What this document is
The commercial structure of one Circular Supply Agreement for the Government of the Cayman Islands — configurations from 200 to 550 TPD, the Beneficiation Fee, the Circular Royalty™, the George Town Landfill add-on, risk and timeline.
- Phase Initial at 200 TPD (73,000 TPY) is the entry point; the CSA scales to 550 TPD without renegotiating commercial terms.
- One CSA, no election: GOCI pays $100/ton and receives a Circular Royalty™ from 13 months after the first fee payment.
- Zero GOCI capital at any phase; George Town Landfill is an Exogenesis™ candidate subject to characterisation.
Cayman Islands
Circular Supply Proposal
A 30-year Circular Supply Agreement converts the Cayman Islands’ disposal cost — and a 2031 landfill deadline — into a royalty return, at zero GOCI capital.
What This Means
What This Means
Beneficiation Fee: $100/ton Year 1
+2.5%/yr escalator
Phase Initial: ~$7.3M/yr (73,000 tpy)
Circular Royalty™: 120% of Fee from Month 13
+1pp/yr escalator (Year 30 = 148%)
Phase Initial: ~$8.76M/yr Year 2
13-month lag · rolling monthly
$0 Beneficiation Fee
Consideration: site deed at signing
+1%/yr escalation from Year 2
Phase Initial: ~$7.3M/yr Year 2
→ ~$9.65M/yr Year 30
13-month lag · symmetric Take-or-Pay
George Town Landfill deeded at signing
(if study confirms viability)
Post-closure obligations transfer to Carbotura · IFRS IAS 37 liability extinguishment
Exogenesis™ Royalty: $50/ton extracted
+1%/yr escalation from Year 2
~$3.65M/yr from Year 6
Subject to Waste Characterization Study
- ›Carbotura offers a 30-year Build-Own-Operate agreement under which Carbotura funds 100% of construction, owns and operates the ACM facility, and processes the Cayman Islands' manufacturing feedstock streams. The Government of the Cayman Islands (GOCI) commits only a per-ton Beneficiation Fee — no capex, no debt, no operating cost.
- ›GOCI pays $100/ton Beneficiation Fee — structurally below the $163/ton contracted rate in the terminated ReGen project and below the $160/ton FWDC planning basis. This represents an immediate per-ton cost reduction at Phase Initial, before Circular Royalty™ is considered.
- ›GOCI begins receiving Circular Royalty™ payments at Month 13 — 13 months after the first Beneficiation Fee payment. The Circular Royalty™ is designed to exceed the Beneficiation Fee on a per-ton basis at steady state.
- ›Three distinct deployment modes address the full feedstock opportunity: central ACM facility (MSW, biosolids, Exogenesis™ legacy mining); distributed Regenesis™ Nodes (1–5 TPD resort / hospitality point-source); and Marine Feedstock Agreement (PACI cruise terminal — MARPOL-compliant on-island destination).
- ›The George Town Landfill reaches capacity ~2031. A Joint Working Group phase authorized by Q1 2027 is the critical-path decision required for Phase Initial COD at Q3 2028 — approximately three years before the current developed capacity limit.
- Every dollar of disposal cost is currently sunk. Under the current system, $160 spent on disposal returns $0 to GOCI. Under the CSA, the same dollar returns $120 in Circular Royalty™ at Month 13 — and grows annually. The opportunity cost of delay is not zero; it is 13 months of royalty payments foregone per year of postponement.
- The ReGen termination created a structural opening. The $17.7M payout and 7-year negotiation carry no forward value. No competing procurement is active. The procurement window is open — and the landfill runway is narrowing.
- Phase Initial (200 TPD) requires only the DEH MSW stream. No third-party contract negotiation. No PACI agreement. No WAC agreement. One counterparty: GOCI / DEH. The simplest possible first-phase structure is also the most urgent.
