What this document is
The commercial structure of one Circular Supply Agreement for the State of Rhode Island — the Beneficiation Fee, the Circular Royalty™, deployment from 400 to 900 TPD, the Johnston site candidate, risk and timeline.
- Phase Initial at 400 TPD (132,000 TPY) is the entry point; the CSA scales to 900 TPD without renegotiating commercial terms.
- One CSA, no election: the State pays $100/ton and receives a Circular Royalty™ from 13 months after the first fee payment.
- Zero State capital at any phase; Central Landfill is an Exogenesis™ candidate subject to characterisation.
Rhode Island
Circular Supply Proposal
A 30-year Circular Supply Agreement converts Rhode Island’s statutorily aggregated residual into a royalty return — 400 to 900 TPD, at zero State capital.
What This Means
Fee: $100/ton Yr 1 · +2.5%/yr
Phase Initial: ~$14.6M/yr (146,000 tpy)
Circular Royalty™: 120% from Month 13
+1pp/yr · Year 30 = 148%
~$17.52M/yr Year 2 → ~$43.1M/yr Year 30
$0 Fee · site deed at signing
~$14.6M/yr Year 2 → ~$19.3M/yr Year 30
Landfill deeded at signing (if study confirms)
Post-closure obligations → Carbotura
Exogenesis™ Royalty: $50/ton · +1%/yr
~$3.65M/yr from Year 6 (indicative)
Subject to Waste Characterization Study
- What is being offered. Carbotura proposes a 30-year Circular Operating Agreement (CSA) under a full Build-Own-Operate structure. Carbotura designs, finances, constructs, and operates the ACM facility at no cost to the State. Rhode Island's sole financial commitment is the Beneficiation Fee — a per-ton payment for feedstock conversion that is designed to be at or below the State's current blended disposal cost.
- What the State commits. Feedstock delivery under existing RIRRC statutory aggregation mechanisms; authorization of a Joint Working Group phase (3 months); designation of a Priority 1 site candidate for permitting. No capital appropriation required.
- What the State receives. Gross cost displacement from Day 1 (TMC replaces higher blended disposal costs). Circular Royalty™ payments beginning 13 months after Phase Initial operations commence — structured to exceed the Beneficiation Fee per ton at steady state. Employment: 120 direct FTE at Phase Initial; 360 direct FTE at Phase Expanded. ESTIMATED
- The hard deadline. The 2027 expiry of the Synagro Technologies contract at the Woonsocket Thermal Conversion Facility is a procurement-forcing event. A Joint Working Group phase authorized in Q2 2026 places Phase Initial COD at Q2 2028 — before the 2027 Woonsocket crisis requires out-of-state sludge displacement at $160+/ton for 30+ municipalities.
- Gross cost displacement is quantified separately from Circular Royalty™ cash flow.
Executive Implications
- Authorization of a Joint Working Group phase is the only near-term decision required. It triggers no capital commitment and produces the verified cost and site data needed to advance the CSA.
- The 2027 Synagro contract expiry is a hard deadline, not an estimate. Rhode Island has less than 24 months to contract an alternative sludge disposal pathway before municipalities face forced out-of-state displacement at $89–160/ton.
- Rhode Island's combustion-based WTE prohibition has eliminated every conventional incineration alternative for four decades. ACM — classified NAICS 325180/325998/327992/331110/331314/331492 (manufacturing), not NAICS 562213 (solid waste combustion) — is not subject to the prohibition. MCR's anoxic, oxygen-free process is mechanistically incompatible with combustion. RIDEM reviews ACM under manufacturing permitting. Carbotura operates under manufacturing classification (NAICS 31–33).
