Continuing the current municipal-landfill disposal model on Ward County's 100 TPD base load forfeits ~$210M of combined fiscal benefit over 30 years from Phase Initial alone — before any partnership is considered.
The 30-year CSA is a royalty-producing asset that replaces a waste liability on Ward County's books.
The relationship structure. Under the CSA, Ward County becomes the manufacturing feedstock supplier to the Carbotura ACM facility; Carbotura is the manufacturer that material stream transfers to under the CSA. This is a supply arrangement, not a service contract — routing decisions belong to Council, not to a procurement office.
FWDC blended $75/ton — ESTIMATED, planning basis only. Ward County component ~$82/ton. Full confirmation deferred to Deployment Study contract review.
T0 = Q2 2026 — ESTIMATED. Carbotura standard deployment schedule anchor; user confirmation pending.
Phase Expanded 2,000 TPD — HARD CONDITIONAL on Bismarck and Grand Forks metropolitan partnerships. Phase Initial 100 TPD is independently sufficient for Ward County base load without any partnership.
Feedstock composition — ESTIMATED using Carbotura standard MSW profile. Stream-specific characterization deferred to Deployment Study.
§1Introduction and Decision Summary
§1.1What This Report Measures
This EIR quantifies the difference between two futures for Ward County's manufacturing-feedstock streams over a 30-year horizon.
- State A (Without Carbotura). The current disposal model continues. Ward County feedstock flows to the City of Minot Landfill at the current FWDC trajectory. Disposal cost escalates at the documented North Dakota regional rate (~3.5%/yr, CPI+1pp). No new revenue offsets accrue.
- State B (With Carbotura). A 30-year CSA executes. ACM Phase Initial commissions Q2 2028. Beneficiation Fee replaces FWDC for committed streams. Circular Royalty™ begins 13 months after corresponding Beneficiation Fee payment and escalates +1pp/yr. Phasing scales 100 → 200 → 400 → 1,000 → 2,000 TPD over 60 months. Phase Expanded conditional on Tier 3 partnerships.
This report does not re-diagnose State A (Deployment Study's role) and does not re-define State B (Proposal's role). Its function is only the delta.
§1.2Decision Summary Table
| Item | Value |
|---|---|
| State A — annual disposal cost (Phase Initial volume, Year 1 baseline) | ~$3.0M (Ward County) |
| State B — annual TMC obligation Year 1 (Phase Initial) | $3.65M |
| State B — annual Circular Royalty™ Year 2 (Phase Initial) | $4.38M |
| Beneficiation Fee) — 30-yr cumulative, Phase Initial only (differential between two independently reported gross transactions — not a netted position) | ~+$45M |
| Combined fiscal benefit — 30-yr cumulative, full Phase Expanded with Tier 3 partnerships | ESTIMATED +$3B+ |
| Capital obligation to County | $0 |
| Regulatory Predicate Transition (RPT) | Standing condition. Both parties commit to the dewaste pathway — manufacturing NAICS required, waste NAICS excluded (562213/562219). Manufacturing NAICS required (325180, 325998, 327992, 331110, 331314, 331492). Basis: RCRA §1004(27) · 40 CFR §261.2(e). MR §3. |
| Key data gaps | FWDC verification (Deployment Study); Tier 3 partnership instruments; stream-specific feedstock composition |
| Decision deadline (Council authorization) | Q2 2026 — concurrent with engagement start, to preserve Phase Initial COD Q2 2028 |
| Cost of delay | ~$1.8–$2.2M Year-2 Royalty foregone per 6-month slip (Phase Initial scale); $25–35M at Phase Expanded scale |
§1.3Fiscal vs. Regional Economic Separation
County fiscal effects (Royalty receipts, TMC outflows, cost displacement) and regional economic impact (employment, regional GDP, tax base) are distinct categories. They are not interchangeable. Royalty receipts flow to the County treasury; regional economic impact flows to the broader Minot Triangle economy and does not appear on the County balance sheet. This EIR maintains that separation throughout.
§2State A Baseline
Source: Deployment Study. Locked Registry values. No new diagnosis introduced.