Commercial Structure and Decision Window
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
| Parameter | Carbotura Commitment | GOCI Commitment |
|---|---|---|
| Structure | Build-Own-Operate (BOO) — 30-year CSA | Circular Supply Agreement — feedstock supply commitment |
| Capital | 100% Carbotura-funded construction and operations | Zero capex. Zero construction debt. Zero operating liability. |
| Primary financial obligation | Circular Royalty™ payments from Month 13 onward | Beneficiation Fee — $100/ton delivered, escalating 2.5%/year |
| Facility ownership | Carbotura SPV for 30-year CSA term. No transfer at expiry. | Feedstock supply — no ownership interest required |
| Feedstock obligation | Accept all contracted streams; process to Circular Materials | Deliver contracted feedstock volume; maintain collection system |
| Performance standard | 99%+ Total Material Conversion; near-zero landfill residuals | Feedstock quality compliance (no restricted materials list) |
| Regulatory classification | NAICS 325180/325998/327992/331110/331314/331492 — manufacturing facility; not NAICS 562213/562219 | Standard manufacturing facility permit — Dept. of Planning |
| Circular Materials ownership | Carbotura SPV (synthetic graphite, graphene compounds, recovered minerals, net-positive ultrapure water) | Not applicable — feedstock supplier role only |
A Joint Working Group phase authorization is required by Q1 2027 to maintain the Phase Initial COD of Q3 2028 — approximately three years before the George Town Landfill reaches its current developed capacity limit (~2031). Authorizing after Q1 2027 compresses or eliminates the buffer between Phase Initial operations and the landfill capacity deadline. Term Sheet phase verification takes approximately 3 months (Q3–Q4 2026 if authorized at T0 = Q3 2026).
Deployment Architecture
Deployment Architecture
§2.1 — Phase Configuration
| Phase | TPD | Modules | Annual Feedstock (TPY) | % of Total Addressable | COD (est.) |
|---|---|---|---|---|---|
| Phase Initial | 200 | 2 | 73,000 | 20% | Q3 2028 |
| Phase Medium | 400 | 4 | 146,000 | 40% | Q1 2030 |
| Phase Expanded | 600 | 6 | 219,000 | 60% | Q3 2031 |
| Phase Full Build-Out | 1,000 | 10 | 365,000 | 100% | Q3 2033 |
§2.2 — BOO Capital Structure
| Capital Item | Phase Initial (200 TPD) | Phase Medium (+200 TPD) | Phase Expanded (+200 TPD) | Full Build-Out (+400 TPD) |
|---|---|---|---|---|
| CapEx — first 100 TPD module | $75.0M (×2 modules) | See incremental below | ||
| CapEx — additional 100 TPD modules | 2 × $57.5M = $115.0M | 2 × $57.5M = $115.0M | 4 × $57.5M = $230.0M | |
| Total phase CapEx (Carbotura-funded) | $150.0M | $115.0M | $115.0M | $230.0M |
| Cumulative programme CapEx | $150.0M | $265.0M | $380.0M | $610.0M |
| GOCI obligation | Beneficiation Fee per ton delivered only. Zero equity contribution. Zero debt service. | |||
§2.3 — Feedstock Stream Coverage by Phase
| Stream | Phase Initial | Phase Medium | Phase Expanded | Full Build-Out | Access Status |
|---|---|---|---|---|---|
| MSW — Commercial & Residential (DEH) | ✓ Partial (200 TPD of 356) | ✓ Full | ✓ Full | ✓ Full | IMMEDIATE |
| WWTP Biosolids (WAC) | ✓ | ✓ | ✓ | CONDITIONAL | |
| Marine / Cruise Feedstock (PACI) | ✓ | ✓ | ✓ | CONDITIONAL | |
| Resort / Regenesis™ Nodes | ✓ | ✓ | ✓ | ACCESSIBLE | |
| Exogenesis™ — Legacy Landfill Mining | ✓ Supplement | ✓ Full | CONDITIONAL | ||
| Sister Islands (Cayman Brac + Little Cayman) | ✓ Optional | ✓ | ACCESSIBLE |
§2.4 — Site Candidate Analysis
Three priority zones identified across the George Town industrial corridor. Coordinates and distances verified April 2026.