- At Phase Expanded, the ACM facility processes 396,000 TPY — diverting 44% of identified feedstock from the Central Landfill. RIRRC's own studies project this level of diversion extends landfill life by 15+ years. ESTIMATED
Commercial Structure and Decision Window
Advanced Circular Manufacturing is a manufacturing process, not a waste-management activity. Microwave Catalytic Reforming operates in an anoxic, oxygen-free, sub-atmospheric environment — mechanistically incompatible with combustion or biological degradation. ACM does not fit within the waste domain and does not operate under waste-domain statutes. The Regulatory Predicate Transition (RPT) — also framed as the dewaste pathway — is the coordinated regulatory shift from legacy disposal-predicate statutes onto manufacturing-predicate classifications. 100% elemental recycling of the municipal material stream requires this transition. Manufacturing NAICS 325180 · 325998 · 327992 · 331110 · 331314 · 331492 (6-code ACM set) plus EPA RCRA §1004(27) / 40 CFR §261.2(e) exclusion pathway in the US; ISIC Rev.4 20-25 + UN CPC 89 internationally. In many jurisdictions the required authorities already exist in latent form within existing statutes; in others the transition requires primary-authority amendments. The Joint Working Group phase includes a regulatory engagement workstream to shepherd the RPT alongside site permitting. Both parties commit to the RPT pathway. Carbotura brings the process-classification evidence, regulatory engagement expertise from prior ACM deployments, and the legal-technical framework. The counterparty brings the standing to engage the local regulator, the political mandate for the transition, and — where applicable — legacy statutory authorities that can be re-instrumented for manufacturing use. The endpoint is categorical: manufacturing classification across all permitting, licensing, and regulatory contexts. Interim bridging authorities may apply during the transition.
Regulatory basis: RCRA §1004(27) · 40 CFR §261.2(e) · 40 CFR §260.43
§1.1 — Circular Operating Agreement Structure
| Term | Value | Notes |
|---|---|---|
| Agreement type | Build-Own-Operate (BOO) | Carbotura owns and operates all capital assets |
| Term | 30 years | From first feedstock delivery date |
| State capital obligation | $0 | Zero capex; Carbotura arranges full project financing |
| State operating obligation | $0 | Zero operating liability beyond feedstock delivery |
| State's financial instrument | Beneficiation Fee — per ton delivered | $100/ton at Phase Initial; escalates 2.5%/year |
| State's financial return | Circular Royalty™ — per ton processed | Begins Month 13; 120% of the current-year Beneficiation Fee; escalates +1pp/year |
| Minimum annual commitment | Phase Initial: 132,000 TPY | Based on 400 TPD × 330 operating days |
| Products output | Graphite, graphene precursors, hydrogen, ultrapure water | All industrial outputs; IP owned by Carbotura |
| Residual stream responsibility | Carbotura | Carbotura manages all residual/non-convertible fraction |
§1.2 — Decision Window
| Procurement Step | Duration | No Later Than | Risk if Delayed |
|---|---|---|---|
| Authorize Joint Working Group phase | 1 vote | Q2 2026 | Misses pre-2027 COD window; sludge displacement to $160+/ton begins |
| Joint Working Group phase completion | 3 months | Q3 2026 | |
| Site designation + permitting initiation | 6 months | Q4 2026 | |
| CSA execution + construction start | T0+6 months | Q4 2026 | |
| Phase Initial COD | T0+24 months | Q2 2028 | |
| First Circular Royalty™ payment | T0+37 months | Q3 2029 |
Deployment Architecture
§2.1 — Phase Configuration
| Phase | TPD | Modules | Annual Throughput | % Addressable | COD | CapEx |
|---|---|---|---|---|---|---|
| Phase Initial | 400 | 4 × 100 TPD | 132,000 TPY | 14.8% | T0 + 24 months | $247.5M |
| Phase Medium | 800 | 8 × 100 TPD | 264,000 TPY | 29.5% | T0 + 42 months | $477.5M cumul. |
| Phase Expanded | 1,200 | 12 × 100 TPD | 396,000 TPY | 44.2% | T0 + 60 months | $707.5M cumul. |
Module math: ceil(deployment_tpd / 100). CapEx: $75M first 100 TPD module + $57.5M per additional 100 TPD module. Operating days: 330/year. All CapEx funded by Carbotura — zero state obligation.