§2.1Feedstock Volume and Disposition (Phase Initial)
| Stream | TPY | TPD | Current Disposition | Operator |
|---|---|---|---|---|
| Ward County MSW (residential + commercial) | ~25,500 | ~70 | the City of Minot Landfill | City of Minot Sanitation Department |
| Ward County C&D residuals | ~5,500 | ~15 | City of Minot Landfill + regional C&D | Mixed haulers |
| Ward County industrial / commercial special | ~3,650 | ~10 | Mixed regional disposal | Mixed |
| Ward County WWTP biosolids | ~1,825 | ~5 | Land application / co-disposal | City of Minot WWTP |
| Ward County base load (State A) | ~36,475 | ~100 |
§2.2State A Cost Structure
| Cost Element | Annual Year 1 | Per-Ton | Source Type |
|---|---|---|---|
| Ward County MSW disposal (collector-facing) | ~$2,090,000 | ~$82 | Estimated |
| Ward County C&D disposal | ~$385,000 | ~$70 | Estimated |
| Ward County industrial / commercial special | ~$330,000 | ~$90 | Estimated |
| Ward County WWTP biosolids disposal | ~$170,000 | ~$95 | Estimated |
| Ward County all-stream blended State A cost | ~$2,975,000 | ~$82 | Modeled |
City of Minot Sanitation Department specific contract terms with Ward County, City of Minot, and individual commercial customers are not publicly documented at the level required for FWDC verification. Confirmation deferred to Deployment Study contract review.
§2.3State A Cost Trajectory
Three documented mechanisms drive forward State A cost growth: (1) Rate escalation — North Dakota commercial waste contracts include CPI + 1pp annual escalators; regional published schedules show ~3.5–4.5%/yr increases. (2) Capital reinvestment pressure — the City of Minot, City of Bismarck, and Grand Forks landfills are each undergoing or scheduling cell expansion 2024–2030; capex passes through to gate rates. (3) Absence of a competitive alternative within Ward County — Minot has one MSW disposal facility, its own municipal landfill; no private or regional competitor exists within the immediate catchment.
| Year | TPY | FWDC / ton | State A Annual Cost |
|---|---|---|---|
| 1 | 36,475 | $82 | $2.99M |
| 5 | 36,475 | $94 | $3.43M |
| 10 | 36,475 | $111 | $4.05M |
| 20 | 36,475 | $157 | $5.73M |
| 30 | 36,475 | $221 | $8.07M |
| 30-yr cumulative State A cost (Ward County base load) | ~$165M |
§2.4State A Environmental and Structural Position
- Net carbon position (State A): All committed Ward County feedstock continues to landfill. Methane emissions from landfilled organics continue per City of Minot Landfill operating profile.
- PFAS exposure: Industrial and biosolids streams continue to landfill or land-apply with no PFAS destruction. Federal regulation (2026–2027) may impose treatment or destination requirements that elevate State A cost trajectory above the +3.5%/yr baseline.
- Rate-setting authority: The City of Minot Sanitation Department sets Ward County's gate rate directly, as a municipal budget decision rather than a private-operator contract negotiation. This removes third-party pricing-power exposure but ties disposal cost to municipal budget cycles instead.
- Capital exposure: $0 immediate but cumulative future exposure as the City of Minot Landfill expands cells, passed through to gate rates.
§3State B Deployment Baseline
Source: Proposal EIR Input Block. No re-derivation.
§3.1Inherited Flags Declaration
Flags carried forward from the Proposal and Registry (disclosed above in the inherited-flags block): FWDC ESTIMATED · T0 ESTIMATED · Ward County feedstock composition ESTIMATED · Tier 3 partnerships NOT YET COMMITTED · Phase Expanded conditional on inter-jurisdictional instruments not yet executed.
§3.2Deployment Configuration
| Phase | TPD | Module Math | TPY | COD | T0 Offset |
|---|---|---|---|---|---|
| Phase Initial | 100 | ceil(100/100) = 1 | 36,500 | Q2 2028 | T0 + 24mo |
| Stage 2 | 200 | ceil(200/100) = 2 | 73,000 | Q3 2029 | T0 + 39mo |
| Phase Medium | 400 | ceil(400/100) = 4 | 146,000 | Q4 2030 | T0 + 54mo |
| Stage 4 | 1,000 | ceil(1000/100) = 10 | 365,000 | Q1 2032 | T0 + 69mo |
| Phase Expanded | 2,000 | ceil(2000/100) = 20 | 730,000 | Q2 2033 | T0 + 84mo |
§3.3Economic Terms
| Parameter | Value |
|---|---|
| Beneficiation Fee (TMC Fee) Year 1 · Minot | $75 / ton — Verified · Architect override below $100 canonical floor |
| TMC escalator | 2.5% / year |
| Royalty rate Year 1 | 120% of TMC |
| Royalty escalator | +1 percentage point / year |
| Royalty payment lag | 13 months, rolling monthly |
| CSA term | 30 years from Phase Initial COD |
| Capital obligation to counterparty | $0 (BOO structure) |
§3.5Timeline Anchoring
| Event | Date | T0 Offset |
|---|---|---|
| T0 — engagement start | Q2 2026 | T0 |
| Council authorization deadline | Q2 2026 | T0 |
| Deployment Study complete | Q3 2026 | T0 + 3mo |
| Phase Initial construction start | Q4 2026 | T0 + 6mo |
| Phase Initial COD | Q2 2028 | T0 + 24mo |
| First Circular Royalty™ payment | Q3 2029 | T0 + 37mo |
| Phase Expanded COD | Q2 2033 | T0 + 84mo |
| CSA term end | Q2 2058 | T0 + 30yr |
§3.6Phase Delta Map
State A infrastructure (grey/steel pins) versus State B Priority 1 ACM site (emerald square). The map shows why the spatial and logistic transition from State A to State B is a route-convergence, not a route-extension — all existing Ward County feedstock flows already pass within 15 miles of the Priority 1 US-2 Industrial Corridor site.
