CARBOTURA
Economic Impact Review · Town of Brookhaven, NY
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Town of Brookhaven · Suffolk County, New York · August 2026

Economic Impact Review

Advanced Circular Manufacturing · State A vs. State B Delta Analysis · Prepared by Carbotura, Inc. · Confidential

Accounting Standard: US GAAP · Currency: USD · All dollar figures ILLUSTRATIVE
Rail export off Long Island — Brookhaven’s endorsed alternative — converts a closing disposal asset into a permanent, escalating operating cost with zero local economic return. Advanced Circular Manufacturing processes the material in the Town and holds roughly 200 direct jobs there at Phase Initial. It also pays the Town a recurring Circular Royalty™ that exceeds the Beneficiation Fee (TMC Fee) per ton from Year 2 and widens every year thereafter, with zero Town capital obligation at any phase. The manufactured outputs are sold globally; what stays with the community is the royalty stream.
Economic Impact Review · ~18 min read · DOC 03 OF 06

What this document is

The quantified delta model for the Town of Brookhaven. State A is the current system, per the Feedstock System Analysis. State B is Advanced Circular Manufacturing deployment, per the Deployment Proposal. No new values are introduced here. This Review measures the economic difference between the two states, for the Town of Brookhaven only.

Three things this document says
  1. Brookhaven’s alternative is not a cheaper disposal contract. It is export. Export sends every dollar off Long Island permanently, with no jobs, no manufacturing value, and no return payment.
  2. Under the Circular Supply Agreement (CSA) the Town pays a Beneficiation Fee (TMC Fee) and receives a Circular Royalty™ that exceeds it per ton from Year 2 ($120.00 received against $102.50 paid). The gap widens every year of the 30-year term, reaching $295.48 against $204.64 in Year 30 — ILLUSTRATIVE at a $100.00 Year-1 fee.
  3. Phase Initial at 400 TPD retains roughly 200 direct manufacturing jobs and displaces about 65,700 tCO₂e per year inside the Town, on already-industrial, already-Town-controlled ground.
Confidence Classifications Carried Forward — Plain English
  • Town-wide addressable feedstock ~1,102 TPD — ESTIMATED. Derived from the Long Island regional per-capita generation rate (4.5 lb/person/day, Long Island Regional Planning Council) applied to the Town’s 2024 Census population of 489,810. The Town publishes no town-wide tonnage. A Deployment Study must verify this against Town and hauler-specific manifests before any binding Circular Supply Agreement (CSA) economics.
  • No verified Town per-ton disposal cost. No public source states a current per-ton cost paid by the Town or its villages. Ash for Trash is a capacity swap, not a per-ton cash payment, so no comparable baseline could be locked. This Review claims no cost-displacement figure.
  • Candidate site — Yaphank / Horseblock Road corridor. Provisional. Coordinates are an approximate corridor centroid, not a confirmed site. Siting is subject to Town control and NYSDEC Region 1 review.
  • Regulatory predicate. Nothing in this Review claims that an ACM module has achieved, or will automatically achieve, End-of-Waste, by-product, or non-waste manufacturing classification under New York law. That transition is a pathway pursued through NYSDEC, not an accomplished fact.
  • Landfill permit horizon. The Brookhaven Landfill permit expires 11 July 2026; the Town seeks extension to 2027–2028. The outcome is outside the Town’s and Carbotura’s control and is treated here as a range, not a date.
Presentation conventions — stated once, governing every figure, table and chart below.
  • ILLUSTRATIVE. Every dollar value here is computed at a $100.00 Year-1 Beneficiation Fee (TMC Fee) for modelling. The formulas are canonical and locked; the fee is set at Term Sheet. Every dollar figure that follows is ILLUSTRATIVE on that basis, whether or not the word is repeated.
  • Separate Transaction Principle. The Beneficiation Fee paid and the Circular Royalty™ received are two independently reported gross transactions, not a netted position. The flows are never netted in any budget line, financial statement, or accounting treatment.
  • Confidence labels. VERIFIED, ESTIMATED, DATA GAP and ILLUSTRATIVE carry the definitions given in Appendix C and the Basis of Presentation.
  • Fiscal and regional effects are categorically distinct. Town fiscal effects (fee obligations, royalty receipts) and regional economic effects (jobs, economic contribution, product value) have different accountability structures, reporting standards and decision implications. They appear separately throughout and must never be aggregated in any budget or financial statement.

§1.1 — What This Review Measures

This Review measures the delta between two defined states for the Town of Brookhaven. It is Town-scoped throughout: every figure below describes Brookhaven. No regional programme is modelled.

STATE A Without Carbotura: The Town continues its current arrangement — municipal solid waste combusted at the Covanta Hempstead waste-to-energy facility, with roughly 350,000 tons per year of resulting ash returned to the Town-owned Brookhaven Landfill at 350 Horseblock Road, Yaphank. Construction and demolition acceptance ended at the close of 2024. The landfill permit expires 11 July 2026, with extension sought to 2027–2028. The Long Island Landfill Law of 1983 bars new landfills across Long Island, so no replacement disposal asset is permittable. The endorsed successor is rail export off Long Island entirely, via the Winters Rail Terminal adjacent to the landfill site and the Townline Rail Terminal at Kings Park.

STATE B With Carbotura: The Town enters a 30-year Circular Supply Agreement (CSA) with Carbotura, Inc. Phase Initial deploys 400 TPD (146,000 TPY) of Advanced Circular Manufacturing capacity in the Yaphank / Horseblock Road corridor. Phase Expanded replicates capacity to 1,200 TPD (438,000 TPY), approaching the full estimated addressable volume. The Town pays a Beneficiation Fee (TMC Fee). From 13 months after Carbotura’s receipt of the first fee payment, the Town receives a rolling Circular Royalty™ that exceeds the fee on a per-ton basis.