§2.2 — BOO Capital Structure
| Capital Item | Who Provides | Phase Initial ($247.5M) | Phase Expanded ($707.5M) |
|---|---|---|---|
| Equity (20%) | Carbotura / sponsors | $49.5M | $141.5M |
| Grant — conservative 15% | Federal / state programs | $37.1M | $106.1M |
| Debt (65%) | Project finance lenders | $160.9M | $459.9M |
| State of Rhode Island | $0 | $0 |
§2.3 — Feedstock Stream Coverage by Phase
| Stream | Phase Initial | Phase Medium | Phase Expanded | Access Status |
|---|---|---|---|---|
| MSW (municipal solid waste) | ✓ Primary | ✓ Continued | ✓ Continued | IMMEDIATE |
| Wastewater Sludge (biosolids) | ✓ Co-primary | ✓ Continued | ✓ Continued | IMMEDIATE |
| Incinerator Residue Ash (IRA) | ✓ Added | ✓ Continued | ACCESSIBLE | |
| Coal Ash (legacy) | Partial | ✓ Full | CONDITIONAL |
§2.4 — Site Candidate Analysis
Site Candidate Summary
| Priority | Zone | Acreage | Zoning | Land Authority | Co-location Advantage | Key Consideration |
|---|---|---|---|---|---|---|
| P1 | Johnston — RIRRC Campus | 30–45 ac | Industrial utility | RIRRC (quasi-public) | Zero MSW transport; on-campus feedstock aggregation by statute | Site agreement with RIRRC; Superfund campus |
| P2 | Port of Providence | 15–30 ac | Marine industrial | ProvPort / Providence | ~0.5 mi from NBC Field's Point (RI's largest WWTP/sludge generator) | Environmental justice sensitivity; waterfront permitting |
| P3 | Quonset Business Park | 50–200+ ac | State industrial park | Quonset Dev. Corp. | Deepwater port; rail access; product export logistics | MSW transport premium; farthest from sludge generators |
§2.5 — Phase Initial Feedstock Sufficiency
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Economic Structure — Beneficiation Fee (TMC Fee)
§3.1 — FWDC Planning Basis
| Input | Value | Source Type | Basis |
|---|---|---|---|
| MSW disposal rate (blended muni/commercial) | ~$85/ton | ESTIMATED | FY2023 municipal $54/ton; commercial $115/ton; blended 800/400 TPD municipal/commercial split |
| Sludge disposal rate (in-state/out-of-state blend) | ~$170/ton | ESTIMATED | West Warwick verified $160+/ton floor; Woonsocket processing rates ESTIMATED |
| IRA ash disposal rate | ~$100/ton | ESTIMATED | RIRRC commercial landfill rate basis |
| Coal ash disposal rate | ~$100/ton | ESTIMATED | Remediation + landfill basis |
| FWDC — blended 1,200 TPD mix | $101.67/ton | MODELED | Blended calculation; see Waste Study §3.3 for derivation |
§3.2 — Beneficiation Fee Formula
§3.3 — Annual TMC Obligation by Phase
| Year | TMC/ton | Phase Initial (132K TPY) | Phase Medium (264K TPY) | Phase Expanded (396K TPY) |
|---|---|---|---|---|
| Year 1 (pre-royalty) | $100.00 | $13,200,000 | ||
| Year 2 | $102.50 | $13,530,000 | ||
| Year 5 | $110.38 | $14,570,000 | $29,140,000 | |
| Year 10 | $128.01 | $16,897,000 | $33,795,000 | $50,692,000 |
| Year 20 | $160.49 | $21,185,000 | $42,369,000 | $63,554,000 |
| Year 30 | $203.28 | $26,833,000 | $53,666,000 | $80,499,000 |
TMC Year N = $100 × (1.025)^(N−1). Phase Medium throughput begins T0+42 months; Phase Expanded T0+60 months. Pre-royalty period (Year 1) shaded: no royalty received during this period.
Circular Royalty™
Standard CSA: the State of Rhode Island pays a per-ton Beneficiation Fee on feedstock delivered; Carbotura pays a Circular Royalty™ calibrated to 120% of the corresponding Fee, +1pp/yr escalator, beginning Month 13. The Circular Royalty™ exceeds the Beneficiation Fee per ton from Year 2 onward (separate transactions, never netted).
- Gross cost displacement is quantified separately from Circular Royalty™ cash flow. Both are independent financial effects of the CSA.
- At steady state, the Circular Royalty™ is designed to exceed the Beneficiation Fee on a per-ton basis.
- Circular Royalty™ payments begin 13 months after corresponding Beneficiation Fee payments and ramp to full run-rate on a rolling basis.