The Industrial Park zone immediately adjacent to the George Town Landfill (Seymour Drive / Esterly Tibbetts Highway) is the Priority 1 candidate by a significant margin. Co-location with the landfill eliminates feedstock transport entirely for the primary DEH MSW stream (~356 TPD). The Exogenesis™ mining operation is on-site. Existing industrial infrastructure (Island Waste Carriers, DEH operations, Pure Air industrial gas) confirms heavy-industrial land use precedent. The site is under Government of the Cayman Islands Crown land authority.
| Priority | Zone | Est. Acreage | Zoning | Land Authority | Co-location Advantage | Key Consideration |
|---|---|---|---|---|---|---|
| P1 | Industrial Park / Landfill Precinct | 15–25 acres (available) | Heavy Industrial | GOCI Crown land / DEH | Adjacent to George Town Landfill — zero transport for 356 TPD MSW stream; Exogenesis™ mining on-site; existing industrial operators confirm land use | Crown land availability and GOCI negotiation; Exogenesis™ remediation agreement required for legacy mining |
| P2 | Airport Industrial Corridor | 10–18 acres | Industrial / Mixed-use | Cayman Islands Airports Authority / GOCI | ~1.5 km from landfill; direct Roberts Drive access; established industrial precinct; Airports Authority land coordination mechanism | Airports Authority coordination required; airspace and noise planning constraints |
| P3 | North Sound / Godfrey Nixon Way Corridor | 8–12 acres | Industrial | Mixed (private / Crown) | ~2.5 km from landfill; North Sound Road industrial corridor; existing manufacturers confirm heavy industrial precedent; ~1.3 km from WAC WWTP | Private land acquisition or lease required; smaller available acreage; proximity to North Sound marine environment requires environmental assessment |
Phase Initial (200 TPD) is fully supportable from the immediately accessible DEH MSW stream without third-party contract negotiation. The 356 TPD IMMEDIATE-classified MSW stream delivered daily to the George Town Landfill by DEH exceeds Phase Initial requirements by 78%. One Circular Supply Agreement counterparty (GOCI / DEH) is required at Phase Initial. All other streams (biosolids, marine, resort) remain additive for Phase Medium and beyond.
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All site data is available in the zone panel →
Economic Structure — Beneficiation Fee
Economic Structure — Beneficiation Fee
The Facility-Wide Disposal Cost (FWDC) used in this Proposal is $160/ton (ESTIMATED). This is a modeled figure derived from the only publicly disclosed Cayman Islands disposal processing cost benchmark: the $163/ton contracted rate in the terminated ReGen (Dart consortium) agreement (Cayman Compass, April 2021). No active per-ton tipping fee is published by DEH. A Joint Working Group phase will establish the verified FWDC through government budget and contract review. All per-ton comparisons in this document use the $160/ton ESTIMATED basis.
Where: Floor = $100/ton | Ceiling = $150/ton | FWDC = $160/ton (ESTIMATED)
→ Applied fee: MAX($100, MIN($150, $155)) = $100/ton (floor applies — fee set at floor)
Annual escalator: 2.5%/year | Carbotura standard parameters
| Phase | Annual Feedstock (TPY) | Year 1 Beneficiation Fee ($/ton) | Year 1 Annual Obligation | Year 2 TMC ($/ton) | Year 10 TMC ($/ton) |
|---|---|---|---|---|---|
| Phase Initial (200 TPD) | 73,000 | $100.00 | $7,300,000 | $102.50 | $128.01 |
| Phase Medium (400 TPD) | 146,000 | $100.00 | $14,600,000 | $102.50 | $128.01 |
| Phase Expanded (600 TPD) | 219,000 | $100.00 | $21,900,000 | $102.50 | $128.01 |
| Full Build-Out (1,000 TPD) | 365,000 | $100.00 | $36,500,000 | $102.50 | $128.01 |
The $100/ton Beneficiation Fee is $60/ton below the $160/ton FWDC planning basis and $63/ton below the $163/ton terminated ReGen contract rate. This represents an immediate gross cost displacement before Circular Royalty™ is factored. At Phase Initial (73,000 TPY), the gross annual avoided disposal cost versus FWDC planning basis is approximately $11.7M/year.
