San Diego County faces a disposal capacity cliff with no conventional replacement on any planning horizon — and the only instrument that resolves it, locks disposal costs, and generates a compounding Circular Royalty™ stream requires a single decision: Execute the LOI/MOU.

Executive Brief · ~10 min read · DOC 04 OF 06

What this document is

The action instrument. This brief distills the Waste Study, Proposal, and EIR into a single decision frame. It names the three configuration options, quantifies the fiscal timeline, states what delay costs, and presents one call to action: Execute the LOI/MOU. No new numbers are introduced here.

Three things this document says
  1. Miramar Landfill — the county’s only municipal disposal facility — closes around 2031. Gregory Canyon is canceled. No replacement is permitted, sited, or in the pipeline. This is the defining structural constraint.
  2. ACM deployment converts the county’s disposal liability into a manufacturing asset: a locked Beneficiation Fee that replaces rising landfill costs, and a Circular Royalty™ that exceeds the fee from Year 2 onward, compounding for 30 years.
  3. Every month T0 is delayed compresses the buffer between Phase Initial Commercial Operations Date and Miramar’s closure — without preserving any additional optionality. The decision window is now.
01

The Situation

San Diego County generates approximately 8,767 tons per day of manufacturing feedstock — a figure that accounts for every material stream currently classified as waste, from residential collection to commercial loads to construction and demolition material. Every ton of this stream that cannot be diverted flows to one of four county landfills, of which only one — West Miramar Sanitary Landfill, operated by the City of San Diego’s Environmental Services Department — remains under municipal control. That facility closes around 2031.

At Miramar’s closure, Republic Services controls all three remaining active county landfills: Sycamore (East County), Otay (South County), and Borrego (desert). With no municipal counterbalance, gate pricing becomes unilateral. The Fully Weighted Disposal Cost — already estimated at $125/ton and rising at approximately 3% per year — has no structural floor post-2031 under State A conditions.

Gregory Canyon Landfill, the county’s only proposed replacement capacity, was permanently canceled in 2016 when the Pala Band of Mission Indians acquired the site. No successor siting process exists. No waste-to-energy or resource recovery facility of any kind operates anywhere in San Diego County. The disposal pathway is narrowing with no conventional alternative in development.

02

The Decision

Carbotura offers a single commercial structure: the Circular Supply Agreement (CSA) — Beneficiation Fee (TMC Fee) plus Circular Royalty™. The only decision at LOI/MOU is which deployment configuration — the capacity tier. The Exogenesis™ Royalty is a CSA add-on, subject to Waste Characterization Study.

2.1 CSA Commercial Structure

The Circular Supply Agreement (CSA)
Circular Royalty™
Beneficiation Fee (TMC Fee) paid per ton; Circular Royalty™ received from 13 months after corresponding Beneficiation Fee payment. Two independent transactions, never netted.

Beneficiation Fee$100/ton, +2.5%/yr
Royalty rate120% of BFₙ, +1pp/yr
Y30 royalty rate148% of BFₙ
Site treatmentCounty retains ownership
Exogenesis™ add-onAvailable
CSA Add-On — Stacks Alongside the Circular Royalty™
Exogenesis™ Royalty · Legacy Landfill Stream
A structured separate royalty stream for legacy material remediation at qualifying landfill sites. $50/ton extracted, +1%/yr. Miramar (approaching 2031 closure) and Republic Services facilities (Sycamore, Otay, Borrego) are candidate sites — eligibility subject to Waste Characterization Study.

Payment$50/ton extracted, +1%/yr
RecipientDirect to San Diego County
Stacks withCircular Royalty™
TriggerWaste Characterization Study confirmation

2.2 Deployment Configuration

The configuration governs capacity only. Every configuration operates under the same CSA commercial structure.

Configuration A — Phase Initial
Initial Deployment
500 TPD
1 × 500 TPD ACM facility · 182,500 TPY

BF Year 1$18.25M/yr
Royalty Year 1 rate$21.90M/yr
+$3.42M/yr
Direct FTE~125
CODT0 + 24 mo
Configuration C — Full Network
Four-Facility County Network
2,000 TPD
4 × 500 TPD ACM facilities · 730,000 TPY

BF Year 1$73.00M/yr
Royalty Year 1 rate$87.60M/yr
Direct FTE~500
Final CODT0 + 60 mo

All financial figures ILLUSTRATIVE · BF $100/ton VERIFIED · Royalty at Year 1 = 120% × BFₙ (Release 28 canonical formula; multiplier on current-year BF) · Config figures shown under the CSA · CSA minimum 30-year term; perpetual absent Non-Renewal Notice. is a differential between two independently reported gross transactions — the Beneficiation Fee and the Circular Royalty™ — and is not a netted position.

The configuration decision (A/B/C) is made at LOI/MOU execution and does not foreclose scale-up. The CSA includes phased expansion provisions enabling the county to transition between configurations via Joint Working Group amendment. The choice is which deployment scale to begin with — not a ceiling on future scope.

03

Fiscal Timeline — Four Periods

“Gross cost displacement and Circular Royalty™ cash flow are quantified separately. 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.”

