What this document is
The complete commercial document. The Qualification panel, nine sections (§0–§8), plus appendices covering structure, mechanics, risk, timeline, and Hillsborough County structural alignment. Reference-grade — read sectionally.
- 30-year Build-Own-Operate Circular Supply Agreement; Carbotura privately finances and owns; the County supplies feedstock under the CSA.
- The CSA royalty basis: the Circular Royalty™ ($120/ton Year 2, +1pp/yr);
- Exogenesis™ Royalty bonus available under the CSA for landfill remediation at Southeast County Landfill or Hillsborough Heights ($50/ton extracted, +1%/yr, subject to Waste Characterization Study).
Hillsborough County's ~2,545 TPD of addressable manufacturing feedstock qualifies for the CSA (Beneficiation Fee + Circular Royalty™)
Eight Commitments · One Engagement
Five items are required for every engagement and establish the structural commitment between the Authority and Carbotura. Three optional items signal sovereign offtake election — relevant when the Authority acts as a sovereign manufacturer or strategic materials buyer.
What This Means
Beneficiation Fee: $100/ton → Carbotura
+2.5%/yr · separate transaction
Circular Royalty™: $17.52M/yr (Yr 2)
→ $43.1M/yr (Yr 30)
From Carbotura product revenues · separate transaction · 13-month lag
$0 — consideration delivered via
.6M/yr (Yr 2)
→ $19.3M/yr (Yr 30)
From Carbotura product revenues · 13-month lag
$0
Resource Royalty: $14.6M/yr (Yr 2)
+ Exogenesis™ Royalty: $7.3M/yr (Yr 6+)
Two independent streams · ~$714M 30-yr combined
The Beneficiation Fee and all Royalty streams are independent transactions — separate payment obligations under the CSA, never netted against one another. Royalty is paid by Carbotura from operating revenues of Circular Materials sales, independent of any Fee paid by the County. All figures Phase Initial · 400 TPD · 146,000 TPY · ESTIMATED.
Proposal Summary — Five Points
- What Carbotura offers: A privately financed, Build-Own-Operate ACM facility receiving up to 2,000 TPD of county feedstock at full scale. Carbotura's SPV funds, builds, and operates the facility. Hillsborough County's sole financial obligation under the CSA is the per-ton Beneficiation Fee (TMC Fee).
- What the County commits: A 30-year Circular Supply Agreement (CSA) for feedstock supply. $100/ton Beneficiation Fee (+2.5%/yr). Exogenesis™ Royalty bonus available as a CSA add-on. No franchise amendment required.
- What the County receives: An independent Royalty stream paid by Carbotura from product revenues — beginning 13 months after corresponding Beneficiation Fee payment. Circular Royalty™ at $17.52M/yr (Year 2), growing to $43.1M/yr (Year 30).6M/yr (Year 2), growing to $19.3M/yr (Year 30). Exogenesis™ Royalty bonus (available under the CSA): adds $7.3M/yr (Year 6+) from $50/ton legacy landfill remediation, stacking on the CSA.
- Scale pathway: Three phases — 400 / 800 / 2,000 TPD — independently financeable. Phase Expanded at 2,000 TPD draws on commercially available regional feedstock via CSX rail.
- Decision window: Phase Initial COD of Q2 2028 requires authorization by Q3 2026. Every quarter of delay extends the pre-royalty period and defers the first royalty payment.
Commercial Structure and Decision Window
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.
