Economic Impact Review — York County, PA

Economic Impact Review · York County, PA

/ton from Day 1

Gross Cost Displacement

−$10.95M

Pre-Royalty Period

+$1.92M

Post-Royalty Onset

+$9.71M

Steady-State (Phase Initial)

Inherited Confidence Flags — From Waste Study & CSA Terms

FWDC: $83/ton — Upgraded to Verified (YCSWA 2025 official budget notice). Original registry status ESTIMATED; no longer applies.
Beneficiation Fee (TMC Fee): $75/ton — Contracted. Executed agreement. No estimation applied.
Phase Initial volume (400 TPD / 146,000 TPY) — Contracted. Executed agreement.
P1 site (Manchester Twp HI Zone) — Confirmed via lease. PADEP permitting in process.
Phase Medium / Expanded feedstock sourcing basis — Estimated. Regional partnerships not yet confirmed. Term Sheet phase deliverable.
Waste stream composition detail — Estimated. Exact stream breakdown is a Term Sheet phase deliverable.
Phase Initial COD H2 2027 — Accelerated 18-month build schedule vs. Carbotura standard 24 months. PADEP permit timing is critical path.
ASR generator — Not confirmed. No major auto shredder residue source identified in York County. Excluded from Phase Initial feedstock basis.

Section 1

Introduction & Summary

§1.1 — What This Report Measures

This Economic Impact Review models the delta between two defined states for York County's contracted 400 TPD feedstock stream:

State	Definition	Source
State A — Current System	York County's contracted feedstock volume continues through the existing YCSWA disposal system: WTE (YCRRC at $83/ton tipping fee), with residual streams routed to Modern Landfill. No ACM facility. No Circular Royalty™. No BOO capital.	Waste Study — locked values
State B — With Carbotura	400 TPD (Phase Initial) delivered to the ACM facility under the executed 30-year CSA. YCSWA pays Beneficiation Fee (TMC Fee) of $75/ton. Carbotura pays Circular Royalty™ from 13 months after corresponding Beneficiation Fee payment. BOO structure: zero YCSWA capex.	CSA Terms EIR Input Block — locked values

Neither state is re-diagnosed in this document. State A values are taken from the Waste Study. State B values are taken from the CSA Terms EIR Input Block exclusively.

§1.2 — Summary Table

Factor	State A	State B — Year 1	State B — Year 2+
Annual disposal cost (400 TPD basis)	$12,118,000/yr ($83/ton)	$10,950,000/yr (Beneficiation Fee only)	$10,950K+ TMC; $13,140K royalty received
Gross cost displacement (Day 1)		+$1,168,000/yr ($8/ton × 146K TPY)	+$1,168,000+/yr (conservative flat)
YCSWA capital obligation	Ongoing: YCRRC capex/upgrade reserves	$0 — BOO structure	$0
Key data gaps	Phase M/E feedstock sourcing; exact composition; PADEP permit timing
Schedule milestone	PADEP permit approval by Q2 2026 → construction start Q2 2026 → H2 2027 COD. Year 2 Circular Royalty™ runs approximately $2.7M per quarter.
Classification (RPT)	ACM permitted only under NAICS 325180 / 325998 / 327992 / 331110 / 331314 / 331492 (manufacturing). Solid waste codes (562213 / 562219) are expressly excluded. Both parties commit to the RPT pathway; the endpoint is categorical — manufacturing classification across all permitting, licensing, and regulatory contexts. Interim bridging authorities may apply during the transition. Federal basis: RCRA §1004(27) · 40 CFR §261.2(e).		Standing condition · MR §3

§1.3 — Fiscal vs. Regional Economic Separation

Required declaration: YCSWA fiscal receipts (Beneficiation Fee obligations, Circular Royalty™ cash flows, gross cost displacement) and regional economic effects (employment, supply chain activity, tax base impact) are distinct categories. They are reported separately in §4 and §5 respectively and must not be combined into a single figure. Circular Royalty™ is a direct YCSWA fiscal receipt. Employment and economic multiplier effects are regional economic impacts, not county fiscal receipts.

Section 2

State A Baseline

Source: Waste Study (locked values). No new diagnosis in this section.