Year 1 — Pre-Royalty
−$100/ton
Beneficiation Fee only. $0 royalty. Designed feature of CSA structure. Concurrent avoided disposal cost ($125/ton ESTIMATED) offsets the fee in real terms.
13 months after corresponding Beneficiation Fee payment — Royalty Ramp
+$120/ton
Rolling Circular Royalty™ commences at $120/ton. Royalty timing: 13 months after corresponding Beneficiation Fee payment (CSA Art. 1.5).
Year 2+ — Steady State
$87.60M/yr
Circular Royalty™ at $120/ton on Config C volume (730,000 TPY), reported separately from the Beneficiation Fee. The rate escalates every year of the term (ILLUSTRATIVE · Release 28 formula).
Year 30 — CSA Horizon
$115M/yr
Annual Circular Royalty™ at Year 30 (ILLUSTRATIVE). CSA continues perpetually absent Non-Renewal Notice. Non-Renewal Notice window: Year 28 from COD; earliest exit Year 30.
Fiscal Position Through the CSA Term — Configuration C (2,000 TPD)
Beneficiation Fee (blue), Circular Royalty™ (emerald), and avoided disposal cost (amber) — three independent gross figures, never netted.
ILLUSTRATIVE · Release 28 formula (canonical) · State A FWDC at 3%/yr CPI · Not contractual commitments
04

Key Facts

MetricValueConfigBasis
Addressable feedstock2,000 TPD / 730,000 TPYConfig CESTIMATED
Beneficiation Fee — Year 1$100.00/ton ($73.00M/yr)Config CVERIFIED
BF escalation2.5%/yr compoundingAllLOCKED
State A FWDC (planning basis)$125/ton ($91.25M/yr avoided)Config CESTIMATED
Circular Royalty™ — Year 1 rate$120.00/ton ($87.60M/yr)Config CLOCKED
(differential between two independently reported gross transactions; not a netted position)+$13.66M/yrConfig CILLUSTRATIVE
30-yr cumulative Circular Royalty™~$1,088MConfig CILLUSTRATIVE
Phase Initial CODT0 + 24 monthsAllPROVISIONAL
First Circular Royalty™ paymentT0 + 37 monthsAllPROVISIONAL
Miramar closure — capacity cliff~2031 (~60 months from Q3 2026)VERIFIED
Direct manufacturing employment~125 / ~250 / ~500 FTEA / B / CESTIMATED
Carbon avoidance (Config C)~1,140,000 tCO₂e/yrConfig CESTIMATED
CSA minimum term30 years from Phase Initial COD; perpetual absent Non-Renewal NoticeAllLOCKED
Non-Renewal Notice windowYear 28 from COD; earliest exit Year 30AllLOCKED

ILLUSTRATIVE figures: computed under Release 28 canonical formula (multiplier on BFₙ, current-year escalated Beneficiation Fee). Figures are not contractual projections; Term Sheet execution required.

05

What Delay Costs

The irreversibility instrument: Miramar Landfill closure (~2031)

Miramar Landfill’s closure is the single most consequential irreversibility event in San Diego County’s waste management timeline. It is verified, it has a defined date, and it is not reversible. At closure, every ton of residual waste that currently flows to a municipally-operated facility transfers to Republic Services’ sole-operator private market.

Under a standard deployment schedule, LOI/MOU execution in Q3 2026 places Phase Initial Commercial Operations Date (T0 + 24 months) at approximately Q3 2028 — approximately 33 months ahead of Miramar’s ~2031 closure. That buffer provides time to establish ACM operations, onboard hauler routes, and build operational confidence before the closure event.

A 12-month delay to LOI/MOU execution reduces that buffer to 21 months. A 24-month delay eliminates it entirely — Phase Initial COD would coincide with the closure event rather than preceding it. Beyond 24 months of delay, the county is reacting to the closure rather than preparing for it.

Delay does not preserve optionality. The CSA Non-Renewal Notice window opens at Year 28 from COD regardless of when LOI/MOU execution occurs. A later start date does not create additional flexibility — it consumes the earliest available exit window without any benefit. The risk asymmetry is one-directional: executing the LOI/MOU preserves options; delaying it forecloses the pre-closure buffer without creating any new ones.

06

Call to Action

San Diego County — ACM Engagement

Decision window · Q3 2026
Execute the LOI/MOU by Q3 2026
Review the full package →
To initiate the LOI/MOU process, contact Carbotura via the CIP engagement portal or through your assigned Relationship Manager.

LOI/MOU execution initiates the Term Sheet phase, during which every PROVISIONAL and ESTIMATED registry value is confirmed through direct data access and site investigation. The Term Sheet produces the final economic and legal terms that become CSA appendices. CSA execution (= T0) starts the deployment clock. Phase Initial COD: T0 + 24 months.

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Source basis: All figures in this brief trace to the San Diego County Assumption Registry (LOCKED WITH WARNINGS, July 2026) and the three preceding package documents (Feedstock System Study, Deployment Proposal, Economic Impact Report). No new values are introduced here. VERIFIED: Miramar FY2026 gate rate (City of SD ESD fee schedule) · operator names (CalRecycle SWIS + RWQCB) · Miramar closure ~2031 (CalRecycle permit) · Gregory Canyon cancellation (Pala land acquisition, 2016). ESTIMATED: feedstock volume (CalRecycle CIWMP 2022) · FWDC $125/ton (modeled). LOCKED: Beneficiation Fee $100/ton (Architect directive) · royalty formula (Release 28 canonical) · CSA term. ILLUSTRATIVE: all royalty dollar figures (Release 28 formula; not contractual until Term Sheet).