Clark County, NV — ACM Executive Briefing · v1.0 · April 2025
← Hub
COMMERCIAL INTEREST DISCLOSURE
This document is a commercial proposal prepared by an interested party. Carbotura Inc. is the proposed commercial partner and has a direct financial interest in Clark County adopting this proposal. All financial projections, benefit estimates, and impact figures were produced by Carbotura Inc. — not by an independent analyst, auditor, or public body. Clark County should seek independent financial, legal, technical, and procurement advice before making any decision. This document is analysis and commentary, not professional advice of any kind. Version 1.0 · April 2025 · Stage 1 of 7
Carbotura EIR Series  ·  Nevada, USA  ·  2025

ACM Partnership
Executive Briefing

A plain-language decision-maker briefing on Clark County's waste market structure, cost trajectory, and Carbotura's Advanced Circular Manufacturing proposal — synthesised from the Clark County Waste Industry Intelligence Report 2025 and the ACM Economic Impact Report & Partnership Proposal (v1.0).

CommunityClark County, Nevada, USA
Population~2,367,000 (2024 est.)
CurrencyUSD ($) · GASB
Regulatory AuthoritySNHD — Solid Waste Management Authority
PublishedApril 2025
Last ReviewedApril 2025
Next ReviewOctober 2025
Stage1 of 7 — Pre-Agreement
This document is a Stage 1 Partnership Proposal prepared by Carbotura Inc. for illustrative and discussion purposes only. All financial figures, projections, timelines, and benefit estimates are based on Carbotura's standard deployment model applied to publicly available community data. They do not constitute a contractual offer, commitment, or guarantee by Carbotura Inc. or any of its affiliates. Actual terms, capacities, and financial outcomes will be established through the formal engagement process, including execution of a Letter of Intent, Term Sheet, and Circular Offtake Agreement.

Executive Summary — For Decision-Makers

ⓘ Analysis & Commentary — Not Professional Advice This briefing synthesises Carbotura's Clark County intelligence and proposal documents. It is analysis prepared by an interested commercial party and does not constitute legal, financial, or procurement advice. Clark County should seek independent professional advice before any decision.
  • The market is structurally locked. Republic Services has held exclusive MSW franchises in Clark County since 1973–1993 across all four jurisdictions. No competitive RFP has ever been issued. All franchises expire 2031–2035. WIR 2025 · s8
  • The disposal cost is opaque. Clark County's estimated Facility-Weighted Disposal Cost (FWDC) is approximately $165/ton — but this is a LOW confidence estimate because Apex's internal transfer rate (what Republic charges itself) has never been disclosed to the County. WIR 2025 · s12 · LVRJ 2016
  • ACM costs less than the status quo on day one. The Carbotura TMC Fee of $150/ton is formula-derived, auditable, and projected to be approximately $15/ton below the current FWDC from the first year of operations. Carbotura Model · April 2025
  • Clark County pays nothing to build it. All capital construction and commissioning is funded by Carbotura Inc. via a special-purpose vehicle. Zero capital is required from Clark County. Carbotura Standard Deployment Model
  • A new revenue stream begins 13 months after first feedstock delivery. The Circular Royalty™ is projected at approximately $9.1M/yr at Tier 1 (1,000 TPD) and grows over 30 years — replacing the County's current 4% tipping fee share, which is calculated on a rate the County cannot audit. Carbotura Model · Master Rules Section 4.3
  • Long-tail liabilities are eliminated for processed feedstock. ACM is designed for near-zero residuals to landfill, eliminating post-closure obligations, PFAS leachate pathways, and financial assurance requirements for the feedstock it processes — estimated at $500M–$3B+ in aggregate under the status quo. WIR 2025 · s13 · conf-l
  • The 2031 franchise window is the key decision point. Las Vegas and North Las Vegas franchises expire in 2031 — the first structural opportunity to introduce a competitive cost benchmark in the modern era. Introducing ACM infrastructure before that window creates negotiating leverage. WIR 2025 · s10
  • The diversion mandate can be met without franchise reform. ACM at Minimum configuration (400 TPD) is designed to bring Clark County to the NAC 444A 25% diversion threshold when combined with existing MRF performance — without requiring any change to the Republic Services franchise. Carbotura Model · ACM Guide v3.7
GOVERNING LANGUAGE PRINCIPLE Process design statements are factual. Outcome claims use conservative framing — "designed for," "near-zero," and "engineered to" — wherever independent verification at full scale is still ahead. Claims must never exceed the evidence behind them. All financial projections in this briefing are illustrative Carbotura estimates at LOW confidence unless separately noted.