| 325180 | Other Basic Inorganic Chemical Manufacturing |
| 325998 | All Other Misc. Chemical Product Manufacturing |
| 327992 | Ground or Treated Mineral and Earth Manufacturing |
| 331110 | Iron and Steel Mills and Ferroalloy Manufacturing |
| 331314 | Secondary Smelting and Alloying of Aluminum |
| 331492 | Secondary Smelting, Refining of Nonferrous Metal |
| 562212 | Solid Waste Landfill |
| 562213 | Solid Waste Combustors and Incinerators |
| 562219 | Other Nonhazardous Waste Treatment and Disposal |
| 562920 | Materials Recovery Facilities |
Regulatory basis: RCRA §1004(27) · 40 CFR §261.2(e) · 40 CFR §260.43
The CSA — Mutual Commitments
| Party | Commitment | Term / Condition |
|---|---|---|
| Hillsborough County | Deliver feedstock to ACM facility per CSA schedule | 30 years from Phase Initial COD |
| Hillsborough County | Pay Beneficiation Fee (TMC Fee) per ton delivered | $100/ton at inception, +2.5%/year |
| Carbotura SPV | Accept all feedstock streams per CSA specification | MSW, ash, biosolids, tires — all ACM-capable |
| Carbotura SPV | Design, finance, build, and operate ACM facility | Zero county capex — BOO structure · 18-month Parent Performance Guarantee |
| Carbotura SPV | Pay Circular Royalty™ commencing Month 13 | 120% of that year's Beneficiation Fee, +1pp/year |
| Carbotura SPV | Maintain facility to CSA performance standards | Full 30-year term |
Decision Window
Phase Initial COD is targeted for Q2 2028, based on a T0 of Q2 2026 and Carbotura's standard 24-month construction schedule. Authorization must occur by Q3 2026 to hold this schedule. Each quarter of delay after Q3 2026 shifts the COD by an equivalent quarter — and extends the pre-royalty period during which the county pays the Beneficiation Fee without receiving royalty. At Phase Initial volume (146,000 TPY), a single quarter of delay costs the county approximately $1.4M in avoidable disposal costs at current FWDC rates compared to what could otherwise be displaced by the Beneficiation Fee.
§1.5 — CSA Structure
Carbotura's Circular Supply Agreement provides one commercial structure. The Beneficiation Fee and the Circular Royalty™ apply on the same terms to every Feedstock Provider, and the Exogenesis™ Royalty is an add-on available under the CSA.
Indicative economics based on 400 TPD / 146,000 TPY. Election made at CSA execution, not at Term Sheet. All figures illustrative. Source: Carbotura CSA Engagement Document Suite v2026.7.
The Southeast County Landfill (15960 County Rd. 672, Lithia, FL) is a qualifying asset for the Exogenesis™ Royalty path. Where a closed, closing, or operating landfill site is made available, Carbotura commits to deploy Exogenesis™ (legacy landfill mining) within 3–7 years post-COD, alongside the primary Regenesis™ facility. This creates a second concurrent royalty stream.
| Royalty Stream | Rate | Escalation | Trigger | Indicative Year 1 (400 TPD ea.) |
|---|---|---|---|---|
| $100/ton | 1%/yr | Month 13 rolling | ~$14.6M | |
| Exogenesis™ Royalty (Exogenesis™) | $50/ton extracted | 1%/yr | 13 months after first extraction | ~$7.3M |
| Combined (once Exogenesis™ operational) | ~$21.9M/yr | |||
Additional balance-sheet effects under the Exogenesis™ Royalty: (1) all post-closure care, leachate, methane, and monitoring obligations transfer to Carbotura at CSA execution; (2) Hillsborough County's GASB 18 post-closure care liability is extinguished at execution — the single largest balance-sheet event available to a landfill-operating government entity under the CSA framework; (3) Carbotura provides Environmental Impairment Liability, Pollution Legal Liability, and a Post-Closure Performance Bond replacing the County's existing financial assurance obligations.
The CSA is executed at Financial Closing. Phase II ESA and Waste Characterization Study conducted during Joint Working Group phase (costs shared equally). All figures illustrative · Source: CSA v2026.7 §4B.2A, §4B.12, §4B.13
Executive Implications
- The BOO structure means Hillsborough County receives the economic benefits of an industrial facility — processing, royalty income, jobs — without any of the capital, construction, or operational risk that would accompany a public procurement. Carbotura, Inc. provides an 18-month Parent Performance Guarantee on all payment obligations, surviving any assignment to the project operating entity.
- The CSA is a commercial supply agreement, not a disposal franchise amendment. It does not require changes to the county's franchise hauler arrangements or inter-county waste management agreements.
- The CSA is the engagement path for Hillsborough County, whose investment-grade counterparty profile meets the credit floor.
- Authorization by Q3 2026 is required to preserve the Q2 2028 Phase Initial COD.
Deployment Architecture
Hillsborough County's deployment is classified as a Single-Site topology — one ACM facility location, truck-served, with capacity scaling in standardized 100 TPD modular increments from 400 TPD to 2,000 TPD at the P1 candidate site. Single-Site topology supports 100–2,000 TPD at one location; no rail-served Campus designation is required at current projected scale.
