | Basis | Source Type |
|---|---|---|---|
| SLVL commercial gate rate (mixed MSW) | $36/ton | Per-ton commercial rate, mechanised unload; minimum $17/load | VERIFIED — saltlakecounty.gov pricing, 2025 |
| Trans-Jordan member-city rate | ~$16–20/ton | Municipal member-city disposal rate; 2018 rate $16/ton with annual increases | ESTIMATED — West Jordan City budget data, 2018; inflated to 2025 basis |
| Commercial transfer station rate (WM / RS) | Not publicly disclosed | Commercial contract rate; varies by volume and term | DATA GAP — contract audit during Term Sheet phase verification |
| Collection / hauling overhead (per ton) | ~$19/ton | Estimated collection vehicle, fuel, and labour overhead above gate rate; varies by route density | ESTIMATED |
| Fully-weighted disposal cost (FWDC) | ~$55/ton | Gate rate ($36/ton SLVL weighted basis) + collection/transport overhead (~$19/ton). Note: Utah disposal costs are structurally among lowest in the Western US. | ESTIMATED — planning basis only |
| Post-closure Trans-Jordan FWDC trajectory | $150–$200+/ton est. | Trans-Jordan director projected 3–4× increase at closure; transfer + Bayview Landfill (Utah County) adds ~30+ mile haul | PROJECTED — Draper Journal, April 2024 |
| Annual disposal spend — full system | ~$40M/yr | 730,000 tpy × $55/ton FWDC | MODELED |
| Post-closure annual disposal spend (south basin) | ~$54–67M/yr est. | ~365,000 tpy south-basin volume × $150–185/ton projected FWDC | PROJECTED |
Required Finding — Gate Rate vs. Full-System FWDC
The verified SLVL gate rate ($36/ton) reflects only the tipping-face cost at the primary county landfill. The system-wide FWDC of ~$55/ton incorporates collection vehicle operations, fuel, labour, and transfer station overhead — the full cost borne per ton of feedstock disposed. The gap between the gate rate and the FWDC is the hidden system cost that does not appear in landfill pricing schedules. Post-Trans-Jordan, the tipping-face cost alone is projected to reach $150–$200/ton for south-valley member cities.
§3.2 Verified Operator Names
| Facility | Current Operator | Former Name (if applicable) | Verification |
|---|---|---|---|
| Salt Lake Valley Landfill | Salt Lake County Solid Waste Management Division | — (co-owned with Salt Lake City) | VERIFIED — saltlakecounty.gov |
| Trans-Jordan Landfill | Trans-Jordan Cities (joint district: West Jordan, Sandy, Draper, Riverton, South Jordan, Murray, Midvale) | Trans-Jordan Cities Landfill | VERIFIED — transjordan.org; Murray City gov site |
| WM Salt Lake Commercial Transfer Station / MRF | Waste Management of Utah, Inc. | VERIFIED — Google Places / wm.com | |
| Republic Services Transfer Station | Republic Services of Utah | VERIFIED — Google Places | |
| Mountain View Landfill (C&D/inert) | Waste Management of Utah, Inc. | Blandfill Landfill (former) | VERIFIED — WM Solutions site; Utah DEQ |
| Central Valley Water Reclamation Facility | CVWRF Joint Enterprise | VERIFIED — cvwrf.org; Google Places | |
| Salt Lake City Water Reclamation Facility | Salt Lake City Public Utilities | VERIFIED — slc.gov/utilities | |
| Bayview Landfill (receiving future Trans-Jordan transfer) | Trans-Jordan Cities (contracted) | TRAINING KNOWLEDGE — contract confirmation during Term Sheet phase verification |
§3.3 Cost Trajectory and Throughput Reliability
Three documented cost escalation mechanisms are active in the Salt Lake County system:
Mechanism 1 — Trans-Jordan Closure and Cost Step-Change
The Trans-Jordan Landfill carries approximately eight years of remaining capacity (~2032–2033). Upon closure, the seven member cities will route approximately 365,000 tpy through two new transfer stations to Bayview Landfill in Utah County — adding approximately 30+ miles of haul and an estimated 3–4× increase in per-ton disposal cost for member-city residents. The Trans-Jordan general manager confirmed this cost trajectory publicly (Draper Journal, April 2024). There is no alternative in-county disposal pathway; Salt Lake County planning authorities have confirmed no viable land for a new in-county MSW landfill.
