Miami-Dade County
ACM Deployment Briefing
A dual-architecture Advanced Circular Manufacturing proposal for Miami-Dade County, Florida. Scalable from 500 to 6,000 TPD. Two deployment pathways: an in-county Industrial-Scale ACM Facility and a rail-connected Central Florida ACM Facility receiving manufacturing feedstock from Miami-Dade’s Regional Transfer Station network. Everything to Everything.
This document has been prepared by Carbotura Inc. for informational and engagement purposes only. All figures marked PRELIMINARY or with confidence indicators are subject to revision upon site assessment, regulatory review, and independent verification. This document does not constitute a binding offer, executed agreement, or guarantee of specific outcomes. All financial projections are based on RevCon 3 baseline assumptions. Carbotura makes no guarantee of specific financial returns. Stage 1 of 7 — Pre-engagement intelligence only.
Why Miami-Dade. Why Now. Why ACM.
- A 1-million-ton-per-year disposal gap. Miami-Dade’s Resources Recovery Facility — which processed up to 4,000 TPD — was destroyed by fire in February 2023 and has been permanently closed. The County faces a structural feedstock capacity deficit requiring a durable, scalable solution. A proposed replacement facility remains in regulatory review with no confirmed timeline or site.
- Two landfills approaching end of life. North Dade Landfill is projected to reach capacity by 2026. South Dade Landfill is projected to reach capacity by 2030. The county estimates initial closure costs of $50 million across both sites and revenue losses exceeding $50 million annually once they close.
- $547/household annual cost and a $39M structural deficit. Miami-Dade residents pay $547 per household per year for collection services. The Department of Solid Waste Management faced a $39 million revenue shortfall in FY 2024–25 — structural, not cyclical. Disposal fees are $16.28–$16.91 per ton plus transfer fees of up to $16.91/ton additional.
- Miami-Dade generates feedstock at roughly twice the national per-capita average. The county’s combined residential and commercial manufacturing feedstock stream is estimated at 4,800–5,200 TPD. This is a structural advantage for Carbotura’s revenue model — larger feedstock volume drives higher Revenue Stack performance at every scale tier.
- Carbotura proposes two deployment architectures. Option A: an Industrial-Scale ACM Facility sited within Miami-Dade County at 500–2,000 TPD, scalable to 6,000 TPD in 100 TPD increments. Option B: Miami-Dade’s existing Regional Transfer Stations serve as feedstock aggregation and rail-loading points. Manufacturing feedstock is transported via Florida East Coast Railway or CSX to Carbotura’s Central Florida ACM Facility (land optioned), where the full Pregenesis → Regenesis → Regenesis MAX sequence is executed at industrial scale. Both architectures are structured under a 30-year Circular Offtake Agreement.
- The Circular Advantage program eliminates capital risk for Miami-Dade. Carbotura finances, builds, owns, and operates every modular factory under a Build, Own, Operate (BOO) model. The County assumes zero capital obligation. The TMC Fee is competitive with or below current disposal costs. The Circular Royalty™ commences at month 13.
- RC3 baseline revenue: $185–$300M per 400 TPD facility. At the proposed 500–2,000 TPD range, the Revenue Stack across up to seven independent streams produces material value for Miami-Dade over the 30-year agreement term. MED
- Carbon impact: designed as carbon-negative. Each 400 TPD Carbotura modular factory is designed for a carbon impact of −1,522 to −1,566 tons CO₂e per day — carbon-negative by design, operating without combustion, without landfill gas, and without stack emissions.
HIGH Public record, official county documents · MED Derived from partial public data, subject to site-specific verification · LOW Estimated, requires independent confirmation
Miami-Dade County faces a structurally irreversible disposal capacity crisis: a permanently closed 1-million-ton-per-year incineration facility, two landfills approaching end of life within four years of each other, rising per-household costs, and a $39 million annual deficit. The proposed replacement is still in regulatory review. Carbotura’s ACM deployment offers an alternative that does not require public capital, does not replicate the technology that failed, and generates a Revenue Stack rather than a cost line. This briefing presents both the intelligence basis for that decision and the two deployment architectures available to Miami-Dade.
Table of Contents
Document Sections
Key Terms & Acronyms
| Term | Expansion | Plain-Language 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 state | What manufacturing feedstock becomes after Regenesis breaks it to its molecular level — an elementally rich intermediate containing carbon, hydrogen, metals, rare earth elements, and other constituents. The Carbotura equivalent of crude oil leaving the wellhead. |
| Pregenesis | Feedstock Preparation Protocol | Shredding, magnetic metals separation, and Liquifact extraction. Direct feed to Regenesis is always the primary pathway. SMUs are buffer storage only. |
| Regenesis | Feedstock Disintegration Protocol | The Recyclotron™ Multiphase Microwave Reactor uses Microwave Catalytic Reforming at 650°C+ in an anoxic environment. No combustion. No oxidation. Output is OmniCrude™. |
| Regenesis MAX | Materials Refining Protocol | OmniCrude™ is refined into finished manufactured materials through carbon activation at 1,800°C, graphitization at 3,000°C, hydrogen separation, metals purification, rare earth extraction, and water purification. |
| Exogenesis | Urban & Landfill Mining Protocol | Precursor to Pregenesis. Deployed when feedstock source is a legacy deposit requiring excavation — closed landfills, coal ash ponds, mining tailings. Distinction is source, not material type. |
| Central Florida ACM Facility | Central Regenesis MAX Facility | Carbotura’s Central Florida full-stack ACM Facility (land optioned). Receives manufacturing feedstock delivered by rail from Miami-Dade’s Regional Transfer Stations and other Florida supply points. Executes the complete Pregenesis → Regenesis → Regenesis MAX sequence at industrial scale, producing the full RevCon product portfolio. |
| BOO | Build, Own, Operate | Carbotura’s financing model. Carbotura finances, builds, owns, and operates every modular factory. Miami-Dade assumes zero capital obligation. The County is a feedstock supplier, not an infrastructure owner. |
| 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. Calibrated to be competitive with or below current disposal costs. |
| Circular Royalty™ | Conversion royalty | A recurring per-ton payment from Carbotura back to Miami-Dade. Derived from manufactured materials revenue. Commences at 13 months after first feedstock delivery. This is revenue to the County, not a cost. |
| Revenue Stack | Seven-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. Decouples performance from any single commodity market. |
| RevCon 3 | Optimized Circular Material baseline | The conservative financial projection baseline. RC3 = $2,000–$10,000/ton. All financial projections in this briefing use RC3. RC4–5 are upside scenarios only. |
| COA | Circular Offtake Agreement | The 30-year agreement governing the ACM partnership. Replaces waste hauling contracts and disposal agreements. |
| Island Mode | Grid-independent operation | The Carbotura modular factory generates 857 MWh/day at 400 TPD — sufficient to fully power itself with approximately 5% reserve. No grid dependency. |
| Feedstock Haulers | ACM logistics providers | Logistics providers who transport manufacturing feedstock to the modular factory. Legacy collection operators transition into Feedstock Hauler roles within the Circular Advantage program. |
| Feedstock Haulers (Rail) | Rail logistics providers | Licensed Feedstock Haulers contracted to transport manufacturing feedstock by rail from Miami-Dade’s Regional Transfer Stations to Carbotura’s Central Florida ACM Facility under the Circular Advantage program. |
| DSWM | Dept. of Solid Waste Management | Miami-Dade County’s primary operator of collection, transfer, and disposal infrastructure. The primary feedstock supplier counterparty for Carbotura. |
| FDEP | Florida Dept. of Environmental Protection | Primary state regulatory authority governing ACM facility siting, permitting, and operational standards in Florida. |
| DERM | Dept. of Regulatory & Economic Resources | Miami-Dade’s local environmental regulatory body. Governs county-level environmental permitting and compliance. |
Every term in this table is a defined term under Carbotura’s Authoritative Voice framework. Where prior county documents, RFPs, or public records use legacy terminology (“waste,” “disposal,” “tipping fees,” “waste-to-energy”), this briefing uses the correct ACM equivalent. Carbotura may acknowledge what the County currently classifies as waste by stating “material currently managed under legacy disposal procurement” when referencing existing operations.