Circular Royalty™ Structure
Circular Royalty™ Structure
Standard CSA: GOCI 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. By design, the Circular Royalty™ per ton 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.
- 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.
Where:
m = month of Beneficiation Fee payment
m+13 = month of corresponding Circular Royalty™ payment (13-month rolling lag)
Royalty_Rate(m) = 120% in Year 1, escalating +1 percentage point per year
TMC(m) = Beneficiation Fee at month m (base $100/ton, escalating 2.5%/year)
§4.0.1 — Royalty Parameter Table
| Parameter | Value | Basis |
|---|---|---|
| Circular Royalty™ base rate | 120% of that year's Beneficiation Fee | Carbotura standard CSA terms |
| Royalty escalator | +1 percentage point per year | Carbotura standard CSA terms |
| Royalty Year 2 (first payment year) | 120% × $100.00 = $120.00/ton | Locked formula |
| Royalty Year 10 | 128% × $124.89 = $159.86/ton | Locked formula |
| Royalty Year 30 | 148% × $199.65 = $295.48/ton | Locked formula |
| Payment lag | 13 months after corresponding Beneficiation Fee payment | Rolling monthly; not annual lump sum |
| Payment structure type | Rolling lagged cash flow | Carbotura standard CSA terms |
| CSA term | 30 years | Carbotura standard |
| Beneficiation Fee escalator | 2.5% per year compound | Carbotura standard CSA terms |
§4.0.2 — Fiscal Period Distinction
| Period | Timing | Description |
|---|---|---|
| Pre-Royalty Period | Months 1–12 after Phase Initial COD (Q3 2028 – Q3 2029 est.) |
GOCI pays Beneficiation Fee; Circular Royalty™ has not yet begun. This is the sole negative cash flow period under the CSA. |
| Royalty Ramp Period | Month 13 to ~Month 24 (Q4 2029 – Q4 2030 est.) |
Rolling royalty payments begin. GOCI receives $120.00/ton Circular Royalty™ against $102.50/ton Beneficiation Fee. |
| Steady State | Year 2 onward through Year 30 | Circular Royalty™ exceeds Beneficiation Fee on a per-ton basis in every year. The royalty rate escalates faster than the fee every year. |
§4.0.3 — Year-by-Year Cash Flow
| Year | Beneficiation Fee/ton | Avoided Disposal (Annual) | Beneficiation Fee Paid (Annual) | Royalty Rate | Royalty Received (Annual) |
|---|---|---|---|---|---|
| Year 1 (pre-royalty) | $100.00 | $11.68M | −$7.30M | $0 | |
| Year 2 (royalty begins) | $102.50 | $11.68M | −$7.48M | 120% | $8.76M |
| Year 5 | $110.38 | $11.68M | −$8.06M | 123% | $9.68M |
| Year 10 | $128.01 | $11.68M | −$9.34M | 128% | $11.68M |
| Year 20 | $163.86 | $11.68M | −$11.96M | 138% | $15.60M |
| Year 30 | $204.69 | $11.68M | −$14.94M | 148% | $21.55M |
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.
Avoided disposal calculated at $160/ton FWDC (ESTIMATED). All figures ESTIMATED. Subject to Joint Working Group phase verification.
GOCI pays the Beneficiation Fee and receives the Circular Royalty™ from Month 13. Site access is provided by lease or licence over Crown land via the Cayman Islands Land Register — no land transfer is required.