Table of Contents

  1. Key Terms & Acronyms
  2. Section A — Status Quo Analysis
  3. Section B — Intelligence Analysis
  4. Section C — ACM Partnership Proposal
  5. Section D — Community & Resident Impact
  6. Section E — Opposition & Friction
  7. Section F — Accountability & Action Pathways
  8. Section G — Sources & Methodology

Key Terms & Acronyms

Term / AcronymExpansionPlain-Language Definition
ACMAdvanced Circular ManufacturingCarbotura's manufacturing process that converts community-sourced feedstock into engineered products using the Recyclotron™ reactor. Not waste disposal — a manufacturing process.
TMC FeeTechnology & Manufacturing Contribution FeeThe per-ton payment Clark County makes to Carbotura. Formula-derived at $150/ton. Replaces the legacy disposal fee framing.
FWDCFacility-Weighted Disposal CostClark County's weighted average cost per ton of managing all waste streams. Currently estimated at ~$165/ton — a conf-l figure due to undisclosed Apex internal transfer rate.
Circular Royalty™—Carbotura's trademark revenue-sharing payment to Clark County from ACM product sales, beginning 13 months after first feedstock delivery.
COACircular Offtake AgreementThe 30-year legal contract between Clark County and the Carbotura SPV.
SNHDSouthern Nevada Health DistrictThe Solid Waste Management Authority (SWMA) for Clark County under NRS 439.362. Issues all waste facility permits in the county.
GASBGovernmental Accounting Standards BoardThe US public-sector accounting standard applicable to Clark County. Governs how balance sheet liabilities are recognised.
NAC 444ANevada Administrative Code 444AThe Nevada regulation mandating a 25% diversion rate for counties over 100,000 population. Clark County currently at ~20%.
Recyclotron™—Carbotura's trademark ACM reactor — operates in an anoxic (no-oxygen) environment using electromagnetic energy. No combustion occurs.
RevCon™—The family of engineered output products from ACM — including manufactured mineral aggregate, Liquifact™, Renewable Graphite, and Renewable Refined Water.
PFASPer- and polyfluoroalkyl substances"Forever chemicals" designated as hazardous substances under CERCLA by US EPA in April 2024. Present in landfill leachate; a growing contingent liability at Apex.
SPVSpecial Purpose VehicleThe project company Carbotura uses to hold, finance, and operate each ACM facility. Clark County contracts with the SPV — not Carbotura Inc. directly.
A — Status Quo Analysis

Current Waste Management Structure

HIGH Multiple independent sources MED Single source / national average adjusted LOW Analyst estimate — treat as indicative

A1 — Who Does What, Under What Contract

Republic Services — Exclusive Franchisee

Holds exclusive MSW collection franchises across all four major jurisdictions. Also owns Apex Regional Landfill (sole MSWLF in Clark County) and the Southern Nevada Recycling Center (primary MRF). NYSE: RSG. WIR 2025 · s2

SNHD — Regulatory Authority

Southern Nevada Health District acts as the Solid Waste Management Authority under NRS 439.362. Issues all facility permits in Clark County. Conducts unannounced inspections. WIR 2025 · s1

Clark County Board — Franchise Authority

Holds, amends, and renews the Clark County franchise agreement with Republic Services. Franchise last amended April 2022. Expires 2035. 4% of Apex tipping fee revenue flows to the County. Clark County Franchise 2022

