Miami-Dade County
ACM Economic Impact Report
& Stage 1 Proposal
From disposal cost to Revenue Stack. From structural deficit to Circular Royalty™. From combustion replacement to Total Material Conversion. This document is the primary decision-maker brief for Miami-Dade County’s transition to Advanced Circular Manufacturing.
Prepared by Carbotura Inc. for informational and engagement purposes only. All financial projections are based on RevCon 3 baseline assumptions. Data sourced from Miami-Dade Waste Industry Intelligence Report 2025 and public records. This document does not constitute a binding offer or executed agreement. Carbotura makes no guarantee of specific financial returns. Stage 1 of 7 — Initial Engagement only. Forward-looking statements apply. All figures marked with confidence badges. Corrections: research@carbotura.com
The Economic Inversion
Miami-Dade County currently pays approximately $36.86/ton (FWDC weighted average) to permanently destroy 100% of the commercial value in its feedstock stream — a stream that generates more than twice the US per-capita average. The Resources Recovery Facility that handled 1 million tons per year is permanently gone. Both county landfills approach capacity by 2030. The proposed WTE replacement is unconfirmed, three years into a siting debate, and estimated at $800M–$1.5B of public capital.
Carbotura proposes to invert this architecture. Under a 30-year Circular Offtake Agreement, Miami-Dade pays a TMC Fee competitive with or below the FWDC from Day 1, and receives a Circular Royalty™ from month 13. Over 30 years at 1,000 TPD, the conservative total community benefit exceeds $4.9 billion — approximately $58 per resident per year (Years 2–30). Miami-Dade assumes zero capital risk. Carbotura builds, owns, and operates.
Today: Miami-Dade pays $36.86/ton to destroy its feedstock. With ACM: Miami-Dade pays ≤$36.86/ton in TMC Fee, receives Circular Royalty™ from month 13, creates 250+ direct jobs at 1,000 TPD, generates 30-year community benefit >$4.9B conservative, and eliminates its $1B+ WTE capital commitment. The economic inversion is not a projection. It is the structural consequence of replacing a disposal system with a manufacturing system. Everything to Everything.
Table of Contents
Disclaimer
This document has been prepared by Carbotura Inc. for informational and Stage 1 engagement purposes only. It is based on data from the Miami-Dade Waste Industry Intelligence Report 2025 and publicly available sources. It does not constitute a binding offer, executed agreement, or guarantee of outcomes. All data carries confidence badges: HIGH = public record · MED = derived calculation · LOW = preliminary estimate.
Carbotura modular factories are designed and operated as Advanced Circular Manufacturing (ACM) facilities — not waste processing, waste management, or waste-to-energy facilities. All permitting will be conducted on a manufacturing classification basis. Nothing herein shall be construed as admission that Carbotura’s operations constitute “waste management” under any statute, rule, or regulation.
Version 3.0 — March 2026 · Next review: September 2026 · Corrections: research@carbotura.com
SQ1Disposal Cost Profile
Source: Miami-Dade Waste Industry Intelligence Report 2025, Section 12 — Cost Analysis. The FWDC is the benchmark against which the ACM TMC Fee is calibrated. All rates from MDC-FEES-1025 (October 2025 schedule).
FWDC Derivation — Σ Calculation
| Stream | Weight | Gate /ton | Transfer /ton | All-In /ton | Weighted | Conf. |
|---|---|---|---|---|---|---|
| MSW Residential (contract) | 45% | $16.28 | $16.66 | $32.94 | $14.82 | HIGH rate · MED weight |
| MSW Commercial (non-contract) | 35% | $16.91 | $16.91 | $33.82 | $11.84 | HIGH rate · MED weight |
| Special waste / bulky (est.) | 10% | $16.91 | $16.91 | ~$42 | $4.20 | HIGH rate · LOW per-ton |
| Emergency overflow (est. market) | 10% | ~$50–$70 | — | ~$60 | $6.00 | LOW — no public rate |
| FWDC — Weighted Average | 100% | Σ(stream × weight) | $36.86/ton | MED overall | ||
Derivation: ($32.94×0.45)+($33.82×0.35)+($42×0.10)+($60×0.10) = $14.82+$11.84+$4.20+$6.00 = $36.86/ton · Range $35–$42/ton · Full methodology in Appendix A and WIR s12
Miami-Dade pays $36.86/ton (weighted average) to permanently destroy all commercial value in its feedstock stream. Per-household annual fee: $547. Collections Fund structural deficit: $39M/yr. Disposal Fund revenue at risk >$50M/yr as landfills close. System net cost to county: increasing year-over-year.
Carbotura’s TMC Fee is structured to be competitive with or below the FWDC from Day 1. From month 13, Miami-Dade receives a Circular Royalty™ derived from manufactured materials revenue — converting the cost line to a revenue line. Per-household fee pressure is reduced, not increased.
SQ2Capacity & Infrastructure Crisis
Resources Recovery Facility (4,000 TPD / 1M tons/yr) permanently closed February 2023 — decommissioned September 2023. North Dade Landfill projected to reach capacity approximately 2026. South Dade Landfill approximately 2030. No confirmed replacement. Proposed WTE replacement: three candidate sites in FDEP preliminary review, no construction contract, community opposition at all three sites. Estimated WTE capital: $800M–$1.5B+ at public risk.