§2.1 — Feedstock Volume & Disposition (State A)

Stream	TPD	TPY	Current Disposition	State A Cost
Contracted MSW (YCSWA)	400	146,000	YCRRC — WTE (Reworld Waste Services)	$83/ton × 146,000 = $12,118,000/yr Verified
Additional MSW	~700	~255,000	YCRRC — WTE	$83/ton (same rate) Estimated volume
WTE Ash Residue	~185	~67,000	Modern Landfill (Republic Services)	$50–75/ton Estimated
C&D Waste	~125	~45,000	Modern Landfill	$60–90/ton Estimated

§2.2 — State A Cost Structure

Cost Element	Annual (Phase Initial basis)	Source Type
YCRRC tipping fee — contracted 400 TPD	$12,118,000	Verified
WTE ash disposal (Modern Landfill)	~$3,350,000–$5,025,000 est.	Estimated
Transfer station overflow costs (post-Q4 2026)	TBD — structural gap, not quantified	Data gap
Out-of-county disposal premium (when Modern LF closes)	+$15–25/ton on diverted streams	Estimated

§2.3 — State A Cost Trajectory

Three mechanisms drive upward State A cost pressure: (1) YCSWA tipping fee escalation — raised to $83/ton in 2025, with further increases signaled; (2) Modern Landfill capacity constraint — reduced intake forces YCSWA to pay out-of-county disposal premiums of $15–25/ton for overflow streams; (3) YCRRC capital reinvestment — RACT III NOx compliance and system upgrades funded through tipping fee revenue, accelerating the rate escalation path. State A cost per ton for the contracted 400 TPD stream is $83/ton today and rising.

§2.4 — State A Environmental & Structural Position

In State A, 146,000 TPY of feedstock is combusted at the YCRRC (WTE), generating approximately 20,000–27,000 tons of ash residue annually requiring secondary landfill disposal. The WTE process is the county's designated disposal method under YCSWA flow control; no alternative processing pathway for this volume is contracted. Three EPA Superfund sites document the historical consequence of inadequate alternative infrastructure investment in York County.

Section 3

State B Deployment Baseline

Source: CSA Terms EIR Input Block exclusively. All values locked.

§3.1 — Inherited Flags (State B)

Phase Initial (400 TPD): fully contracted, site confirmed under lease, PADEP permitting in process. All Phase Initial financial figures carry Contracted or Verified status. Phase Medium (1,000 TPD) and Phase Expanded (2,000 TPD) figures carry Estimated status pending feedstock volume confirmation and YCSWA volume amendment.

§3.2 — Deployment Configuration

Phase	TPD	Modules	TPY	COD	CapEx (Carbotura)
Phase Initial	400	ceil(400÷100) = 4	146,000	H2 2027	$247.5M
Phase Medium	1,000	ceil(1000÷100) = 10	365,000	~Q1 2030	+$345.0M incremental
Phase Expanded	2,000	ceil(2000÷100) = 20	730,000	~Q3 2031	+$575.0M incremental

§3.3 — Economic Terms (State B)

Parameter	Value	Status
Beneficiation Fee (TMC Fee) Year 1	$75.00/ton	Contracted
Beneficiation Fee (TMC Fee) escalator	2.5%/year	Carbotura standard
Circular Royalty™ base rate	120% of that year's Beneficiation Fee (TMC Fee)	Contractual
Royalty escalator	+1 percentage point/year	Contractual
Royalty payment lag	13 months after corresponding TMC payment	Contractual
YCSWA capital obligation	$0	BOO structure
Annual TMC obligation (Phase Initial, Y1)	$10,950,000	Derived
Annual Royalty (Phase Initial, Y2)	$13,140,000	Derived

§3.4 — Residual Obligations (State B)

Under the BOO structure, all ACM facility residual streams are Carbotura's sole operational and financial responsibility. YCSWA has no liability for ACM process residuals, secondary treatment requirements, or regulatory compliance at the facility level. This is a structural improvement over State A, where YCRRC ash residue disposal is YCSWA's direct cost obligation.

§3.5 — Timeline Anchoring (State B)

Phase Initial COD: H2 2027 (Q3 2027 target). First Beneficiation Fee (TMC Fee): ~Q3 2027. First Circular Royalty™: ~Q4 2028 (13 months after first TMC payment). Pre-royalty period: H2 2027 through ~Q4 2028 (~13 months). Phase Medium and Expanded timelines carry ESTIMATED status.