Apex Regional Landfill

2,200 acres — largest active MSWLF in the US. Republic Services owned. Sole disposal option within Clark County. Republic sets its own tipping fees; internal rate not disclosed to County. WIR 2025 · s3

A2 — Key Financial Data

$165/t Estimated FWDC LOW WIR 2025 s12
$37.54/t Last Published Apex Gate Rate (2016) HIGH LVRJ 2016
4% County Revenue Share from Apex Tipping Fees HIGH Clark County Franchise 2022
~$344–562M Estimated Total Annual System Cost LOW WIR 2025 s12
Undisclosed Republic's Internal Transfer Rate at Apex — withheld from County LVRJ 2016
29.7% Republic Services Adj. EBITDA Margin FY2023 — rising to ~32% by Q3 2024 HIGH RSG SEC 2023–24

A3 — Regulatory Framework

The governing statutory framework is NRS 444 (solid waste management) and NAC 444A (recycling mandate), with the SNHD acting as the permitting and enforcement authority under NRS 439.362. NRS 268.081 grants municipalities the power to issue exclusive franchise contracts without competitive tendering — the legal basis for Republic's monopoly position across all four Clark County jurisdictions. WIR 2025 s1 Nevada's 25% diversion mandate for large counties under NAC 444A has been unmet by Clark County since 2012. NDEP 2025 No enforcement action for persistent non-compliance has been documented. MED

A4 — Identified Liabilities

PFAS / CERCLA
$100M–$1B+
Post-April 2024 EPA CERCLA hazardous substance designation. Apex-specific monitoring scope undisclosed. Likely off-balance-sheet at RSG. WIR 2025 s13-A · US EPA 2024
Off balance sheet
Post-Closure
$200M–$800M
Apex 30+ yr RCRA Subtitle D obligation. On RSG balance sheet; Clark County-specific figure not disaggregated. WIR 2025 s13-B
RSG balance sheet
Legacy Sites
$10M–$80M
Pre-1991 landfill closures. Potential CERCLA PRP exposure for Clark County as historical operator of pre-franchise sites. WIR 2025 s13-D
Mixed / historical
Total Estimated
$500M–$3B+
Aggregate long-tail exposure. Mostly on RSG balance sheet but not permanently insulated from Clark County. LOW WIR 2025 s13
Analyst estimate

A5 — Community Impact Summary

Clark County's ~2,367,000 residents face CPI-linked annual service fee increases with no competitive check, a diversion rate 5 percentage points below the statutory mandate, and 40+ million annual visitors generating commercial MSW at the county's expense under a franchise model that retains commodity revenue at the operator level. No EPR framework exists in Nevada — ratepayers bear the full cost of MRF infrastructure. WIR 2025 s5, s9, s11; NDEP 2025

B — Intelligence Analysis

Market Structure & Contract Architecture

B1 — Market Structure & Operator Mapping

Clark County's solid waste market is the most concentrated in the United States: a single operator holds exclusive MSW collection rights in all four major jurisdictions, owns the sole MSWLF in the county, and controls the primary residential MRF. Estimated market concentration: ~85% share of total solid waste activity for Republic Services. LOW — analyst estimate; no independent audit published. WIR 2025 s7 Independent operators (Western Elite, Luna's Recycling, A Track Out Solutions) are confined to the unfranchised C&D segment and face disposal pricing set by the incumbent at the only in-county landfill.

B2 — Contract Architecture & Renewal Windows

JurisdictionFranchise ExpiryFranchise Fee to JurisdictionFranchise History
Clark County20354% of gross Apex tipping fee revenue LVRJ 2016Since 1993. No competitive RFP in history.
City of Las Vegas20315% of gross receipts LVRJ 2017Since 1985. Renewed 2017 by 5-2 vote without RFP over documented competitor and legislative objections.
City of North Las Vegas2031Rate not publicly documented LOWSince 1978. CPI methodology aligned April 2025. Citizen Portal 2025
City of Henderson2035Rate not publicly documented LOWSince 1973 — longest-running franchise in the region.