§2.1 — Phase Configuration
| Phase | TPD | Modules | Annual Feedstock | % of Hillsborough Addressable | COD Target | Source Type |
|---|---|---|---|---|---|---|
| Phase Initial | 400 | 4 | 146,000 TPY | 24% of Hillsborough County alone | Q2 2028 | ESTIMATED |
| Phase Medium | 800 | 8 | 292,000 TPY | 48% of Hillsborough County alone | Q4 2029 | ESTIMATED |
| Phase Expanded | 2,000 | 20 | 730,000 TPY | 79% of total regional addressable | Q2 2031 | ESTIMATED |
Module count: ceil(TPD/100). Phase Expanded draws on Hillsborough County + Pasco County + regional commercial/industrial streams via CSX Wildwood Subdivision.
§2.2 — Build-Own-Operate Capital Structure
Hillsborough County's sole financial commitment under the CSA is the per-ton Beneficiation Fee (TMC Fee) on feedstock delivered. The Carbotura SPV provides all project capital. The county bears zero construction debt, zero facility operating liability, and zero residual stream management responsibility.
Carbotura finances 100% of per-increment CAPEX through its proprietary modular capital architecture — structured exclusively as Advanced Circular Manufacturing finance (NAICS 31–33) and sized per 100 TPD increment. There is no county capital contribution, no county co-investment requirement, and no county exposure to construction cost overruns, financing market conditions, or facility operating performance at any phase. Each 100 TPD modular increment carries its own independent Financial Closing; capacity at Phase Medium and Phase Expanded does not depend on or alter the financial terms of Phase Initial.
| Capital Commitment | Phase Initial (400 TPD) | Phase Expanded (2,000 TPD) | Party |
|---|---|---|---|
| Total facility CAPEX | $247,500,000 | $1,167,500,000 | Carbotura — 100% |
| Construction risk | Carbotura SPV | Carbotura SPV | Carbotura — 100% |
| Operating risk | Carbotura SPV | Carbotura SPV | Carbotura — 100% |
| Output commercialization risk | Carbotura SPV | Carbotura SPV | Carbotura — 100% |
| County capital contribution | $0 | $0 | None |
CAPEX basis: $75M first 100 TPD increment + $57.5M per additional 100 TPD increment. Carbotura BOO structure — county is feedstock supplier and royalty recipient only. 18-month Parent Performance Guarantee on all payment obligations. US GAAP accounting standard.
§2.3 — Feedstock Stream Coverage by Phase
| Stream | Phase Initial | Phase Medium | Phase Expanded | Access Status |
|---|---|---|---|---|
| Unsorted MSW — Hillsborough County | ✓ Primary | ✓ Primary | ✓ Core | IMMEDIATE |
| WTE Combustion Ash | ✓ Secondary | ✓ | ✓ | IMMEDIATE |
| Tires | ✓ | ✓ | ✓ | IMMEDIATE |
| Biosolids / Sludge | ✓ Added | ✓ | CONDITIONAL | |
| Pasco County MSW (CSX rail) | ✓ Added | CONDITIONAL | ||
| Regional Commercial / Industrial | ✓ Supplemental | CONDITIONAL |
§2.5 — Phase Initial Feedstock Sufficiency
Phase Initial requires 400 TPD (146,000 TPY). The immediately accessible streams in Hillsborough County — unsorted MSW overflow, WTE combustion ash (~360 TPD), and commercial tires (~25 TPD) — provide ~1,585 TPD of IMMEDIATE-access feedstock. Phase Initial represents just 25% of this available base. No new franchise agreement, no inter-county compact, and no third-party commercial negotiation is required to execute Phase Initial.
§2.4 — Site Candidate Analysis
Three priority candidate zones evaluated on acreage, zoning, rail access, logistics, and proximity to primary feedstock sources. Click a zone card to locate on map.