§3.6 — Phase Delta Map — State A vs. State B

Geographic comparison of waste infrastructure under State A (current system) and State B (with Carbotura ACM facility). Click any location in the panel to navigate the map.

Phase Delta — State A → State B

State A — Current System

York County Resource Recovery Center

WTE · 1,344 TPD · $83/ton · Reworld Waste Services

Modern Landfill

Active · intake reduced >40% · terminal capacity decline · Republic Services

York City WWTP

Active · PA American Water · biosolids land-applied

YCSWA Transfer Station

Under construction · Q4 2026 · overflow routing only

State B — With Carbotura

ACM Facility — Priority 1 Site

Manchester Twp HI Zone · Leased · Permitting · 400 TPD Phase Initial · H2 2027

WTE/RRF Landfill WWTP Transfer ACM Site (B)

State A infrastructure verified March 2026. State B site confirmed under lease; PADEP permitting in process.

Section 4

Delta Analysis

§4.1 — Three Delta Components

The fiscal delta between State A and State B consists of exactly three components, each of which must be stated separately:

#	Component	Direction	Mechanism
1	Gross Cost Displacement	Positive from Day 1	$83/ton State A disposal cost − $75/ton Beneficiation Fee (TMC Fee) = $8/ton × 146,000 TPY = $1,168,000/yr (Year 1 basis, conservative flat)
2	Circular Royalty™ Cash Flow	$0 Year 1; Positive Year 2+	Royalty(m+13) = TMC(m) × Royalty_Rate(m). Year 1 = $0; Year 2 = $13,140,000; growing annually to $32,355,000 in Year 30
3	Residual Obligation	Positive (cost elimination)	ACM facility residual streams are Carbotura's sole obligation — eliminating YCSWA's current WTE ash disposal cost to Modern Landfill for the contracted stream

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

§4.1 — Phase-by-Phase Comparative Table

Item	Phase Initial Y1	Phase Initial Y2	Phase Initial Y30
State A annual cost (disposal only)	$12,118,000	$12,118,000+	Escalating
Beneficiation Fee obligation	$10,950,000	$11,224,000	$22,299,000
Gross cost displacement	+$1,168,000	+$1,168,000	+$1,168,000+
Circular Royalty™ received	$0 (pre-royalty)	$13,140,000	$32,355,000
Capital obligation (YCSWA)	$0	$0	$0

§4.3 — Pre-Royalty Period Separation (Required)

Year 1 and post-13 months after corresponding Beneficiation Fee payment periods have materially different fiscal characteristics. They must not be combined.

Year 1 (H2 2027 – ~Q4 2028): YCSWA pays the Beneficiation Fee (TMC Fee) ($10,950,000) and receives zero Circular Royalty™. This is the pre-royalty period — a structurally defined, finite cost window.

From 13 months after corresponding Beneficiation Fee payment (~Q4 2028): The Circular Royalty™ begins on a rolling basis.

"Circular Royalty™ payments begin 13 months after corresponding Beneficiation Fee (TMC Fee) payments and ramp to full run-rate on a rolling basis."

§4.4 — 30-Year Gross Cost Displacement

Year	Beneficiation Fee (TMC Fee)/ton	FWDC (est. flat $83)	Displacement/ton	Annual Displacement	Cumulative Displacement
1	$75.00	$83.00	$8.00	$1,168,000	$1,168,000
2	$76.88	$83.00	$6.12	$894,000	$2,062,000
5	$82.73	$83.00	$0.27	$39,000	$4,212,000
6+	>$83.00	$83.00 (conservative flat)	TMC exceeds flat FWDC — see note	See note	See note

Note: Using a conservative flat $83/ton FWDC, the Beneficiation Fee (TMC Fee) escalating at 2.5%/yr overtakes the flat FWDC in Year 6. In practice, YCSWA's tipping fee has escalated annually; if FWDC escalates at ≥2.5%/yr (consistent with recent history), gross displacement persists throughout the 30-year term.