B3 — Financial Flows

Under the current structure, Clark County's primary financial position is as fee recipient (4% of Apex tipping revenues — the only variable the County has direct sight of) and as CPI-escalating collection fee payer (via commercial ratepayers). Republic Services retains: disposal margin at Apex (internal rate undisclosed), MRF commodity sales ($117–177/ton, 2023–Q3 2024 RSG SEC 2023-24), landfill gas-to-energy revenue (sufficient to power ~11,000 homes PBS/SWANA 2021), and all RevCon™ processing revenue. Clark County's financial position improves with ACM — which adds both a cost saving and a new revenue stream — without requiring any change to the existing franchise agreements.

B4 — Forward-Looking Risk Exposure

⚠ PFAS — THE EMERGING TRIGGER The April 2024 EPA CERCLA designation of PFOA and PFOS as hazardous substances US EPA April 2024 is the single most consequential near-term risk development for Clark County's waste system. As EPA enforcement practice develops, Republic Services will face increasing pressure to accrue a specific PFAS liability at Apex — which could alter franchise renewal terms, insurance pricing, and counterparty risk assessments. Clark County that has already introduced ACM infrastructure will be in a structurally stronger position at the 2031 and 2035 franchise renewals than Clark County that has not.
C — ACM Partnership Proposal

What Changes Under ACM

C1 — Status Quo vs ACM

Status Quo $165/t FWDC

Unilaterally-set disposal cost at the only in-county landfill. Internal transfer rate undisclosed. CPI-escalating collection fees. 4% tipping fee revenue share Clark County cannot audit. Near-zero diversion incentive for the operator. WIR 2025 s12 · LVRJ 2016

→
ACM $150/t TMC Fee

Formula-derived, auditable, and fixed at the ceiling. $15/t projected saving from day one. Circular Royalty™ income from Year 2. Near-zero residuals to legacy disposal. Liabilities eliminated for processed feedstock. Zero capital from Clark County. Carbotura Model · April 2025

C2 — Financial Model (All Three Tiers)

Minimum 400 TPD
TMC Fee: $21.9M/yr
Cost saving vs SQ: ~$2.2M/yr
Circular Royalty™ Yr 2: ~$2.92M/yr
30-yr benefit: ~$193M
Per resident/yr: ~$2.80
All figures LOW
Tier 1 1,000 TPD
TMC Fee: $54.75M/yr
Cost saving vs SQ: ~$5.5M/yr
Circular Royalty™ Yr 2: ~$9.13M/yr
30-yr benefit: ~$545M
Per resident/yr: ~$7.93
All figures LOW
Tier 2 2,000 TPD
TMC Fee: $109.5M/yr
Cost saving vs SQ: ~$11.0M/yr
Circular Royalty™ Yr 2: ~$21.9M/yr
30-yr benefit: ~$1.195B
Per resident/yr: ~$17.42
All figures LOW
FINANCIAL PROJECTIONS — ALL FIGURES CONF-L All financial figures above are Carbotura illustrative projections based on the standard deployment model at Business Baseline (50% of current RevCon™ market pricing). They are not a contractual commitment. Independent review is required before any decision. Per-resident/year formula: [30-yr combined] ÷ 2,367,000 ÷ 29 (Years 2–30).

C3 — The ACM Process (Required Technology Description)

How ACM Works — For a Non-Technical Audience

Carbotura's system integrates proven component technologies — including microwave energy, catalytic reforming, and advanced separation — each with decades of industrial use. The Recyclotron™ reactor uses electromagnetic energy in an anoxic (no-oxygen) environment. No combustion occurs. Community-sourced manufacturing feedstock enters as OmniCrude™ (pre-processed material) and exits as RevCon™ engineered outputs — manufactured mineral aggregate, Liquifact™ liquid reformate, Renewable Graphite, Renewable Refined Water, and Recovered Thermal Energy. The Atmospheric Protection System (APES) manages air quality throughout, designed for near-zero atmospheric emissions from the reforming process.