Disclaimer
| Provision | Terms |
|---|---|
| Document Purpose | This briefing has been prepared by Carbotura Inc. for Stage 1 engagement purposes only. It is designed to present an initial intelligence assessment and partnership architecture proposal. It does not constitute a legally binding offer, executed agreement, memorandum of understanding, or commitment to deploy. |
| Data Confidence | All data is sourced from public records and official county publications unless otherwise noted. Confidence badges (HIGH / MED / LOW) appear inline with each material claim. HIGH = public record. MED = derived estimate. LOW = preliminary projection requiring site verification. |
| Financial Projections | All financial projections use RevCon 3 as the conservative baseline tier ($2,000–$10,000/ton). RC4–5 are upside scenarios only and are not presented as primary projections. Revenue ranges reflect feedstock composition variability and local market conditions. Projections are subject to independent verification, final site assessment, and applicable regulatory frameworks. |
| Technology Claims | Carbotura’s modular factory system is a proprietary integration of established, commercially proven technologies. The innovation is in sequencing, control, and optimization — not novel science. Process design statements (anoxic operation, no combustion, temperatures exceeding 1,200°C for PFAS breakdown) are factual design specifications. Outcome statements use “designed for,” “near-zero,” and “engineered to” until independent third-party verification at commercial scale is complete. |
| Regulatory Classification | 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 and regulatory engagement will be conducted on this basis. Nothing in this document should be construed as an admission that Carbotura’s operations constitute “waste management” under any applicable statute, rule, or regulation. |
| IP Protection | This document does not disclose protected Carbotura intellectual property. Specific catalyst compositions, proprietary process sequencing, microwave frequency and power specifications, engineering tolerances, reactor design parameters, software control algorithms, and supplier identities are protected under Carbotura’s trade secret framework. Independent technical due diligence is welcomed under appropriate NDA. |
| Document Version | Version 1.0 — March 2026. This document supersedes no prior agreements. Subject to revision. Next scheduled review: September 2026. |
| Corrections | Factual corrections and data updates: media@carbotura.com |
Carbotura Inc. — Advanced Circular Manufacturing — March 2026
Current Material Flow Infrastructure
Miami-Dade County operates the largest integrated municipal feedstock management system in Florida — and one of the most structurally stressed in the United States. The February 2023 destruction of the Resources Recovery Facility has exposed a 1-million-ton-per-year gap that no single replacement solution has yet addressed. What follows is an intelligence-grade map of the current system: its operators, financial architecture, regulatory obligations, and accruing liabilities.
Operator Landscape
Miami-Dade DSWM
Primary county operator. Serves 340,000+ households in unincorporated Miami-Dade and 10 municipalities. Owns and operates 2 active landfills (North Dade, South Dade), 3 Regional Transfer Stations, 13 Trash & Recycling Centers, and 2 Home Chemical Collection Centers. Operates dedicated collection fleet. HIGH
County OperatorCovanta (Reworld) — Doral RRF
Operated the Resources Recovery Facility under contract since 1985. Facility destroyed by fire February 2023. Permanently closed by BCC vote September 2023. Closure Plan submitted to FDEP March 2024. Title V Air Permit withdrawn. ~75 standby employees fully demobilized. HIGH
Former Operator — ClosedWaste Management (WM)
Major private hauler operating in Miami-Dade. Secured a letter agreement with the county post-RRF fire for up to 1 million tons of additional disposal capacity, subject to contract renegotiation. National market share ~34% by revenue. Key commercial and municipal collection provider. HIGH
Private Hauler / DisposalWaste Connections — JED Landfill
County negotiated additional 300,000 tons of disposal capacity at JED Landfill post-RRF closure, subject to renegotiation by March 2024. Provides emergency overflow capacity buffer as county landfills approach capacity. HIGH
Overflow DisposalRepublic Services
Second-largest national hauler by revenue (~25% national share). Active in South Florida commercial and municipal markets. Provides licensed collection and hauling services within Miami-Dade under Chapter 15 permit framework. MED
Private HaulerAtkinsRealis USA (Design)
Contracted November 2023 (R-1096-23) as Design Criteria Professional and Owner’s Representative for Miami-Dade’s proposed new waste-to-energy replacement facility. Conceptual design capacity: up to 4,000 TPD. Three candidate sites under FDEP preliminary permit review: Opa-Locka West Airport (first choice), Medley, former Doral RRF site. HIGH
WTE Replacement DesignThe county’s current operator landscape is fragmented, emergency-patched, and dependent on private haulers and competitor landfill capacity for overflow management. The proposed WTE replacement is in preliminary permitting — not construction. The existing system has no single operator capable of delivering the integrated capacity, revenue diversification, or regulatory classification advantage that an ACM deployment provides.
Financial Architecture
| Revenue / Cost Stream | Rate / Value | Confidence | Notes |
|---|---|---|---|
| Household collection fee (full-service) | $547/yr | HIGH | FY 2024–25. Non-ad valorem assessment on property tax bill. No increase from FY 2023–24 — $39M loan from Disposal Fund required to maintain service level. |
| Landfill disposal fee — contract rate | $16.28/ton | HIGH | Effective Oct 1, 2025. For permitted haulers and municipalities under long-term contract. |
| Landfill disposal fee — non-contract rate | $16.91/ton | HIGH | Non-contracted parties. Combined with transfer fee, all-in cost reaches ~$33–$34/ton. |
| Transfer station fee (added to disposal fee) | $16.66–$16.91/ton | HIGH | Oct 2025 schedule. Contract and non-contract rates respectively. Doubles effective per-ton cost for material moving via transfer stations. |
| DSWM structural deficit — Collections Fund | $39M | HIGH | FY 2024–25. Covered by internal loan from Disposal Fund. Driven by: post-RRF capacity costs, inflation (8.6% in 2022; 6.9% projected 2023), recycling processing fees on 60,000 tons, COVID-era tonnage shift from commercial to residential. |
| Landfill closure cost estimate (both facilities) | ~$50M | HIGH | Initial closure cost, $25M per landfill. Does not include post-closure monitoring, leachate management, or PFAS remediation obligations. |
| Annual landfill revenue at risk post-closure | >$50M/yr | HIGH | County projection. North Dade alone: $17M+/yr. Revenue loss begins as landfills reach capacity and close. |
| Special handling fee (per load) | $87.85/load | HIGH | Added to per-ton disposal fee. Oct 2025 schedule. |
| Estimated all-in disposal cost (transfer + gate) | ~$33–$40/ton | MED | Derived: landfill gate fee + transfer station fee. Excludes special handling, transport, and overhead allocation. This is the benchmark TMC Fee is calibrated against. |
Miami-Dade’s current cost structure is a triple squeeze: rising per-ton disposal costs, a $39M structural deficit in the collection fund, and the impending loss of $50M+ in landfill revenues as both facilities close. The county’s financial model has no path to equilibrium under the current architecture. An ACM partnership converts this liability stack into a Revenue Stack.