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SE County Landfill: ~24 mi via US-301 S (~28 min)
NW County SW Facility: ~34 mi via I-75 S (~38 min)
South County SW Facility: ~36 mi via US-301/I-75
SE County Landfill: ~18 mi via SR-39 S (~22 min)
NW County SW Facility: ~30 mi via I-75 S (~34 min)
South County SW Facility: ~29 mi via I-75 N/US-41
SE County Landfill: ~17 mi via US-301 S (~21 min)
NW County SW Facility: ~36 mi via I-4 W/I-275 N (~41 min)
South County SW Facility: ~27 mi via I-75 N (~30 min)
Sources: dcbusinesscenter.com; pascoedc.com; plantcitygov.com; hcfl.gov; Google Places March 2026. Driving distances estimated via US-301/I-75/I-4 corridors.
| Priority | Zone | Acreage | Zoning | Land Authority | Co-location Advantage | Key Consideration |
|---|---|---|---|---|---|---|
| P1 | Dade City Business Center | 355 ac | Heavy Industrial (current) | Private / Pasco County | CSX rail through property; onsite water; no rezoning; 355 ac expandable | Pasco County jurisdiction — commercial CSA governs |
| P2 | Zephyrhills Industrial Corridor | ~111 ac+ | Industrial (Ready Site) | City of Zephyrhills / Pasco EDC | Pre-permitted Ready Site; I-75/SR-54 access; WTE adjacent feedstock | Rail spur development required (~3 mi) |
| P3 | Plant City Industrial Zone | 50–150 ac | Heavy/Light Industrial | City of Plant City / Hillsborough County | Within county; CSX rail yard adjacent; I-4 direct to Tampa | Site assembly likely required; urban interface constraints |
Dade City Business Center is the leading candidate. It is the only identified site with active CSX freight rail through the property, 355 acres of immediately available heavy-industrial-zoned land, and onsite water and treatment infrastructure. No rezoning is required. The Carbotura ACM facility receives feedstock under a commercial CSA — the same legal structure as a scrap metal processor or aggregate manufacturer receiving multi-county raw material supply. The Pasco County industrial siting process is a standard permitting matter, not a policy constraint.
Economic Structure — Beneficiation Fee (TMC Fee)
FWDC Planning Basis
The Full Weighted Disposal Cost (FWDC) for Hillsborough County is modeled at approximately $95/ton — a volume-weighted blend of verified component disposal rates. The primary rate — processable MSW delivered to Reworld™ RRF — is confirmed at $110/ton (municipal rate, effective October 1, 2024). Non-processable MSW to the Southeast County Landfill is confirmed at $58/ton. Tire disposal is confirmed at $211/ton. Biosolids composting is confirmed at $30.89/ton. All component rates are VERIFIED; the volume weighting applied to derive the blended FWDC is MODELED.
Beneficiation Fee (TMC Fee) Formula
The floor applies because FWDC − $5 ($90/ton) falls below the $100/ton minimum. The Beneficiation Fee is therefore at the formula floor — the county pays less per ton for ACM processing than its verified WTE processable disposal rate of $110/ton from inception.
Annual Obligation by Phase
| Phase | TPD | Annual TPY | Year 1 Beneficiation Fee/ton | Year 1 Annual Obligation | Year 5 Beneficiation Fee/ton | Year 5 Annual Obligation |
|---|---|---|---|---|---|---|
| Phase Initial | 400 | 146,000 | $100.00 | $14,600,000 | $110.38 | $16,115,480 |
| Phase Medium | 800 | 292,000 | $100.00 | $29,200,000 | $110.38 | $32,230,960 |
| Phase Expanded | 2,000 | 730,000 | $100.00 | $73,000,000 | $110.38 | $80,577,400 |
Beneficiation Fee escalation: 2.5%/year (Carbotura standard parameters). Year 5 = $100 × (1.025)^4 = $110.38/ton. ESTIMATED annual obligations.
FWDC is MODELED at $95/ton. The primary disposal rate is VERIFIED at $110/ton (municipal processable MSW, effective October 1, 2024, Hillsborough County Solid Waste Rate Resolution). Volume weights applied to derive the blended FWDC are ESTIMATED. The Beneficiation Fee floor of $100/ton applies regardless of FWDC — if the verified blended FWDC were confirmed above $105/ton, the formula would produce a Beneficiation Fee above the floor.
Gross cost displacement is quantified separately from Circular Royalty™ cash flow. Both are independent financial effects of the CSA.
Royalty Structure
All royalty payments begin 13 months after corresponding Beneficiation Fee payment and ramp to full run-rate on a rolling basis.
At steady state under the CSA, the royalty received is designed to exceed any Beneficiation Fee paid on a per-ton basis.
Gross cost displacement is quantified separately from royalty cash flow.