C4 — Circular Royalty™ Structure

The Circular Royalty™ begins 13 months after first feedstock delivery — not at facility opening or immediately. Year 1 is construction and commissioning. The Circular Royalty™ is a share of ACM-derived product revenues — a manufacturing revenue share, not a disposal rebate or dividend. It is designed to grow over the 30-year partnership term as ACM output volumes and product market values develop. At Tier 1, the 29-year projected total (Years 2–30) is approximately $265M. LOW — Carbotura projection.

C5 — 30-Year Engagement Timeline

Stage 1

Partnership Proposal YOU ARE HERE

This briefing is part of Stage 1. No commitment required. Clark County reviews and engages.

Stage 2

Letter of Intent (LOI)

Non-binding. Confirms mutual interest. Establishes parameters for feasibility study.

Stage 3

Feasibility & Site Assessment

Joint technical and planning assessment. Site confirmed. Detailed engineering specifications.

Stage 4

Term Sheet

Binding commercial heads of terms. TMC Fee, Circular Royalty™ rate, feedstock volumes agreed.

Stage 5

Circular Offtake Agreement (COA)

Full 30-year legal contract. SNHD and NDEP permitting engagement begins.

Stage 6

Construction & Commissioning

Carbotura-financed. Zero capital from Clark County. First feedstock delivery triggers Year 2 Circular Royalty™ clock.

Stage 7

Operations & Partnership (Years 1–30)

Full operations. Circular Royalty™ begins Year 2. Annual performance reporting. Optional scale-up provisions.

D — Community & Resident Impact

What ACM Means for Clark County Residents

Lower Cost Trajectory

TMC Fee indexed to grow at 2% pa vs the current franchise's CPI escalation (~3%). The cost gap compounds over 30 years in Clark County's favour. Carbotura Model · conf-l

Diversion Mandate Met

ACM at 400 TPD (Minimum) is designed to bring Clark County's combined diversion rate to ~25.1% — meeting the NAC 444A mandate without franchise reform or MRF improvement. ACM Guide v3.7 · conf-l

New Community Revenue

Circular Royalty™ from Year 2 — approximately $2.92M/yr at Minimum, $9.13M/yr at Tier 1, $21.9M/yr at Tier 2. Unrestricted revenue for Clark County. Carbotura Model · conf-l

Manufacturing Jobs

~60–400 permanent direct manufacturing roles (tier-dependent), plus ~1.8× indirect and induced employment. Diversifies the Las Vegas metro economy beyond hospitality. Carbotura Model · conf-l

PFAS Liability Pathway Closed

Every ton processed by ACM is a ton that generates zero PFAS leachate exposure, zero post-closure obligation, and zero financial assurance requirement for Clark County. ACM Guide v3.7

Zero Capital Risk

Carbotura finances all construction via SPV. Clark County has no balance sheet obligation, no debt exposure, and no GASB 18 post-closure accrual for ACM-processed feedstock. GASB 18; Carbotura Deployment Model

E — Opposition & Friction

Handling Likely Questions

"Will this upset Republic Services or risk our franchise?"
ACM is complementary to — not competitive with — the existing franchise. Clark County can introduce ACM under its existing powers without altering any franchise agreement. ACM strengthens the County's negotiating position at the 2031 and 2035 renewals by providing a demonstrated alternative cost benchmark. Republic Services' franchise is unaffected.
"Isn't the $165/ton FWDC just a Carbotura estimate?"
Yes — and it carries a conf-l data quality flag throughout our documents. The reason it is an estimate is that Republic Services has not disclosed its internal Apex transfer rate to Clark County. If the true FWDC is higher than $165/ton (which it may be, given the opacity), the TMC Fee saving is larger — not smaller. The case for ACM improves with every dollar the true disposal cost exceeds our estimate.
"Is ACM technology proven?"
ACM integrates proven component technologies — microwave energy, catalytic reforming, and advanced separation — each with decades of industrial use. Carbotura's integration of these at commercial scale carries qualifying language throughout our documents: "designed for," "engineered to achieve," and "near-zero" distinguish design specifications from independently-verified commercial outcomes. This is consistent with our transparency standards.
"Teamsters Local 631 will oppose this."
ACM creates new manufacturing employment that does not exist in Clark County today — ~150–400 permanent roles (tier-dependent) alongside the existing franchise workforce. ACM does not displace Republic Services' collection workforce; it adds a manufacturing workforce in a new facility. The labour argument for ACM is additive, not competitive.
"What if the Circular Royalty™ projections are wrong?"
All Circular Royalty™ figures are Carbotura projections at Business Baseline (50% of current market pricing for RevCon™ outputs) and carry conf-l confidence. The TMC Fee cost saving is the conservative floor of the value case — it does not depend on commodity market performance. Even in a scenario where Circular Royalty™ underperforms the projection, Clark County still benefits from the $15/ton TMC Fee saving and zero capital cost from day one.
"This isn't recycling — can we count it toward our diversion rate?"
ACM achieves Total Material Conversion — designed for near-zero residuals to legacy disposal from accepted feedstock. How ACM outputs count toward Nevada's diversion rate calculation under NAC 444A is a question for NDEP and the formal engagement process. Clark County should seek legal and regulatory advice on this specific question. Carbotura will work with Clark County and NDEP to establish the appropriate classification in the COA negotiation stage.