Carbotura ACM deployment at 500 TPD Phase 1 immediately diverts ~180,000 tons/year from North Dade Landfill — extending its operational life and deferring closure. Scalable to 2,000+ TPD in 100 TPD increments, replacing more than the RRF’s capacity at scale. Option A (in-county) or Option B (rail-delivered feedstock from Miami-Dade Transfer Stations to Central Florida ACM Facility via FEC/CSX). No combustion. No siting controversy. BOO model means zero county capital.
| Facility | Capacity | Status | Timeline |
|---|---|---|---|
| RRF (Covanta, Doral) | 4,000 TPD / 1M TPY | Permanently Closed | Fire Feb 2023 · Decommissioned Sept 2023 · Closure Plan FDEP Mar 2024 |
| North Dade Landfill | Primary overflow | Approaching Capacity | ~2026 projected HIGH |
| South Dade Landfill | Secondary disposal | Medium-Term Risk | ~2030 projected HIGH |
| WTE Replacement (proposed) | Up to 4,000 TPD | Preliminary Review | No site confirmed · No construction contract · 8–12+ yrs to operations |
| Carbotura ACM (proposed) | 500→6,000+ TPD | Stage 1 Engagement | BOO · Zero county capital · Scalable · No combustion siting required |
SQ3Liability Exposure
Conservative aggregate liability: $50M closure + $70M post-closure + $100M+ PFAS + $500M+ revenue loss (10yr) + $1B+ WTE capital + $195M+ Collections Fund deficit (5yr) = >$1.7B. PFAS unquantified. Five of six liability categories are off-balance-sheet or not separately disclosed.
BOO model eliminates WTE capital commitment (F). Feedstock diversion extends landfill life — deferring closure obligations (A, B). Exogenesis converts legacy landfill deposits into feedstock. PFAS destruction at 1,200°C+ reduces CERCLA exposure (D). Circular Royalty™ resolves Collections Fund deficit (Collections). Revenue Stack replaces lost landfill gate revenue (E).
SQ4Market & Operator Landscape
Primary residential operator: DSWM (340,000+ HH). Primary commercial haulers: WM (~30–40% commercial share) and Republic Services (~20–30%). Emergency overflow: WM (up to 1M TPY) and Waste Connections JED (300K TPY). No incumbent processor — RRF permanently closed. WTE replacement design in progress (AtkinsRealis). No long-term disposal contract in force. Contract window is open.
No incumbent combustion operator exists since February 2023. Emergency agreements are temporary. Design contract does not bind the county to construction. WM, Republic, and independent Chapter 15 haulers all transition to Feedstock Hauler roles under the Circular Advantage program — preserving their revenues with a new destination. Miami-Dade is in its widest contract flexibility window in 40 years.
SQ5Goals vs. Reality
| Stated Goal | Target | Current Status | Under WTE | Under ACM |
|---|---|---|---|---|
| 50% per-capita reduction | By 2030 | Tracking away — 2× national avg, no diversion infrastructure | No improvement — WTE is disposal, not diversion | Total Material Conversion: 42–45% material recovery + energy + water |
| Zero Waste County | 2022 goal · ZWMP 2026 | Planning only. No industrial platform | Incompatible — combustion is disposal, not Zero Waste | ACM is the industrial architecture that makes Zero Waste achievable |
| State recycling compliance (§403.706) | State goals | Degraded — RRF WTE credit stream severed Feb 2023 | Restored — WTE credit (1 MWh = 1 ton) | 42–45% material recovery + separate statutory determination required |
| Near-zero emissions processing | Climate Action 2021 | No progress pathway under combustion or landfill | Incompatible — combustion produces regulated stack emissions | Designed for near-zero — Atmospheric Protection System, no combustion, no stack |
| Replace RRF capacity | 1M TPY+ equivalent | Gap unfilled — emergency coverage only · 3 years unresolved | 8–12+ years to WTE operations · community opposition · $1B+ public capital | BOO deployment: 500 TPD Phase 1 · scalable to 6,000+ TPD · No public capital |
EIR1Cost Transformation
This section corrects SQ1. The cost of managing Miami-Dade’s manufacturing feedstock stream under the ACM model is structurally lower than the current system from Day 1 — and becomes a revenue line from month 13.
FWDC $36.86/ton weighted average. 100% net cost to Miami-Dade. No material value recovered. Landfill gate revenue (~$50M+/yr) disappears as both landfills close. Collections Fund deficit $39M/yr and growing. WTE capital commitment $800M–$1.5B+ pending.
ACM TMC Fee: competitive with or below $36.86/ton FWDC. No capital obligation. Circular Royalty™ begins month 13 — Revenue Stack at RC3 baseline: $185–$300M/yr per 400 TPD facility. At 1,000 TPD: ~$462–$750M/yr Revenue Stack to Carbotura; Circular Royalty™ to Miami-Dade proportional to volume and RevCon tier achieved.
| Cost / Revenue Item | Current System | ACM System (RC3) | Conf. |
|---|---|---|---|
| Per-ton disposal cost | ~$36.86/ton | TMC Fee ≤ $36.86/ton | MED |
| Annual disposal cost (4,800 TPD × 365) | ~$64.5M/yr | ≤$64.5M/yr (TMC Fee parity) | MED |
| Capital commitment (WTE replacement) | $800M–$1.5B+ | $0 — BOO model | HIGH |
| Circular Royalty™ (month 13+) | None | Begins month 13 — recurring | MED |
| Revenue Stack (per 400 TPD, RC3) | None | $185–$300M/yr | MED |
| Net cost position at 1,000 TPD (Year 2+) | Net cost — growing | Net revenue — Circular Royalty™ active | MED |
Miami-Dade’s feedstock management cost position inverts from Day 1. TMC Fee at cost parity from delivery start. Circular Royalty™ converts the cost line to a revenue line at month 13. $800M–$1.5B+ WTE capital obligation disappears. The cost transformation is permanent and compounds over 30 years.