Neither state is re-diagnosed here. State A values trace to the Feedstock System Analysis; State B values trace to the Deployment Proposal. This Review quantifies the difference.

§1.2 — Decision Summary Table

DimensionSTATE ASTATE BDelta
Destination for Town material after landfill closureRail export off Long Island — permanentManufactured in Brookhaven under a 30-year CSAMaterial benefits local community through royalties
Where the money goesOff Long Island, in full, in perpetuityBeneficiation Fee (TMC Fee) paid to Carbotura, escalating 2.5%/yrFee is offset by a larger Circular Royalty™ receipt from Year 2 (separate transactions)
Payment received by the Town$0 — export returns nothingCircular Royalty™ from 13 months after the first Beneficiation Fee payment+$17.52M/yr at Phase Initial Year 2; +$43.14M/yr at Year 30 Illustrative
Town capital obligation$0$0Equal
Direct manufacturing employment0 — export creates no local manufacturing jobs~200 FTE at 400 TPD; ~600 FTE at 1,200 TPD+~200 to +~600 direct jobs
Per-ton fiscal flows (Town)Export cost only — no return paymentYear 1: Fee paid; Royalty $0 (pre-royalty). Year 2+: Royalty exceeds Fee per ton (separate transactions)—
30-year trajectoryExport cost with no ceiling and no local returnBeneficiation Fee escalates 2.5%/yr; Circular Royalty™ multiplier rises +1pp/yrRoyalty growth outpaces Fee growth by construction
Carbon positionCombustion plus long-haul rail transport~65,700 tCO₂e/yr displaced at Phase Initial; ~197,100 tCO₂e/yr at Phase ExpandedStructural improvement
Key data gapNo published Town per-ton disposal costBeneficiation Fee set at Term SheetAll dollar figures ILLUSTRATIVE
Classification (RPT) ACM permitted only under manufacturing NAICS (325180 / 325998 / 327992 / 331110 / 331314 / 331492 — six-code manufacturing set). Solid waste codes (562212 / 562213 / 562219 / 562920) 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). New York predicate transition is a pathway pursued with NYSDEC Region 1 — not an accomplished classification. Standing condition · MR §3
Analysis Basis — The Circular Supply Agreement (CSA) Carbotura offers a single commercial structure: the Circular Supply Agreement (CSA) — Beneficiation Fee (TMC Fee) plus Circular Royalty™. Every delta calculation assumes it. The Town pays the fee and receives the royalty at a 120% multiplier rising +1 percentage point per year, from 13 months after Carbotura’s receipt of the first fee payment (CSA Art. 1.5).

§1.3 — Fiscal vs. Regional Economic Separation

Town fiscal effects and regional economic effects are categorically distinct and are never aggregated in this Review. The governing declaration is stated in full under Presentation conventions, above.

Source: Feedstock System Analysis. All values from the locked Assumption Registry or the Feedstock System Analysis. No new diagnosis.

§2.1 — The Current System

ElementCurrent ConditionConfidence
Town population489,810 (2024 Census, QuickFacts PST045225)VERIFIED
Town-wide addressable feedstock~1,102 TPD (~402,000 tons/year) — 489,810 × 4.5 lb/person/day ÷ 2,000ESTIMATED
Municipal solid waste routeAsh for Trash — Town MSW combusted at the Covanta Hempstead waste-to-energy facility since 1990VERIFIED
Ash returned for landfilling~350,000 tons/year to the Brookhaven Landfill, YaphankESTIMATED
Construction & demolition debris~600,000 tons (2022), ~470,000 tons (2023); acceptance ended at the close of 2024VERIFIED
Brookhaven Landfill350 Horseblock Road, Yaphank · a roughly 500-acre Town-owned waste-management complex, within which the landfill cells sit · opened 1974VERIFIED
Landfill permit expiration11 July 2026 — extension sought to 2027–2028VERIFIED
Permitting authorityNYSDEC Region 1, 6 NYCRR Part 360 seriesVERIFIED
Town per-ton disposal costNot published. Ash for Trash is a capacity swap, not a per-ton cash payment.DATA GAP

§2.2 — Why There Is No Local Replacement

The Long Island Landfill Law (1983). Enacted after landfill leachate was found in the region’s sole-source aquifer, the Law bans new landfills across Long Island and closed all but two by 1989. Municipal solid waste landfilling on Long Island ended in 1990. A replacement landfill for Brookhaven is not permittable at any price. This is a capacity constraint, not a cost problem, and it has no local legal remedy inside the disposal paradigm.
The planning structure compounds it. Uniquely on Long Island, the 13 towns and 2 cities are the waste-planning units, not the counties. Brookhaven owns its own post-landfill answer. There is no county-level facility to fall back on.

§2.3 — The Endorsed Alternative: Rail Export

On-site disposal capacity ends in the 2026–2028 window, and no new Long Island landfill is permittable. The regionally endorsed path is therefore rail export of processed ash and residual material off Long Island entirely. Two projects define it:

ProjectLocationRole
Winters Rail TerminalAdjacent to the Brookhaven Landfill site, YaphankRail-served transfer and export facility
Townline Rail TerminalKings ParkServes Huntington and Smithtown export
Estimated regional transfer capacity~6,000 TPD

All ten Suffolk Town Supervisors and the County Executive have endorsed rail export as the clear solution for moving material off Long Island. This Review does not dispute that endorsement or argue against building the terminals. It addresses what export does to the Town’s economics.

§2.4 — What Export Costs the Town Economically

Key Structural Finding — Total Leakage Every dollar the Town spends on export leaves Long Island. The material leaves, and the manufacturing value it contains leaves with it. No manufacturing jobs are created. No royalty, fee, or revenue share flows back. In no year of the export trajectory does the Town receive a payment. That zero local economic return is structural, not a function of the rate negotiated.