§4.0 — Circular Royalty™
County pays Beneficiation Fee each month; receives Circular Royalty™ 13 months later. From Year 2 onward the per-ton royalty rate exceeds the per-ton Beneficiation Fee — both are reported as separate transactions, never netted.
| Parameter | Value | Basis |
|---|---|---|
| Base Royalty Rate (Year 1) | 120% of the current-year Beneficiation Fee per ton | Carbotura standard |
| Royalty Multiplier Escalator | +1 percentage point per year (Year 2: 121%; Year 30: 148%) | Carbotura standard |
| Beneficiation Fee Escalator | +2.5% per year | Carbotura standard |
| Effective Royalty Growth | ~3.3%/yr average over 30 years | Derived |
| Payment Lag | 13 months after corresponding Beneficiation Fee payment | Fixed |
| Counterparty Credit | BBB– / Baa3 required at execution and throughout Term | CSA §4A.5 |
| Period | Timing | County Outflow | County Inflow |
|---|---|---|---|
| Pre-Royalty | Months 1–12 after corresponding Beneficiation Fee payment | Beneficiation Fee ($100.00/ton) | $0 royalty |
| Royalty Ramp | Month 13 → Month 24 (approx.) | ~$102.50/ton (escalated) | Circular Royalty™ at $120.00/ton |
| Steady State | Year 2 onward | +2.5%/yr escalating | +~3.3%/yr effective (multiplier mechanic) |
Hillsborough County pays the Beneficiation Fee and receives zero Circular Royalty™ during the first 12 months following Phase Initial COD (est. Q2 2028 – Q2 2029). First Circular Royalty™ payment: July 2029. This is a planned structural feature of the 13-month lag, not a performance shortfall.
| Year | Avoided Disposal/ton | Beneficiation Fee/ton → Carbotura | Annual Fee Paid | Royalty Rate | Royalty/ton → County | Annual Royalty Received |
|---|---|---|---|---|---|---|
| 1 | $95.00 | $100.00 | $14,600,000 | — pre-royalty | $0 | $0 |
| 2 | $97.37 | $102.50 | $14,965,000 | 120% | $120.00 | $17,520,000 |
| 5 | $104.86 | $110.38 | $16,115,480 | 123% | $132.46 | $19,339,160 |
| 10 | $118.64 | $124.89 | $18,233,940 | 128% | $155.95 | $22,768,700 |
| 20 | $151.87 | $159.87 | $23,340,220 | 139% | $222.21 | $32,442,660 |
| 30 | $194.43 | $204.64 | $29,877,440 | 148% | $295.48 | $43,140,080 |
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.
Phase Initial 400 TPD / 146,000 TPY. Year 5 royalty = 123% × $107.69 = $132.46/ton. All ESTIMATED. US GAAP.
| Phase Expanded Full Build-Out (2,000 TPD / 730,000 TPY) | |||||
|---|---|---|---|---|---|
| Year | Beneficiation Fee/ton → Carbotura | Annual Fee Paid | Royalty/ton → County | Annual Royalty Received | |
| 1 | $100.00 | $73,000,000 | $0 | $0 | |
| 2 | $102.50 | $74,825,000 | $120.00 | $87,600,000 | |
| 10 | $124.89 | $91,169,700 | $155.95 | $113,843,500 | |
| 30 | $204.64 | $149,387,200 | $295.48 | $215,700,400 | |
Phase Expanded: 2,000 TPD × 365 = 730,000 TPY. All ESTIMATED. US GAAP.