Mechanism 2 — SLVL Capital Reinvestment Pressure
The Salt Lake Valley Landfill has faced documented financial pressures over its operating history, including periods requiring capital reinvestment to maintain AAA bond rating (Salt Lake County Council records). Rate escalation at SLVL has historically tracked regulatory compliance costs, equipment reinvestment, and post-closure liability reserve requirements — all of which increase as the facility matures. The commercial gate rate of $36/ton, while low by national standards, is subject to upward revision on these grounds.
Mechanism 3 — Absence of Competitive Alternatives
No viable private-sector disposal alternative exists within Salt Lake County. The Mountain View Landfill (WM) is restricted to C&D and inert loads. Transfer to Tooele County adds distance and cost. The two-landfill system has no market-competitive pricing discipline; rate decisions are made by joint public authority boards with no external competitive check.
Throughput Reliability — UNFC G-Axis Basis
Unlike a geological ore body whose value declines as reserves deplete, the county's manufacturing feedstock stream is perpetually renewable — structurally stable or growing with population and economic activity. This Throughput Reliability is a material differentiator in UNFC G-axis classification and provides durable collateral basis for the 30-year Circular Supply Agreement.
5-year trend
Utah population growth averaged ~1.5%/year 2018–2023, among the highest in the US (US Census Bureau). Salt Lake County accounts for approximately 38% of Utah's total population and drives the majority of valley feedstock generation growth.
30-year projection basis
Utah Governor's Office of Planning and Budget (GOPB) projects Utah's population to reach 5.5 million by 2060, with Salt Lake County growing proportionally. At standard per-capita generation of 4.9 lbs/day and 1.5%/yr growth, the Inferred Feedstock Resource grows from ~2,000 TPD to approximately 2,800 TPD at the end of a 30-year CSA term — supporting a conservative 2,000 TPD addressable basis throughout the full agreement horizon.
G-axis classification
Throughput Reliability: HIGH — perpetually renewable urban resource with documented growth trajectory. Source uncertainty is structurally lower than any geological resource because the feedstock is generated continuously by urban economic activity, not drawn down from a finite deposit.
Section 4
Regulatory Baseline
Hard deadlines, permit status, environmental compliance, and the ACM classification framework.
Regulatory Predicate Transition (RPT) — Required Disclosure
Carbotura will not execute agreements or commit capital in any jurisdiction that classifies the ACM facility under solid waste NAICS codes (562213 / 562219) rather than manufacturing codes (325180, 325998, 327992, 331110, 331314, 331492). The federal regulatory basis is grounded in RCRA §1004(27), 40 CFR §261.2(e), and 40 CFR §260.43. Utah's regulatory classification of the ACM facility as a manufacturing operation — not a solid waste disposal facility — is a condition precedent to engagement advancement. This is a structural legal requirement, not a negotiating position.
Regulatory Landscape
| Item | Description | Relevance | Action Window |
|---|---|---|---|
| Trans-Jordan closure horizon | ~8 years remaining capacity (~2032–2033); transition to Bayview transfer model begins ~2025–2032 | Creates a hard procurement decision window: an alternative feedstock disposition pathway must be contracted before closure to avoid the 3–4× cost step-change | Decision required by ~2028–2030 to allow for ACM facility construction and commissioning ahead of closure |
| Utah Administrative Code R315 | Utah DEQ Division of Waste Management and Radiation Control — governs solid waste facility permitting under R315-303/304/305 | The ACM facility is classified as a manufacturing operation, not a solid waste facility, and therefore does not require a R315 solid waste permit | CCP verification with Utah DEQ during Term Sheet phase verification stage |
| North Temple Landfill — DEQ VCP | 770-acre closed landfill (1959–1979) in NW Salt Lake City; contaminated groundwater; active Utah DEQ Voluntary Cleanup Program; owned by State of Utah SITLA | Represents a legacy environmental liability on the county's footprint; future Exogenesis™ Protocol opportunity; no current disposal relevance | Ongoing DEQ remediation; development timeline TBD by SITLA |
| Trans-Jordan EPA Superfund (closed) | Trans-Jordan Landfill is a former EPA Superfund site (EPA ID: UTD980635817); current operational status not affected by historical listing | Environmental compliance history documented; currently operating as a Class 1 Subtitle D facility in good standing | No action required; historical record only |
| SLC Inland Port development | ~16,000-acre inland port development area in northwest SLC; overlaps with North Temple Landfill footprint; under Utah Inland Port Authority jurisdiction | Industrial development in the target site zone; potential site competition or co-development opportunity; ACM complements industrial logistics infrastructure | Monitor for UIPA site plan updates; coordinate during Term Sheet phase verification |
| Manufacturing classification (NAICS 31–33) | Manufacturing classification basis (NAICS 31–33) | Establishes federal regulatory basis for ACM classification as manufacturing; outcome will directly govern Utah state classification pathway | Monitor petition progress; CCP verification required before engagement advancement |
Section 5
Feedstock Opportunity
System-wide addressable volume, access classifications, and phase configuration.
