+$93/ton at Year 30 steady state on Phase Expanded volumes.
What this document is
What Clark County pays and receives under its current system compared with an Advanced Circular Manufacturing deployment — each flow quantified and reported separately across the 30-year term.
- Continuing with the current system leaves Clark County exposed to a date it does not control: regional siting capacity goes to first movers, and the build from execution to commissioning runs 12–18 months.
- Under the CSA Clark County pays a Beneficiation Fee and receives a Circular Royalty™; both are gross figures and are shown independently throughout.
- The direction of the conclusion holds across the sensitivity range, including where the unconfirmed disposal cost is verified lower than the planning estimate.
- Read the commercial structure ↗Terms, phases, risk and timeline.
- See the feedstock assessment ↗Volumes, routes and current costs.
- Start with the brief ↗The decision and its deadline, in one page.
What This Report Measures
§1.1 — Document Role
This EIR quantifies the fiscal, economic, and structural delta between:
STATE A Current system: all feedstock to Apex at $61.14/ton FWDC (estimated) under Republic Services exclusive franchise. No royalty. No manufactured outputs.
STATE B ACM deployment: 500→1,000→2,000 TPD phased; Beneficiation Fee $100/ton (+2.5%/yr); Circular Royalty™ 120% base (+1pp/yr), 13-month rolling lag. NAICS 325180, 325998, 327992, 331110, 331314, 331492.
Neither state is re-diagnosed here. The Waste Study covers State A diagnosis. The Proposal covers State B transaction structure.
§1.2 — Decision Summary Table
| Factor | State A | State B Yr 1 | State B Yr 2+ |
|---|---|---|---|
| Annual disposal (730k TPY) | $44.6M/yr est. | $73.0M TMC | $74.8M+ escalating |
| Circular Royalty™ received | $0 | $0 (pre-royalty) | $87.6M+ (Year 2) |
| County capital obligation | Ongoing disposal franchise cost | $0 | $0 |
| Key data gaps | Apex current rate (W2); site confirmation (W3); CCWRD biosolids cost (W6) | ||
| Cost of delay (Expanded) | ~$5.5M per month in Year 2+ Circular Royalty™ deferred | ||
This Economic Impact Report models the Delta between State A (current disposal trajectory) and State B (Carbotura CSA).1–§4.1 for full CSA Structure.
§1.3 — Fiscal vs. Regional Economic Separation
Clark County fiscal effects (treasury receipts: avoided disposal and Circular Royalty™) and regional economic effects (FTE employment, economic output, tax base) are distinct categories. They are not combined anywhere in this report.
Current System — Source: Waste Study
§2.1 — Feedstock Volume and Disposition
| Stream | TPY est. | TPD | Destination | Operator |
|---|---|---|---|---|
| Residential MSW | ~804,000 | ~2,203 | Apex via Republic transfer | Republic Services, Inc. |
| Commercial / Hospitality MSW | ~803,000 | ~2,200 | Apex via franchise | Republic Services, Inc. |
| C&D Debris | ~856,000 | ~2,345 | Apex + Lincoln County alt. | Republic Services / Western Elite |
| Biosolids (CCWRD) | ~36,500 | ~100 | CCWRD internal + permitted | Clark County Water Reclamation District |
| Food Waste / Organics | ~130,000 | ~356 | Co-mingled to Apex | Republic Services, Inc. |
| Industrial / Special / Imported | ~259,150 | ~710 | Apex + SNHD-permitted | Various |
| TOTAL | ~2,593,000 Est | ~7,105 | Single destination: Apex (98.5%) | Republic Services, Inc. |
§2.2 — State A Cost Structure (730k TPY planning basis)
| Cost Element | Annual | $/ton | Source Type |
|---|---|---|---|
| Disposal — FWDC planning basis | $44,632,200 | $61.14 | Estimated |
| Transport (intra-county) | ~$2.2M-$5.8M | $3-8 | Estimated |
| Apex actual rate | Not disclosed | Not disclosed | Data gap — W2 |
| State A FWDC (730k TPY) | $44,632,200/yr | $61.14/ton | Nevada EREF 2024 avg. |
§2.3 — State A Cost Trajectory — Three Mechanisms
1. Contractual rate escalation — Republic Services holds sole authority to set and increase Apex tipping fees. No market ceiling exists. 2. Capital reinvestment pressure — Apex compliance obligations (leachate, PFAS, gas capture) create ongoing capex Republic Services has historically cited for rate increases. 3. Absence of competitive alternatives — Apex is the only Class I MSW landfill in Clark County. Market concentration is structural and permanent in the medium term.