§4.5 — 30-Year Circular Royalty™ Table (Phase Initial)

Year	Beneficiation Fee (TMC Fee)/ton	Annual TMC	Royalty/ton	Annual Royalty
1	$75.00	$10,950,000	$0	$0
2	$76.88	$11,224,000	$90.00	$13,140,000
3	$78.80	$11,504,000	$93.02	$13,581,000
5	$82.73	$12,079,000	$99.35	$14,505,000
10	$93.68	$13,677,000	$116.98	$17,079,000
15	$106.15	$15,498,000	$137.51	$20,076,000
20	$119.60	$17,462,000	$161.42	$23,567,000
25	$135.31	$19,755,000	$189.25	$27,631,000
30	$152.74	$22,299,000	$221.61	$32,355,000

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.

State B Fiscal Position — Three Gross Items, Years 1–20

State B converts disposal cost into Beneficiation Fee (Beneficiation Fee (TMC Fee)) plus royalty income. All three items shown gross. Year 1 is cost-only; Year 2 onward royalty income exceeds Beneficiation Fee (TMC Fee).

Avoided disposal cost Beneficiation Fee (TMC Fee) paid Circular Royalty™ received

$83.00

Avoided disposal · Year 1

$75.00

Beneficiation Fee (TMC Fee) paid · Year 1

$90.00

Royalty received · Year 2

Source: Carbotura delta model · Registry values · State B per CSA Terms EIR Input Block — FWDC $83/ton VERIFIED; TMC $75/ton CONTRACTED; Royalty 120% Y1 +1pp/yr. Phase Initial 146,000 TPY.

"At steady state, the Circular Royalty™ is designed to exceed the Beneficiation Fee (TMC Fee) on a per-ton basis."

Section 5

System-Level Impact

§5.1 — Employment Delta

Required declaration: Employment figures below are regional economic impacts, not York County fiscal receipts. They represent jobs created in the regional economy and are distinct from the YCSWA fiscal analysis in §4.

Category	State A	State B — Phase Initial	Delta
Direct permanent jobs (ACM facility)	0 (no new facility)	40 FTE	+40 FTE
Indirect / induced jobs (2.5× multiplier)	0	~100 jobs	+~100 jobs
Annual regional economic impact	$0 (incremental)	~$38M/yr	+~$38M/yr
Construction employment (18-month build)	0	~120–160 FTE (temporary)	+~120–160 temporary

§5.2 — Environmental Delta

The following environmental performance figures are stated on a designed-for basis, consistent with Carbotura standard parameters. Actual performance is confirmed during Term Sheet phase verification and validated during operations.

Metric	State A	State B (Phase Initial)	Delta
Carbon emissions avoided (MT CO₂e/yr)	0 additional avoidance	~132,000 MT CO₂e/yr	+132,000 MT CO₂e/yr
Landfill diversion (TPY)	0 from contracted stream	146,000 TPY	+146,000 TPY
Industrial water recovery	None	~7.3M gal/yr	+7.3M gal/yr
WTE ash residue eliminated (contracted stream)	~20,000–27,000 TPY to landfill	0 (ACM processes ash streams)	~20K–27K TPY landfill avoidance

§5.3 — PFAS Structural Delta

State A routes MSW through the YCRRC WTE process, which generates combustion gases requiring continuous air emissions monitoring (YCRRC is subject to 24/7 DEP-linked emissions monitoring). PFAS compounds in MSW feedstock may be present in WTE air emissions and ash leachate — currently managed under PADEP permit compliance. State B subjects feedstock to characterization during Term Sheet phase verification stage; ACM's manufacturing process handles feedstock in a non-combustion pathway with different emissions profile. PFAS regulatory evolution (EPA MCLs for PFAS in water) represents a regulatory risk to the State A system's ash disposal pathway at Modern Landfill; this risk does not transfer to YCSWA under the State B BOO structure.

§5.4 — No-Fallback Analysis

No-Fallback Condition

York County has no confirmed long-term disposal pathway for overflow waste beyond Modern Landfill's indeterminate operational horizon. YCSWA's 2026–2039 RFP produced no publicly announced alternative capacity contract for the full volume. The transfer station under construction adds routing flexibility, not processing capacity. In a no-fallback scenario — Modern Landfill closure with no alternative contracted — YCSWA's marginal disposal cost for overflow streams increases by $15–25/ton in out-of-county transport premiums. State B's ACM contract eliminates this fallback risk for the contracted 400 TPD, regardless of Modern Landfill's closure timing.