Regulatory Framework
| Authority | Jurisdiction | Relevance to ACM Deployment |
|---|---|---|
| Florida DEP (FDEP) | State — primary | Governs solid waste facility permitting, Title V air permits, landfill closure plans, and siting approvals. Currently reviewing three candidate WTE replacement sites. ACM facility classification as a manufacturing facility — not a solid waste facility — is the central regulatory positioning objective. FDEP withdrew the RRF Title V Air Permit upon county notification of closure intent. |
| Miami-Dade DERM | County — environmental | Dept. of Regulatory & Economic Resources. Issues county environmental permits, oversees local air and water quality compliance, and administers the Wellfield Protection Program — directly relevant given PFAS leachate risk at both county landfills adjacent to sensitive groundwater zones. |
| US EPA — Region 4 | Federal | Oversees CERCLA/Superfund obligations, PFAS designation enforcement, Clean Air Act compliance, and National Pollutant Discharge Elimination System (NPDES) permits. Region 4 covers Florida. PFAS designated as hazardous substances under CERCLA (April 2024) — creates retroactive liability exposure for landfill operators handling material with PFAS content. |
| Miami-Dade Chapter 15 | County code | Governs all private hauler permits, landscaper permits, tire generator permits, and hauler licensing. Defines the current waste collection and transport regulatory regime. ACM Feedstock Haulers operate within Chapter 15’s hauler licensing structure under a transitional classification framework. |
| Florida Statute 403 | State | Florida Environmental Reorganization Act. Primary environmental permitting framework governing solid waste, air, and water permits in Florida. ACM facility classification negotiations operate within this statute’s definitional boundaries. |
| FEC Railway / CSX | Federal — DOT / FRA | Option B rail corridor. OmniCrude™ transport via Florida East Coast Railway (Miami to Central Florida) or CSX. Rail transport of manufactured intermediate products is subject to DOT/FRA classification — distinct from solid waste transport regulation. OmniCrude™ is a manufactured intermediate, not a solid waste, and must be classified accordingly for rail manifest purposes. |
Miami-Dade’s regulatory environment is currently in a state of active transition — the RRF closure plan is with FDEP, three WTE replacement sites are in preliminary permit review, and PFAS liability is crystallising under new federal designation. This transition window is precisely the right moment for ACM classification to be established: before legacy frameworks solidify around a replacement facility, and before landfill PFAS liability compounds further.
Liability Exposure
The aggregate undisclosed liability exposure facing Miami-Dade’s solid waste system — PFAS, landfill closure, RRF settlement, deficit carry, and WTE capital — likely exceeds $1.5 billion over the next decade. The ACM deployment under Carbotura’s BOO model transfers the capital risk for replacement infrastructure entirely to Carbotura, converts the feedstock liability into a Revenue Stack, and creates a pathway to Exogenesis-based landfill mining of the existing legacy deposits.
ACM Intelligence Analysis
This section applies an Advanced Circular Manufacturing intelligence lens to Miami-Dade’s current system — identifying the structural conditions, contract vulnerabilities, financial flow architecture, and forward-looking risk vectors that make this county an exceptional ACM deployment opportunity.
Market Structure
Miami-Dade’s feedstock management market exhibits three structural characteristics that are directly favorable to an ACM transition: concentrated operator dependency, a permanent capacity gap, and an irreplaceable legacy technology that has been decommissioned without a confirmed successor.
Capacity Gap — Structural
The RRF processed up to 4,000 TPD (approximately 1 million tons per year). No replacement has been constructed, contracted, or financed. The gap has been patched with emergency landfill capacity from Waste Management and Waste Connections — a temporary bridge, not a solution. Every additional year without a replacement accelerates landfill capacity depletion.
Failed Technology Paradigm
The proposed replacement is another combustion-based facility — the same fundamental technology that destroyed itself in February 2023. Community opposition to the proposed WTE replacement has been documented in Doral, Medley, and around the Opa-Locka site. A resident and advocate coalition (Florida Rising) has publicly opposed combustion replacement. The ACM paradigm does not combust; it does not emit stack gases; and it does not require a comparable footprint.
Duopoly Hauler Dependency
Waste Management and Republic Services collectively account for approximately 59% of US landfill market share by volume. In Miami-Dade, both hold significant contract positions. The county is structurally dependent on two national operators for overflow disposal — neither of whom is incentivised to advocate for a technology that eliminates the landfill tipping revenue model.
Feedstock Volume Advantage
Miami-Dade generates manufacturing feedstock at approximately twice the US national per-capita average, as acknowledged in public advocacy. With ~2.72 million residents and substantial commercial density, the available feedstock stream is estimated at 4,800–5,200 TPD — making this one of the largest ACM deployment opportunities in the continental United States. MED
Zero Waste Master Plan — In Progress
Miami-Dade initiated a Zero Waste Master Plan in 2024, with completion expected by 2026. The plan explicitly acknowledges that the county needs to identify alternatives to combustion and landfill. The ACM framework is the only commercially structured industrial architecture that satisfies the Zero Waste strategic intent while operating at the scale Miami-Dade requires.
Climate Vulnerability — Sea Level
Miami-Dade is among the most climate-vulnerable large counties in the US. Both landfills — North Dade and South Dade — are in proximity to sensitive coastal and groundwater zones. As sea level rises and hurricane intensity increases, the county’s liability exposure at unlined or partially lined landfill cells will compound. Legacy landfill remediation is a structural certainty; the question is when, not if. MED
Miami-Dade presents an ACM deployment scenario with four compounding structural advantages: a permanent capacity gap with no confirmed solution, a failed combustion technology paradigm creating community and political openness to alternatives, one of the largest per-capita feedstock streams in the US, and an active Zero Waste planning process that lacks any industrial partner capable of delivering at scale. The ACM deployment timing is not speculative — it is aligned with the county’s own transition window.
Contract Architecture
| Contract / Agreement | Status | Structure & ACM Relevance |
|---|---|---|
| Covanta RRF — Original Contract | CLOSED | 30+ year operational agreement, now terminated. Closure negotiations ongoing with Sedgwick (insurance adjuster) and Covanta regarding fire claims. County no longer bound by any long-term combustion facility contract — this is the clean break that opens the ACM window. |
| WM — Emergency Capacity Agreement | RENEGOTIATING | Letter agreement for up to 1 million tons additional landfill capacity. Subject to formal contract renegotiation. No long-term lock-in reported. This is a bridge arrangement, not a strategic solution. Subject to renegotiation timelines that have now passed their stated deadlines. |
| Waste Connections — JED Capacity | RENEGOTIATING | Additional 300,000 tons at JED Landfill. Subject to renegotiation by March 2024. Status of renewed terms not publicly confirmed. Provides northern county overflow but does not address South Dade capacity. |
| AtkinsRealis — WTE Design PSA | ACTIVE | Professional Services Agreement for Design Criteria Professional and Owner’s Representative (R-1096-23, Nov 2023). Design work underway. No construction contract executed. Three sites in FDEP preliminary review — no confirmed site. This contract does not obligate the county to build; it obligates design and planning services only. |
| Municipal Service Inter-Locals | ACTIVE | Collection service inter-local agreements with El Portal, Florida City, Medley, Miami Beach, Miami Springs, North Bay Village, South Miami, Virginia Gardens, and West Miami for recycling. These inter-locals can be transitioned into feedstock supply agreements under the Circular Advantage program. Each municipality becomes a feedstock supplier, not a collection service recipient. |
| Circular Offtake Agreement (Proposed) | PROPOSED | Carbotura’s 30-year Circular Offtake Agreement would replace all emergency capacity agreements and landfill disposal contracts. TMC Fee replaces per-ton disposal fees. Circular Royalty™ begins month 13. BOO model means no capital obligation for Miami-Dade at any point in the 30-year term. |
The county has no binding long-term disposal infrastructure commitment currently in place. The emergency agreements are temporary. The design contract is not a build contract. Miami-Dade is in a position to execute the Circular Offtake Agreement as its primary infrastructure decision without conflicting with any existing contractual obligation of material consequence.