No dollar figure is assigned to the export cost here, because no verified Town-specific per-ton export rate is published. The argument does not need one: at any rate, the Town’s return is zero and the cost escalates for the life of the arrangement.

§2.5 — State A Structural Position

DimensionState A Condition
Post-closure destinationExport dependency — permanent, escalating, and outside the Town’s control
Local economic returnNone. Export produces no local manufacturing employment and no payment to the Town.
Carbon profileCombustion at Hempstead plus long-haul rail transport emissions added by export
Aquifer positionSole-source aquifer protection is the reason the 1983 Law exists; landfill closure is a protective step, but export does not create any new local environmental asset
Site outcome at YaphankClosed landfill plus post-closure reserve fund; the Town’s stated vision is redevelopment as an “energy park,” currently unbuilt

Source: Deployment Proposal EIR Input Block only. No new values introduced.

§3.1 — What Carbotura Manufactures

Advanced Circular Manufacturing (ACM) processes delivered feedstock through elemental dissociation. The manufactured outputs are synthetic graphite, graphene compounds, and recovered minerals, plus net-positive ultrapure water. Carbotura does not sell power, electricity, or hydrogen. ACM modules are manufactured products deployed under a Design for Manufacturability (DFM) model: capacity is added by replicating modules, not by bespoke site construction.

§3.2 — Deployment Configuration

PhaseTPDAnnual FeedstockShare of Estimated Town-wide Volume
Phase Initial400146,000 TPY~36% of the ~1,102 TPD ESTIMATED addressable volume — conservative entry configuration
Phase Expanded1,200438,000 TPYApproaches the full estimated addressable volume

The ~1,102 TPD addressable volume is ESTIMATED and requires Deployment Study verification against Town and hauler-specific manifests. It reflects municipal solid waste alone. Landfill leachate and wastewater treatment sludge are additional accepted feedstock streams that widen the addressable volume beyond MSW, in volumes the Deployment Study will establish.

§3.3 — State B Economic Terms

ParameterValueSource
Beneficiation Fee (TMC Fee) — Year 1$100.00 per ton IllustrativeModelling basis · set at Term Sheet
Beneficiation Fee annual escalator2.5% per year, compoundedCarbotura standard
Circular Royalty™ multiplier120% at first payment, rising +1 percentage point per year to 150%Carbotura standard
Circular Royalty™ calculationThat year’s multiplier applied to the escalated Beneficiation FeeCarbotura standard
Circular Royalty™ commencement13 months after Carbotura’s receipt of the first Beneficiation Fee payment (canonical CSA royalty trigger, Art. 1.5)CSA Art. 1.5
Payment basisRolling monthly — not an annual batchCarbotura standard
Town capital obligation$0VERIFIED
Town operating liability$0VERIFIED
CSA term30 years from Phase Initial commercial operationCarbotura standard
Commercial structureSingle Circular Supply Agreement (CSA) structure — Beneficiation Fee (TMC Fee) plus Circular Royalty™. No election.Carbotura standard

§3.4 — Site Context

The candidate area is the Yaphank / Horseblock Road corridor: existing Town-owned solid-waste infrastructure with established heavy-vehicle access. The site is a roughly 500-acre Town-owned waste-management complex, within which the landfill cells sit. The Town’s stated post-closure vision for it is redevelopment as an “energy park,” and the Yaphank Fuel Cell Park already operates there, so industrial and energy reuse has already begun. An ACM module here lands on already-industrial, already-Town-controlled ground rather than greenfield. Carbotura has no relationship to the fuel cell park and does not sell power or electricity.

Transition-status discipline. Nothing in this Review claims that an ACM module has achieved, or will automatically achieve, End-of-Waste, by-product, or non-waste manufacturing classification. The regulatory predicate transition is a pathway pursued through NYSDEC Region 1, not an accomplished fact. No claim is made that this would not be a permitted facility under current New York law.

§3.5 — Permitting and Timeline Anchoring

StepAuthority / Timing
Pre-application meetingNYSDEC Region 1 Regional Permit Administrator — standard first step
Permit application6 NYCRR Part 360 series
Local siting and zoningTown of Brookhaven
Environmental review coordinationSuffolk County
First Beneficiation Fee paymentMonth 1 following commercial operation
First Circular Royalty™ payment13 months after Carbotura’s receipt of the first Beneficiation Fee payment

The Phase Delta Map shows the infrastructure transition from State A (the current system and its endorsed export successor) to State B (ACM deployment). State A facilities appear in steel, amber, and red; the Phase Initial ACM candidate area appears in emerald. All positions are indicative.

Phase Delta Map — requires Google Maps API key in config.js
State A — Waste-to-energy
State A — Landfill
State A — Export terminals
State B — ACM candidate area
State A — Current System
Covanta Hempstead waste-to-energy facility · Town MSW combusted since 1990 · ash returns to Yaphank
Brookhaven Landfill · 350 Horseblock Road, Yaphank · a roughly 500-acre Town-owned waste-management complex, within which the landfill cells sit · permit expires 11 July 2026
Winters Rail Terminal (adjacent to the landfill) and Townline Rail Terminal, Kings Park · the endorsed export route · ~6,000 TPD estimated regional transfer capacity
State B — With Carbotura
ACM candidate area — Yaphank / Horseblock Road corridor
Existing Town-owned solid-waste infrastructure · established heavy-vehicle access · consistent with the Town’s stated “energy park” post-closure vision · Phase Initial 400 TPD · approximate corridor centroid, not a confirmed site

§4.1 — Retention versus Leakage

The delta between State A and State B reduces to one question: does Brookhaven capture economic benefit from its own material, or does that material leave with nothing coming back?