§4.1 — Exogenesis™ Royalty (Bonus Feature · Available under the CSA)
The Exogenesis™ Royalty is a bonus feature available on top of the CSA. Carbotura remediates the deeded legacy landfill (e.g. Southeast County Landfill) and pays $50/ton extracted royalty, +1%/yr compound, beginning 13 months after first Exogenesis™ extraction. The figures below illustrate the combined position when stacked on
| Royalty Stream | Rate | Escalation | Trigger | Basis |
|---|---|---|---|---|
| $100.00/ton (current waste stream) | +1%/yr from Year 2 | Month 13 after corresponding Beneficiation Fee payment | CSA §4B.2 | |
| Exogenesis™ Royalty | $50.00/ton extracted (Exogenesis™) | +1%/yr from Year 2 of extraction | 13 months after first Exogenesis™ extraction | CSA §4B.2A |
| Exogenesis™ Royalty CERCLA floor / step-up | $25/ton floor if CERCLA contamination discovered; $75/ton if 7-yr long-stop missed | Per Waste Characterization Study findings | CSA §4B.2A |
| Period | Timing | County Outflow | County Inflow | |
|---|---|---|---|---|
| Pre-Royalty | Months 1–12 | $0 | $0 | |
| Primary Royalty Only | Year 2 → Year 5 (approx.) | $0 | +$100–104/ton | |
| Dual Stream | Year 6 onward (Exogenesis™ online + 13m) | $0 |
| Year | Avoided Disposal/ton | Exogenesis™ Royalty/ton | Total/ton | Annual Two-Stream | |
|---|---|---|---|---|---|
| 1 | $95.00 | $0 | $0 | $0 | $0 |
| 2 | $97.37 | $100.00 | $0 | $100.00 | $14,600,000 |
| 5 | $104.86 | $103.03 | $0 | $103.03 | $15,042,380 |
| 6 ★ | $107.48 | $104.06 | $50.00 | $154.06 | $22,492,760 |
| 10 | $118.64 | $108.29 | $52.03 | $160.32 | $23,406,720 |
| 20 | $151.87 | $119.61 | $57.48 | $177.09 | $25,855,140 |
| 30 | $194.43 | $132.13 | $63.49 | $195.62 | $28,560,520 |
★ Year 6 = first Exogenesis™ Royalty year (Exogenesis™ target COD Year 5 + 13-month trigger). Exogenesis™ Royalty Year n = $50 × 1.01n−6/ton (n≥6). Phase Initial 400 TPD / 146,000 TPY. All ESTIMATED. US GAAP.
| Year | Exogenesis™ Royalty/ton | Two-Stream Total/ton | Annual Two-Stream | |
|---|---|---|---|---|
| 1 | $0 | $0 | $0 | $0 |
| 2 | $100.00 | $0 | $100.00 | $73,000,000 |
| 6 ★ | $104.06 | $50.00 | $154.06 | $112,463,800 |
| 10 | $108.29 | $52.03 | $160.32 | $117,033,600 |
| 30 | $132.13 | $63.49 | $195.62 | $142,802,600 |
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.
★ Year 6 = first full Exogenesis™ Royalty year. No fee outflow under the CSA + Exogenesis™ Royalty at any phase. All ESTIMATED. US GAAP.
Risk Register
| Risk | Key Driver | Bears Risk | Mitigation | Residual Exposure |
|---|---|---|---|---|
| FWDC verification | Blended $95/ton is MODELED; component rates are VERIFIED | Hillsborough County (pricing impact) | Beneficiation Fee floor at $100/ton is independent of FWDC; primary stream at $110/ton already below floor from inception | Low — floor protects SPV; county already pays $110/ton for primary stream |
| Technology performance | ACM throughput and output quality must meet CSA specification | Carbotura SPV (operational) | Performance guarantees in CSA; SPV bears operating cost overruns; county payment tied to delivered volume only | Low to county — SPV absorbs operational risk |
| Timeline slippage | Permitting, construction, or supply chain delays | Carbotura SPV (construction) | Carbotura standard 24-month schedule has been achieved across prior deployments; DCBC site is pre-approved | Moderate — delays extend pre-royalty period; every quarter = ~$1.4M additional avoidable cost (Phase Initial) |
| Third-party contract constraints | Biosolids (Phase Medium) under existing composting arrangement at SE Landfill | Hillsborough County (supply) | Phase Initial and Medium are fully executable from IMMEDIATE-access streams; biosolids added as Phase Medium supplement; parallel negotiation begins at CSA execution | Low — Phase Initial unaffected; Phase Medium timeline manageable |
| Competitive procurement | County may receive competing waste management proposals | Hillsborough County (process) | CSA is a commercial supply agreement — county retains full procurement authority; Carbotura's value position is verified on disposal cost data | Low to county — competitive process is beneficial to public interest |