§5.1 System-Wide Addressable Volume
Total Inferred Urban Mine
~2,000
TPD / 730,000 tpy · ESTIMATED
Immediately Accessible
~1,500
TPD residential + commercial MSW
Conditionally Accessible
~500
TPD C&D + biosolids (conditional)
Phase Initial Commitment
400
TPD · Carbotura standard Phase Initial
§5.2 Addressability Table
| Stream | Volume (tpy) | TPD | Access Classification | Phase | Notes |
|---|---|---|---|---|---|
| Residential MSW | ~328,500 | ~900 | IMMEDIATE | Phase Initial → Expanded | County/city-operated routes; no private contract barrier |
| Commercial MSW | ~219,000 | ~600 | IMMEDIATE | Phase Initial → Expanded | Subject to private hauler route agreements; standard commercial terms |
| Non-composted green waste | ~7,300 | ~20 | IMMEDIATE | Phase Initial | Currently mixed into general feedstock at SLVL/Trans-Jordan |
| Construction feedstock (C&D) | ~109,500 | ~300 | CONDITIONAL | Phase Medium → Expanded | Requires reclassification of C&D feedstock under manufacturing CSA; regulatory confirmation during Term Sheet phase verification |
| Municipal biosolids (CVWRF + SLC WRF) | ~65,700 | ~180 | CONDITIONAL | Phase Medium | Requires separate engagement with CVWRF Joint Enterprise and SLC Public Utilities; current disposition via land application |
| Total Addressable | ~730,000 | ~2,000 | ESTIMATED | ||
§5.3 Phase Configuration Preview
Phase Initial · 400 TPD
4 Modules · 146,000 tpy
Conservative. Residential MSW only; no third-party negotiation required. Fully addressable via municipal Circular Supply Agreement with Salt Lake County. No conditional stream required. COD target: Q2 2028.
Phase Medium · 1,000 TPD
10 Modules · 365,000 tpy
Standard buildout. Residential + commercial MSW + C&D conditional stream. Requires hauler route agreements (Republic Services / WM) and C&D classification confirmation. Full ops target: Q4 2029.
Phase Expanded · 2,000 TPD
20 Modules · 730,000 tpy
Full system. All immediately accessible + all conditional streams. Requires CVWRF/SLC WRF biosolids agreement. Processes the county's full urban mine. Full ops target: Q2 2031.
Section 6
Feedstock Infrastructure Map
Current disposal and processing infrastructure — active, approaching capacity, historical, and conditional facilities.
Feedstock Infrastructure · Salt Lake County
Active MSW landfill
Approaching capacity
Transfer station
WWTP / biosolids
C&D / inert
Closed / historical
Sources: saltlakecounty.gov; transjordan.org; wm.com; republicservices.com; cvwrf.org; slc.gov; Utah DEQ deq.utah.gov; Google Places API. Operator and address data verified April 2026. Closed-facility locations approximate from DEQ/EPA records.