What happens to…STATE A — ExportSTATE B — ACM
The materialLeaves Long Island by rail, permanentlyProcessed at the Town module; manufactured outputs sold globally
The manufacturing value in the materialCaptured elsewhere, by someone else, with nothing returnedReturned to the Town as a per-ton Circular Royalty™
The jobsCreated elsewhere — transport handling only, locally~200 direct FTE at Phase Initial; ~600 at Phase Expanded
The moneyLeaves Long Island in full, every year, foreverBeneficiation Fee paid; a larger Circular Royalty™ paid back to the Town from Year 2 onward
The site at YaphankClosed landfill; energy-park vision unbuiltOperating manufacturing capacity on already-industrial ground
This is the central economic finding of the Review. Export is not a cheaper or dearer version of the same thing. It is a different economic category: a pure outflow. ACM is a two-way transaction in which the Town both pays and receives, and receives more per ton than it pays from Year 2 of the term onward.
Structural Context — How the Town’s Other Landfill Obligations Are Financed The Town is separately engaged in an active NYSDEC corrective-measures process for the Brookhaven Landfill. On 5 August 2026 the Division of Materials Management, Region 1 returned the Town’s draft Corrective Measures Report (dated May 2026) unable to approve it, with 40 technical comments at Appendix 1. A revised draft is due within 90 days, on or about 3 November 2026. The measures under evaluation are immediate landfill closure and capping, landfill reclamation, groundwater extraction and treatment, enhanced leachate plume monitoring, and municipal water connections. That process sits outside this Review’s delta model; no measure is evaluated here.

It is nonetheless relevant here, for one reason. The Town’s own Report expresses its cost framework in total debt repayment, total annual property tax increase across the township, and annual tax impact to the average home over the term of borrowing. Every measure under evaluation is therefore financed the same way: by Brookhaven taxpayers, through property-tax increases and municipal borrowing.

That sharpens the retention-versus-leakage frame. Rail export is an outflow the Town pays for indefinitely with no return. The corrective-measures programme is an outflow taxpayers fund through the tax levy and its debt service. A Circular Supply Agreement runs the other way: the Town receives a per-ton Circular Royalty™ instead of levying a tax increase or issuing debt. The direction of the flow is the finding, not its magnitude.

Deliberate omissions. No dollar figure from the Report’s cost table is cited here. DEC comment 28 challenges those calculations as containing errors, so no figure drawn from it is safe to quote. Selection of a corrective measure is the Town’s decision, not DEC’s (DEC comment 37) and not Carbotura’s. Nothing in this Review claims that NYSDEC has endorsed, selected, approved, or is considering Carbotura; that Carbotura is or would be a corrective measure; or that Carbotura treats groundwater, remediates a plume, or addresses the contaminants named in the correspondence. Carbotura processes solid material only.

§4.1 — Per-Ton Schedule (Both Configurations)

The per-ton schedule below is identical for Phase Initial and Phase Expanded: configuration changes the tonnage, not the rate. ILLUSTRATIVE basis as stated above.

YearBeneficiation FeeCircular Royalty™
Year 1$100.00— (13-month lag)
Year 2$102.50$120.00
Year 5$110.38$132.46
Year 10$124.89$155.96
Year 20$159.87$215.23
Year 30$204.64$295.48

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.

Structural PropertyThe Beneficiation Fee escalates at a fixed 2.5% per year; the Circular Royalty™ multiplier rises +1 percentage point per year on top of that same escalated base. The multiplier grows while the fee escalator stays constant, so the gap between what the Town receives and what it pays cannot narrow. After Year 1, no year is worse than the one before it.

Separate Transaction Principle applies — see Presentation conventions.

Per-Ton Position — Beneficiation Fee vs. Circular Royalty™, Years 1–30
The fee escalates at a fixed 2.5%/yr. The royalty multiplier rises +1pp/yr on top of that same escalated base. The gap widens for the full 30-year term.
Source: Carbotura canonical royalty formula (Corpus Release 31) · ILLUSTRATIVE basis · Town of Brookhaven, August 2026

§4.3 — Pre-Royalty Period Separation (Required)

Year 1 and the post-commencement royalty periods have materially different fiscal characteristics. They must not be combined in any budget projection, annual financial statement note, or briefing to the Town Board.

PeriodBrookhaven PaysBrookhaven ReceivesPer-Ton Position
Year 1 — Pre-RoyaltyMonth 1 to Month 12 Beneficiation Fee (TMC Fee) at $100.00/ton $0 Fee only — royalty has not yet commenced
Royalty RampFrom 13 months after the first fee payment Beneficiation Fee (2.5%/yr) 120% multiplier · rolling monthly · building Turning positive
Steady State — Year 2+Year 2 onward $102.50/ton, compounding $120.00/ton, rising Royalty exceeds Fee per ton — by contractual design
Year 30 — MaximumFull escalation $204.64/ton $295.48/ton (148% multiplier) Widest position of the term

Circular Royalty™ payments begin 13 months after Carbotura’s receipt of the first Beneficiation Fee payment and ramp on a rolling monthly basis. It is not an annual switch-on: each fee payment generates a corresponding royalty payment thirteen months later.

§4.4 — Configuration Totals (30-Year)

MeasurePhase InitialPhase Expanded
Throughput400 TPD · 146,000 TPY1,200 TPD · 438,000 TPY
Year-2 Circular Royalty™$17.52M$52.56M
Year-30 Circular Royalty™$43.14M$129.42M
30-year cumulative Circular Royalty™$829.4M$2.488B
30-year cumulative Beneficiation Fee (TMC Fee)$641.0M$1,922.9M
Direct manufacturing employment~200 FTE~600 FTE
Carbon displaced~65,700 tCO₂e/yr~197,100 tCO₂e/yr

ILLUSTRATIVE; Separate Transaction Principle applies. Cumulative figures are the sum of the annual flows across the 30-year term.