§4.0.1 — Contractual Definition
Royalty_Rate(m): 120% in Year 1; escalates +1 percentage point per year thereafter
Structure: rolling lagged cash flow — monthly accrual, 13-month lag on each payment
§4.0.2 — Parameter Table
| Parameter | Value | Status |
|---|---|---|
| Royalty base rate (Year 1) | 120% of the current-year Beneficiation Fee | LOCKED |
| Beneficiation Fee escalator | 2.5%/year compounding | LOCKED |
| Royalty rate escalator | +1 percentage point per year | LOCKED |
| Payment lag | 13 months after corresponding TMC payment | LOCKED |
| Calculation basis | Rolling monthly | LOCKED |
| Agreement term | 30 years | LOCKED |
§4.0.3 — Fiscal Period Distinction
| Period | Timing | TMC Position | Royalty Position |
|---|---|---|---|
| Pre-royalty | Months 1–12 (Year 1) | $100/ton paid | $0 received |
| Royalty ramp | Month 13 – ~Month 24 | $102.50/ton paid | $120/ton received (rolling) |
| Steady state | Year 2 onward — growing | Escalating at 2.5%/yr | Escalating at 2.5%/yr + 1pp/yr |
1. Gross cost displacement is quantified separately from Circular Royalty™ cash flow.
2. At steady state, the Circular Royalty™ is designed to exceed the Beneficiation Fee on a per-ton basis.
3. Circular Royalty™ payments begin 13 months after corresponding Beneficiation Fee payments and ramp to full run-rate on a rolling basis.
§4.0.4 — Year-by-Year Cash Flow
| Year | Avoided Disposal | TMC/ton | Royalty Rate | Royalty/ton |
|---|---|---|---|---|
| Year 1 | $101.67 | $100.00 | $0 | |
| Year 2 ← First royalty | $104.21 | $102.50 | 120% | $120.00 |
| Year 5 | $112.22 | $110.38 | 123% | $132.46 |
| Year 10 | $126.97 | $128.01 | 128% | $155.96 |
| Year 20 | $162.53 | $160.49 | 138% | $215.24 |
| Year 30 | $208.06 | $203.28 | 148% | $294.49 |
Royalty/ton in Year N = (119% + N%) × TMC of Year N−1. TMC Year N = $100 × (1.025)^(N−1). All figures ESTIMATED. ESTIMATED
§4.5 — Royalty vs. TMC Crossover Visualization
§4.5 — Fiscal Position: Three Gross Items
§4.1 — Exogenesis™ add-on (Subject to Waste Characterization Study)
Exogenesis™ becomes a CSA element only after: (1) Waste Characterization Study confirming extractable mass economics; (2) qualifying asset confirmation; (3) mutual agreement. Presented here as a structured option for discussion at engagement stage.
Potential additive royalty stream available under the CSA. If elected after study confirmation: the State of Rhode Island deeds Central Landfill, Johnston RI to Carbotura at CSA execution (second instrument). Carbotura deploys the Exogenesis™ Programme — APS + fully electric fleet — within 3–7 years post-COD.
| Parameter | Value | Basis |
|---|---|---|
| Royalty rate (if elected) | $50.00/ton extracted (Year 1) | CSA Schedule E.2 (draft) |
| Escalation | +1.0% per year from Year 2 of extraction | CSA Schedule E.2 (draft) |
| Payment lag | 13 months after first extraction (rolling monthly) | Fixed |
| Programme onset (if elected) | Year 5 post-COD; Year 6 first royalty payment | Engineering schedule |
| Qualifying asset | Central Landfill, Johnston RI — state's sole active MSW landfill, closure ~2041 | Subject to Waste Characterization Study |
| Carbotura obligations (if elected) | All post-closure care, leachate management, methane capture, groundwater monitoring, RIDEM compliance transfer at CSA execution | CSA §6 (draft) |
| Stacking | Independent of and additive to the CSA — never netted (MR §4.8) | Separate Transaction Principle |
| Condition | Subject to Waste Characterization Study · qualifying asset confirmation · mutual agreement · option for discussion at engagement stage | Architect decision 2026-05-11 |
Indicative Cash Flow (if study confirms & elected — ~73,000 tpy est.)
| Year (post-COD) | Rate $/ton | Annual Exogenesis™ Royalty |
|---|---|---|
| 1–5 | $0 (programme ramp) | |
| 6 | $50.00 | +$3,650,000 (indicative) |
| 10 | $52.02 | +$3,797,460 |
| 20 | $57.47 | +$4,195,310 |
| 30 | $63.49 | +$4,634,770 |
| 30-yr indicative (if elected) | ~$103M | |
Royalty figures are amounts received. The royalty is paid 13 months in arrears, so the figure shown for a year is earned on the previous year’s delivered tonnage.
All values INDICATIVE. ~73,000 tpy planning basis — subject to Waste Characterization Study confirmation. Post-closure liability extinguishment is independent of and additional to the Exogenesis™ Royalty cash flow.