§2.4 — State A Environmental and Structural Position
State A generates zero manufactured outputs. Carbon from landfill methane continues unmitigated. PFAS compounds co-disposed without elemental dissociation. Diversion stalled at 20%, 5pp below Nevada's 25% statutory goal. No structural alternative to the Republic Services franchise within county boundaries.
ACM Deployment — Source: Proposal
§3.1 — Inherited Flags
State B is modelled from Proposal-locked parameters. FWDC is estimated (W2). Site is provisional (W3). Timeline is Carbotura standard (W4). All figures are planning-basis projections.
§3.2 — Deployment Configuration
| Phase | TPD | Modules | TPY | COD |
|---|---|---|---|---|
| Initial | 500 | 5 modules | 182,500 | T0 + 24 months |
| Medium | 1,000 | 10 modules | 365,000 | T0 + 42 months |
| Expanded | 2,000 | 20 modules | 730,000 | T0 + 60 months |
§3.3 — Economic Terms
| Parameter | Value |
|---|---|
| Beneficiation Fee base | $100.00/ton (locked) |
| TMC escalator | 2.5%/year |
| Circular Royalty™ base | 120% of the current-year Beneficiation Fee |
| Royalty escalator | +1 percentage point/year |
| Payment lag | 13 months (rolling) |
| CSA term | 30 years |
| Clark County capex | $0 — BOO structure |
§3.4 — Residual Obligations
At Phase Expanded (2,000 TPD), approximately 1,863,000 TPY (5,105 TPD) continues to flow to State A destinations at prevailing FWDC rates. Phase Expanded addresses 28.1% of the total Clark County system.
§3.5 — Timeline Anchoring
T0 = engagement authorisation. Phase Initial COD = T0+24 months. First Circular Royalty™ = T0+37 months (13 months after Phase Initial COD). Carbotura standard schedule — subject to Term Sheet phase verification confirmation.
§3.6 — Phase Delta Map
State A infrastructure (grey/steel markers) and State B ACM Priority 1 site (emerald square). Right panel shows both states in plain institutional language.
Sources: Wikipedia (Apex, CCWRD); US DOJ/EPA (Sunrise Mountain); Google Places API. March 2026.
Map requires a Google Maps API key.
Set GOOGLE_MAPS_API_KEY in config.js.
Three Components and Quantified Fiscal Position
§4.1 — Three Delta Components
- Gross cost displacement: For every ton processed by ACM instead of Apex, Clark County avoids $61.14/ton FWDC. Direct cost avoided — not a revenue receipt.
- Circular Royalty™ cash flow: Beginning T0+37 months, Carbotura pays 120% of that year's Beneficiation Fees (13-month rolling lag). Actual revenue receipt to county treasury.
- Residual obligation: 71.9% of total stream (5,105 TPD / 1,863,000 TPY) continues to State A at prevailing rates. State B displaces 28.1% of total system.
Year 1 and post-Month 13 periods have materially different fiscal characteristics. They must not be combined. Year 1: Beneficiation Fee paid ($73M expanded), $0 royalty. From Month 13: rolling royalty begins. Steady state: royalty exceeds Beneficiation Fee per ton by design.
§4.1 — Phase-by-Phase Comparative Table (Expanded Phase, Annual)
| Item | Year 1 | Year 2 | Year 5 | Year 10 | Year 30 |
|---|---|---|---|---|---|
| ACM volume (TPY) | 730,000 | 730,000 | 730,000 | 730,000 | 730,000 |
| State A cost (FWDC×TPY) Est | $44.6M | $44.6M | $44.6M | $44.6M | $44.6M |
| Beneficiation Fee paid (State B) | $73.0M | $74.8M | $80.6M | $91.2M | $152.9M |
| Circular Royalty™ received | $0 (pre-royalty) | $87.6M | $96.7M | $113.8M | $220.8M |
| Gross cost displacement | $44.6M avoided | $44.6M | $44.6M | $44.6M | $44.6M |
| Residual cost (State A, 1.86M TPY) | $113.9M | $113.9M | $113.9M | $113.9M | $113.9M |
| Clark County capital obligation | $0 | $0 | $0 | $0 | $0 |
§4.3 — State A vs. State B Comparison Chart
State A disposal cost (grey) vs State B: Royalty received (emerald positive) and Beneficiation Fee paid (red negative).
Source: Registry §E/§F locked parameters · FWDC $61.14/ton (Estimated, EREF 2024).