Two Gross Flows — Beneficiation Fee Paid and Circular Royalty™ Received, Years 1–20
Both items shown gross and separately, never netted. Year 1 is fee-only; from Year 2 onward the royalty received exceeds the fee paid, every year.
View:
Beneficiation Fee Paid Circular Royalty™ Received
Source: Carbotura canonical royalty formula (Corpus Release 31) · ILLUSTRATIVE basis · Annual view at Phase Initial 146,000 TPY · August 2026

§5.1 — Employment Delta (Regional Effects)

Required declaration: Employment figures are regional economic effects, not Town fiscal receipts. They do not appear in the Town’s accounts and must not be recorded as such.
ParameterSTATE ASTATE BDelta (B vs A)
Direct manufacturing FTE — Phase Initial (400 TPD)0~200 FTE+~200 FTE
Direct manufacturing FTE — Phase Expanded (1,200 TPD)0~600 FTE+~600 FTE
Employment basis50 direct FTE per 100 TPD — Carbotura standard deployment model
Employment under rail exportExport creates transfer and haulage handling, not manufacturing employment. No manufacturing FTE is created in the Town under State A.

Direct FTE only. Indirect and induced effects follow from a manufacturing payroll of this size but are not quantified here, and no multiplier is asserted. Subject to independent assessment at the Deployment Study.

§5.2 — Environmental Delta

Required disclaimer: State B environmental figures are designed-for metrics from Carbotura’s ACM platform, not independently verified operational results for Brookhaven. Subject to confirmation at the Deployment Study.
ParameterSTATE ASTATE BDelta (B vs A)
Carbon displaced — Phase Initial0~65,700 tCO₂e/yr+~65,700 tCO₂e/yr
Carbon displaced — Phase Expanded0~197,100 tCO₂e/yr+~197,100 tCO₂e/yr
Carbon basis0.45 tCO₂e displaced per ton processed — Carbotura baseline
Long-haul transport emissionsAdded by rail export of every tonEliminated for every ton processed in the TownStructural reduction
WaterNet-positive ultrapure water produced by the processPositive
Manufactured outputsNone — material leaves the regionSynthetic graphite, graphene compounds, recovered mineralsLocal manufacturing output created

§5.3 — Aquifer and Land-Use Position

Long Island’s groundwater system is a designated sole-source aquifer, and protecting it is why the 1983 Long Island Landfill Law exists. Closing the Yaphank landfill is a protective step, but closure alone creates nothing new — the material simply moves. An ACM module in the Yaphank / Horseblock Road corridor keeps material handling on already-industrial, already-Town-controlled ground with established containment and heavy-vehicle access. It processes that material through elemental dissociation into manufactured products rather than depositing it, consistent with the Town’s stated “energy park” vision for the site.

§5.4 — No-Fallback Analysis

Without State B, State A continues with three structural conditions no negotiation inside the disposal paradigm can resolve:

  1. No permittable local replacement (hard): the 1983 Law bars a new Long Island landfill at any price.
  2. Permanent outflow (structural): export is an operating cost paid forever, with no return payment, no local manufacturing employment, and no captured value.
  3. No local asset created (structural): after closure and export, Brookhaven holds a closed site, a post-closure reserve obligation, and a recurring bill.

§6.1 — Risk Register (Delta Analysis Frame)

RiskKey DriverA ExposureB ExposureDelta (B vs A)
Feedstock volume below estimate~1,102 TPD figure is ESTIMATED, not manifest-verifiedNo changeRoyalty scales with delivered tonnage; per-ton relationship unchangedNo Town penalty — volume risk is symmetric
Landfill permit extension deniedNYSDEC Region 1 decision on the 2027–2028 requestExport dependency begins soonerIncreases the value of having ACM capacity contracted earlyState B advantage larger
Export rates rise faster than expectedRail capacity, long-haul disposal marketCost rises with no offsetting receiptBeneficiation Fee escalator contractually fixed at 2.5%/yrState B advantage larger
Permitting timeline slippagePart 360 series review, Town siting, County coordinationNo changeRoyalty commencement moves with commercial operation dateDelay defers benefit; it does not reduce the per-ton structure
Module capacity underperformanceDelivered throughput below configurationN/AProportional reduction; residual material continues on existing routes; no penalty on the TownPartial benefit; no Town financial risk
Regulatory predicate transition slower than hopedNYSDEC classification pathwayN/AModule operates under its granted permit; classification transition pursued separatelyPathway risk, disclosed — no classification claimed
Beneficiation Fee set above the modelling basisTerm Sheet outcomeNo changeRelationship preserved at any fee level
Royalty multiplier policy changeRenegotiation at CSA renewalN/AFirst 30 years locked at execution; renewal at Year 30Long-term stable

§6.2 — Feedstock Variability ±20% (Phase Initial)

ScenarioAnnual VolumeYear-2 Beneficiation Fee ObligationYear-2 Circular Royalty™ Receipt
Base case — 400 TPD146,000 TPY$14.97M$17.52M
−20%116,800 TPY$11.97M$14.02M
+20%175,200 TPY$17.96M$21.02M

Volume risk is symmetric, and the per-ton relationship is unchanged at any volume. Town exposure is bounded by actual delivered tonnage; there is no minimum-volume penalty. ILLUSTRATIVE.

§6.3 — Fee-Level Sensitivity: No Sign-Change Threshold

Finding — No Sign-Change Threshold ExistsSet the fee above the $100.00 modelling basis and the royalty rises proportionally; set it lower and both fall proportionally. The relationship between them does not change. Year 1 is always pre-royalty — structural, not a sensitivity.