Interactive map requires a Google Maps API key.
Set GOOGLE_MAPS_API_KEY in config.js.
Right panel remains fully functional without a map key.
§4Delta Analysis
§4.1Three Delta Components
The State A → State B transition produces three independent fiscal components, each quantified separately:
- Gross cost displacement — State A FWDC obligation that no longer accrues under State B (feedstock redirects to ACM rather than landfill).
- Circular Royalty™ cash flow — New revenue inflow to the County treasury. $0 Year 1 (13-month lag); rolling-monthly thereafter; escalating +1pp/yr.
- Residual obligation — State A cost continuing during the construction window (T0 → Phase Initial COD) and for any non-committed streams.
"Gross cost displacement and Circular Royalty™ cash flow are quantified separately.
"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."
§4.1Phase-by-Phase Comparative Table
| Phase | ACM Volume (TPY) | State A / ton | TMC / ton | Gross Delta / ton | Royalty Y1 / ton | Royalty Y2+ / ton | Capital |
|---|---|---|---|---|---|---|---|
| Phase Initial | 36,500 | $82 | −$75 | +$7 | $0 (lag) | +$90 | $0 |
| Phase Medium | 146,000 | $90 | −$83 | +$7 | $0 | +$103 | $0 |
| Phase Expanded | 730,000 | $103 | −$91 | +$12 | $0 | +$115 | $0 |
Pre-Royalty Period Separation
Year 1 and post-13 months after corresponding Beneficiation Fee payment periods have materially different fiscal characteristics. They must not be combined.
- Year 1 (Pre-Royalty, Months 1–12): County pays Beneficiation Fee at $75/ton. Receives $0 in Circular Royalty™.
- Royalty Ramp (Year 2, Months 13–24): Circular Royalty™ ramps to full run-rate on a rolling basis (120% × current BF, widening yearly).
- Steady-state (Year 3 onward): Circular Royalty™ compounds on a widening spread over the escalated Beneficiation Fee — receipts grow faster than the ongoing BF outflow every year.
§4.430-Year Gross Cost Displacement Table
Ward County base load (Phase Initial only, no Tier 3 partnerships) — conservative base case. State A FWDC escalated at 3.5%/yr.
| Year | TPY | State A Cost (escalated) | Avoided in State B | Cumulative Avoided |
|---|---|---|---|---|
| 1 | 36,500 | $2.99M | $2.99M | $2.99M |
| 5 | 36,500 | $3.43M | $3.43M | $15.7M |
| 10 | 36,500 | $4.05M | $4.05M | $34.2M |
| 20 | 36,500 | $5.73M | $5.73M | $82M |
| 30 | 36,500 | $8.07M | $8.07M | $165M |
| 30-yr cumulative gross cost displacement (Phase Initial only) | ~$165M | |||
§4.530-Year Circular Royalty™ Table
Phase Initial only base case (Ward County base load, 36,500 TPY held constant).
| Year | TMC Paid | Royalty Received (Y2+ rolling) |
|---|---|---|
| 1 | $3.65M | $0 |
| 2 | $3.74M | $4.38M |
| 5 | $4.03M | $4.83M |
| 10 | $4.56M | $5.70M |
| 20 | $5.83M | $7.87M |
| 30 | $7.47M | $10.83M |
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.