Financial Flows — Current System vs. ACM Model
$547/household/year collected via non-ad valorem assessment. Funds DSWM collections operations. Per-ton disposal fees ($16.28–$16.91 gate + $16.66–$16.91 transfer = ~$33–$34/ton all-in) paid to county landfills. County retains gate revenue until landfills close. No revenue from material value recovery. No Circular Royalty equivalent. System generates cost — not value. Structural deficit of $39M absorbs internal loan from Disposal Fund. Future capital commitment: ~$1B+ for WTE replacement, all county-borne.
TMC Fee paid by Miami-Dade to Carbotura — competitive with or below current per-ton disposal cost. No capital commitment from the county. Stream 1: TMC Fee revenue to Carbotura. Stream 2–7: Manufactured materials, energy, water, carbon credits — Carbotura revenue. Circular Royalty™: Begins month 13 — recurring revenue back to Miami-Dade derived from RevCon product sales. Over a 30-year COA, the Circular Royalty becomes the county’s primary financial return. At scale (2,000 TPD), Revenue Stack at RC3 baseline: $185–$300M per 400 TPD increment. County’s capital obligation: $0.
The current system extracts $547/household/year from residents, generates a structural deficit, and is heading toward a $1B+ capital commitment that the county would bear alone. The ACM system replaces that architecture with a zero-capital, Revenue Stack model where the county’s financial relationship with its feedstock stream shifts from net cost to net revenue within 13 months of first delivery.
Risk & Liability — Forward-Looking
| Risk Vector | Horizon | Severity | ACM Mitigation Pathway |
|---|---|---|---|
| North Dade Landfill — Capacity | 2026 | Critical | ACM deployment at 500+ TPD immediately diverts feedstock volume from North Dade, extending operational life and deferring closure costs. At 1,000+ TPD, closure can be deferred by multiple years while remediation planning begins. |
| South Dade Landfill — Capacity | 2030 | Critical | Same diversion model applies. Exogenesis Protocol can be deployed to begin systematic mining of legacy deposits, converting them to OmniCrude™ and extending landfill operational life through selective cell decommissioning. |
| PFAS — Drinking Water / Groundwater | Active | Critical | Carbotura’s system is designed for complete PFAS molecular breakdown at 1,200°C+ processing temperatures — above the threshold required for PFOS/PFOA destruction. By accepting PFAS-contaminated feedstock (leachate, biosolids, contaminated soils), the ACM facility directly reduces the county’s PFAS liability pathway. |
| WTE Replacement — Community Opposition | 2025–26 | High | ACM is not combustion. The Recyclotron™ operates in an anoxic environment without flame, oxidation, or stack emissions. Community opposition to a combustion replacement does not apply to an ACM facility. This is a differentiated positioning advantage, not a technical claim. |
| Climate / Sea Level — Landfill Exposure | 2030+ | High | Accelerating landfill closure and transitioning to ACM reduces the county’s long-term exposure to climate-driven contamination events at landfill sites. An ACM facility’s 10-acre footprint and enclosed operation profile presents substantially lower climate vulnerability than an unlined landfill cell adjacent to coastal groundwater. |
| WTE Capital Commitment Risk | 2026+ | High | If the county commits to a ~$1B WTE replacement, it absorbs all capital risk, operating risk, and regulatory risk for a combustion-based facility. ACM under BOO eliminates this commitment entirely. The ACM decision must precede any WTE construction contract to capture this benefit. |
| Federal PFAS CERCLA Enforcement | 2026+ | High | With PFAS designated as hazardous substances under CERCLA (April 2024), retroactive liability for landfill operators handling PFAS-contaminated material is now an active federal enforcement risk. ACM deployment reduces the volume of PFAS-containing feedstock entering landfills, directly reducing the county’s CERCLA exposure surface. |
Every major risk vector Miami-Dade faces over the next decade — landfill capacity, PFAS liability, WTE capital commitment, community opposition, climate vulnerability — is either eliminated or materially reduced by an ACM deployment. The question is not whether Miami-Dade should transition. The question is whether it does so in front of these risks or after they have compounded. The ACM window is now.
Dual Deployment Architecture
Carbotura proposes two deployment architectures for Miami-Dade County. They are not mutually exclusive — Option A may be deployed independently, Option B may be deployed independently, or both may be deployed in sequence as part of a phased expansion. Both operate under the same Circular Advantage commercial framework and the same 30-year Circular Offtake Agreement structure.
Option A — In-County Industrial-Scale ACM Facility
In-County Industrial-Scale ACM Facility
A fully integrated Carbotura modular factory sited within Miami-Dade County. The facility executes the complete ACM sequence — Pregenesis through Regenesis MAX — on a single 10-acre footprint per 400 TPD module. All OmniCrude™ conversion and Regenesis MAX refining occurs on-county. Manufactured materials are shipped to offtake buyers directly from the facility. No rail transport of OmniCrude™ required.
| Parameter | Value | Notes |
|---|---|---|
| Architecture type | Industrial-Scale Regenesis Facility | Full Regenesis + Regenesis MAX in single installation per module |
| Initial deployment scale | 500 TPD | Scalable to 1,000 → 2,000 → 6,000 TPD in 100 TPD increments |
| Facility footprint (per 400 TPD) | 10 acres | Modular — additional modules add footprint proportionally |
| Preferred siting criteria | Industrial-zoned, rail/road access, enclosed bay capacity | Medley industrial corridor, Opa-Locka Industrial District, Hialeah industrial zones — preliminary candidates |
| Feedstock input | MSW, commercial, tires, biosolids, coal ash (if applicable) | Feedstock Haulers deliver to enclosed, airlocked receiving bay |
| OmniCrude™ transport | None — processed on site | Distinction from Option B: no rail logistics layer and no external ACM facility dependency |
| Energy mode | Island Mode (grid-independent) | 857 MWh/day at 400 TPD; ~5% reserve buffer |
| Water recovery | 87,000+ gallons/day ultrapure | Per 400 TPD baseline |
| Carbon impact | −1,522 to −1,566 CO₂e/day | Per 400 TPD baseline; carbon-negative by design |
| Direct employment | 100 FTE per 400 TPD | Plus ~300 indirect/induced per facility |
| Capital obligation — Miami-Dade | $0 | BOO model — Carbotura finances, builds, owns, operates |
Option A is the most straightforward path from the current feedstock crisis to an operational ACM system. A single 500 TPD module addresses approximately 10% of Miami-Dade’s feedstock stream immediately and creates a scalable platform. It can be operational within the Carbotura BOO construction timeline, requires no intergovernmental rail coordination, and delivers maximum local employment and economic impact.