§6.4 — Royalty Multiplier Sensitivity (Per Ton, Year 30)

ScenarioYear 2Year 10Year 30
Multiplier static at 120%120%120%120%
Multiplier +1pp/yr (contractual)120%128%148%

Even with a static 120% multiplier, the Circular Royalty™ exceeds the Beneficiation Fee in every year from Year 2. The contractual +1pp/yr escalation is what turns a fixed advantage into a widening one. Figures ILLUSTRATIVE.

§6.5 — Timing Sensitivity

ScenarioConsequence
Deployment Study authorised nowMaximum overlap between ACM commercial operation and the landfill’s remaining permitted life; export dependency minimised
Deployment Study deferredExport arrangements are contracted first and become the default; ACM enters against an incumbent rather than into an open window
No actionFull export dependency, permanently, with no local return of any kind

§7.1 — Binding Constraints

Constraint 1 — the landfill permit horizon. The permit expires 11 July 2026, extension sought to 2027–2028. Granted or not, the horizon is short and outside the Town’s unilateral control. C&D acceptance has already ended.

Constraint 2 — no permittable local replacement. The 1983 Law forecloses the obvious answer. No disposal path keeps the material and the money on Long Island; only a manufacturing path does.

Constraint 3 — export becomes the incumbent once contracted. The Winters and Townline terminals are moving forward with broad regional endorsement. Once export flows are committed, they define the default for a long period. The closing window is the one in which ACM is weighed as an alternative rather than as a displacement of an incumbent.

§7.2 — Irreversibility Mechanism

Structural Irreversibility The irreversible mechanism is not a Carbotura deadline. It is a statutory ban on local replacement capacity (1983) and a closing permitted asset (2026–2028), meeting a regionally endorsed export solution now being built. Once Brookhaven’s tonnage is committed to export contracts, the economics of the Town’s material are settled for the duration of those contracts, as a pure outflow. The Town’s own permit calendar creates the urgency, not Carbotura.

§7.3 — Optionality Matrix

ActionOptions PreservedOptions Foreclosed
Authorise the Deployment StudyAll phases open; feedstock figures verified against real manifests; export remains fully available as a parallel or partial routeNone
Defer until export contracts are executedACM still technically feasibleACM must displace committed tonnage rather than absorb open tonnage
Take no actionExport proceeds as endorsedNo local manufacturing employment; no Circular Royalty™ receipt; permanent outflow of the Town’s material value
The Deployment Study is the lowest-cost, highest-optionality action available. It verifies the feedstock estimate against Town and hauler manifests, establishes the Term Sheet cost baseline, and commits the Town to nothing. Every subsequent option is preserved, including full export.

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

§8.1 — Fiscal Flows (Town of Brookhaven Accounts — US GAAP)

ILLUSTRATIVE; Separate Transaction Principle applies. Under US GAAP as applied to the Town: Beneficiation Fee obligations are operating service costs; Circular Royalty™ receipts are operating revenue, receivable from 13 months after Carbotura’s receipt of the first fee payment; capital obligation is nil.

§8.2 — Regional Economic Effects

Required disclaimer: The following are regional economic impacts, not Town fiscal receipts, and must not be recorded as such in the Town’s accounts.
EffectSTATE ASTATE BDelta
Direct manufacturing FTE (Phase Initial)0~200+~200
Direct manufacturing FTE (Phase Expanded)0~600+~600
Local manufacturing outputNone — material exportedSynthetic graphite, graphene compounds, recovered mineralsCreated

§8.3 — Environmental Effects

EffectSTATE ASTATE BDelta
Carbon displaced (Phase Initial)0~65,700 tCO₂e/yr+~65,700 tCO₂e/yr
Carbon displaced (Phase Expanded)0~197,100 tCO₂e/yr+~197,100 tCO₂e/yr
Long-haul export transportEvery tonEliminated for processed tonnageStructural improvement
WaterNet-positive ultrapure waterPositive

§8.4 — Structural Effects

EffectSTATE ASTATE BDelta
Where the economic value goesOff Long Island, permanentlyReturned to the Town as Circular Royalty™Leakage converted to a royalty return
Payment received by the TownNone at any rateCircular Royalty™ from Year 2Introduced
Town capital liability$0$0Equal
Yaphank site trajectoryClosed landfill; energy-park vision unbuiltOperating manufacturing capacity consistent with the Town’s stated visionImproved

§8.5 — Unresolved Data Gaps

Data GapImpact on Delta AnalysisResolution Pathway
Town-wide MSW generation tonnageAddressable volume is ESTIMATED from a regional per-capita average; affects phase sizing, not the per-ton structureDeployment Study verification against Town and hauler-specific manifests
Town per-ton disposal costNo cost-displacement figure can be stated; this Review makes no such claimTown finance disclosure under Deployment Study NDA
Beneficiation Fee (TMC Fee) baseAll dollar figures remain ILLUSTRATIVE until setTerm Sheet
Landfill permit extension outcomeShifts the timing of full export dependency, not its characterNYSDEC Region 1 determination
Site confirmation in the Yaphank corridorCoordinates are an approximate centroidTown siting review and site investigation at Term Sheet phase

Executive Implications

  • Brookhaven’s choice is not between two disposal prices. It is between an outflow and a transaction. Rail export returns nothing at any rate. Advanced Circular Manufacturing pays the Town a Circular Royalty™ that exceeds the Beneficiation Fee (TMC Fee) per ton from Year 2 and widens every year of the 30-year term.
  • The structural case does not depend on any figure still open. The royalty is a multiplier of at least 120% on the same fee the Town pays, so the relationship holds at any fee level. The Deployment Study establishes the scale, not whether the benefit exists.
  • The jobs and the carbon are local, and export can never replicate them. Roughly 200 direct manufacturing jobs at Phase Initial and roughly 600 at Phase Expanded, with about 65,700 and 197,100 tCO₂e displaced per year respectively — all inside the Town, on already-industrial, already-Town-controlled ground.
  • The Yaphank corridor is the natural site, and the Town has already said so. Its stated post-closure vision for the landfill site is an energy park. An ACM module fits that trajectory and uses infrastructure the Town already owns.
  • Every other landfill obligation on the Town’s desk is financed by taxpayers; this one pays the Town. The corrective-measures process now before NYSDEC is costed in total debt repayment, township-wide property tax increase, and annual tax impact to the average home over the term of borrowing. A Circular Supply Agreement is the only pathway in this Review under which money moves toward the Town. Carbotura is not a corrective measure, and the selection is the Town’s to make.
  • The window is defined by the Town’s own permit calendar. The landfill permit expires 11 July 2026 with extension sought to 2027–2028, and the endorsed export terminals are moving. Authorising the Deployment Study costs the Town nothing and forecloses nothing, including export.