§4.6Three-Item Gross Fiscal Chart
Year-by-Year Delta — Full Schedule (Years 1–30)
| Year | State A Cost | Beneficiation Fee Paid | Circular Royalty™ Received |
|---|---|---|---|
| 1 | $2.99M | −$3.65M | $0 |
| 2 | $3.07M | −$3.74M | +$4.38M |
| 3 | $3.15M | −$3.83M | +$4.53M |
| 5 | $3.43M | −$4.03M | +$4.83M |
| 10 | $4.05M | −$4.56M | +$5.70M |
| 20 | $5.73M | −$5.83M | +$7.87M |
| 30 | $8.07M | −$7.47M | +$10.83M |
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.
Year 1: $2.99M avoided − $3.65M TMC = −$0.66M. Year 2+: each year inverting and growing. All figures Phase Initial base case (36,500 TPY held constant).
§5System-Level Impact
§5.1Employment Delta
§5.1 reflects regional employment impacts, not County treasury receipts. These flow to the Minot Triangle workforce; they do not flow to the Ward County general fund.
| Phase | State A Direct (disposal) | State B Direct FTE | Delta (Direct FTE) | Indirect Jobs (×2.5) | Annual Economic Impact (regional) |
|---|---|---|---|---|---|
| Phase Initial | ~3 | 25 | +22 | +55 | +$4M |
| Phase Medium | ~5 | 70 | +65 | +163 | +$14M |
| Phase Expanded | ~12 | 280 | +268 | +670 | +$58M |
§5.2Environmental Delta (designed-for language)
| Attribute | State A | State B (designed-for performance) |
|---|---|---|
| Carbon position (committed feedstock) | Net positive emissions (landfill methane + transport) | Net carbon negative (graphite sequestration + internal hydrogen power) — designed-for |
| Landfill diversion | 0% of committed feedstock | ~100% of committed feedstock — designed-for |
| Internal energy | N/A | Hydrogen powers facility internally; near-zero external grid draw — designed-for |
| External hydrogen offtake | N/A | None — internal use only |
§5.3PFAS Structural Delta
State A: Industrial and biosolids streams continue to landfill or land-apply with no PFAS destruction. Federal regulation (2026–2027) expected to impose treatment or destruction-efficiency requirements that elevate State A cost trajectory above the documented +3.5%/yr baseline.
State B: ACM (MCR) is designed to achieve high PFAS destruction efficiency on processable feedstock streams. Committing PFAS-bearing streams to ACM positions Ward County ahead of forthcoming federal regulation. Designed-for performance basis; stream-specific PFAS destruction efficiency confirmation deferred to Deployment Study.
§5.4No-Fallback Analysis
Should State A continue and the regional siting window pass without Ward County engagement:
- Republic concentration risk persists indefinitely. Three-of-four-landfill operator concentration creates structural pricing-power exposure compounding with each annual escalation cycle.
- First-mover RCRA-eligible decision window closes. Other North Dakota regional communities absorb available ACM siting capacity. Re-entry available but on later, less favorable terms.
- Regional partnership coordination cycle restarts. Bismarck and Grand Forks 18–24-month coordination cycle must begin from a later T0; Phase Expanded shifts proportionally.
- PFAS regulatory exposure direct. Federal rule promulgation (2026–2027) imposes State A cost step-changes without a Royalty offset.
There is no "do nothing" scenario that preserves optionality at zero cost. Inaction has compounding cost.