EIR2Liability Elimination
This section corrects SQ3. Each of the six liability categories identified in SQ3 is directly addressed by ACM deployment — through elimination, deferral, or conversion.
| Liability (SQ3) | SQ3 Exposure | ACM Response | Net Liability Impact |
|---|---|---|---|
| A — Landfill Closure Capital | ~$50M initial | Feedstock diversion at 500+ TPD reduces North Dade landfill inflow by ~180,000 tons/yr. At 1,000 TPD: ~360,000 tons/yr diverted. NDL operational life extended 2–4+ years depending on diversion rate. | Deferred — $50M obligation deferred proportionally to diversion rate |
| B — Post-Closure Monitoring | $40–$100M est. | Exogenesis Protocol enables active mining of legacy landfill cells — converting legacy deposits to OmniCrude™ rather than waiting for post-closure monitoring obligations to accumulate. | Reduced — active Exogenesis converts liability to feedstock revenue |
| C — RRF Fire Settlement | Active / Unquantified | ACM deployment does not directly resolve the Covanta settlement — that is a separate legal process. However, ACM confirms Miami-Dade has secured replacement infrastructure, removing the county’s operational dependency on any Covanta partial restart. | Neutral on settlement; removes operational dependency |
| D — PFAS / CERCLA | >$100M est. | Carbotura’s system is designed for complete PFAS molecular breakdown at 1,200°C+. By routing PFAS-containing feedstock (biosolids, leachate, contaminated soils) through the ACM facility, Miami-Dade directly reduces the volume of PFAS material entering or remaining in its landfills. | Reduced — PFAS destruction pathway active from first delivery |
| E — Revenue Loss Post-Closure | >$50M/yr | Circular Royalty™ from month 13 replaces landfill gate revenue as the Disposal Fund’s primary revenue source. At scale, Circular Royalty™ exceeds landfill gate revenue in both quantum and durability (30-year term vs. ~4 years remaining landfill life). | Eliminated — Circular Royalty™ replaces and exceeds lost gate revenue |
| F — WTE Capital Commitment | $800M–$1.5B+ | Carbotura BOO model eliminates this liability entirely. No county capital required. Carbotura finances, builds, owns, and operates. Miami-Dade’s only obligation is feedstock supply under the COA. | Eliminated — $0 capital obligation |
Five of six major liability categories are eliminated or materially reduced by ACM deployment. The sixth (RRF fire settlement) is legally independent but operationally resolved. The aggregate $1.7B+ liability stack — the compound consequence of four decades of combustion and landfill dependency — is structurally transformed by a single 30-year Circular Offtake Agreement.
EIR3Capacity Solution
This section corrects SQ2. The ACM deployment provides a capacity solution that is faster, cheaper, lower-risk, and structurally superior to the proposed WTE replacement across every relevant dimension.
All ~4,800+ TPD feedstock currently routed to two landfills both approaching capacity. No non-landfill processing in place. WTE replacement: no confirmed site, no construction contract, 8–12+ years to operations, ~$1B+ public capital, community opposition. County is in acute capacity distress.
ACM Phase 1 at 500 TPD diverts ~180,000 TPY immediately — extending NDL life and reducing landfill concentration risk. No combustion: no air quality permitting battles, no community opposition to emissions. Modular design: 100 TPD increments mean each module is a replicated proven system, not a first-of-kind construction. BOO: county assumes no capital or construction risk at any phase.
Revenue ranges extrapolated from RC3 baseline $185–$300M per 400 TPD · MED · RC4–5 upside not shown · Not a guarantee of financial returns
EIR4Jobs & Economic Impact
EIR5Fiscal Impact
| Fiscal Item | Current Trajectory | With ACM (1,000 TPD) | Conf. |
|---|---|---|---|
| Collections Fund deficit | $39M/yr structural — requires Disposal Fund loan | Circular Royalty™ revenue available from Year 2 to support Collections Fund | HIGH current · MED ACM |
| Disposal Fund gate revenue | $50M+/yr — disappears as landfills close by 2030 | Circular Royalty™ replaces and exceeds gate revenue — 30-year term | HIGH current · MED ACM |
| Per-household fee ($547/yr) | Upward pressure — deficit, inflation, WTE debt service | Stable or declining — Circular Royalty™ offsets cost pressure | HIGH current · MED ACM |
| WTE capital debt service | $800M–$1.5B+ new obligation if WTE proceeds | $0 — BOO model, no county capital or debt | HIGH |
| GASB 60 balance sheet impact | WTE as county-owned = full capital on balance sheet | COA as service concession under GASB 60 = zero capital obligation on Miami-Dade balance sheet | MED — confirm with auditors |
| Net fiscal position (Year 2) | Deficit deepening — multiple converging pressures | Improving — Circular Royalty™ active, no WTE debt, deficit-reducing | MED |
EIR6Environmental Correction
Carbon-Negative by Design
Each 400 TPD module: −1,522 to −1,566 tons CO₂e/day. 30-year carbon impact: 17 million tons CO₂e per 400 TPD facility. At 1,000 TPD: 30-year carbon impact >42.5 million tons CO₂e. Carbon-negative by design — not by offset. HIGH
Near-Zero Emissions — No Combustion