CSA Structure
At CSA execution, the State of Rhode Island The Exogenesis™ add-on (Central Landfill, Johnston RI) is a CSA add-on available for discussion — activation requires Waste Characterization Study, qualifying asset confirmation, and mutual agreement.
Application Note: Both options are commercially available to Rhode Island as a state public authority.
Exogenesis™ is a CSA add-on available for discussion, not a commitment. Activation requires: (1) Waste Characterization Study confirming extractable mass economics; (2) qualifying asset confirmation; (3) mutual agreement. Asset: Central Landfill, Johnston RI — state's sole active MSW landfill, closure ~2041.
Risk Register
| Risk | Key Driver | Who Bears It | Mitigation | Residual Exposure |
|---|---|---|---|---|
| FWDC verification | Modeled FWDC may differ from contracted rates | State (TMC Floor protects Carbotura) | Joint Working Group phase produces verified FWDC before CSA execution | Low — $100 floor ensures minimum value regardless of FWDC outcome |
| Technology performance | ACM conversion efficiency and output quality | Carbotura — BOO structure | Performance warranties; liquidated damages in CSA; Carbotura owns all capital | Low for State — no capital at risk; feedstock redirected to RIRRC if ACM offline |
| Timeline slippage | Permitting delays extend beyond 2027 Woonsocket deadline | Shared — State (sludge displacement costs); Carbotura (revenue delay) | Authorize Joint Working Group phase Q2 2026; P1 site co-location minimizes permitting complexity | Med — every month of delay risks sludge municipalities to $160+/ton out-of-state routes |
| Third-party sludge contracts | NBC or municipalities sign long-term alternative sludge contracts before CSA | State — reduces sludge stream volume | MSW stream (750K TPY) is legally mandated regardless; Phase Initial supportable on MSW alone | Low — sludge stream is supplemental to MSW sufficiency |
| Competitive procurement | Alternative waste management technology deployment in RI | State — market risk | WTE combustion prohibition eliminates any conventional incineration competitor; ACM's manufacturing classification is unaffected by the prohibition; rail haul ($89–100/ton) remains more expensive than Beneficiation Fee | Low — statutory WTE prohibition and RIRRC mandatory delivery create structural barriers to competition |
| Residual stream management | Non-convertible fraction of feedstock requires disposal | Carbotura — contractual obligation | CSA requires Carbotura to manage all residuals; State has no liability | Low for State |
| PFAS regulatory evolution | Federal/state PFAS limits may restrict biosolids reuse and co-processing | Shared — affects sludge access classification | ACM MCR process is designed to destroy PFAS within the closed-loop anoxic environment at 1,200°C+ localized hot spots; no PFAS-containing emissions released; product characterization under Carbotura technical program | Med — evolving federal standards; mitigated by ACM's PFAS destruction capability |
Deployment Timeline
| Milestone | Target | Offset | Notes |
|---|---|---|---|
| ⚑ Synagro Contract Expiry — HARD DEADLINE | 2027 | Fixed | City of Woonsocket exits sludge incineration; 30+ municipalities displaced. Action window: under 24 months. |
| Authorize Joint Working Group phase | Q2 2026 (T0) | T0 | Decision required no later than Q2 2026 to hit Phase Initial COD by Q2 2028 |
| Joint Working Group phase completion | Q3 2026 | T0 + 3 months | Verified FWDC; confirmed site; refined TPD allocation |
| Site designation + permitting initiation | Q4 2026 | T0 + 6 months | P1 Johnston/RIRRC provisional; RIDEM/EPA coordination |
| CSA execution + Phase Initial construction start | Q4 2026 | T0 + 6 months | Full BOO financing closed; construction commences |
| Phase Initial COD | Q2 2028 | T0 + 24 months | 400 TPD operational; 132,000 TPY throughput. First Beneficiation Fee obligations begin. |
| First Circular Royalty™ payment | Q3 2029 | T0 + 37 months | 13 months after Phase Initial COD; rolling royalty commences |
| Phase Medium full operations | Q4 2029 | T0 + 42 months | 800 TPD; 264,000 TPY |
| Phase Expanded full operations | Q4 2031 | T0 + 60 months | 1,200 TPD; 396,000 TPY; full system economics |
Carbotura standard deployment schedule. T0 assumed January 2026 for planning purposes; subject to Term Sheet phase verification and authorization timing. All dates ESTIMATED.