§4.4 — 30-Year Gross Cost Displacement
At $61.14/ton FWDC planning basis, 730,000 TPY generates $44,632,200/year in avoided disposal cost. Over 30 years at constant FWDC: $1,338,966,000 cumulative avoided disposal cost (undiscounted). Note: if actual Apex rate exceeds planning basis, this figure is conservative.
§4.5 — 30-Year Circular Royalty™ Schedule
| Year | TMC $/ton | Royalty Rate | Royalty $/ton | Annual Royalty (730k TPY) |
|---|---|---|---|---|
| 1 | $100.00 | $0.00 | $0 | |
| 2 | $102.50 | 120% | $120.00 | $87,600,000 |
| 5 | $110.38 | 123% | $125.63 | $91,709,700 |
| 10 | $124.89 | 128% | $133.50 | $97,455,000 |
| 20 | $163.86 | 138% | $172.48 | $125,910,400 |
| 30 | $209.76 | 148% | $302.42 | $220,766,600 |
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.
§4.6 — Three-Item Gross Fiscal Chart
Avoided Disposal Cost (amber, positive) · Beneficiation Fee Paid (red, negative) · Circular Royalty™ Received (emerald, positive Year 2+).
Source: Registry §E/§F · TMC $100/ton · Royalty 120% base +1pp/yr · FWDC $61.14/ton (Estimated, EREF 2024).
Executive Implications — Delta Analysis
- Year 1 is a cost restructuring, not a new liability: The $73M TMC obligation replaces $44.6M in disposal costs at Apex. The $28.4M premium returns as royalty from Year 2 at 120% of the current-year Beneficiation Fee — the premium pays itself back in 13 months.
- Gross cost displacement is additive, not duplicative: Avoided disposal cost and Circular Royalty™ together constitute the full county value. Both are presented gross and separately — not netted.
Employment, Environmental, PFAS, and No-Fallback
§5.1 — Employment Delta
Employment figures represent regional economic effects — not county treasury receipts. Do not add to fiscal royalty figures.
| Metric | Phase Initial | Phase Expanded | Basis |
|---|---|---|---|
| Direct FTE Est | +125 | +500 | Carbotura standard scaled |
| Indirect/induced jobs Est | +~375 | +~1,500 | Carbotura standard multiplier |
| Annual economic impact Est | +$40M+ | +$160M+ | Carbotura standard scaled |
§5.2 — Environmental Delta
All environmental figures are designed-for performance on the basis of Carbotura standard parameters. Actual performance subject to site-specific conditions.
| Metric | State A | State B (Expanded) | Delta |
|---|---|---|---|
| Carbon avoidance Est | Landfill methane unmitigated | 7,610-7,830 tCO2e/day avoided | ~85M tCO2e over 30yr |
| Water recovery | $0 | 435,000 gal/day ultrapure | +435,000 gal/day |
| Material throughput | ~20% recycling diversion | ~90% sold globally · ~100% converted (ACM) | ~+70pp sold-globally |
| Grid dependency | Full grid dependency | Near-zero external energy draw | Island Mode capable |
§5.3 — PFAS Structural Delta
State A: PFAS-containing material (Las Vegas Strip hospitality, food packaging, fire suppression residues) co-disposed at Apex without elemental dissociation. Leachate pathway toward Las Vegas Wash and Lake Mead carries unquantified PFAS loading from decades of co-disposal.
State B: ACM processes at 1,200°C+ in an anoxic, oxygen-free environment — designed for complete PFAS elemental dissociation. Every ton processed by ACM is a ton that does not add to Apex's PFAS burden or leachate pathway. As EPA PFAS regulations tighten, this structural advantage compounds.
§5.4 — No-Fallback Analysis
Clark County has no credible alternative to Apex for large-volume MSW disposal within county boundaries. No new Class I landfill siting process is underway. The nearest alternative (Lincoln County, 2.5 hours) is viable only for C&D haulers absorbing transport cost. State A is not a stable baseline — it is a cost escalation trajectory with no competitive ceiling mechanism.