The Recyclotron™ operates in an anoxic environment. The system is designed to operate without combustion or oxidation. No flame, no stack, no regulated combustion emissions. Atmospheric Protection System engineered for near-zero environmental impact. Direct contrast with proposed WTE replacement. HIGH — design spec
PFAS Molecular Destruction
Processing temperatures exceeding 1,200°C. Designed for complete PFAS molecular breakdown. Miami PFOS: 18.98 ppt (4.7× EPA limit). Miami ranked 3rd nationally PFAS groundwater. Direct environmental liability reduction pathway in a county facing active CERCLA exposure. HIGH — design spec
87,000+ Gallons Ultrapure Water/Day
Per 400 TPD module. At 1,000 TPD: 217,500+ gallons ultrapure water per day. In a county with documented PFAS contamination of drinking water and sea-level vulnerability threatening coastal aquifer integrity, on-site ultrapure water production has direct municipal value. HIGH — approved metric
Island Mode — Grid-Independent
857 MWh/day per 400 TPD — fully self-powered, ~5% reserve. In a county with documented hurricane grid vulnerability, a self-powered ACM facility provides infrastructure continuity value during grid disruption events. HIGH
97% Energy Efficiency vs. Virgin
583 kWh/ton (ACM) vs. 17,066 kWh/ton (virgin materials production). Processing efficiency advantage of 97% vs. conventional virgin materials manufacturing. This is the energy efficiency of recovering materials from feedstock vs. extracting them from the earth. HIGH
P0What We're Proposing
Carbotura proposes a 30-year Circular Offtake Agreement with Miami-Dade County under the Circular Advantage program. Carbotura will finance, build, own, and operate one or more Advanced Circular Manufacturing facilities — processing Miami-Dade’s manufacturing feedstock stream through Total Material Conversion and delivering the Circular Royalty™ back to the County from month 13. Miami-Dade assumes zero capital obligation at any point in the 30-year term.
Build, Own, Operate
Carbotura finances, builds, owns, and operates every modular factory for the full 30-year term. Miami-Dade is the feedstock supplier and Circular Royalty™ recipient — not the infrastructure owner.
30-Year Circular Offtake Agreement
The COA defines: feedstock delivery obligations, TMC Fee schedule (competitive with or below FWDC), Circular Royalty™ quantum and timing, scale-up schedule, and all commercial terms. This document is Stage 1 engagement — COA is Stage 3.
Two Architecture Options
Option A: In-county Industrial-Scale ACM Facility (500–6,000+ TPD) — full Pregenesis → Regenesis → Regenesis MAX on-site.
Option B: Miami-Dade Regional Transfer Stations (rail loading) → manufacturing feedstock via FEC/CSX → Central Florida ACM Facility (land optioned, full-stack). Both available. Both BOO.
Stage 1 of 7
This document is Stage 1 engagement. No financial commitment required from Miami-Dade at Stage 1. Stage 2: technical due diligence. Stage 3: Term Sheet. Stage 4: Regulatory classification. Stage 5: Construction. Stage 6: Commercial operations. Stage 7: Scale.
P1About Advanced Circular Manufacturing
| Protocol | Function | Key Process | Output |
|---|---|---|---|
| Pregenesis | Feedstock Preparation | Shredding, magnetic metals separation, Liquifact extraction. Direct feed to Regenesis is always the primary pathway. SMUs are buffer storage only — never standard output. | Prepared feedstock + separated metals + Liquifact |
| Regenesis | Feedstock Disintegration | Recyclotron™ Multiphase Microwave Reactor — Microwave Catalytic Reforming at 650°C+ in an anoxic environment. No combustion. No oxidation. Electromagnetic energy, not thermal combustion. | OmniCrude™ — molecularly disintegrated intermediate state |
| Regenesis MAX | Materials Refining | OmniCrude™ refined through: carbon activation at 1,800°C, graphitization at 3,000°C, hydrogen separation, metals purification, rare earth extraction, glass refinement, water purification. | Full RevCon product portfolio — RC1 through RC5 |
| Exogenesis | Urban & Landfill Mining | Deployed when feedstock source is a legacy deposit — closed landfill cells, coal ash ponds, mining tailings. Precursor to Pregenesis. Converts liability into feedstock. North & South Dade Landfills are primary Exogenesis candidates. | Extracted, conditioned feedstock for Pregenesis |
P2Three-Tier Build Plan
Carbotura proposes a three-phase deployment for Miami-Dade, scalable from 500 TPD Phase 1 to full-scale 2,000+ TPD in 100 TPD increments. Each phase is independently operational — scale is driven by feedstock volume agreements and infrastructure readiness, not by construction dependency.
Phase 1 — 500 TPD
Purpose: Validate operations. Demonstrate TMC. Establish Circular Royalty™ baseline.
Diverts: ~180,000 TPY from North Dade Landfill.
Employment: ~125 direct FTE + ~375 indirect.
Revenue Stack RC3: ~$230–$375M/yr.
Timeline: BOO construction from Stage 5 execution.
Phase 2 — 1,000 TPD
Purpose: Scale to commercial throughput. Second 500 TPD module commissioned.
Diverts: ~365,000 TPY — approaching North Dade full diversion.
Employment: ~250 direct FTE + ~750 indirect.
Revenue Stack RC3: ~$462–$750M/yr.
Activation: ~12–18 months after Phase 1 COD per COA schedule.
Phase 3 — 2,000+ TPD
Purpose: Full South Dade catchment plus commercial/C&D streams. Approaches RRF replacement capacity equivalency.
Diverts: ~730,000 TPY — significant landfill life extension for SDL.
Employment: ~500 direct FTE + ~1,500 indirect.