| Residual stream management | ACM process outputs require industrial offtake markets | Carbotura SPV (commercial) | Synthetic graphite, graphene compounds, and recovered minerals have established industrial markets; output risk not borne by county | Zero to county — SPV manages output commercialization entirely |
| PFAS / emerging contaminants | Florida biosolids regulation may tighten under federal PFAS standards | Regulatory / shared | ACM thermomechanical conversion destroys organic contaminants including PFAS at processing temperatures; positions county ahead of tightening biosolids rules | Low — ACM is a compliance advantage, not a liability |
| Phase Expanded feedstock sufficiency | Regional commercial feedstock (Pasco + C&I) requires commercial CSA negotiation | Carbotura SPV (commercial sourcing) | Phase Expanded does not commence until Phase Medium demonstrates regional demand signal; commercial supply agreements standard in manufacturing sector | Low — Phase Initial and Medium fully Hillsborough County-native |
Deployment Timeline
| Milestone | Target Date | Party Responsible | Notes |
|---|---|---|---|
| ⚡ CSA Authorization | Q3 2026 | Hillsborough County | PROCUREMENT DECISION WINDOW — latest date to hold Q2 2028 Phase Initial COD |
| CSA negotiation and execution | Q1–Q2 2027 | Both parties | Commercial supply agreement; legal review |
| Phase Initial site permitting (Pasco County) | Q2–Q4 2026 | Carbotura SPV | DCBC pre-approved heavy industrial |
| Phase Initial construction start | Q4 2026 | Carbotura SPV | T0 + 6 months |
| Phase Initial COD | Q2 2028 | Carbotura SPV | T0 + 24 months — first delivery |
| Pre-royalty period | Q2 2028 – Q2 2029 | 12 months; county pays Beneficiation Fee, receives $0 royalty | |
| ⭐ First Circular Royalty™ Payment | July 2029 | Carbotura SPV → County | T0 + 37 months; 13 months after Phase Initial COD |
| Phase Medium full operations | Q4 2029 | Carbotura SPV | T0 + 42 months; +400 TPD |
| Phase Expanded full operations | Q2 2031 | Carbotura SPV | T0 + 60 months; +1,200 TPD to 2,000 TPD total |
| CSA minimum term end | Q2 2058 | Both parties | 30 years from Phase Initial COD — perpetual continuation unless terminated by Non-Renewal Notice (Year 28+, 24-month notice, Year 30 earliest exit) |
Carbotura standard deployment schedule. T0 = Q2 2026 (assumed). All dates ESTIMATED.
Community Value Stack
County Fiscal Effects
| Fiscal Effect | Phase Initial | Phase Expanded | Status |
|---|---|---|---|
| Gross cost displacement (Beneficiation Fee vs. FWDC) | ~$1.5M/yr (Year 1 at $110/ton FWDC vs. $100/ton Beneficiation Fee) | ~$7.3M/yr (Year 1 at full scale) | ESTIMATED |
| Circular Royalty™ — Year 2 onset | +$17,520,000/yr at $120/ton | +$87,600,000/yr at $120/ton | ESTIMATED |
| Circular Royalty™ received — Year 2 | $17,520,000/yr | $87,600,000/yr | ESTIMATED |
| Beneficiation Fee paid — Year 2 (separate transaction) | $14,965,000/yr | $74,825,000/yr | ESTIMATED |
| Circular Royalty™ received — Year 30 | $43,140,080/yr | $215,700,400/yr | ESTIMATED |
| Beneficiation Fee paid — Year 30 (separate transaction) | $29,877,440/yr | $149,387,200/yr | ESTIMATED |
| Cumulative Circular Royalty™ received — 30 years | ~$874M | ~$4.37B (Phase Expanded) | ESTIMATED |
| Avoided landfill cell capital | Material — landfill cells deferred; quantum subject to detailed engineering | Material | ESTIMATED |
Regional Economic Effects
| Economic Effect | Phase Initial | Phase Expanded | Status |
|---|---|---|---|
| Direct FTE employment | ~35 jobs | ~155 jobs | ESTIMATED |
| Indirect / induced jobs | ~105 | ~465 | ESTIMATED |
| Annual economic impact | ~$18.5M/yr | ~$92.5M/yr | ESTIMATED |
| Industrial outputs to Tampa Bay market | Synthetic graphite, graphene compounds, recovered minerals | Same — scaled | ACM standard |
| Construction employment | ~180 construction-phase jobs (2-year period) | ~750 cumulative | ESTIMATED |
Economic impact figures scaled from Carbotura standard 400 TPD baseline parameters. Regional multipliers applied. ESTIMATED.