Risk Register (10 Risks) and Sensitivity Analysis
§6.1 — Structured Risk Register
| Risk | Key Driver | Who Bears It | Mitigation | Residual |
|---|---|---|---|---|
| FWDC below planning basis | Apex rate may be lower than $61.14/ton Nevada average | Neutral to positive — TMC resolves to $100 floor regardless; royalty math unchanged | Term Sheet phase verification rate discovery | — |
| Manufacturing classification challenge (SNHD) | SNHD or state attempts solid waste NAICS classification | Both — Both parties commit to the RPT pathway | Manufacturing classification (NAICS 31–33); proactive regulatory pre-engagement | HIGH residual — absolute withdrawal trigger |
| Republic Services franchise constraint | Exclusive collection rights limit commercial MSW access for Phase Medium+ | Clark County | Phase Initial on immediately-accessible streams only; franchise addressed at Phase Medium | MEDIUM — Phase Initial fully executable |
| Phase Initial feedstock shortfall | Residential routing barriers | Carbotura SPV (throughput guarantee) | — | LOW |
| Technology performance below nameplate | MCR throughput or recovery rates | Carbotura SPV | Modular architecture; performance guarantees; phased commissioning | LOW per module |
| Timeline slippage — SNHD permitting | Manufacturing permitting timeline; site acquisition | Shared | Three site candidates; standard schedule includes contingency | MEDIUM — each month defers ~$5.5M royalty |
| TMC vs. FWDC escalation divergence | FWDC growth rate relative to TMC 2.5%/yr escalation | Clark County | Floor/ceiling structure limits TMC range; FWDC sensitivity reviewed in FS | MEDIUM |
| CSA counterparty credit (Carbotura SPV) | SPV insolvency over 30-year term | Clark County | Step-in rights; performance bonds; project finance covenants | LOW |
| PFAS regulatory escalation at Apex | EPA tightening PFAS standards; Apex compliance cost increases | Republic Services (State A only) | ACM eliminates PFAS burden; no compliance exposure in State B | POSITIVE for State B — regulatory asymmetry |
| Lake Mead drought / leachate liability escalation | Sustained low water levels; heightened Apex environmental scrutiny | Republic Services (State A only) | ACM eliminates leachate pathway from processed material | POSITIVE for State B |
§6.2 — Feedstock Variability ±20%
| Scenario | TPY | Annual TMC Yr 2 | Annual Royalty Yr 2 |
|---|---|---|---|
| Base case | 730,000 | $74.8M | $87.6M |
| -20% feedstock | 584,000 | $59.8M | $70.1M |
| +20% feedstock | 876,000 | $89.8M | $105.1M |
The model is robust to significant volume variation.
§6.3 — FWDC Sensitivity — Sign-Change Threshold
FWDC affects only the avoided-cost component, not the royalty arithmetic. Sign-change threshold: none in Year 2+.
§6.4 — Royalty Escalator Sensitivity
| Escalator | Yr 10 Royalty $/ton | Yr 30 Royalty $/ton |
|---|---|---|
| 0 pp/yr (flat 120%) | $150.00 | $251.71 |
| +1 pp/yr (base case) | $155.96 | $302.42 |
| +2 pp/yr (upside) | $162.04 | $353.13 |
§6.5 — Timeline Slippage
| Scenario | Phase Initial COD | First Royalty | Royalty Deferred (Expanded) |
|---|---|---|---|
| Base case | T0 + 24 months | T0 + 37 months | |
| 6-month slippage | T0 + 30 months | T0 + 43 months | ~$43.8M |
| 12-month slippage | T0 + 36 months | T0 + 49 months | ~$87.6M |
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.
Binding Constraints, Irreversibility, and Optionality
§7.1 — Binding Constraints
- ▶Republic Services franchise (1993, amended 2005): Grants sole tipping fee authority and exclusive MSW collection rights to Republic Services. No market ceiling on Apex rate escalation. Every year without an alternative destination is a year of uncontrolled cost growth.
- ▶SNHD manufacturing classification pathway: The Regulatory Predicate Transition (RPT) requires NAICS 325180, 325998, 327992, 331110, 331314, 331492 classification. SNHD must engage manufacturing — not solid waste — regulatory pathway.
- ▶Carbotura deployment queue: CSA execution secures Clark County's capital allocation position in Carbotura's regional deployment pipeline.
§7.2 — Decision Window Table
| Decision Point | Recommended Timing | Cost of Missing Window |
|---|---|---|
| LOI/MOU execution | Within 6 months of initial engagement | ~$5.5M/month Year 2 royalty deferred (Expanded) |
| CSA execution | T0 + 4-6 months | Delays COD and first royalty proportionally |
| SNHD pre-engagement (manufacturing classification) | Concurrent with Term Sheet phase verification | Post-COD reclassification is resolved under the RPT pathway |
The binding irreversibility mechanism is the 1993 Republic Services franchise agreement — specifically, the sole tipping fee authority clause. Every year this franchise runs without an alternative, Clark County's leverage in any future franchise renegotiation weakens. The ACM facility is the only credible alternative destination for large-volume MSW that Clark County can deploy within the county. Once the next franchise renewal window passes without a demonstrated county alternative, the negotiating gap widens structurally.