Appendix A — Evidence Chain
| Figure | Value | Public Source | Source Type | Confidence |
|---|---|---|---|---|
| SLVL commercial gate rate | $36/ton (mixed MSW) | saltlakecounty.gov/landfill/pricing/, accessed April 2026 | VERIFIED | HIGH |
| Trans-Jordan remaining capacity | ~8 years (~2032–2033) | Draper Journal, "Talkin' trash, wish-cycling," April 8, 2024 | VERIFIED — press | HIGH |
| Post-closure cost increase | 3–4× current rate | Draper Journal, April 2024 (Trans-Jordan director statement) | VERIFIED — press | MODERATE-HIGH |
| Trans-Jordan Sandy Transfer Station | Opened spring 2025 | Herriman City blog, October 2025; Murray City gov site | VERIFIED | HIGH |
| Bayview Landfill (receiving facility) | Utah County, ~800+ acres | Draper Journal, April 2024 | VERIFIED — press | HIGH |
| No new in-county landfill | Planning authority confirmation | Draper Journal, April 2024: "There will never be another landfill in Salt Lake County" | VERIFIED — press | HIGH |
| North Temple Landfill — size, dates | 770 acres, 1959–1979, active DEQ VCP | Utah DEQ project summary; Salt Lake City Weekly, 2019 | VERIFIED | HIGH |
| Mountain View Landfill — classification | Class VI C&D + Class V asbestos monofill | WM Solutions site (wmsolutions.com), April 2026 | VERIFIED | HIGH |
| Trans-Jordan EPA Superfund listing | EPA ID: UTD980635817 | US EPA CUMULIS database | VERIFIED — federal database | HIGH |
| FWDC — full system | ~$55/ton | Modeled: SLVL gate rate ($36/ton verified) + collection overhead (~$19/ton estimated) | MODELED | MODERATE — collection overhead estimated |
| Total feedstock volume | ~2,000 TPD | Carbotura standard per-capita parameters; Utah DEQ data; SLC Sustainability Dept. 2024 Annual Report (66,596 tons city residential) | ESTIMATED | MODERATE — Term Sheet phase verification audit required |
| MSW composition | Standard US EPA fractions | US EPA Municipal Solid Waste Characterisation Data (most recent published) | ESTIMATED | MODERATE — community-specific audit required |
Appendix B — Change Factors
Five material factors that would change the diagnostic findings if altered.
| # | Factor | Direction | Mechanism |
|---|---|---|---|
| 1 | Trans-Jordan capacity extension | Reduces urgency | If Trans-Jordan executes additional capacity (new cell, expansion of Bayview agreement, volume reduction via recycling) and extends operational life by 5+ years, the procurement decision window expands. The cost structure remains unchanged; only the timeline shifts. The no-in-county-replacement finding is unchanged. |
| 2 | FWDC materially lower than $55/ton | Reduces State A delta; does not change royalty economics | If Term Sheet phase verification audit reveals the full-system FWDC is below $45/ton, the State A→State B disposal cost delta narrows. The Circular Royalty™ economics are unchanged; the community's return shifts from disposal cost savings + royalty to royalty-dominant. Total value may actually increase as the narrative simplifies to: current spend generates $0; ACM generates positive income. |
| 3 | Utah regulatory classification risk | Blocks or delays engagement | If Utah DEQ or Utah Department of Environmental Quality classifies the ACM facility as a solid waste treatment or disposal operation under R315, the Regulatory Predicate Transition (RPT) is not met and the engagement cannot advance until either federal classification confirmation or a state-level manufacturing classification determination is obtained. |
| 4 | Salt Lake County population decline or flattening | Reduces Throughput Reliability score | Utah's population growth trajectory is structurally dependent on in-migration and housing supply. A major economic contraction, natural disaster (Wasatch Fault seismic event), or regulatory housing restriction could slow or pause growth. This would not affect the UNFC Inferred classification but would reduce the confidence interval on 30-year throughput growth projections. The 2,000 TPD addressable basis remains conservative relative to current generation even under reduced growth. |
| 5 | Alternative technology solution adopted | Forecloses feedstock pathway | If Salt Lake County or Trans-Jordan Cities formally awards an alternative technology procurement (WtE, gasification, anaerobic digestion at scale) ahead of CSA execution, the primary feedstock stream becomes contractually committed. The decision window is effectively the pre-award period of any alternative technology RFP. No active alternative technology RFP has been identified in public records as of April 2026; this requires confirmation during Term Sheet phase verification stage. |
Appendix C — Sources and References
- Salt Lake County Solid Waste Division — Landfill Pricing. saltlakecounty.gov/landfill/pricing/. Accessed April 2026. Commercial per-ton gate rate, materials accepted, facility contact.