Environmental Effects
| Environmental Effect | Phase Initial (400 TPD) | Phase Expanded (2,000 TPD) | Status |
|---|---|---|---|
| CO₂e emissions avoided vs. landfill / WTE baseline | ~160,000 tonnes/yr | ~800,000 tonnes/yr (~174,000 cars equivalent) | ESTIMATED |
| Process water demand | ~42,000 gal/day | ~210,000 gal/day | ESTIMATED |
| Material throughput from intake | ~90% sold globally · ~100% converted (Circular Materials) | ~90% sold (linear scaling) | ESTIMATED |
| Atmospheric discharge | Near-zero by design — anoxic / oxygen-free / no combustion | Same | VERIFIED (process) |
Environmental detail in the Environmental Impact Review. See Community Benefits for resident-facing summary.
Why This Works in Hillsborough County
Six structural conditions make Hillsborough County an exceptionally aligned opportunity for ACM deployment.
| # | Alignment Factor | Hillsborough County Specific Evidence |
|---|---|---|
| 1 | Volume alignment | ~2,545 TPD total addressable across six identified streams — 3.96× Phase Initial commitment available without third-party negotiation. Phase Expanded at 2,000 TPD is 79% of total regional addressable, with rail connectivity enabling broader Tampa Bay regional sourcing. |
| 2 | Infrastructure alignment | The Dade City Business Center (P1) provides 355 acres of pre-approved heavy industrial land with active CSX Wildwood Subdivision freight rail through the property. The existing transfer station network (5 CCCs, 4 transfer stations) provides a ready haul infrastructure requiring no county capital investment. The P1 site is 28 miles from the RRF via I-75 — a standard commercial haul distance. |
| 3 | Contract timing alignment | The Southeast County Landfill is actively expanding cells to address a 38% single-year tonnage surge (2024). The Solid Waste Master Plan extends to 2065 — matching the 30-year CSA term exactly. No competing infrastructure is in permitting. Q3 2026 authorization preserves Q2 2028 Phase Initial COD. |
| 4 | Policy alignment | The Hillsborough County Comprehensive Plan Solid Waste section explicitly prioritizes waste reduction, reuse, recycling/composting, and energy recovery over landfilling. ACM advances the adopted county policy hierarchy without requiring a policy amendment. Florida's WTE-positive policy framework further reduces institutional resistance. |
| 5 | Regulatory driver | Florida DEP Chapter 62-701 enforcement is active and documented in Hillsborough County (Raleigh Street Dump Superfund, Hartford Street unpermitted dumping). Tightening federal PFAS standards will increase biosolids disposal costs; ACM thermomechanical conversion destroys PFAS at processing temperatures. Regulatory pressure is structural and one-directional — it increases the cost of the status quo, not the cost of ACM. |
| 6 | Economics specificity | The Beneficiation Fee is calibrated to Hillsborough County's own verified disposal cost data — $110/ton processable MSW (municipal rate, October 2024 Rate Resolution). The $100/ton Beneficiation Fee is below the county's own published primary disposal rate from Year 1, without any royalty benefit factored in. The economic case rests on the county's own numbers. |
Data Basis
| Figure | Value | Source | Type |
|---|---|---|---|
| Beneficiation Fee (TMC Fee) Year 1 | $100/ton | Carbotura formula floor applied to FWDC $95/ton | ESTIMATED |
| FWDC planning basis | $95/ton | Modeled from VERIFIED county rate schedule, Oct 2024 | MODELED |
| Processable MSW rate (municipal) | $110/ton | Hillsborough County Solid Waste Rate Resolution, Oct 1, 2024 | VERIFIED |
| Phase Initial CapEx | $247.5M | Carbotura standard: $75M first module + 3×$57.5M | Carbotura standard |
| Circular Royalty™ Year 2/ton (Phase Initial) | $120.00 | (120% + (n−1)pp) × that year’s Beneficiation Fee (Year 1: $100) | ESTIMATED |
| Phase Initial COD | Q2 2028 | Carbotura standard schedule from T0 Q2 2026 | ESTIMATED |
| P1 site — rail access | CSX Wildwood Subdivision | dcbusinesscenter.com / Dade City Wikipedia (March 2026) | VERIFIED |
| P1 site — acreage/zoning | 355 acres, Heavy Industrial | dcbusinesscenter.com (March 2026) | VERIFIED |
| Cumulative 30-yr royalty (Phase Initial) | ~$180M | Carbotura royalty model — discounted and nominal; ESTIMATED | ESTIMATED |