Sources

SourceRole in Delta Analysis
U.S. Census Bureau QuickFacts — Brookhaven town, Suffolk County, New York (PST045225)Town population 489,810 (2024); feedstock estimate basis
Long Island Regional Planning Council — per-capita generation rate4.5 lb/person/day; the multiplier in the feedstock estimate
NY Office of the State Comptroller — Local Governments and the Municipal Solid Waste Landfill Law (2018)Long Island Landfill Law 1983; town-level planning structure
NYSDEC — Brookhaven Landfill fact sheets; 6 NYCRR Part 360 seriesPermit horizon; Region 1 permitting pathway
NYSDEC Division of Materials Management, Region 1 — letter of 5 August 2026 to the Town of Brookhaven, RE: Draft Corrective Measures Report comments (public regulatory correspondence)Status of the corrective-measures process; the measures under evaluation; the cost framework expressed in debt repayment, township-wide property tax increase, and per-home annual tax impact
Town of Brookhaven — Solid Waste Management Facility pageFacility address, site scale, ownership, post-closure vision
Regional press coverage (WSHU, Waste Dive, TBR News Media, 2023–2024)Ash for Trash arrangement; C&D tonnages; rail export endorsement
Suffolk County — Town Supervisors and County Executive rail-export endorsementState A successor trajectory
Carbotura standard deployment model50 direct FTE per 100 TPD; 0.45 tCO₂e displaced per ton processed
Carbotura Circular Supply Agreement standard parametersBeneficiation Fee escalator, Circular Royalty™ multiplier and formula, 13-month commencement, 30-year term

Methodology Notes

Feedstock: 489,810 × 4.5 lb/person/day ÷ 2,000 = ~1,102 TPD (~402,000 tons/year), ESTIMATED.

Beneficiation Fee (TMC Fee): $100.00 per ton in Year 1, escalating 2.5% per year compounded. Set at Term Sheet.

Circular Royalty™: multiplier from 120% rising +1 percentage point per year toward 150%, applied to that same year’s escalated fee (Corpus Release 31). Payments begin 13 months after Carbotura’s receipt of the first fee payment (CSA Art. 1.5), hence the Year-2 first payment.

Annual and cumulative figures: per-ton values × configuration tonnage (146,000 TPY Phase Initial, 438,000 TPY Phase Expanded), summed across the 30-year term.

Employment: 50 direct FTE per 100 TPD, Carbotura standard deployment model. Direct FTE only; no multiplier asserted.

Carbon: 0.45 tCO₂e displaced per ton processed, Carbotura baseline. 146,000 × 0.45 = ~65,700 tCO₂e/yr; 438,000 × 0.45 = ~197,100 tCO₂e/yr.

Cost displacement: deliberately not quantified — no public Town per-ton cost exists, and Ash for Trash is a capacity swap.

Accounting: US GAAP (MR §28). Fee obligations are operating service costs; royalty receipts are operating revenue. Capital obligation nil. Separate Transaction Principle applies.

Supplements the authoritative glossary in the Feedstock System Analysis. Terms defined there are not repeated.