Option B — Rail-Delivered Feedstock to Central Florida ACM Facility
Miami-Dade Regional Transfer Stations (Rail Loading) + Central Florida ACM Facility
Under Option B, Miami-Dade’s three existing Regional Transfer Stations — which already aggregate, compact, and load the county’s full feedstock stream — serve as the rail-loading infrastructure for a Carbotura-operated rail-delivery architecture. Manufacturing feedstock is loaded at the Transfer Stations and transported by rail via the Florida East Coast Railway (FEC) or CSX corridor to Carbotura’s Central Florida ACM Facility, where land has already been optioned. The full ACM sequence — Pregenesis → Regenesis → Regenesis MAX — is executed at the Central Florida facility. No Carbotura processing equipment is required within Miami-Dade County under Option B. This is the regional-scale refinery model: Miami-Dade supplies the feedstock; the Central Florida facility converts it.
| Parameter | Value | Notes |
|---|---|---|
| Miami-Dade component | Regional Transfer Stations (feedstock aggregation + rail loading) | Feedstock → OmniCrude™ conversion. Compact footprint. No Regenesis MAX on-county. |
| Central Florida component | Central Florida ACM Facility (full-stack) | Receives OmniCrude™ from all Florida nodes. Land optioned. Hub refinery architecture. |
| OmniCrude™ transport | Rail — FEC / CSX corridor | Florida East Coast Railway Miami–Orlando corridor. OmniCrude™ is a manufactured intermediate — classified and transported as industrial product, not regulated material. |
| Miami-Dade footprint | Smaller than Option A per node | No Carbotura processing footprint required in-county. Transfer Stations are existing DSWM infrastructure performing existing operations — rail loading is the only operational addition. |
| Scalability model | Multiple Transfer Station loading points, single Central Florida ACM Facility | Additional Transfer Station rail-loading arrangements can be added across Miami-Dade municipalities. Central Florida ACM Facility scales to serve all contributing Transfer Station networks. |
| Feedstock delivery | Feedstock Haulers to enclosed node bay | No change to collection-side logistics |
| Central Florida ACM Facility revenue scale | Aggregated multi-county Revenue Stack | Central Florida ACM Facility processes manufacturing feedstock from Miami-Dade + other Florida counties. Revenue at RC3 scales with combined TPD. |
| Employment — in-county | Transfer Station rail-loading operations + Feedstock Hauler (rail) roles | In-county employment at Transfer Station rail-loading operations. Facility employment at Central Florida ACM Facility. |
| Capital obligation — Miami-Dade | $0 | BOO across entire architecture — Transfer Station arrangements and Central Florida ACM Facility |
Option B is the refinery model at regional scale. Manufacturing feedstock from Miami-Dade flows north via rail from existing Transfer Stations to a Central Florida ACM Facility that aggregates supply from multiple counties — exactly as crude from multiple wellheads flows to a central refinery. For Miami-Dade, this architecture is particularly suited to scenarios where in-county land for a full-stack facility is constrained, or where the county wishes to participate in a broader Florida ACM network from the outset.
Scale Tiers — 500 to 6,000 TPD
Both Option A and Option B are scalable in 100 TPD increments from initial deployment to 6,000+ TPD. Miami-Dade’s estimated available feedstock stream of ~4,800 TPD can be progressively enrolled as deployment matures. The four representative scale tiers below apply to either architecture.
Revenue ranges extrapolated linearly from RC3 baseline of $185–$300M per 400 TPD. Actual results depend on feedstock composition, RevCon tier achieved, and market conditions. All projections use RevCon 3 conservative baseline. MED · RC4–5 upside not shown.
Miami-Dade’s feedstock stream is large enough to support the full 6,000 TPD envelope — making this one of the few US counties capable of sustaining a maximum-scale ACM deployment. The modular 100 TPD increment design means the county can start at 500 TPD, validate operations, and expand without disruption to existing collection infrastructure. Each increment adds a Revenue Stack without adding capital risk to Miami-Dade.
Comparative Architecture Analysis
| Factor | Current System (WTE + Landfill) | Option A — In-County ACM | Option B — Rail-Delivered Feedstock |
|---|---|---|---|
| Capital obligation | ~$1B+ (WTE). $50M+ (closure). County-borne. | $0 — BOO model | $0 — BOO model |
| Combustion | Yes — WTE burns material with oxygen | None — anoxic Microwave Catalytic Reforming | None — same |
| Stack emissions | Yes — Title V permit required | Designed for near-zero — Atmospheric Protection System | Designed for near-zero — same |
| Revenue to county | None — net cost. Gate revenue only until landfills close. | Circular Royalty™ from month 13 | Circular Royalty™ from month 13 |
| PFAS handling | Landfill accumulation. CERCLA exposure. | Designed for complete molecular breakdown at 1,200°C+ | Same — at Transfer Station rail-loading point |
| Landfill life | North Dade ~2026. South Dade ~2030. | Feedstock diversion extends life. Exogenesis enables active mining. | Same diversion model via nodes |
| In-county employment | ~75 at RRF (closed). Ongoing hauler workforce. | 100 FTE per 400 TPD + ~300 indirect | Transfer Station rail-loading operations + Feedstock Hauler (rail) roles |
| In-county land requirement | RRF was ~50+ acres. WTE replacement: comparable. | 10 acres per 400 TPD module | Smaller — node only (no Regenesis MAX footprint) |
| Community opposition risk | High — documented opposition to WTE combustion replacement | Low — no combustion, no stack, enclosed facility | Low — same |
| Regulatory classification path | Solid waste — Title V, FDEP Part IV permitting | ACM manufacturing — distinct classification pathway | ACM at node + interstate manufacturing logistics |
On every material dimension — capital obligation, emissions profile, revenue generation, PFAS handling, landfill life extension, community acceptance, and regulatory classification — both ACM deployment architectures outperform the current system and the proposed WTE replacement. The choice between Option A and Option B is an operational and siting preference, not a performance preference. Both are unconditionally superior to the baseline.
ACM Partnership Proposal
Carbotura proposes a Circular Advantage program engagement for Miami-Dade County. The commercial framework is the Circular Offtake Agreement — a 30-year Build, Own, Operate partnership under which Carbotura assumes all capital and operational risk, and Miami-Dade transitions from net infrastructure cost to net revenue generation. This section describes what changes, how the financial model works, how the Circular Royalty™ is structured, and how the 30-year engagement unfolds.
What Changes
Manufacturing feedstock is collected twice weekly from 340,000+ households and transported by Feedstock Haulers to two landfills and three transfer stations. The Resources Recovery Facility that previously handled 1 million tons per year is permanently closed and being remediated. The proposed WTE replacement has no confirmed site, no construction contract, and no financing plan. Miami-Dade pays per-ton disposal fees into a system that generates no material value, depletes two landfills by 2026–2030, and carries a structural $39M annual deficit. PFAS accumulates in landfill cells adjacent to sensitive groundwater zones.
The same feedstock stream is delivered to a Carbotura ACM facility — in-county (Option A) or to the rail-loading Transfer Stations (Option B). Pregenesis prepares feedstock. Regenesis converts it to OmniCrude™. Regenesis MAX refines it into manufactured materials across the RevCon Valorization Ladder. Miami-Dade pays a TMC Fee (competitive with or below current disposal cost) and receives a Circular Royalty™ beginning month 13. Landfills receive less feedstock — extending operational life and deferring closure costs. PFAS-containing feedstock is destroyed at the molecular level. No combustion. No stack. No landfill gas. No capital obligation.