- Trans-Jordan Landfill — Official Site. transjordan.org. Accessed April 2026. Facility overview, Sandy Transfer Station, member cities.
- Draper Journal — "Talkin' trash, wish-cycling, and recycling right." draperjournal.com, April 8, 2024. Trans-Jordan capacity horizon (~8 years), cost projection (3–4×), Bayview Landfill, no new in-county landfill.
- Herriman City Blog — Transfer Station Opened. herriman.gov, October 2025. Confirms Sandy Transfer Station open for residential use.
- West Jordan Journal — "West Jordan solid waste fee increases." westjordanjournal.com, November 8, 2018. Trans-Jordan member city tipping fee $16/ton (2018 basis).
- Utah DEQ — North Temple Landfill Project Summary. deq.utah.gov. Accessed April 2026. 770 acres, 1959–1979, groundwater contamination, VCP status.
- Salt Lake City Weekly — "Buried Hazards." cityweekly.net. North Temple Landfill history, inland port context, ~800 acres of buried MSW.
- WM Solutions — Mountain View Landfill. wmsolutions.com/locations/details/id/75. Accessed April 2026. Class VI C&D + Class V asbestos monofill classification.
- US EPA CUMULIS — Trans-Jordan Landfill. EPA ID: UTD980635817. Accessed April 2026. Former Superfund site listing.
- Central Valley Water Reclamation Facility. cvwrf.org. Accessed April 2026. Joint enterprise operator, facility address, biosolids program.
- Salt Lake City Sustainability — Rates and Recycling. slc.gov/sustainability/rates/. Accessed April 2026. 2024 collection tonnage (66,596 tons residential); rate structure.
- Salt Lake Valley Solid Waste Management — Board Minutes. utah.gov/pmn, June 25, 2025. WFWRD government rate; SLC and County co-owner rate discussions; litter abatement fee process.
- Waste Advantage Magazine — "Utah Landfill Shuffles, Gains Space." Trans-Jordan capacity management; 365,000 tpy intake; seven member cities confirmed.
- US EPA — Municipal Solid Waste Characterisation. Composition estimates for standard US MSW streams (organics, paper, plastics, metals, glass).
- Utah Governor's Office of Planning and Budget (GOPB). Population projections to 2060. Used for Throughput Reliability 30-year growth basis. Data age: 2023–2024.
- Google Places API. Facility addresses, coordinates, ratings for SLVL, Trans-Jordan, CVWRF, SLC WRF, WM Transfer, Republic Services Transfer. Accessed April 2026.
Appendix D — Authoritative Glossary
- Advanced Circular Manufacturing (ACM)
- Carbotura's proprietary modular manufacturing process that converts heterogeneous manufacturing feedstock into Manufactured Circular Materials and energy products via Microwave Catalytic Reforming and anoxic elemental dissociation. The facility is classified as a manufacturing operation under NAICS 325180, 325998, 327992, 331110, 331314, 331492 — not a solid waste disposal facility.
- Manufacturing Feedstock
- Any material stream delivered to an ACM facility under a Circular Supply Agreement. ACM is capable of processing all material streams described in this assessment. The term "manufacturing feedstock" replaces all legacy solid waste terminology in Carbotura documentation.
- Beneficiation Fee (Total Material Conversion Fee)
- The Beneficiation Fee paid by the feedstock supplier per ton of material delivered under a Circular Supply Agreement. The Beneficiation Fee replaces the gate fee or tipping fee paid under legacy disposal arrangements. For Salt Lake County: $120/ton, escalating at 2.5%/year.
- Circular Royalty™
- The conversion royalty paid by Carbotura to the feedstock supplier, calculated as a percentage of the corresponding month's Beneficiation Fee with a 13-month payment lag. Base royalty rate: 120% of the corresponding Beneficiation Fee, escalating at +1 percentage point per year. At steady state, the Circular Royalty™ is designed to exceed the Beneficiation Fee on a per-ton basis.