Advanced Circular Manufacturing (ACM)
Carbotura’s manufacturing platform. Delivered feedstock is processed through elemental dissociation into synthetic graphite, graphene compounds, and recovered minerals, plus net-positive ultrapure water. Capacity is added by replicating manufactured modules under a Design for Manufacturability (DFM) model.
Ash for Trash
The arrangement in place since 1990: Town municipal solid waste is combusted at the Covanta Hempstead waste-to-energy facility, and the resulting ash — approximately 350,000 tons per year — returns to the Town-owned Brookhaven Landfill in Yaphank for landfilling. A capacity swap, not a per-ton cash payment.
Beneficiation Fee (TMC Fee)
The per-ton fee the Town pays Carbotura for accepting and processing delivered feedstock. Modelled at $100.00 per ton in Year 1, escalating 2.5% per year compounded. Set at Term Sheet. Never a tipping, gate, or disposal fee.
Circular Royalty™
The recurring per-ton payment Carbotura makes to the Town. The multiplier begins at 120% and rises one percentage point per year toward 150%, applied to that same year’s escalated Beneficiation Fee. Payments begin 13 months after Carbotura’s receipt of the first fee payment and run on a rolling monthly basis.
The per-ton difference between the Circular Royalty™ received and the Beneficiation Fee paid, shown for illustration only. It widens every year of the term by construction. It is not a net position — see the Separate Transaction Principle under Presentation conventions.
Delta Model
The analytical framework of this Review. Measures the economic, employment, and environmental difference between State A (the current system and its endorsed export successor, per the Feedstock System Analysis) and State B (ACM deployment, per the Deployment Proposal).
Long Island Landfill Law (1983)
New York State law enacted after landfill leachate was found in Long Island’s sole-source aquifer. It banned new landfills across Long Island and required closure of all but two by 1989; municipal solid waste landfilling on Long Island ended in 1990. It is why no replacement disposal asset is permittable for Brookhaven.
Pre-Royalty Period
The first twelve months following commercial operation. The Town pays the Beneficiation Fee on delivered tonnage and receives $0 Circular Royalty™. A bounded, designed feature of the CSA structure; recognise it separately in Year 1 budget planning.
Retention vs. Leakage
The central economic frame of this Review. Under rail export the material and every dollar spent leave Long Island permanently, with no return payment and no local manufacturing employment. Under ACM the material is processed at a Town-sited module and the manufactured outputs are sold globally; the jobs stay in the Town, and a recurring Circular Royalty™ flows back to it. What is retained is the economic benefit, not the material.
State A
The Town’s current system per the Feedstock System Analysis: Ash for Trash with Covanta Hempstead; ash landfilled at Yaphank under a permit expiring 11 July 2026, extension sought to 2027–2028; successor is endorsed rail export via the Winters and Townline terminals.
State B
The ACM deployment condition per the Deployment Proposal: Phase Initial 400 TPD rising to Phase Expanded 1,200 TPD in the Yaphank / Horseblock Road corridor under a 30-year Circular Supply Agreement (CSA), with zero Town capital obligation.
FigureValuePublic SourceTypeConfidence
Town population489,810 (2024)U.S. Census QuickFacts PST045225VERIFIEDHigh
Long Island per-capita generation4.5 lb/person/dayLong Island Regional Planning CouncilVERIFIEDHigh
Town-wide addressable feedstock~1,102 TPDDerived: population × per-capita rateESTIMATEDLow
Brookhaven Landfill — address, site scale, ownership350 Horseblock Road, Yaphank · a roughly 500-acre Town-owned waste-management complex, within which the landfill cells sit · opened 1974Town of Brookhaven; NYSDEC fact sheetsVERIFIEDHigh
Landfill cell footprint (acreage)Not stated — public sources conflict because they measure different boundaries (permitted cell footprint vs. parcel vs. complex)Town of Brookhaven; NYSDEC; regional pressCONFLICTING
Landfill permit expiration11 July 2026 (extension sought to 2027–2028)NYSDEC Region 1VERIFIEDHigh
C&D tonnage~600,000 t (2022); ~470,000 t (2023); acceptance ended end-2024Regional press coverage 2023–2024VERIFIEDMedium
Ash returned annually~350,000 tons/yrRegional press coverage; Town facility pageESTIMATEDMedium
Long Island Landfill Law1983 · new landfills banned · MSW landfilling ended 1990NY Office of the State Comptroller (2018)VERIFIEDHigh
Rail export endorsementAll 10 Suffolk Town Supervisors + County ExecutiveRegional press coverageVERIFIEDHigh
Regional transfer capacity~6,000 TPDWinters / Townline terminal project descriptionsESTIMATEDMedium
Town per-ton disposal costNot publishedDATA GAP
Beneficiation Fee (TMC Fee) Year 1$100.00/tonCarbotura modelling basis — set at Term SheetILLUSTRATIVEModelling basis
Circular Royalty™ Year 2 / Year 30$120.00 / $295.48 per tonCarbotura canonical royalty formula (Release 31)Carbotura standardHigh
Direct FTE50 per 100 TPDCarbotura standard deployment modelCarbotura standardMedium
Carbon displaced0.45 tCO₂e per ton processedCarbotura baselineCarbotura standardMedium
Corrective Measures Report statusDraft dated May 2026 returned unapproved 5 August 2026 · 40 technical comments · revised draft due on or about 3 November 2026NYSDEC Region 1 letter, 5 August 2026VERIFIEDHigh
Corrective-measures cost frameworkExpressed as total debt repayment, total annual township-wide property tax increase, and annual tax impact to the average home over the term of borrowing — i.e. taxpayer-financedNYSDEC Region 1 letter, 5 August 2026 (comment 28)VERIFIEDHigh
Candidate site coordinates40.8987, −72.9026Approximate Yaphank / Horseblock Road corridor centroidESTIMATEDLow
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Basis of Presentation

Basis of Presentation — Assumptions & Confidence

Source-of-truth references for the key figures cited throughout this document. Full Assumption Registry available on request from the Town of Brookhaven engagement team.

FieldValueConfidenceSource
Beneficiation Fee (TMC Fee) Year 1$100.00 per tonILLUSTRATIVEModelling basis — set at Term Sheet
Beneficiation Fee escalator2.5%/yr compoundedCANONICALCarbotura standard CSA parameter
Circular Royalty™ multiplier120% rising +1pp/yr to 150%CANONICALCarbotura standard CSA parameter
Circular Royalty™ Year 2 / Year 30$120.00 / $295.48 per tonILLUSTRATIVECanonical royalty formula, Corpus Release 31
Royalty commencement13 months after the first Beneficiation Fee paymentCANONICALCanonical CSA royalty trigger, Art. 1.5
CSA term30-year minimum + perpetual continuationCANONICALCarbotura standard CSA parameter
Town-wide addressable feedstock~1,102 TPDESTIMATEDCensus population × Long Island per-capita rate
Tax treatmentNAICS 31–33 manufacturing classification or PILOT equivalentRPTMR §30 classification (RPT)

Confidence flags follow the Carbotura Confidence Flag classification: VERIFIED (contracted or audited) MODELED (calculated from documented inputs) ESTIMATED (best-available, confirmed at Term Sheet phase) ILLUSTRATIVE (computed at a stated modelling basis, not a contractual projection).

Canonical Principles
  1. Carbotura is a manufacturer, not a waste manager. Advanced Circular Manufacturing converts delivered feedstock into products; it does not manage or dispose of waste.
  2. The Beneficiation Fee and the Circular Royalty™ are independent transactions. They are reported separately and in full, and are never netted against each other.
  3. Hydrogen powers the facility internally — it is generated and consumed on site to run the process, and is not sold as offtake.