Eliminated — Combustion Replacement
The ~$1B WTE capital commitment is eliminated. Miami-Dade does not finance, build, or operate a replacement combustion facility. Community opposition to combustion siting becomes irrelevant.
Eliminated — Landfill Revenue Loss
ACM feedstock diversion extends landfill operational lives, preserving gate revenue longer and deferring $50M in closure costs. Exogenesis enables active mining of legacy deposits.
Added — Circular Royalty™
A new recurring revenue stream from Carbotura to Miami-Dade, derived from manufactured materials sales. Begins month 13. Grows with scale. Paid for 30 years.
Added — PFAS Destruction Pathway
Feedstock entering the ACM facility — including PFAS-contaminated leachate and biosolids — is processed at 1,200°C+. The system is designed for complete PFAS molecular breakdown. Direct reduction of CERCLA exposure.
Transitioned — Feedstock Haulers
Existing haulers become Feedstock Haulers under the Circular Advantage program. Collection infrastructure and workforce are preserved. The only change is destination and classification — not collection operations.
Transitioned — Water Recovery
87,000+ gallons per day of ultrapure water per 400 TPD module. In a county facing increasing water scarcity and sea-level pressure, this output has direct municipal utility value.
The collection infrastructure does not change. The workforce does not change. The feedstock volume does not change. What changes is where the feedstock goes, what it becomes, and who gets paid — transitioning Miami-Dade from a net cost operator to a feedstock supplier in a manufacturing system that generates revenue from materials that currently go to landfill.
Financial Model — TMC Fee, Revenue Stack, Household Impact
| Financial Element | Current System | ACM System (RC3 Baseline) | Conf. |
|---|---|---|---|
| Per-ton disposal cost to Miami-Dade | ~$33–$40/ton (gate + transfer) | TMC Fee ≤ current disposal cost | HIGH |
| Capital obligation | ~$1B+ (WTE replacement) | $0 — BOO model | HIGH |
| Annual revenue from ACM partnership | $0 (net cost) | Circular Royalty™ — begins month 13, grows with scale | MED |
| Revenue Stack (per 400 TPD facility, RC3) | N/A | $185–$300M/yr | MED |
| Landfill closure costs | ~$50M (both facilities) | Deferred by feedstock diversion. Exogenesis enables active mining of legacy cells. | HIGH |
| PFAS remediation liability | Growing — CERCLA activated April 2024 | Reduced — PFAS-containing feedstock destroyed in-process | MED |
| Per-household annual cost | $547/yr (FY25) | Stable or declining — TMC Fee offset by Circular Royalty™ return | MED |
| Collection fund structural deficit | $39M — requires internal loan | Circular Royalty™ revenue available to support collection fund from year 2 | MED |
The ACM financial model replaces Miami-Dade’s ~$1B capital commitment and structural deficit with a zero-capital, revenue-generating partnership. At 500 TPD Phase 1, the Revenue Stack is already material. At 2,000 TPD Phase 3, it approaches $1B annually. The county’s per-household cost stabilises or declines as Circular Royalty™ revenue supplements the collection fund. Over 30 years, the cumulative Circular Royalty™ return to Miami-Dade represents one of the most transformative financial outcomes available to any county in the US.
Circular Royalty™ Structure
Commencement
The Circular Royalty™ begins 13 months after first feedstock delivery to the Carbotura ACM facility. This is the point at which Regenesis MAX has produced and sold manufactured materials at commercial scale. It is not a rebate and not a revenue share — it is a conversion royalty derived from the manufactured value of the feedstock the county supplied.
Scaling Mechanism
The Circular Royalty™ scales with the volume of feedstock delivered and the RevCon tier of manufactured materials produced. As deployment scales from 500 to 2,000+ TPD, the royalty base grows proportionally. RC3 is the conservative calculation baseline. Higher RevCon tiers produce higher royalty income.
Contractual Basis
The Circular Royalty™ is defined and guaranteed within the 30-year Circular Offtake Agreement. It is not discretionary and does not depend on Carbotura’s profitability. It is a contractual payment obligation, paid per-ton delivered, from manufactured materials revenue. Terms are subject to commercial negotiation at COA execution.
Municipal Application
Miami-Dade may apply Circular Royalty™ revenue to: collection fund deficit reduction, household fee offsetting, landfill remediation and closure cost funding, PFAS remediation co-investment, community infrastructure, or general operating revenue. The county determines application; Carbotura determines and pays the quantum.
Miami-Dade will be the first US county of this scale to receive a Circular Royalty™ — a contractual payment derived from the manufactured value of its own feedstock stream. Over 30 years at 2,000 TPD, the cumulative Circular Royalty™ return becomes one of the most significant municipal revenue streams ever generated from a materials infrastructure partnership in Florida’s history.
30-Year Engagement Timeline — Stage 1 to Full Scale
Miami-Dade is currently at Stage 1. The path from this briefing to first Circular Royalty™ payment is seven stages, all of which Carbotura navigates as the BOO operator. The county’s active investment is time and decision-making authority. Carbotura’s investment is capital. The 30-year engagement produces a cumulative value transfer to Miami-Dade that no combustion facility or landfill expansion can approach.
Community & Resident Impact
The ACM deployment directly affects Miami-Dade’s 2.72 million residents across three dimensions: the cost they pay for materials infrastructure services, the environmental quality of the air, water, and land they depend on, and the quality and quantity of jobs the ACM system generates in their communities.
Household Cost Impact
Miami-Dade’s $547/household fee has not kept pace with inflation. The DSWM reported a $39 million structural deficit in FY 2024–25, covered only by an internal loan from the Disposal Fund. Without a structural revenue solution, household fees must rise. The county’s own documents acknowledge further rate increases will be required in the Collections Fund.
Ongoing inflation in collection costs, landfill capacity pressure, and eventual closure of both landfills (by 2026–2030) will require sustained household fee increases. The ~$1B WTE replacement — if financed through debt service allocated to ratepayers — adds further upward pressure. Best-case: fees rise modestly. Worst-case: fees rise substantially as multiple cost events compound simultaneously.
TMC Fee structured to be competitive with or below current disposal cost — no increase to per-ton cost baseline. Circular Royalty™ commencing month 13 provides the county with a revenue source that can be applied to offset collection fund costs. At scale, the Circular Royalty™ materially reduces the county’s structural deficit and creates downward pressure on per-household fees. Capital obligation: $0 — no debt service.
Miami-Dade residents currently pay $547 per household per year for a system that is structurally in deficit, losing its primary disposal infrastructure, and heading toward either a multi-year fee increase cycle or a $1B public capital commitment. The ACM partnership is designed to hold or reduce per-household costs while generating Circular Royalty™ revenue that the county can deploy for resident benefit. The cost comparison is not close.