| Parameter | Value | Basis |
|---|---|---|
| Beneficiation Fee | $0 — at CSA execution | CSA §4B.1 |
| $100.00/ton of gross feedstock delivered | CSA §4B.2 | |
| Royalty Escalation | +1.0% per year from Year 2 | CSA §4B.2 |
| Payment Lag | 13 months after first Beneficiation Fee payment (rolling monthly) | Fixed |
| Take-or-Pay | Symmetric bilateral — $100/ton both directions | CSA §4B.3 |
| Accounting | IFRS (Cayman Islands — no domestic GAAP) · Site access: IFRS 16 / IAS 17 · Post-closure: IAS 37 extinguishment | Statutory |
| CSA Term | 30 years from Phase Initial COD (Q3 2028) · perpetual continuation unless terminated by Non-Renewal Notice | Locked |
| Year | Fee/ton | Circular Royalty™ $/ton | Annual Royalty (73,000 TPY) |
|---|---|---|---|
| 1 | $0 | $0 | $0 (pre-royalty) |
| 2 | $0 | $100.00 | +$7,300,000 |
| 5 | $0 | $103.03 | +$7,521,190 |
| 10 | $0 | $108.29 | +$7,905,170 |
| 20 | $0 | $119.61 | +$8,731,530 |
| 30 | $0 | $132.13 | +$9,645,490 |
.01n−2/ton. Phase Initial 200 TPD / 73,000 TPY. All ESTIMATED · Royalty and Fee are independent CSA transactions, never offset (Separate Transaction Principle MR §4.8). IFRS accounting.
- Under the CSA, GOCI pays the Beneficiation Fee per tonne delivered and receives the Circular Royalty™ from Month 13.
- At steady state, the.
- .
Exogenesis™ is presented here as a structured option for discussion. It becomes a CSA element only after: (1) Waste Characterization Study confirming extractable mass economics; (2) qualifying asset confirmation; (3) mutual agreement incorporated into the CSA. The George Town Landfill's 2031 capacity deadline creates urgency to begin that study process now.
Potential additive royalty stream, subject to Waste Characterization Study and mutual agreement. If elected after study confirmation, activated when GOCI deeds George Town Landfill to Carbotura at CSA execution (second instrument, independent of Carbotura deploys the Exogenesis™ Programme — APS mechanical sorting + fully electric extraction fleet — within 3–7 years post-COD, alongside the primary Regenesis™ facility.
| Parameter | Value | Basis |
|---|---|---|
| Royalty rate (if elected) | $50.00/ton extracted (Year 1 of extraction) | 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 |
| Asset transfer (if elected) | George Town Landfill deeded via GOCI Crown land instrument (CILS) at CSA execution — second instrument, independent of site swap | Cayman Islands land law |
| Carbotura obligations (if elected) | All post-closure care, leachate management, methane capture, groundwater monitoring transfer at CSA execution. EIL + PLL + Post-Closure Performance Bond provided by Carbotura (IFRS IAS 37 liability extinguishment for GOCI). | CSA §6 (draft) |
| Stacking | Independent of and additive to the Circular Royalty™ or8) | 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 |
| Year (post-COD) | Extraction (est. tpy) | Rate $/ton | Annual Exogenesis™ Royalty |
|---|---|---|---|
| 1–4 | $0 (programme not yet operational) | ||
| 5 | ~73,000 (est.) | $50.00 | $0 (13-month lag) |
| 6 | ~73,000 | $50.00 | +$3,650,000 |
| 10 | ~73,000 | $52.02 | +$3,797,460 |
| 30 | ~73,000+ | $63.49 | +$4,634,770 |
| 30-yr indicative cumulative (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. George Town Landfill estimated ~73,000 tpy extractable (planning basis only — subject to Waste Characterization Study confirmation). IFRS IAS 37 post-closure care liability extinguishment is independent of and additional to the Exogenesis™ Royalty cash flow.
CSA Structure
At CSA execution, GOCI The Exogenesis™ add-on (George Town Landfill) is a CSA add-on available for discussion — activation requires Waste Characterization Study, qualifying asset confirmation, and mutual agreement. The option is exercised at signing and is exclusive.
Cayman Islands Application Note: One CSA structure applies. The 0% CIT environment and Exempted Company structure provide the tax abatement framework. The George Town Landfill 2031 capacity deadline is the most time-sensitive structural driver — beginning the Waste Characterization Study now creates the option to include Exogenesis™ in the CSA framework before that deadline.