- Circular Royalty™ Structure
- Three-phase royalty structure: (1) Pre-royalty period — Months 1–12 of CSA: Beneficiation Fee paid, $0 royalty; (2) Royalty ramp — Month 13 to approximately Month 24: rolling royalty begins at 120% of Month 1 Beneficiation Fee; (3) Steady-state — Year 2 onward: royalty exceeds Beneficiation Fee per ton by design. Circular Royalty™ payments begin 13 months after corresponding Beneficiation Fee payments and ramp to full run-rate on a rolling basis.
- Fully-Weighted Disposal Cost (FWDC)
- The total cost borne by a community per ton of manufacturing feedstock disposed, including gate fees/tipping fees, collection vehicle operations, transport, transfer station processing, and administrative overhead. Salt Lake County planning basis: ~$55/ton (ESTIMATED). SLVL verified gate rate component: $36/ton.
- Circular Supply Agreement (CSA)
- The 30-year commercial agreement between the feedstock supplier (Salt Lake County) and Carbotura governing feedstock delivery, Beneficiation Fee, Circular Royalty™, and Circular Materials rights. The CSA is the legal instrument that converts the feedstock stream's balance sheet character from disposal liability to income instrument.
- UNFC Urban Mining Framework
- The United Nations Framework Classification for Resources, adapted to urban mining and anthropogenic resources. Applied by Carbotura to classify community feedstock streams on three axes: E (socio-economic viability via TMC/Circular Materials), F (project feasibility via ACM facility specification), and G (source uncertainty via MSW audit).
- Proven Feedstock Reserve
- UNFC classification tier: feedstock volume legally committed under a signed Circular Supply Agreement. Corresponds to G1 (high certainty). Current status: $0 (pre-engagement).
- Indicated Feedstock Resource
- UNFC classification tier: feedstock volume covered by a signed MOU, LOI, or formal expression of interest. Corresponds to G2 (moderate certainty). Current status: $0 (pre-MOU).
- Inferred Feedstock Resource
- UNFC classification tier: total annual manufacturing feedstock generation in the target jurisdiction. The theoretical addressable feedstock universe — the full urban mine. Corresponds to G3 (lower certainty). Salt Lake County Inferred Resource: ~2,000 TPD / ~730,000 tpy (ESTIMATED).
- Throughput Reliability
- The UNFC G-axis characteristic describing the perpetually renewable nature of the urban feedstock stream. Unlike a finite geological resource that depletes as reserves are extracted, urban feedstock is generated continuously by population activity. Higher Throughput Reliability = higher G-axis classification confidence = stronger CSA Reserve collateral basis. Salt Lake County Throughput Reliability: HIGH — Utah population growing ~1.5%/yr.
- Elemental Conversion Efficiency
- The ratio of input feedstock mass to manufactured Circular Materials output mass within the ACM process. Expressed per material category (carbon fraction, metals, inorganics). Used in UNFC G-axis ore grade characterisation to determine recoverable yield per ton of Inferred Feedstock Resource.
- Feedstock Disintegration / Regenesis™ Protocol
- ACM's thermal processing stage. Replaces all legacy references to waste treatment, incineration, combustion, or thermal processing in public-facing documentation.
- Circular Materials
- The manufactured output products of the ACM process, including synthetic graphite, recovered metals, engineered aggregates, and energy equivalents. Circular Materials replaces legacy terms "recycled materials," "byproducts," and "residuals."
- Regulatory Predicate Transition (RPT)
- Carbotura's contractual requirement that the ACM facility be classified under manufacturing NAICS codes (325180, 325998, 327992, 331110, 331314, 331492) rather than solid waste disposal codes (562213 / 562219) in the engagement jurisdiction. The federal basis is RCRA §1004(27) / 40 CFR §261.2(e).
- North Temple Landfill
- A 770-acre closed municipal landfill in northwest Salt Lake City, operated approximately 1959–1979, currently under Utah DEQ Voluntary Cleanup Program. Represents a legacy disposal liability and a potential future Urban & Landfill Mining (Exogenesis™ Protocol) opportunity for Carbotura.
- Exogenesis™ Protocol
- Carbotura's Urban & Landfill Mining process — the systematic extraction and ACM processing of historical feedstock deposits from closed or legacy landfills. Replaces legacy terms "landfill mining" and "site cleanup."