Environmental Outcomes
Carbon-Negative by Design
Each 400 TPD Carbotura modular factory is designed for a carbon impact of −1,522 to −1,566 tons CO₂e per day — carbon-negative by design. Over 30 years, a single 400 TPD facility is engineered to deliver a 17 million ton CO₂e cumulative carbon impact. For Miami-Dade at 2,000 TPD, the 30-year carbon impact exceeds 85 million tons CO₂e. HIGH
Near-Zero Emissions — No Combustion
The Recyclotron™ operates in an anoxic (no oxygen) environment. The system is designed to operate without combustion or oxidation. No flame. No stack. No ash requiring landfill disposal. No NOx, SOx, or dioxin stack emissions associated with combustion. The Atmospheric Protection System is engineered for near-zero environmental impact. This is a design specification, not a performance claim. HIGH
PFAS Destruction Pathway
The Carbotura system processes material at temperatures exceeding 1,200°C — above the thermal destruction threshold for PFOS and PFOA. The system is designed for complete PFAS molecular breakdown. For Miami-Dade, where Miami drinking water shows PFOS at 18.98 ppt (EPA limit: 4 ppt) and the city ranks 3rd nationally in groundwater PFAS contamination, this is a direct environmental liability reduction pathway. HIGH — design spec
Ultrapure Water Recovery
87,000+ gallons of ultrapure water per day per 400 TPD module. In a county with among the highest water stress in Florida and documented PFAS contamination of drinking water sources, this output has direct municipal value. At 2,000 TPD, daily water recovery exceeds 435,000 gallons. HIGH — approved metric
Landfill Legacy Remediation
The Exogenesis Protocol enables active mining of legacy landfill cells — converting legacy deposits into OmniCrude™ rather than waiting for unlined cells to leach into South Florida’s shallow water table. This converts a liability into a feedstock source. Both North Dade and South Dade Landfills are adjacent to sensitive groundwater zones identified in academic literature. MED
Grid-Independent Energy Generation
857 MWh per day per 400 TPD in Island Mode — fully self-powered with ~5% reserve. No grid dependency. In a county with documented hurricane vulnerability and grid resilience concerns, a self-powering ACM facility provides infrastructure continuity value above and beyond the manufacturing mission. HIGH
Miami-Dade is simultaneously facing a PFAS drinking water emergency (PFOS at 4.7x EPA limit), groundwater contamination risk from landfills adjacent to sensitive aquifer zones, and a proposal to replace one combustion facility with another. The ACM deployment addresses all three vectors: PFAS destruction by design, landfill leachate reduction through feedstock diversion and Exogenesis, and combustion elimination. The environmental case for ACM deployment in Miami-Dade is among the strongest of any jurisdiction Carbotura has assessed.
Jobs & Economic Development
| Employment Category | Scale | Count | Notes |
|---|---|---|---|
| Direct FTE — ACM Facility | Per 400 TPD module | 100 FTE | Operations, engineering, maintenance, quality, safety. Permanent, full-time roles. HIGH |
| Indirect / Induced — Economic multiplier | Per 400 TPD facility | ~300 | Supply chain, professional services, logistics, local spending. Standard multiplier applied to ACM facility operations. HIGH |
| Total employment — 500 TPD Phase 1 | ~500 TPD | ~500 total | ~125 direct + ~375 indirect/induced. Higher than RRF employment at closure (75 standby). MED |
| Total employment — 2,000 TPD Phase 3 | ~2,000 TPD | ~2,000 total | ~500 direct + ~1,500 indirect/induced. MED |
| Feedstock Hauler workforce — preserved | Existing fleet | Maintained | Existing collection workforce transitions to Feedstock Hauler roles within the Circular Advantage program. No redundancies required at collection operations level. HIGH |
| Feedstock Hauler (rail) roles (Option B) | Rail logistics | New roles | Option B creates Feedstock Hauler (rail) roles for transport of manufacturing feedstock between Miami-Dade Transfer Stations and the Central Florida ACM Facility. New role category in the county’s logistics sector. MED |
| Annual economic impact per 400 TPD | Per facility | $32M+/yr | Direct economic activity in the local economy, excluding Circular Royalty™ transfers. HIGH — approved metric |
The ACM deployment at 500 TPD Phase 1 creates more direct employment than the Covanta RRF had at closure — in higher-skilled, more durable manufacturing roles. At 2,000 TPD, total employment impact approaches 2,000 jobs in a county with documented economic equity challenges. The annual economic footprint of $32M+ per 400 TPD module compounds over 30 years into one of the most significant industrial economic contributions in South Florida’s recent history.
Accountability & Action Pathways
The decisions that determine Miami-Dade’s infrastructure future are being made now. The officials responsible for those decisions are identified below. The action pathways available to stakeholders — county officials, community advocates, business leaders, and residents — are described here for accountability and engagement purposes.
F1 — Key Decision-Makers
| Official / Body | Role | Relevant Decision Authority |
|---|---|---|
| Miami-Dade Board of County Commissioners (BCC) | 13-member elected body | Approves all infrastructure contracts exceeding threshold values, adopts fee schedules, authorises capital commitments, and votes on intergovernmental agreements. The BCC approved WTE site selection (Sept 2023) and the AtkinsRealis design contract. The BCC would authorise any Circular Offtake Agreement. |
| Mayor Daniella Levine Cava | Miami-Dade County Mayor | County Mayor’s office leads solid waste infrastructure strategy. Mayor Cava’s office negotiated the emergency WM and Waste Connections capacity agreements. The Mayor’s office oversees DSWM and recommends policy to the BCC. |
| DSWM Director | Dept. of Solid Waste Management | Operational authority for all collection, disposal, and infrastructure decisions. Administers hauler permits, fee schedules, and facility operations. The DSWM Director is the primary operational counterparty for a Stage 2 Carbotura engagement. |
| DERM Director | Dept. of Regulatory & Economic Resources | County environmental permitting authority. Issues local air and water quality permits. Key stakeholder for ACM facility classification at the county level and for PFAS remediation pathway discussions. |
| Florida DEP Secretary | State regulatory authority | FDEP oversees all solid waste facility permitting and ACM facility siting reviews in Florida. Pre-application engagement with FDEP’s Division of Waste Management is a Stage 4 action item. FDEP has already withdrawn the RRF Title V permit — indicating active engagement with the county’s transition. |
F2 — Key Decision Milestones
| Milestone | Timeline | Significance |
|---|---|---|
| North Dade Landfill — projected capacity | ~2026 | Once capacity is reached, overflow will require external landfill capacity at premium cost. ACM deployment at 500 TPD before this date materially reduces the pressure. |
| Zero Waste Master Plan — completion | 2026 | The ZWMP, when adopted, will establish Miami-Dade’s official infrastructure direction. ACM engagement prior to ZWMP completion ensures the framework is considered as a primary pathway — not retrofitted afterward. |
| WTE replacement — site confirmation | TBD 2026+ | Once a WTE site is confirmed and a construction contract executed, Miami-Dade’s infrastructure trajectory will be locked for 20–30 years. ACM engagement must precede this decision to preserve the option. |
| South Dade Landfill — projected capacity | ~2030 | Second landfill closure within 4 years of first. Combined closure represents $50M+ capital and $50M+/yr revenue loss. ACM scale deployment prior to 2028–2030 mitigates this event. |
F3 — Public Records & Oversight Mechanisms
Florida Public Records Act
Chapter 119, Florida Statutes. All Miami-Dade DSWM contracts, RFPs, fee schedules, and budget documents are public record. Requests may be submitted to DSWM Public Records at 305-514-6666 or via the county’s public records portal.
BCC Meeting Agendas & Broadcasts
Miami-Dade BCC meetings are broadcast live and archived at miamidade.gov. All agenda items, supporting memos, and votes are public record. Solid waste infrastructure items are typically scheduled under the County Mayor’s report or as standalone agenda items.
FDEP Permitting — Public Comment
All FDEP permit applications — including those for the proposed WTE replacement sites — include a mandatory public comment period. Community input on WTE site selection is currently active as sites move through preliminary FDEP review.