Section 6

Risk & Sensitivity

§6.1 — Structured Risk Register

#	Risk	State	Impact	Likelihood	Mitigation
1	PADEP permit delay	B	COD slip; royalty onset deferred ~$2.7M/quarter	Moderate	Active permitting; Carbotura responsible
2	Modern Landfill accelerated closure	A	Ash/C&D disposal cost surge +$15–25/ton; no fallback	Moderate–High	ACM contract eliminates risk for contracted stream
3	FWDC escalation faster than TMC escalator	A	State A costs rise faster than modeled; ACM economics improve	Moderate (favorable to B)	No YCSWA action needed; improves B position
4	FWDC flat or declining	A/B	Reduced gross cost displacement in later years	Low (counter to recent trend)	—
5	ACM throughput below contract spec	B	Reduced Beneficiation Fee (TMC Fee) billings; reduced royalty base	Low for YCSWA	BOO — Carbotura's operational obligation; YCSWA pays only per ton processed
6	Phase M/E feedstock not confirmed	B	Expansion phases delayed; value stack limited to Phase Initial	Moderate	Term Sheet phase deliverable; Phase Initial economics standalone
7	YCSWA executes alternate disposal contract for overflow streams	B	Phase M/E feedstock locked into competing contract	Moderate	Phase Initial unaffected; Phase M/E amendment timing
8	PFAS regulatory tightening	A	Ash disposal at Modern Landfill may require enhanced liner compliance; cost increase	Moderate (regulatory trend)	Transitions to Carbotura under State B BOO
9	Royalty payment timing (counterparty)	B	Royalty delay if Carbotura liquidity issue	Low	CSA includes payment terms and remedies; Term Sheet phase verification validates counterparty
10	Construction cost escalation (Carbotura)	B	Carbotura's cost — not YCSWA's. Zero YCSWA capex risk.	n/a for YCSWA	BOO — Carbotura's sole exposure

§6.2 — Feedstock Variability ±20%

Scenario	TPD	Annual TPY	TMC Y1	Royalty Y2
Base case	400	146,000	$10,950,000	$13,140,000
−20% volume	320	116,800	$8,760,000	$10,512,000
+20% volume	480	175,200	$13,140,000	$15,768,000

The economic structure is robust to volume variation at Phase Initial scale.

§6.3 — FWDC Sensitivity — Sign-Change Threshold

FWDC Sign-Change Threshold

The gross cost displacement component turns negative when the Beneficiation Fee (TMC Fee) exceeds the FWDC. At the 2.5%/yr TMC escalator, the Beneficiation Fee (TMC Fee) reaches $83/ton in approximately Year 5–6. However, the Circular Royalty™ becomes positive in Year 2 and grows at a rate that dominates the gross displacement effect. The economic case does not depend on gross cost displacement maintaining a positive sign.

§6.4 — Royalty Escalator Sensitivity

The contracted +1pp/yr escalator is the base case.

§6.5 — Timeline Slippage (T0 Delays)

Delay scenario	COD	First royalty	Cost of delay
No delay (base)	H2 2027	Q4 2028
1 quarter delay	Q1 2028	Q1 2029	~$2.7M forgone Year 2 royalty
2 quarter delay	Q2 2028	Q2 2029	~$5.4M forgone
4 quarter delay	H2 2028	Q4 2029	~$10.8M forgone

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.

Section 7

Timing Analysis

§7.1 — Binding Constraints (Named)

Three binding constraints determine the implementation timing:

Constraint	Instrument	Deadline	Consequence of Miss
1. PADEP Permit Approval	PADEP permit — ACM facility, Manchester Township	Q2 2026 (to maintain H2 2027 COD)	Each quarter delay = ~$2.7M forgone Year 2 royalty; COD slips to 2028+
2. YCSWA Alternate Disposal Contract	YCSWA 2026–2039 RFP — contracts effective Jan 1, 2026	Contract execution underway; Phase M/E volumes at risk once signed	Phase M/E volumes locked into alternative routing for contract duration; limits ACM expansion
3. Modern Landfill Closure	Republic Services operational decision; court order potential	Indeterminate; accelerated closure possible	YCRRC ash disposal cost surges; YCSWA's no-fallback position worsens