Revenue Stack RC3: ~$925M–$1.5B/yr.
Exogenesis: Active landfill mining commences for legacy cells.
P2bDeployment Site Zones
Five rail-connected industrial land zones have been identified across Miami-Dade, Broward, and Palm Beach counties. Zones 1 and 2 are in-county — feedstock arrives direct by road from the three DSWM Regional Transfer Stations with no logistics premium. Zones 3 through 5 are in adjacent counties and carry an additional feedstock logistics cost per ton, shown below. All five zones have existing or proximate FEC or CSX rail service.
Medley Industrial Corridor
Miami-Dade County · CSX rail direct · ~2 mi from NW Transfer Station
Miami-Dade’s primary heavy industrial zone. CSX runs directly through. ~1,200 acres industrial-zoned. Individual parcels 5–50+ acres; assemblage possible. WTE candidate site confirms large-facility siting precedent in this corridor.
In-county. Feedstock delivered direct by road from Transfer Stations.
FEC Hialeah Logistics Campus
Miami-Dade County · FEC mainline adjacent · Flagler Global Logistics site
200 acres adjacent to FEC Hialeah Yard currently under development by Flagler Global Logistics (FEC sister company). Confirms FEC rail connectivity and large-scale industrial development viability at this location. FEC also holds 80+ additional parcels (~600 acres total) along mainline available for development lease.
In-county. FEC rail available on-site.
Port Everglades / FEC Fort Lauderdale
Broward County · FEC near-dock terminal · ~32 mi from MDC Transfer Stations
FEC near-dock terminal at Port Everglades. Densely developed — parcels typically 1–10 acres. Best suited as a feedstock aggregation and transload point rather than a full-stack ACM facility. Broward County contributed 20 acres for a recent FEC logistics investment here.
Road transport MDC Transfer Stations to site (~32 mi). Short-haul truck rate basis.
Western Broward Industrial Corridor
Broward County · CSX mainline / I-75 · ~22 mi from MDC Transfer Stations
Miramar / Pembroke Park western corridor. CSX mainline runs adjacent to US-27. Larger parcels available (10–50 acres possible). Materially lower land cost than coastal Broward. Risk: rapid residential rezoning is reducing available industrial inventory year-over-year.
Road transport MDC Transfer Stations to site (~22 mi). Short-haul truck rate basis.
Riviera Beach / Port of Palm Beach
Palm Beach County · FEC exclusive rail rights · ~80 mi from MDC Transfer Stations
FEC holds exclusive rail rights to Port of Palm Beach and 6 miles of pier-side trackage. Western Riviera Beach industrial zones have available parcels at meaningfully lower land cost than Broward. Proximity also allows Broward County feedstock to be aggregated into the same supply chain, improving throughput economics at scale.
FEC rail from Hialeah Yard to Riviera Beach (~80 mi). Includes transload at Miami end. Lower per-ton cost than Central FL at 230 mi.
P3Financial Comparison
| Financial Parameter | WTE Replacement (if county-owned) | Carbotura ACM (BOO) |
|---|---|---|
| Capital commitment (county) | $800M–$1.5B+ · All at public risk | $0 · BOO model |
| Construction risk | County-borne · First new WTE in FL in years | Carbotura-borne · Modular construction — replicated proven 100 TPD modules |
| Operating cost (per ton) | Industry benchmark $45–$75/ton for WTE O&M | TMC Fee ≤ FWDC $36.86/ton · County pays, not builds |
| Revenue to county | None — WTE is a cost facility | Circular Royalty™ from month 13 · 30-year recurring |
| PFAS handling | Combustion at <1,000°C — insufficient for PFAS destruction · Ash to landfill | Processing at 1,200°C+ — designed for complete PFAS molecular breakdown |
| Community opposition risk | High — documented at all three candidate sites | Low — no combustion, no stack, no ash, no odour profile |
| Time to operations | 8–12+ years (site confirmation → permitting → construction) | BOO timeline from Stage 5 execution · North Dade capacity crisis addressed before closure |
| Climate compatibility | Incompatible with near-zero emissions goals | Carbon-negative by design · −1,566 CO₂e tons/day per 400 TPD |
| 30-year net position (1,000 TPD) | Net cost — $1B+ capital + O&M + no revenue | Net revenue — Circular Royalty™ active · Zero capital · 30-yr term |
P4Community Returns — 30-Year Analysis
| Community Benefit Category | 1,000 TPD — Conservative Low (RC3) | Per Resident/Year (Yrs 2–30) | Conf. |
|---|---|---|---|
| Circular Royalty™ (30-yr cumulative) | Derived from Revenue Stack RC3 · Quantum per COA negotiation | Subject to COA terms | MED |
| WTE capital avoided (30-yr) | ~$800M–$1.5B avoided · No debt service | ~$10–$19/resident/yr avoided capital obligation | LOW — uncommitted |
| Employment economic impact (30-yr) | $80M+/yr × 30 years = $2.4B+ cumulative | ~$28/resident/yr | MED |
| Landfill closure deferral (value) | ~$50M initial + $40–$100M post-closure deferred | ~$3–$4/resident/yr deferred cost | MED |
| Disposal revenue loss avoided (30-yr) | Circular Royalty™ replaces $50M+/yr gate revenue | ~$18/resident/yr replaced | MED |
| Carbon impact value | >42.5M tons CO₂e over 30 yrs at 1,000 TPD | Qualitative — no carbon price assumed | HIGH — metric |
| Conservative aggregate 30-yr community benefit | >$4.9B (conservative low, 1,000 TPD) | ~$58/resident/yr | MED |
Per-resident formula: $4.9B ÷ 2,720,000 ÷ 29 = ~$62/resident/yr. Conservative approach uses $4.9B floor, yielding ~$58–$62/resident/yr. All figures subject to forward-looking disclaimer above.