F — Accountability & Action Pathways

F1 — Named Officials Responsible for Current Decisions

RoleBodyResponsibilityContact / Source
Board of County Commissioners (7 members)Clark CountyHold, amend, and renew the Clark County franchise agreement. Vote on any ACM engagement.clarkcountynv.gov/commissioners
Clark County ManagerClark CountySenior executive responsible for day-to-day administration including franchise oversight.clarkcountynv.gov/government
Las Vegas City Council (9 members)City of Las VegasHold the Las Vegas franchise agreement expiring 2031. The 2017 renewal (5-2 vote without RFP) is the most recent documented decision point. LVRJ 2017lasvegasnevada.gov
SNHD Board of HealthSNHDApprove or deny solid waste facility permits (including any future ACM facility) after public hearing. WIR 2025 s2southernnevadahealthdistrict.org

F2 — Key Decision Dates & Upcoming Milestones

2031

Las Vegas & North Las Vegas franchise expiry. First competitive window in modern era. Earliest practical point for ACM to provide an in-county cost benchmark for renewal negotiations.

2024–2026

EPA PFAS CERCLA enforcement timeline develops. Financial disclosure obligations for Apex may crystallise before 2031 — creating balance sheet pressure on Republic Services' renewal terms.

FY2025–26 Budget

Next Clark County budget cycle. Opportunity to commission independent waste cost analysis and ACM feasibility assessment within current planning process.

2027

Nevada biennial legislative session. Next opportunity for NRS 268.081 amendment (competitive procurement requirement) or EPR legislation.

2035

Clark County & Henderson franchise expiry. Second competitive window. Combined 2031+2035 approach creates a coordinated four-jurisdiction competitive test.

Now — Stage 2 LOI

A Letter of Intent with Carbotura is non-binding. It confirms mutual interest and enables the joint feasibility study — at zero cost to Clark County.

F3 — Public Records Requests (NPRA — NRS Chapter 239)

📄 WHAT TO REQUEST — AND FROM WHOM Under the Nevada Public Records Act (NRS Chapter 239), members of the public, journalists, and officials may request: (1) Clark County's franchise agreement with Republic Services — already publicly available at clarkcountynv.gov; (2) SNHD's financial assurance instrument and value held for Apex Regional Landfill — submit to SNHD Solid Waste Compliance Section, 280 S. Decatur Blvd., Las Vegas, NV 89107; (3) any independently commissioned waste cost analysis held by Clark County or any of the four franchise jurisdictions; (4) NDEP's current scope of PFAS analyte testing under Groundwater Discharge Permit NS0093011 at Apex. A model NPRA request template is available from transparency@carbotura.com.