Exogenesis™ is a CSA add-on available for discussion — not a commitment at this stage. Activation requires: (1) Waste Characterization Study confirming extractable mass economics; (2) qualifying asset confirmation; (3) mutual agreement incorporated into CSA. The George Town Landfill's ~2031 capacity deadline creates urgency: Phase Initial COD is Q3 2028, leaving approximately 3 years between first feedstock delivery and the landfill deadline. Beginning the Waste Characterization Study now preserves the option to include Exogenesis™ in the CSA framework before that deadline closes. If elected after study confirmation, all post-closure care, leachate, and IAS 37 obligations transfer to Carbotura at CSA execution.
Risk Register
Risk Register
| Risk | Key Driver | Who Bears It | Mitigation | Residual |
|---|---|---|---|---|
| FWDC Verification | Current FWDC is ESTIMATED at $160/ton — no verified per-ton rate published | Shared — GOCI (procurement basis); Carbotura (TMC Floor) | Joint Working Group phase establishes verified FWDC via government budget review | Low — TMC Floor ($100) and Ceiling ($150) are hard contract parameters; FWDC variance affects comparison basis only |
| Technology Performance | MCR output quality, uptime, and Circular Materials yield | Carbotura SPV — GOCI bears no operating liability | BOO structure; performance bonds; 30-year O&M contract; Carbotura liability for Circular Materials | Low to GOCI — zero operating cost exposure |
| Timeline Slippage | Joint Working Group phase authorization delay; regulatory approvals; construction overruns | Carbotura (construction); GOCI (authorization) | Q1 2027 decision window defined; standard Carbotura deployment schedule applied; Phase Initial timeline allows landfill buffer | Moderate — landfill capacity ~2031 creates hard backstop; each quarter's delay narrows buffer |
| Third-Party Contract Constraints | Phase Medium requires WAC and PACI agreements; resort node agreements | Carbotura (Phase Medium planning); GOCI (facilitator role) | Phase Initial proceeds without any third-party agreements; Phase Medium structures negotiated during Phase Initial ops | Low for Phase Initial; moderate for Phase Medium timeline |
| Competitive Procurement | GOCI may re-procure WTE or alternative processing facility | Carbotura (opportunity risk) | CSA exclusivity clause for contracted stream; ReGen history creates structural complexity for competing procurement | Moderate — open procurement window; CSA provides institutional lock once executed |
| Exogenesis™ Permitting | Legacy landfill mining requires GOCI / DEH remediation agreement and environmental approval | Shared — Carbotura (design, permitting); GOCI (site access) | Exogenesis™ Protocol included in Joint Working Group phase scope; remediation is GOCI benefit (eliminates liability) | Moderate — novel approval pathway for island jurisdiction; GOCI motivation is strong (liability elimination) |
| PFAS / Emerging Contaminants | Any PFAS regulatory tightening affecting feedstock acceptance | Carbotura (process technology) | MCR achieves complete elemental dissociation of PFAS at 1,200°C+; no residual concern | Very low — MCR mechanistically eliminates PFAS; regulatory direction favors ACM |
| Island Currency / Forex | Beneficiation Fee and Royalty denominated in USD; CI$ peg is 1.22 USD | Minimal — CI$ is pegged to USD; no forex risk | CI$ peg has been maintained continuously; CSA denominated in USD | Very low |
Implementation Timeline
Implementation Timeline
| Milestone | Date (est.) | Notes |
|---|---|---|
| T0 — CSA Authorization / T0 date | Q3 2026 | Assumed T0; subject to GOCI confirmation |
| Joint Working Group phase — authorization | Q3 2026 | Decision window: no later than Q1 2027 to maintain Phase Initial schedule |
| Joint Working Group phase — complete | Q4 2026 | ~3 months; FWDC verification, site confirmation, stream quantification |