Community Value Stack
§7.1 — Direct Fiscal Effects (State Treasury / RIRRC)
| Fiscal Effect | Phase Initial | Phase Expanded | Mechanism | Status |
|---|---|---|---|---|
| Sludge displacement cost avoidance (post-2027) | ~$5.2–7.5M/yr | ~$12M+/yr | Versus out-of-state rail/truck at $89–160/ton for displaced volumes | ESTIMATED |
| Landfill life extension (diversion credit) | +5–8 years | +15+ years | 132K–396K TPY diverted from Central Landfill reduces capacity depletion rate | ESTIMATED |
§7.2 — Regional Economic Effects
| Economic Effect | Phase Initial | Phase Expanded | Status |
|---|---|---|---|
| Direct employment — facility operations | 120 FTE | 360 FTE | ESTIMATED |
| Indirect employment — regional supply chain | 360 jobs | 1,080 jobs | ESTIMATED |
| Annual regional economic impact | ~$28M | ~$84M | ESTIMATED |
| Carbon displacement | ~160,000 tCO₂e/yr | ~480,000 tCO₂e/yr | ESTIMATED |
| RI Act on Climate alignment | ACM material outputs displace carbon-intensive industrial production; consistent with RI 45% GHG reduction target by 2030 | VERIFIED | |
Regional economic effects are separate from and in addition to direct fiscal effects. Combining them would misrepresent the community's fiscal position. Employment and economic figures: Carbotura standard parameters scaled to 120 direct FTE per 400 TPD module. ESTIMATED
Why This Works in Rhode Island
- Volume alignment. Rhode Island generates approximately 895,000 TPY of identifiable manufacturing feedstock across four confirmed streams. Phase Expanded at 1,200 TPD requires 396,000 TPY — 44% of identified feedstock. Phase Initial at 400 TPD requires 132,000 TPY — 14.8% of identified feedstock. Volume sufficiency is not a constraint at any phase.
- Infrastructure alignment. The Priority 1 site — the RIRRC Johnston campus — has the feedstock aggregation mechanism built in by statute. R.I. Gen. Laws § 23-19 requires all 39 municipalities to deliver residential waste to Johnston. An ACM facility on or adjacent to the RIRRC campus receives its primary feedstock stream at zero transport cost. No other state in the programme offers this degree of feedstock co-location certainty.
- Contract timing alignment. The 2027 Synagro contract expiry at Woonsocket is a hard, publicly documented deadline. A Joint Working Group phase authorized in Q2 2026 produces a Phase Initial COD of Q2 2028 under the Carbotura standard schedule — before full sludge system collapse. The deployment window is not a projection; it is a demonstrated timeline against a fixed external event.
- Policy alignment. Rhode Island's combustion-based WTE prohibition has created a structural disposal gap for four decades. This prohibition targets NAICS 562213 (Solid Waste Combustion & Incineration) — it does not apply to ACM. ACM's Microwave Catalytic Reforming (MCR) process operates in a closed, oxygen-free (anoxic), sub-atmospheric environment: combustion is mechanistically excluded by design. ACM is classified NAICS 325180 (Other Basic Inorganic Chemical Manufacturing), 325998 (All Other Misc. Chemical Product Manufacturing), 327992 (Ground or Treated Mineral and Earth Manufacturing), 331110 (Iron and Steel Mills and Ferroalloy Manufacturing), 331314 (Secondary Smelting and Alloying of Aluminum), and 331492 (Secondary Smelting, Refining of Nonferrous Metal). Rhode Island's RIDEM reviews ACM under manufacturing facility permitting — not solid waste facility regulations. Manufacturing classification (NAICS 31–33) — grounded in RCRA §1004(27) and 40 CFR §261.2(e) — eliminates the "discarded material" predicate at title transfer under the Circular Supply Agreement. ACM's internal hydrogen is generated to power the facility and returns as net-positive ultrapure water — not sold externally, not eligible for § 45V; Ash Carbonation (CaO + CO₂ → CaCO₃) qualifies for § 45Q Carbon Capture Credits; domestic battery-grade synthetic graphite and critical minerals production qualifies for § 45X Advanced Manufacturing Production Credits — all requiring manufacturing NAICS classification. RI's Act on Climate (45% GHG reduction by 2030) and the 100% renewable energy standard by 2033 further align with ACM's carbon capture profile and recovered-mineral output.