P4bPublic & Resident Impact
| Impact Area | Current System | With ACM (1,000 TPD) |
|---|---|---|
| Household fee ($547/yr) | Upward pressure — deficit unresolved, WTE debt service pending, landfill revenue declining | Stable or declining — Circular Royalty™ supplements DSWM operating revenue from Year 2 |
| PFAS in drinking water | PFOS 18.98 ppt (4.7× EPA limit) · Miami 3rd nationally · No resolution pathway under current system | ACM processes PFAS-containing feedstock at 1,200°C+ — designed for molecular breakdown. Direct reduction in PFAS entering groundwater via landfill leachate pathway. |
| Air quality near processing | Proposed WTE: combustion stack emissions, ash transport, odour profile from combustion facilities | No combustion. No stack. Enclosed, airlocked feedstock receiving bay. Atmospheric Protection System engineered for near-zero environmental impact. |
| Community employment | RRF: 75 employees at closure. WTE replacement: construction jobs only (temporary) | ~250 permanent direct FTE at 1,000 TPD + ~750 indirect/induced. Manufacturing roles, not construction temporaries. |
| Landfill impact on neighbourhoods | Both landfills operational until capacity; odour, truck traffic, leachate risk continue and compound | Feedstock diversion reduces landfill inflow — extending operational life, reducing odour events, reducing leachate risk proportional to diversion volume |
| Climate resilience | Two large unlined landfill cells adjacent to South Florida groundwater — compounding climate risk as sea level rises | Exogenesis enables systematic decommissioning of legacy landfill cells — converting climate liability to manufactured materials revenue |
P5Implementation Pathway — Stages 1–7
10-Year Indicative Financial Model
Indicative 10-year P&L for Miami-Dade County under a 1,000 TPD ACM deployment, RC3 conservative baseline. All figures illustrative. Subject to COA terms. Forward-looking disclaimer applies.
| Year | Activity | TMC Fee Paid | Circular Royalty™ Received | Net Position | Cumulative |
|---|---|---|---|---|---|
| Yr 0 | COA execution. Site assessment. Stage 3 complete. | $0 | $0 | $0 | $0 |
| Yr 1 | Construction & commissioning. Phase 1 (500 TPD) COD. First feedstock delivery. | TMC Fee begins at 500 TPD | — | Cost parity | — |
| Yr 2 | Phase 1 operations. Month 13: Circular Royalty™ commences. Phase 2 (1,000 TPD) construction begins. | TMC Fee (500 TPD rate) | Circular Royalty™ Phase 1 begins | First net revenue to county | Year 1 cost offset begins |
| Yr 3 | Phase 2 (1,000 TPD) commissioned. Circular Royalty™ doubles with scale. | TMC Fee (1,000 TPD rate) | Circular Royalty™ Phase 2 rate | Growing net revenue | Cumulative benefit building |
| Yr 4–5 | Stabilised 1,000 TPD operations. Revenue Stack diversifying across all 7 streams. | Stable TMC Fee | Stable Circular Royalty™ | Net positive — growing | $100M+ cumulative range |
| Yr 6–10 | Phase 3 evaluation (2,000 TPD potential). NDL life extended by diversion. Exogenesis initiated at legacy cells. | TMC Fee at contracted rate | Circular Royalty™ + Exogenesis feedstock value | Strongest net positive years | $500M–$1B+ range (conservative) |
| Yr 10 | 10-year milestone review. Phase 3 decision. SDL life assessment. | TMC Fee (contracted) | Circular Royalty™ (contracted) | Net positive — structural | >$500M conservative low |
Model uses RC3 conservative $185–$300M Revenue Stack per 400 TPD · Circular Royalty™ quantum: COA-negotiated · TMC Fee: at or below FWDC · MED confidence overall
Risk Allocation Matrix
| Risk Category | Carbotura Bears | Miami-Dade Bears | Notes |
|---|---|---|---|
| Capital Risk | 100% — BOO model, Carbotura finances all construction | $0 | No county bond issuance. No debt service. |
| Construction Risk | 100% — modular design mitigates single-point failure | $0 | Replicated 100 TPD proven modules, not greenfield custom construction. |
| Technology Risk | 100% — proprietary integration of proven technologies | $0 | First factory under construction, 2027 operations. ~$7B pipeline validated. |
| Operational Risk | 100% — BOO, Carbotura operates for 30-year term | $0 | County is feedstock supplier only. No operational obligation. |
| Market Risk (materials prices) | Carbotura bears Revenue Stack market variability | Circular Royalty™ structured to be insulated from single commodity market | 7-stream Revenue Stack decouples performance from any one market. |
| Feedstock Supply Risk | Carbotura dependent on COA feedstock delivery | Miami-Dade has contractual obligation to deliver feedstock per COA schedule | This is Miami-Dade’s primary obligation. Mitigated by: county holds feedstock flow control authority under §403.706 and Chapter 15. |
| Regulatory / Permitting Risk | Carbotura leads ACM classification and permitting | County pre-application engagement required at Stage 4 | ACM classification precedent established in other jurisdictions. Both parties engaged on this. |
| PFAS Liability Risk | ACM facility reduces PFAS liability through molecular destruction | County retains existing CERCLA exposure for pre-deployment legacy deposits | ACM deployment reduces forward accumulation. Exogenesis addresses legacy deposits. |
Regulatory Pathway
| Step | Authority | Action | Timing |
|---|---|---|---|