§6Risk and Sensitivity
§6.1Structured Risk Register
| # | Risk | Driver | Bearer | Quantification | Mitigation | Residual |
|---|---|---|---|---|---|---|
| 1 | FWDC verification | FWDC ESTIMATED at $75/ton blended | Both | $20/ton variation = ~$3.7M annual State A cost variation at Phase Medium | Deployment Study FWDC audit | Low |
| 2 | Technology performance | MCR commercial-scale vs. design | Carbotura | $0 to County (BOO) | Performance guarantees; conversion efficiency thresholds; reserve account | Low |
| 3 | Timeline slippage | Permitting, financing, construction | Both | $1.8–$2.2M Year-2 Royalty foregone per 6mo slip (Phase Initial) | Standard 24mo construction window; cure provisions | Medium |
| 4 | Municipal rate-setting exposure | Sole disposal facility sets gate rates via municipal budget cycle | County (incumbent contracts) | +1pp/yr above CPI escalation = ~$3M cumulative Year 30 vs. baseline | Staggered phase scaling; CSA hauler-direction provisions | Medium |
| 5 | Competitive procurement | Other operators approach catchment communities | Both | First-mover positioning erosion if delay >12 months | RPT-aligned classification; 30-year exclusivity in CSA | Low |
| 6 | PFAS regulatory | Federal PFAS rules 2026–2027 | County (State A); Carbotura (feedstock spec) | State A cost step-change $5–$15/ton estimated | ACM PFAS destruction; feedstock spec in CSA | Low |
| 7 | Tier 3 partnership coordination | FW + Grand Forks instruments require 18–24mo of intergovernmental work | Both | Phase Expanded slip 12mo per uncoordinated party = ~$15M Year-1 Royalty foregone at scale | Begin Tier 3 coordination concurrent with Ward County CSA execution | Medium |
| 8 | NDDEQ permit duration | North Dakota state regulatory environment may shift | Carbotura | Permit denial = Carbotura withdrawal under RPT | NDDEQ engagement at Deployment Study; RPT withdrawal protection | Low |
| 9 | Manufacturing classification confirmation | Regulatory classification outcome | Both | Adverse outcome = Carbotura withdrawal under RPT; County retains State A | RPT structure protects both parties from misclassification deployment | Low (RPT-aligned) |
| 10 | Macro inflation / interest-rate | SPV financing close in elevated-rate environment | Carbotura | $0 to County (BOO); affects Carbotura WACC and SPV terms | Staged construction; standard refinancing provisions | Low (to County) |
| 11 | Workforce availability — regional | Skilled operations, technical, engineering hire in central North Dakota | Carbotura | Hire delay = COD slip risk | Local-hire targeting; apprenticeship partnerships with Hill College | Low |
| 12 | Groundwater/wetlands proximity (Site P3) | If P3 selected, environmental review required — specifics TBD at Deployment Study | Carbotura | Mitigation cost or P3 disqualification | Standard environmental review at Deployment Study; P1 default if P3 disqualified | Low |
§6.2Feedstock Variability Sensitivity (±20%)
| Phase | Base TPD | −20% | +20% | Phase Initial Year-2 Royalty Impact |
|---|---|---|---|---|
| Phase Initial | 100 | 80 | 120 | ±$0.88M annual |
| Phase Medium | 400 | 320 | 480 | ±$3.87M annual |
| Phase Expanded | 2,000 | 1,600 | 2,400 | ±$22.8M annual |
§6.3FWDC Sensitivity — Sign-Change Threshold
(Royalty per ton) − (TMC per ton) + (Avoided Disposal per ton) > 0.
For Year 2 Phase Initial: Royalty ($120) − TMC ($102.50) = . State B is robust to FWDC variation. This is a structural feature of the Carbotura formula, not a model artifact.
§6.4Royalty Escalator Sensitivity (0 / +1 / +2 pp)
| Escalator | Year 30 Royalty Rate | Year 30 Royalty / ton | Year 30 Annual Royalty (Phase Expanded) |
|---|---|---|---|
| 0 pp/yr (no escalation) | 120% | $245.57 | $179M |
| +1 pp/yr (base case) | 149% | $296.77 | $216.6M |
| +2 pp/yr (upside) | 178% | $354.94 | $259M |
§6.5Timeline Slippage Sensitivity
| Slippage | Phase Initial COD | First Royalty |
|---|---|---|
| 0 (base case) | Q2 2028 | Q3 2029 |
| +6 months | Q4 2028 | Q1 2030 |
| +12 months | Q2 2029 | Q3 2030 |
| +24 months | Q2 2030 | Q3 2031 |
§7Decision Window Analysis
§7.1Binding Constraints
- T0 anchor + 24-month construction. Phase Initial COD requires ~24 months from financing close. T0 = Q2 2026 places Phase Initial COD at Q2 2028. Each month of T0 slippage moves COD month-for-month.
- Classification pathway. Manufacturing classification (NAICS 31–33) is the classification basis of every engagement. First-mover communities secure positioning advantages.
- City of Minot Landfill rate-cycle. Each annual escalation cycle compounds State A cost without offsetting Royalty inflow. Beginning the CSA before the next municipal rate-cycle close preserves comparison clarity.
§7.2Decision Window Table
| Decide By | Phase Initial COD |
|---|---|
| Q2 2026 (engagement start) | Q2 2028 |
| Q4 2026 | Q4 2028 |
| Q2 2027 | Q2 2029 |
| Q4 2027 | Q4 2029 |
| Q2 2028 | Q2 2030 |
§7.3Irreversibility Mechanism
Minot does not face a single binding regulatory irreversibility (no landfill closure order, no diversion mandate trigger). The irreversibility is competitive and capacity-driven: each month that passes, more North Dakota regional communities enter Carbotura engagement pipelines. North Dakota regional ACM siting capacity is finite.