§7.2 — Schedule Constraints Table

Window	Opens	Closes	Key Action
PADEP Permit Approval Window	Now (Q1 2026 — in process)	Q2 2026 (H2 2027 COD requirement)	Permit approval and construction mobilization
Term Sheet phase verification confirmation	Q1 2026	Q2 2026	Stream composition, hauler routing, Phase M basis
Phase M/E volume amendment window	Now	Before YCSWA signs alt. disposal contracts for those volumes	YCSWA volume amendment to CSA for Phase M/E
CSA execution (30-year term begins)	Upon Phase Initial COD H2 2027	H2 2027	Royalty clock starts 13 months after corresponding Beneficiation Fee payment after COD

§7.3 — Irreversibility Mechanism

Irreversibility Finding — YCSWA 2026–2039 Disposal Capacity Contracts

The specific irreversibility instrument is the YCSWA 2026–2039 Municipal Solid Waste Disposal/Processing Capacity Agreement, for which contract execution was anticipated by May 2025 (contracts effective January 1, 2026). Once YCSWA executes long-term disposal contracts for MSW, ash residue, C&D waste, and sewage sludge volumes above the contracted 400 TPD, those streams are legally committed to alternative disposal pathways for the contract duration — potentially through 2039. The Phase Medium and Expanded ACM volumes cannot be sourced from those contractually committed streams without YCSWA executing an early termination or amendment. The 400 TPD Phase Initial contract is insulated — it is the basis of the executed agreement. Phase Medium and Phase Expanded volumes remain to be secured through YCSWA volume amendment before alternative disposal contracts are executed for those streams.

§7.4 — Optionality Matrix

Option	Available Now?	Available Q3 2026?	Available 2028?
Phase Initial COD H2 2027	Yes — permitting in process	Conditional on permit	No — timeline passed
Phase M/E volume amendment	Yes — window open	Conditional on YCSWA alt. contracts	Likely closed — alt. contracts signed
Term Sheet phase verification	Yes	Yes	Retrospective only
Full 30-year CSA economics	Yes	Conditional on H2 2027 COD	Reduced (shorter term remaining)

Section 8

Effects Summary

No new figures in this section. All values trace to preceding sections of this document.

§8.1 — Fiscal Effects Table

Fiscal Effect	Year 1 (Pre-Royalty)	Year 2+ (Post-Royalty Onset)	Year 30 (Steady-State)
Gross cost displacement	+$1,168,000	+$894,000–$1,168,000	Per sensitivity (§6.3)
Circular Royalty™ received	$0	+$13,140,000	+$32,355,000
Beneficiation Fee obligation	−$10,950,000	−$11,224,000	−$22,299,000
YCSWA capital obligation	$0	$0	$0

§8.2 — Regional Economic Effects

Required disclaimer: The following are regional economic effects, not York County fiscal receipts.

Phase Initial: 40 direct permanent FTE + ~100 indirect/induced jobs + ~$38M annual economic impact. Phase Expanded (2,000 TPD): 200 direct FTE + ~500 indirect jobs + ~$190M annual economic impact. Construction: ~120–160 temporary FTE over 18-month build.

§8.3 — Environmental Effects

Required disclaimer: Environmental performance figures are stated on a designed-for basis consistent with Carbotura standard parameters. Actual figures confirmed during Term Sheet phase verification and validated during operations.

Phase Initial: ~132,000 MT CO₂e/year avoided; 146,000 TPY landfill diversion; ~7.3M gal/year industrial water recovery; elimination of ash disposal for contracted stream at Modern Landfill.

§8.4 — Structural Effects

The BOO structure eliminates all capital exposure. The 30-year CSA term provides York County with a confirmed, contracted disposal pathway that satisfies Pennsylvania Act 101 10-year capacity planning obligations for the contracted volume. The ACM facility is positioned adjacent to the YCRRC logistics axis, requiring no new infrastructure investment by YCSWA.

§8.5 — Unresolved Data Gaps

Data Gap	Impact on Analysis	Resolution Path
Phase Medium / Expanded feedstock sourcing	Phase M/E financial figures carry ESTIMATED status; expansion value stack cannot be quantified precisely	Term Sheet phase verification; YCSWA volume amendment
Exact waste stream composition	ACM product yields unquantified at this stage	Term Sheet phase verification characterization
PADEP permit approval timeline	COD date and royalty onset date carry ±1–2 quarter uncertainty	Active permitting in process
YCSWA alternate disposal contract execution	Phase M/E volume availability depends on whether alternate contracts were signed before ACM volume amendment	YCSWA procurement status review
Modern Landfill operational horizon	Ash residue disposal cost trajectory uncertain beyond 2026	Monitor Republic Services operational decisions; Kreutz Creek litigation outcome

Appendix A

Sources & Methodology

Public-readable labels only. All Registry-derived figures traced to public source.