| Phase Initial construction start | Q1 2027 | Post-feasibility; site permitting parallel path |
| Phase Initial COD — 200 TPD | Q3 2028 | T0 + 24 months; first feedstock delivery; pre-royalty period begins |
| First Circular Royalty™ payment | Q4 2029 | 13 months after Phase Initial COD; rolling monthly royalty commences |
| Phase Medium full operations — 400 TPD | Q1 2030 | Includes WAC biosolids and PACI marine feedstock; T0 + 42 months |
| ⚠️ George Town Landfill hard capacity deadline | ~2031 | Current developed footprint capacity exhausted at ~13,000 cu yd/month intake. Phase Initial operational 3 years ahead of this deadline under current schedule. |
| Phase Expanded full operations — 600 TPD | Q3 2031 | Exogenesis™ mining supplement commences; T0 + 60 months |
| Phase Full Build-Out — 1,000 TPD | Q3 2033 | Full programme scale; Sister Islands integration |
| CSA term end | Q3 2058 | 30-year term from Phase Initial COD |
Community Value Stack
Community Value Stack
Fiscal Effects — GOCI
| Item | Phase Initial | Phase Medium | Full Build-Out | Source Type |
|---|---|---|---|---|
| Gross cost displacement (TMC vs. FWDC) | $4.38M/year | $8.76M/year | $21.90M/year | ESTIMATED |
| Circular Royalty™ received (Year 2+) | $8.76M/year (rising) | $17.52M/year (rising) | $43.80M/year (rising) | ESTIMATED |
| Landfill capital avoidance (new site procurement) | ~$60–100M+ (one-time) | ESTIMATED | ||
| Exogenesis™ remediation value (liability elimination) | Not quantified | Not quantified | Not quantified | Joint Working Group phase deliverable |
All fiscal figures ESTIMATED. Gross cost displacement uses $160/ton FWDC planning basis (ESTIMATED). Subject to Joint Working Group phase verification.
Regional Economic Effects
| Item | Phase Initial | Phase Medium | Full Build-Out | Source Type |
|---|---|---|---|---|
| Direct permanent FTE | 50 | 100 | 250 | ESTIMATED |
| Indirect / induced jobs | 150 | 300 | 750 | ESTIMATED |
| Annual economic impact (USD) | $16M+ | $32M+ | $80M+ | ESTIMATED |
| Construction employment | ~250 peak | ~450 peak | ~900 peak | ESTIMATED |
| ACM manufacturing classification (NAICS) | Adds manufacturing sector GDP contribution — new to Cayman Islands economic base | LOCKED | ||
Scaled from Carbotura standard 400 TPD baseline parameters. ESTIMATED. Detailed economic impact analysis is a Joint Working Group phase deliverable.
Why This Works in the Cayman Islands
Why This Works in the Cayman Islands
| # | Alignment Factor | Evidence |
|---|---|---|
| 1 | Volume alignment | ~130,000 TPY (356 TPD) VERIFIED MSW stream fully supports Phase Initial (200 TPD) with 78% surplus capacity. Active streams reach 413 TPD supporting Phase Medium. Exogenesis™ legacy material provides Phase Expanded+ supplement. Full 1,000 TPD build-out addressable through phased additions. |
| 2 | Infrastructure alignment | Priority 1 site (Industrial Park / Landfill Precinct) is co-located with the George Town Landfill — eliminating feedstock transport cost for the entire primary MSW stream. Existing DEH collection infrastructure requires only destination-change, not system redesign. Island compactness means all feedstock sources are within 10 km. |
| 3 | Contract timing alignment | George Town Landfill reaches developed capacity ~2031 (VERIFIED). Phase Initial COD is Q3 2028 — 3 years ahead of this deadline. First Circular Royalty™ payment arrives Q4 2029 — before the hard deadline. Phase Expanded (600 TPD) with Exogenesis™ mining activates at Q3 2031 — coinciding with landfill capacity limit and eliminating the disposal obligation entirely. |
| 4 | Policy alignment | GOCI 10-year National Solid Waste Plan (Minister Ebanks-Wilks, November 2025) explicitly calls for "processing facilities" and acknowledges recycling alone is insufficient. ACM qualifies as the processing facility solution under this framework. The plan allocates ~$8M+ capital for 2025/26 — Joint Working Group phase is a qualifying expenditure. |