F4 — Oversight & Complaint Mechanisms

Nevada State Auditor

Independent audit authority. audit.nv.gov

NDEP

State environmental regulator. Oversees SNHD's Clark County programme. ndep.nv.gov

US EPA Region 9

Federal environmental oversight. PFAS CERCLA enforcement authority. epa.gov/region9

Nevada AG / Legislature

Competition in waste hauling is a documented legislative concern (Senators Farley and Denis, 2017). LVRJ 2017

F5 — Media & Corrections Contact

📬 CARBOTURA — CORRECTIONS, ENQUIRIES & MEDIA For document corrections, factual disputes, or media enquiries regarding this briefing or any Carbotura Clark County document: transparency@carbotura.com  ·  Carbotura responds within 10 working days. Corrections are published with a visible dated notice, not silently edited.

G — Sources & Methodology

G1 — Primary Sources

#SourceIssuing BodyDateAccess
1Clark County, Nevada Waste Industry Intelligence Report 2025Carbotura Inc.2025Clark_County_NV_WIR_FINAL.html (this suite)
2ACM Economic Impact Report & Partnership Proposal — Clark County, Nevada (v1.0)Carbotura Inc.April 2025Carbotura_ClarkCounty_NV_Combined.html (this suite)
3Clark County / Republic Services Franchise Agreement (signed April 2022)Clark County Board of CommissionersApril 2022clarkcountynv.gov · Franchise Services
4"Clark County's deal with Republic Services a money loser"Las Vegas Review-JournalJuly 2016reviewjournal.com
5"Las Vegas City Council OKs Republic Services contract extension"Las Vegas Review-JournalApril 2017reviewjournal.com
62025 Legislative Counsel Bureau Report — Recycling and Waste ReductionNevada Division of Environmental Protection (NDEP)2025leg.state.nv.us
7PFAS Hazardous Substance Designation under CERCLAUS Environmental Protection AgencyApril 2024epa.gov/pfas
8Republic Services Q4 2023 & Q3 2024 Earnings Press ReleasesRepublic Services, Inc. (NYSE: RSG)2024SEC EDGAR / investor.republicservices.com
9ACM Guide v3.7 — Carbotura Nomenclature & Technology GuideCarbotura Inc.2025Available on request from transparency@carbotura.com
10GASB Statement 18 — MSWLF Closure and Postclosure Care CostsGovernmental Accounting Standards Board1993 (current)gasb.org

G2 — Methodology Notes

The FWDC of $165/ton is derived as a weighted average of gross disposal costs across five stream categories, using Clark County's published rate schedule (2023-24), EREF national benchmarks (2023), and RSG SEC filing data for MRF commodity prices. The most significant limitation is the undisclosed Apex internal transfer rate — Clark County's own disposal cost is therefore not independently verifiable from public sources. All ACM financial projections use Carbotura's standard deployment model at Business Baseline (50% of current RevCon™ market pricing). Per-resident/year figures apply the formula: [30-yr combined benefit] ÷ 2,367,000 ÷ 29 (Years 2–30, per Master Rules Section 4.3).

G3 — Confidence Level Legend

HIGH Multiple independent sources or operator SEC filings — independently verifiable MED Single source, national average adjusted for region, or secondary reporting LOW Analyst estimate from analogous data — treat as indicative only

G4 — Data Quality Disclosures

CRITICAL DATA GAP — APEX INTERNAL TRANSFER RATE The most consequential data gap in this briefing — and in all Clark County Carbotura documents — is the undisclosed Apex internal transfer rate. This is the rate Republic Services charges itself for depositing its own collected waste at Apex. Without it, the true FWDC cannot be calculated, the true cost saving cannot be verified, and the true disposal margin embedded in the franchise cannot be assessed. All figures that depend on the FWDC carry LOW confidence for this reason. Clark County should commission an independent waste cost audit — including a formal request for the internal transfer rate under Nevada's franchise disclosure framework — as a prerequisite to any franchise renewal decision.

G5 — Document Changelog

VERSIONDATECHANGES
v1.0 April 2025 Initial release. Synthesised from Clark County WIR 2025 and ACM EIR & Partnership Proposal v1.0. Governed by Carbotura Master Rules v1.1 and Exec Briefing Prompt v1.3.