| 1 | FDEP Division of Waste Management | Pre-application meeting. Establish that ACM facility is a manufacturing facility under §403.703, not a solid waste management facility under §403.703(36). Manufacturing exclusion: RCRA 40 CFR 261.2(e) — materials used as ingredients in a manufacturing process are excluded from solid waste definition. | Stage 4 |
| 2 | Miami-Dade DERM | County-level environmental pre-application engagement. Confirm local permit pathway for manufacturing facility (not solid waste facility). Wellfield Protection Program compliance assessment for facility location. | Stage 4 |
| 3 | FDEP Air Quality | Atmospheric Protection System engineering review. Confirm near-zero emission profile. Anoxic operation (no combustion) means no Title V combustion permit required — a fundamentally different permitting pathway than the WTE replacement. | Stage 4–5 |
| 4 | Florida §403.706(4)(a) | Separate statutory determination for ACM material recovery credits. ACM achieves 42–45% material recovery — materially higher than any combustion equivalent. Requires FDEP determination of credit equivalency for manufactured materials recovery. | Stage 4 |
| 5 | Miami-Dade Chapter 15 | Feedstock Hauler transition authorisation. Existing Chapter 15 permitted haulers registered as Feedstock Haulers under COA. No new permit category required — transition by agreement within existing framework. | Stage 3–4 |
| 6 | DOT / FRA (Option B only) | Manufacturing feedstock rail transport classification. Feedstock transported under Option B is a pre-conversion raw material classified under applicable DOT/FRA industrial materials categories — not regulated solid waste transport. FEC / CSX corridor coordination. | Stage 4 |
GASB Accounting Analysis
| GASB Standard | Application | ACM Impact |
|---|---|---|
| GASB 60 — Service Concession Arrangements | The proposed 30-year Circular Offtake Agreement is a service concession arrangement: Carbotura provides the capital, operates the facility, and returns revenue (Circular Royalty™). Miami-Dade receives a service without owning the infrastructure. | No capital obligation appears on Miami-Dade’s balance sheet. The COA is an operating expenditure — not a lease, not a bond. Contrast with county-owned WTE: full $800M–$1.5B+ capital on balance sheet as infrastructure asset with corresponding debt. |
| GASB 18 — Closure & Post-Closure Care | Miami-Dade must recognise landfill closure and 30-year post-closure monitoring obligations as they are incurred over landfill operational life. | ACM feedstock diversion extends landfill operational life — deferring closure obligation recognition. Exogenesis enables systematic cell decommissioning with revenue offset. |
| GASB 49 — Pollution Remediation | PFAS liability at landfill sites must be recognised when a pollution remediation obligation is probable and the cost can be reasonably estimated. CERCLA designation (April 2024) increases probability of recognition trigger. | ACM deployment reduces the volume of PFAS-containing material entering landfills — reducing the probability and quantum of future pollution remediation recognition. PFAS destruction at 1,200°C+ reduces forward liability accumulation. |
| GASB 34/10 — Enterprise Fund | DSWM operates as an enterprise fund. Circular Royalty™ payments received from Carbotura would be recognised as operating revenue in the enterprise fund — improving operating surplus and reducing the Collections Fund structural deficit. | Circular Royalty™ as new recurring revenue line in the enterprise fund. Material improvement to operating surplus trajectory. |
ACM Glossary & Term Definitions
| Term | Expansion | Definition |
|---|---|---|
| ACM | Advanced Circular Manufacturing | The industry category Carbotura created and operates within. A manufacturing discipline — not waste management. Carbotura replaces the waste domain. |
| TMC | Total Material Conversion | The outcome all four Carbotura Protocols collectively achieve: designed to convert virtually all incoming manufacturing feedstock into saleable manufactured materials, recovered energy, and ultrapure water — with near-zero residual, near-zero emissions, and near-zero discharge. |
| OmniCrude™ | Molecularly disintegrated intermediate | What manufacturing feedstock becomes after Regenesis breaks it to its molecular level. The Carbotura equivalent of crude oil leaving the wellhead. OmniCrude™ is not feedstock — it is what feedstock becomes. |
| BOO | Build, Own, Operate | Carbotura’s financing model. Carbotura finances, builds, owns, and operates every modular factory. Miami-Dade bears zero capital obligation. |
| COA | Circular Offtake Agreement | The 30-year agreement governing the ACM partnership. Defines TMC Fee, Circular Royalty™, feedstock delivery obligations, scale schedule, and all commercial terms. |
| TMC Fee | Manufacturing service fee | The per-ton fee paid by Miami-Dade to Carbotura for feedstock conversion services. Replaces disposal fees, tipping fees, and gate fees. Structured to be competitive with or below the FWDC. |
| Circular Royalty™ | Conversion royalty | A recurring per-ton payment from Carbotura to Miami-Dade. Derived from manufactured materials revenue. Commences 13 months after first feedstock delivery. Never referred to as a rebate, discount, or revenue share — it is a conversion royalty. |