Carbotura Engagement
To request a technical briefing, schedule a Stage 2 engagement meeting, or obtain additional ACM deployment documentation for Miami-Dade County officials, contact Carbotura Intelligence & Analysis: media@carbotura.com
The most important action Miami-Dade County officials can take today is to request a Stage 2 technical briefing before the Zero Waste Master Plan is finalised and before a WTE construction contract is executed. Both of those events lock the county’s infrastructure trajectory for a generation. The ACM window is open now. It does not stay open indefinitely.
Sources & Methodology
G1 — Source Bibliography
| Source ID | Document / Publication | Date | Retrieval |
|---|---|---|---|
| MDC-DSWM-2025 | Miami-Dade DSWM — Official service pages, facility descriptions, and permit framework | 2025 | miamidade.gov/global/solidwaste |
| MDC-FEES-1025 | Miami-Dade DSWM Disposal Facility Fees Schedule (effective Oct 1, 2025) | Oct 2025 | miamidade.gov/resources/solid-waste/documents/disposal-facility-fees.pdf |
| MDC-FEE-MEMO-2024 | Miami-Dade Proposed Solid Waste Fees — FY 2024–25 Executive Summary | 2024 | miamidade.gov/global/news-item.page |
| MDC-BCC-231209 | Miami-Dade BCC Agenda Item 231209 — DSWM Collections Fund Deficit and Fee Proposal | Dec 2023 | miamidade.gov/govaction/legistarfiles/Matters/Y2023/231209.pdf |
| MDC-BCC-2023-CAP | Miami-Dade BCC Executive Summary — DSWM Capacity Report and Landfill Closure Projections | 2023 | Public record — BCC archives |
| BCC-R1096-23 | Miami-Dade BCC Resolution R-1096-23 — AtkinsRealis WTE Design Criteria Professional Agreement | Nov 2023 | Miami-Dade BCC Legistar |
| BCC-SPEC-0923 | Miami-Dade BCC Special Meeting — WTE Site Selection and RRF Closure Vote | Sept 19, 2023 | miamidade.gov / BCC Broadcast Archive |
| FDEP-WTE-2024 | FDEP WTE Commission Reports and Documents — Preliminary Site Permit Review | 2024 | miamidade.gov/global/solidwaste/sustainable-solid-waste/wte-commiss-reports-and-documents.page |
| FDEP-CLOSURE-2024 | FDEP RRF Closure Plan Submission — March 2024 and Title V Permit Withdrawal | Mar 2024 | miamidade.gov RRF Commission Reports |
| WDIVE-0923 | WasteDive — Miami-Dade advances plans for new WTE facility; RRF closure | Sept 20, 2023 | wastedive.com/news/miami-dade-county-florida-advances-plans-for-new-wte-facility |
| NBCM-0824 | NBC Miami — Miami-Dade proposed WTE plant renderings and community opposition | Aug 6, 2024 | nbcmiami.com |
| MDC-ZWMP-2024 | Miami-Dade Zero Waste Master Plan — RFP and initiation (2024, completion 2026) | 2024 | miamidade.gov Sustainable Solid Waste Campus |
| EPA-PFAS-2024 | US EPA — Final PFAS Hazardous Substance Designation under CERCLA | Apr 2024 | congress.gov/crs-product/TE10118 |
| FIU-PFAS-2024 | FIU Institute of Environment — “It’s raining PFAS in South Florida” — Miami ranked 3rd nationally for PFAS groundwater contamination | Dec 2024 | sciencedirect.com / floridaspecifier.com |
| TAPWATER-2024 | TapWater.org — Miami PFAS levels from 2024 Water Quality Report (MDC Water & Sewer Dept.) | 2024 | tapwater.org/florida/miami |
| NSU-LEACHATE | Lecours, M.J. — “Solid Waste Landfills in Miami-Dade County: The Leachate Problem” — NSU Works | Academic | nsuworks.nova.edu/cnso_stucap/179 |
| DERM-2024 | Miami-Dade DERM Environmental Research & Reports — Wellfield Protection and Soil Reuse Guidance | 2024 | miamidade.gov/environment/research-reports.asp |
| WDIVE-MS-2023 | WasteDive — US waste and recycling industry market share analysis | May 2023 | wastedive.com/news/us-waste-recycling-market-waste-business-journal-2023 |
| CAV-37 | Carbotura Authoritative Voice v3.7 — Governing terminology, commercial framework, BOO model, Circular Advantage, Circular Royalty™ specifications | Feb 2026 | Carbotura Inc. — Proprietary |
| CAV-METRICS | Carbotura Approved Performance Metrics — 400 TPD baseline: carbon impact, energy, water, employment, economic impact, RC3 revenue range | 2026 | Carbotura Inc. — Authoritative Voice v3.7 §10 |
| MDC-RES-FEE-2526 | Miami-Dade DSWM Residential Solid Waste Service Fees — FY 2025–26 | 2025 | miamidade.gov/global/service.page (residential fees) |
G2 — Methodology Notes
- Feedstock volume estimate (~4,800 TPD): Derived from: (a) RRF design capacity of 4,000 TPD, (b) public statements that Miami-Dade generates feedstock at approximately twice the national per-capita average, (c) population of 2.72M applied against Florida average municipal feedstock generation rates. This is a MED-confidence estimate pending DSWM data room access.
- Scale tier revenue projections: Linear extrapolation from Carbotura’s approved RC3 baseline of $185–$300M per 400 TPD facility. Applied proportionally to scale tiers. Not independently verified. Subject to feedstock composition, RevCon tier achieved, and market conditions.
- All-in disposal cost (~$33–$40/ton): Derived from Oct 2025 DSWM fee schedule: contract gate fee ($16.28) + transfer station fee ($16.66) = $32.94 minimum all-in. Non-contract rates: $16.91 + $16.91 = $33.82. Excludes special handling, transport allocation, and overhead. Classified as MED confidence — full FWDC requires access to internal allocation data.
- WTE replacement capital estimate (~$1B+): Derived from publicly reported WTE facility construction costs nationally. Palm Beach SWA (2015): reported ~$680M at 2,000 TPD. Pasco County expansion (2023): ~$550M for capacity expansion. A 4,000 TPD greenfield facility in 2026 is estimated at $800M–$1.5B+. Classified LOW confidence — no publicly disclosed Miami-Dade capital estimate for the replacement.
- PFAS concentration data: Sourced from TapWater.org (Miami-Dade Water & Sewer Dept. 2024 Water Quality Report). PFOS: 18.98 ppt vs. EPA limit of 4 ppt. PFOA: 7.2 ppt vs. EPA limit of 4 ppt. FIU ranking (3rd nationally) from Atmospheric Pollution Research Vol. 15, Issue 12, Dec 2024.
G3 — Confidence Level Legend
| Badge | Definition | Source Standard |
|---|---|---|
| HIGH | Directly sourced from official county documents, FDEP filings, BCC resolutions, or Carbotura’s approved performance metrics | Public record or Carbotura approved specifications |
| MED | Derived from partial public data, reasonable interpolation, or Carbotura projections applied to Miami-Dade conditions. Subject to site verification. | Derivation documented in G2 |
| LOW | Preliminary estimate requiring independent confirmation, site assessment, or DSWM data room access | Stated explicitly when used; derivation documented |
G4 — Data Quality Disclosures
G5 — Document Changelog
| Version | Date | Changes |
|---|---|---|
| v1.0 | March 2026 | Initial publication. Full dual-architecture briefing for Miami-Dade County. Sections A–G. brand.carbotura.com v2.1 SP-01+02 applied. Carbotura Authoritative Voice v3.7 compliant. |