Item	Methodology / Source	Source Type
FWDC ($83/ton)	YCSWA official 2025 budget announcement; West Manchester Township public notice September 2024; ycswa.com	Verified
Beneficiation Fee (TMC Fee) ($75/ton)	Executed YCSWA/Carbotura feedstock agreement	Contracted
Royalty formula	Royalty(m+13) = TMC(m) × Royalty_Rate(m); 120% base; +1pp/yr; 13-month lag. Carbotura contractual standard.	Contractual
Phase sizing	Phase Initial 400 TPD contracted; Phase M/E from YCSWA addressable volume; module size 100 TPD (Carbotura standard)	Mixed — Phase I contracted; M/E estimated
Environmental performance	Carbotura standard parameters: ~33,000 MT CO₂e/yr per 100 TPD module. Designed-for basis.	Modeled
Employment figures	Carbotura standard: 10 direct FTE per 100 TPD module; 2.5× indirect multiplier	Modeled
Timeline basis	User-confirmed H2 2027 COD target; T0 = Q1 2026; 13-month royalty lag; accelerated 18-month build schedule acknowledged	Verified (user-confirmed)
FWDC escalation assumption	Conservative flat $83/ton for gross displacement calculation. Royalty and Beneficiation Fee (TMC Fee) use formula-defined escalators independent of FWDC.	Conservative assumption
Population / census	US Census Bureau — Annual Estimates of Resident Population, Vintage 2024	Verified

Glossary Additions

The combined annual financial effect: Circular Royalty™ received + Gross Cost Displacement − Beneficiation Fee (TMC Fee) paid. Negative in Year 1 (pre-royalty period); positive from Year 2 onward; growing to approximately +$9.7M/year in Year 30 on Phase Initial basis.

Pre-Royalty Period

The 13 months following Phase Initial COD (approximately H2 2027 through Q4 2028) during which YCSWA pays the Beneficiation Fee (TMC Fee) and receives $0 Circular Royalty™. This period is finite, structurally defined, and must not be combined with post-royalty periods in aggregate financial statements.

Royalty Ramp Period

The ramp period reflects the rolling nature of the royalty formula: each month's TMC payment generates a royalty 13 months later.

Steady-State Period

Year 2 onward — full run-rate Circular Royalty™ cash flow in place, compounding annually.

State A / State B

State A: York County's current waste system — WTE at YCRRC ($83/ton), ash to Modern Landfill, no ACM. State B: York County's waste system with Carbotura ACM facility operating at Phase Initial (400 TPD) under the executed 30-year CSA. State A values source exclusively from the Waste Study. State B values source exclusively from the CSA Terms EIR Input Block.

US GAAP

United States Generally Accepted Accounting Principles — the accounting standard applied throughout this EIR. All financial figures are in nominal US dollars unless stated otherwise. No IFRS treatment applies to this engagement.

Appendix C

Evidence Chain

Figure	Value	Source	Type
FWDC	$83/ton (2025)	West Manchester Twp notice; YCSWA budget announcement Sept 2024	Verified
Beneficiation Fee (TMC Fee)	$75/ton	Executed YCSWA contract	Contracted
Phase Initial volume	400 TPD / 146,000 TPY	Executed YCSWA contract	Contracted
Site — P1 Manchester Twp	Leased; PADEP permitting	User-confirmed; mantwp.com	Confirmed
COD target	H2 2027	User-confirmed	Verified
Royalty formula	Royalty(m+13) = TMC(m) × Rate(m)	Carbotura contractual standard	Contractual
YCSWA RFP 2026–2039	Contracts effective Jan 1, 2026	ycswa.com procurement notice Jan 2025	Verified
Modern Landfill status	Intake reduced >40%; near closure	Fox43 2025; York Dispatch 2024	Verified
Carbon performance	~132,000 MT CO₂e/yr (Phase Initial)	Carbotura standard: 33,000 MT per 100 TPD module	Modeled
Employment (Phase Initial)	40 direct FTE	Carbotura standard: 10 FTE per 100 TPD module	Modeled