| FWDC | Facility-Weighted Disposal Cost | The weighted average all-in cost per ton of feedstock management across all active disposal streams. Miami-Dade FWDC: ~$36.86/ton (mid-point, Oct 2025 rate basis). The ACM TMC Fee benchmark. |
| RevCon 3 | RC3 — Optimized Circular Material | The conservative financial projection baseline. RC3 = $2,000–$10,000/ton manufactured materials value. All financial projections in this document use RC3. RC4–5 are upside scenarios not cited. |
| Revenue Stack | 7-stream revenue architecture | Up to seven independent revenue streams per modular factory: TMC Fee, strategic materials sales, Circular Royalty™, energy, water, carbon credits, and specialty offtake. |
| Island Mode | Grid-independent operation | The Carbotura factory generates 857 MWh/day at 400 TPD — sufficient to fully power itself with ~5% reserve. No grid dependency. |
| Exogenesis | Urban & Landfill Mining Protocol | Precursor to Pregenesis. Deployed when feedstock source is a legacy deposit requiring excavation — North Dade and South Dade Landfill legacy cells are primary Exogenesis candidates. |
| DSWM | Dept. of Solid Waste Management | Miami-Dade County’s primary feedstock management operator. Primary feedstock supplier counterparty for Carbotura under the COA. |
| FDEP | Florida Dept. of Environmental Protection | Primary state regulatory authority. Governs facility siting, permits, and ACM manufacturing classification in Florida. |
| DERM | Dept. of Regulatory & Economic Resources | Miami-Dade county-level environmental regulatory body. County environmental permitting and PFAS compliance oversight. |
Source Bibliography
| # | Source ID | Document / Publication | Date | Type |
|---|---|---|---|---|
| 1 | WIR-MDC-2025 | Miami-Dade County Waste Industry Intelligence Report 2025 — Carbotura EIR Series · v1.0 | March 2026 | Primary commissioned intelligence report — basis for all SQ sections |
| 2 | MDC-FEES-1025 | Miami-Dade DSWM Disposal Facility Fees Schedule (effective Oct 1, 2025) | Oct 2025 | Official county rate schedule — FWDC primary rate basis |
| 3 | MDC-FEE-MEMO-2024 | Miami-Dade DSWM Proposed Solid Waste Fee Memo — FY 2024–25 | 2024 | Official county document — Collections Fund deficit source |
| 4 | MDC-BCC-231209 | BCC Agenda Item 231209 — DSWM Collections Fund Deficit and Fee Proposal | Dec 2023 | Official BCC document — $39M deficit, landfill closure costs |
| 5 | MDC-BCC-2023-CAP | Miami-Dade BCC Executive Summary — DSWM Capacity Report and Landfill Closure Projections | 2023 | Official BCC document — NDL 2026, SDL 2030, $50M closure estimate |
| 6 | BCC-R1096-23 | BCC Resolution R-1096-23 — AtkinsRealis WTE Design Criteria Professional PSA | Nov 2023 | Official BCC resolution |
| 7 | BCC-SPEC-0923 | Miami-Dade BCC Special Meeting — WTE Site Selection and RRF Closure Vote | Sept 19, 2023 | Official BCC meeting record |
| 8 | FDEP-CLOSURE-2024 | FDEP RRF Closure Plan Submission and Title V Permit Withdrawal | Mar 2024 | Regulatory filing |
| 9 | WDIVE-0923 | WasteDive — Miami-Dade advances plans for new WTE facility; RRF closure vote | Sept 20, 2023 | Trade publication |
| 10 | EPA-PFAS-2024 | US EPA — Final PFAS Hazardous Substance Designation under CERCLA | Apr 2024 | Federal regulatory action |
| 11 | FIU-PFAS-2024 | FIU — “It’s raining PFAS in South Florida” — Atmospheric Pollution Research Vol.15, Dec 2024 | Dec 2024 | Peer-reviewed academic study |
| 12 | TAPWATER-2024 | TapWater.org Miami — PFAS data from MDC Water & Sewer Dept. 2024 Water Quality Report | 2024 | Public water quality database |
| 13 | MDC-ZWMP-2024 | Miami-Dade Zero Waste Master Plan — RFP, initiation, and public engagement page | 2024 | Official county program documentation |
| 14 | MDC-RES-FEE-2526 | Miami-Dade DSWM Residential Solid Waste Service Fees — FY 2025–26 | 2025 | Official county fee schedule — $547/HH |
| 15 | FSS-403706 | Florida Statute §403.706 — Local Government Solid Waste Responsibilities | Current | State statute — county obligations, WTE recycling credit mechanism |
| 16 | FSS-403703 | Florida Statute §403.703 — Solid Waste Definitions | Current | State statute — definitional framework, manufacturing exclusion pathway |
| 17 | FAC-62701 | FAC Rule 62-701 — Solid Waste Management Facilities | Current | State administrative code — Class I landfill, closure requirements |
| 18 | MDC-CH15 | Miami-Dade County Code Chapter 15 — Solid Waste Management | Current | County ordinance — hauler permit framework |
| 19 | RCRA-D | RCRA Subtitle D — 40 CFR 261 (solid waste definitions, manufacturing exclusion 261.2(e)) | Current | Federal regulation |
| 20 | NBCM-0824 | NBC Miami — Miami-Dade proposed WTE plant renderings and community opposition | Aug 2024 | Local news — community opposition documentation |
| 21 | CAV-37 | Carbotura Authoritative Voice v3.7 — Governing terminology, BOO model, Circular Advantage program specifications | Feb 2026 | Carbotura proprietary — governing document |
| 22 | CAV-METRICS | Carbotura Approved Performance Metrics — 400 TPD baseline: carbon, energy, water, FTE, economic impact, RC3 revenue range | 2026 | Carbotura proprietary — approved performance reference |
| 23 | WDIVE-MS-2023 | WasteDive — US waste & recycling industry market share analysis | May 2023 | Trade publication |