| 5 | Organic mandate and regulatory driver | The landfill capacity deadline is not a projection — it is a parliamentary-stated fact confirmed by two government ministers. No competing procurement is active (ReGen terminated July 2024). MARPOL obligations create a regulatory driver for on-island marine feedstock processing. Little Cayman open burning creates an immediate compliance obligation. |
| 6 | Economics specificity | $100/ton Beneficiation Fee vs. $160/ton FWDC planning basis (ESTIMATED from $163/ton terminated ReGen rate) = $60/ton gross displacement. Circular Royalty™ of $120/ton begins Month 13, growing to $295/ton by Year 30. No other disposition option offers a return payment on feedstock delivered. The only other pricing benchmark the Cayman Islands government ever accepted was $163/ton — this offer is $63/ton lower at base and returns cash. |
Appendix A — Data Basis
| Item | Value Used | Source | Source Type |
|---|---|---|---|
| Annual landfill intake (MSW) | ~130,000 TPY (2024) | Cayman Compass, Nov 2025 (Finance Committee) | VERIFIED |
| Landfill capacity deadline | ~2031 | Minister Ebanks-Wilks, Nov 2025; Minister Turner, Parliament 2025 | VERIFIED |
| FWDC planning basis | $160/ton (MODELED) | Derived from terminated ReGen $163/ton contract (Cayman Compass April 2021) | ESTIMATED ⚠️ |
| Beneficiation Fee | $100/ton (formula applied) | Registry §E; formula floor applied | LOCKED |
| Circular Royalty™ formula | Royalty(m+13) = TMC(m) × Rate(m) | Carbotura standard CSA terms | LOCKED |
| CapEx — Phase Initial | $150M (2 × $75M) | Carbotura standard CapEx parameters | ESTIMATED |
| Employment and economic impact | 50 FTE / $16M+ (Phase Initial) | Carbotura standard 400 TPD baseline, scaled | ESTIMATED |
| Site coordinates — P1 | ~19.3025°N, 81.3640°W | Google Places API, April 2026 | CANDIDATE |
Appendix B — Selective Glossary
- Beneficiation Fee (Total Material Conversion Fee)
- The Beneficiation Fee paid per ton of manufacturing feedstock delivered to the ACM facility. Cayman Islands: $100/ton, escalating 2.5%/year. This is the community's sole financial obligation under the CSA.
- Circular Royalty™
- The conversion royalty paid by the ACM facility SPV to the feedstock source, commencing 13 months after corresponding Beneficiation Fee payments. Base rate: 120% of that year's Beneficiation Fee/ton; +1pp escalation per year. At steady state, designed to exceed the Beneficiation Fee on a per-ton basis.
- Circular Supply Agreement (CSA)
- The 30-year bilateral contract governing feedstock supply, Beneficiation Fee, Circular Royalty™, and performance standards. The complete commercial instrument for the ACM engagement.
- Facility-Wide Disposal Cost (FWDC)
- The total per-ton cost to GOCI of disposing of manufacturing feedstock under the current system. Cayman Islands: $160/ton ESTIMATED (MODELED from terminated ReGen $163/ton benchmark). Subject to Joint Working Group phase verification.
- Gross Cost Displacement
- The difference between FWDC and Beneficiation Fee — the per-ton saving from switching to ACM before Circular Royalty™ is considered. Cayman Islands Year 1: $160 − $100 = $60/ton gross displacement (ESTIMATED).
- Fiscal Flows, Shown Separately
- The annual sum of all fiscal effects: avoided disposal cost + Beneficiation Fee paid (negative) + Circular Royalty™ received. Year 1: negative (no royalty yet). Year 2 onward: positive and growing.
- Pre-Royalty Period
- The 13-month period from first feedstock delivery to first Circular Royalty™ payment. The pre-royalty period must be explicitly identified in all financial analysis and never blended with steady-state figures.
- Build-Own-Operate (BOO)
- The project delivery structure under which Carbotura funds 100% of construction, owns the ACM facility throughout the CSA term, and operates at its own cost and risk. GOCI bears no capex, no construction debt, and no operating liability. The facility is not transferred to GOCI at CSA expiry.