- Organic mandate and regulatory driver. The Synagro 2027 deadline is the defining regulatory driver for this proposal. RIDEM's own administrator has confirmed that the entire state relies on the Woonsocket incinerator as a sludge disposal option. Rhode Island's food waste ban (2016) and mandatory recycling targets further compress acceptable disposal options. ACM absorbs contaminated and mixed streams that recycling facilities reject.
- Economics specificity. The Beneficiation Fee of $100/ton is set at the Carbotura standard floor — applied here because Rhode Island's blended FWDC of $101.67/ton produces a formula result ($96.67) below the $100 floor. This is the minimum possible Beneficiation Fee under the standard framework, and it is below the verified out-of-state sludge disposal rate of $160+/ton already being paid by West Warwick today. The economic case does not depend on projection — it is verifiable against existing procurement costs paid in the current fiscal year.
Appendix A — Data Basis
- Beneficiation Fee ($100/ton): User-specified; confirmed against FWDC formula result. Source: Carbotura registry lock.
- FWDC ($101.67/ton MODELED): Derived from RIRRC tipping fee schedule (FY2023 $54/ton municipal, extrapolated); West Warwick sludge disposal cost (RI Current, February 2026, $160+/ton verified); RIRRC commercial rate (~$115–130/ton estimated). Full derivation: Waste Study §3.3.
- Circular Royalty™ parameters: Carbotura standard defaults — locked per MI v3.0. No external source required.
- CapEx formula: Carbotura standard — $75M first 100 TPD + $57.5M per additional 100 TPD. Locked per MI v3.0.
- Site candidates: P1 — RIRRC (rirrc.org); P2 — ProvPort (provport.com); P3 — Quonset Development Corporation (quonset.com). Driving distances: Google Maps estimates, March 2026.
- 2027 Synagro deadline: Valley Breeze (March 2026); Rhode Island Current (September 2025). Contractual expiry confirmed via public reporting.
- WTE prohibition: ecoRI.org (April 2025). Statutory reference: Rhode Island General Assembly.
- Employment / economic impact: Carbotura standard parameters scaled at 120 direct FTE per 400 TPD module. ESTIMATED.
- Carbon displacement: Carbotura standard parameters. ESTIMATED.
Appendix B — Selective Glossary
- BOO — Build-Own-Operate
- A project delivery structure in which Carbotura designs, finances, constructs, owns, and operates the ACM facility at no capital cost to the State. Rhode Island's sole financial obligation is the per-ton Beneficiation Fee.
- Circular Royalty™
- A structured per-ton cash payment from Carbotura to the State, calculated as Royalty(m+13) = TMC(m) × Royalty_Rate(m). Base rate: 120% of the current-year Beneficiation Fee. Escalates +1pp/year. Payment lag: 13 months. At steady state, designed to exceed the Beneficiation Fee on a per-ton basis.
- CSA — Circular Operating Agreement
- The 30-year commercial contract governing feedstock delivery, Beneficiation Fee, Circular Royalty™ payments, and operational parameters between Carbotura and the State.
- FWDC — Fully Weighted Disposal Cost
- The blended per-ton cost of disposing of all feedstock streams under current system economics. For Rhode Island, FWDC = $101.67/ton (MODELED). Used as the reference for Beneficiation Fee formula. Derivation disclosed in Waste Study §3.3.
- Gross Cost Displacement
- The annual reduction in disposal cost resulting from substituting the Beneficiation Fee for the FWDC. In Year 1, Rhode Island's gross cost displacement is approximately +$0.53/ton (FWDC $101.67 minus TMC $100.00 = $1.67/ton, plus transport savings where applicable). Quantified separately from Circular Royalty™ cash flow.
- Fiscal Flows, Shown Separately
- The sum of gross cost displacement plus Circular Royalty™ payments minus Beneficiation Fee obligations, expressed per ton and in total annual dollars. Year 1: −$100/ton (pre-royalty).
- Pre-Royalty Period
- Months 1–12 following first feedstock delivery. During this period, the State pays the Beneficiation Fee and receives zero Circular Royalty™. The first Circular Royalty™ payment arrives in Month 13, covering the first month's TMC payment at 120% of that amount.
- Beneficiation Fee — Total Materials Conversion Fee
- The per-ton fee paid by the State to Carbotura for converting feedstock into industrial products. Formula: MAX($100, MIN($150, FWDC − $5)). For Rhode Island: $100/ton (floor applies; FWDC − $5 = $96.67 < $100 floor). Escalates 2.5%/year.