§7.4 — Optionality Matrix
| Option | County CapEx | Revenue | FWDC Control | Timeline |
|---|---|---|---|---|
| Continue State A (Apex) | $0 | $0 royalty | None — Republic Services sets rates | Ongoing escalation |
| County-owned WTE/RRF | $200M-$500M+ | Gate fees only | Full — county-owned | 8-12 year development |
| ACM BOO CSA | $0 | $87.6M+ Year 2 royalty | TMC floor/ceiling + royalty offset | T0+24 months Phase Initial |
| Do nothing | $0 | $0 | None | Queue position loss |
All Values Traced to Preceding Sections
§8.1 — Fiscal Effects
| Fiscal Item | Year 1 | Year 2 | Year 30 | Source |
|---|---|---|---|---|
| Avoided disposal (730k TPY) | $44.6M | $44.6M | $44.6M | §4.4 |
| Beneficiation Fee paid | ($73.0M) | ($74.8M) | ($152.9M) | §4.1 |
| Circular Royalty™ received | $0 | $87.6M | $220.8M | §4.5 |
§8.2 — Regional Economic Effects
Not county fiscal receipts — regional economic activity generated by ACM operations.
Phase Expanded: +500 direct FTE (est.) · +~1,500 indirect jobs (est.) · +$160M+ annual economic impact (est.) · First manufacturing-classification advanced material processing facility in Nevada.
§8.3 — Environmental Effects
Designed-performance basis. Actual performance subject to site-specific conditions.
~85M tCO2e avoided over 30yr (est.) · 435,000 gal/day ultrapure water recovered · PFAS elemental dissociation on all processed material · ~90% sold globally · ~100% converted · near-zero external energy draw.
§8.4 — Structural Effects
State B establishes Clark County's first credible large-volume MSW alternative to Apex. Even at 28.1% of total stream, an operating ACM facility changes the franchise renegotiation dynamic with Republic Services materially — from no alternative to a demonstrated, operating alternative destination with competitive economics.
§8.5 — Unresolved Data Gaps
| Gap | Impact on Analysis | Resolution Path |
|---|---|---|
| Apex current contracted tipping rate (W2) | FWDC may understate actual avoided cost advantage. Direction: ACM likely stronger than modelled. | Term Sheet phase verification — direct rate request |
| CCWRD biosolids disposal cost (W6) | Biosolids valued at zero in FWDC. Actual avoided cost unknown. | CCWRD direct engagement |
| Site P1 land confirmation (W3) | P1 provisional — acquisition timeline not modelled. | North Las Vegas City planning |
| 2025 Clark County disposal volumes | Feedstock estimated from 2021 data. | SNHD annual disposal reports |
Sources and Methodology
| Element | Method / Source | Note |
|---|---|---|
| FWDC derivation | Nevada statewide 2024 EREF average ($61.14/ton) | ESTIMATED |
| Beneficiation Fee formula | MAX($100, MIN($150, FWDC-$5)) → $100/ton floor | User input locked |
| Phase sizing | 500/1,000/2,000 TPD user input; modules = TPD/100 | User input |
| Royalty formula | Royalty(m+13) = TMC(m) × Royalty_Rate(m); 120% Year 1, +1pp/yr | Carbotura rule default |
| Environmental performance | Carbotura standard 400 TPD baseline, scaled by (TPD/400) | ESTIMATED — designed for |
| Employment basis | 100 FTE per 400 TPD, scaled | ESTIMATED |
| Timeline basis | Carbotura standard deployment schedule | BASELINE |
Glossary Additions
Evidence Chain
| Figure | Value | Source | Type |
|---|---|---|---|
| FWDC planning basis | $61.14/ton | EREF (2025), Analysis of MSW Landfill Tipping Fees 2024 | ESTIMATED |
| Total Clark County disposal | 2,593,185 TPY (2021) | NDEP 2021 / UNLV Municipal Waste study | VERIFIED |
| Beneficiation Fee | $100.00/ton | User input — locked | USER INPUT |
| Royalty parameters | 120% / +1pp/yr / 13 months | Carbotura standard | RULE DEFAULT |
| Clark County recycling rate | ~20% | NDEP 2025 LCB Report | VERIFIED |
| Apex operator + franchise terms | Republic Services / 1993 franchise / sole fee authority | Wikipedia; Las Vegas Review-Journal 2016/2026; Waste Dive | VERIFIED |
| CCWRD operator | Clark County Water Reclamation District | Wikipedia; CCWRD official site | VERIFIED |
| Sunrise Mountain closure | Closed 1994; EPA decree 2008; remediated 2011 | US DOJ press release Aug 2008; Las Vegas Paving | VERIFIED |