The basis of this irreversibility is manufacturing classification (NAICS 31–33) — the federal classification basis under which all Carbotura CSAs proceed.
§7.4Optionality Matrix
| Decision | Phase Initial Optionality | Tier 3 Partnership Optionality | RCRA First-Mover Optionality |
|---|---|---|---|
| Authorize Phase Initial Q2 2026 | Preserved | Preserved (separately negotiable) | Preserved |
| Authorize Q4 2026 | Preserved (moderate slip) | Preserved (slight slip) | Preserved (modest erosion) |
| Authorize Q2 2027 | Preserved (notable slip) | Preserved (12mo slip) | Eroding |
| Authorize Q2 2028 | Preserved (24mo slip) | At-risk | Significantly eroded |
| Defer indefinitely | — | Forfeit | Forfeit |
§8Effects Summary
No new figures introduced. All values trace to §1–§7.
§8.1Fiscal Effects (County Treasury)
| Period | (differential between two independently reported gross transactions — not a netted position) |
|---|---|
| Year 1 | −$0.66M (TMC paid; Royalty $0; State A avoided $2.99M) |
| Year 2+ | +$3.71M annual (Royalty inversion begins) |
| Year 30 | +$11.43M annual + cumulative ~$210M |
| 30-year cumulative gross cost displacement (Phase Initial only) | ~+$165M |
| Combined 30-year County fiscal delta vs. continuing State A (Phase Initial only) | ~+$210M |
| Phase Expanded full case (with Tier 3 partnerships) — combined 30-year County fiscal delta | ESTIMATED +$3B+ |
§8.2Regional Economic Effects
§8.2 figures are regional economic effects, not County treasury receipts. They do not appear on the County balance sheet.
| Phase at full ops | Direct FTE | Indirect | Annual Regional Economic Impact |
|---|---|---|---|
| Phase Initial | 25 | 63 | $4M |
| Phase Medium | 70 | 175 | $14M |
| Phase Expanded | 280 | 700 | $58M |
Plus property tax base addition of $75M–$1.17B (phase-dependent capital improvement).
§8.3Environmental Effects
§8.3 figures reflect designed-for performance basis. Stream-specific environmental performance verification deferred to Deployment Study and operational reporting.
- Net carbon position: Net carbon negative across all committed feedstock under State B (designed-for); net carbon positive under State A.
- Landfill diversion: ~100% of committed streams under State B (designed-for); 0% under State A.
- PFAS structural exposure: Material reduction under State B for industrial and biosolids streams; unchanged under State A.
§8.4Structural Effects
- Rate-setting authority: Municipal-budget-driven gate-rate exposure persists under State A; removed under State B as committed feedstock redirects to ACM.
- Capital exposure: $0 to County under State B vs. cumulative future capital exposure under State A (cell expansion pass-through at the City of Minot Landfill).
- Federal regulatory positioning: State B aligns with NAICS manufacturing classification (RPT-aligned); State A retains solid-waste disposal classification exposure.
§8.5Unresolved Data Gaps
| Gap | Impact | Resolution Path |
|---|---|---|
| Ward County stream-specific FWDC composition | Affects per-ton State A cost precision | Deployment Study contract review with City of Minot Sanitation Department |
| City of Minot Sanitation Department Ward County contract terms | Affects timing of contract migration | Deployment Study contract review |
| City of Minot WWTP biosolids destination specifics | Affects $170k/yr Ward County biosolids stream commitment | Service-agreement coordination with City |
| Tier 3 partnership entity-specific commitments | Affects Phase Stage 4 / Phase Expanded sizing certainty | Inter-jurisdictional coordination 2026–2028 |
| North Dakota NDDEQ permit timeline specifics for ACM facility | Affects Phase Initial COD certainty | Deployment Study NDDEQ pre-application engagement |
| Manufacturing classification confirmation | Affects engagement continuation | Manufacturing classification (NAICS 31–33) |
| Groundwater/wetlands proximity assessment for Site P3 | Affects P3 site eligibility | Site selection environmental review |
ASources and Methodology
State A baseline: Sourced from Deployment Study (Section 1 of engagement). State B baseline: Sourced from Proposal EIR Input Block (Section 2 of engagement).
FWDC derivation: Per Deployment Study Appendix B (per-capita generation × North Dakota regional median × phase-weighted blending). Beneficiation Fee formula: MAX($100, MIN($150, FWDC − $5)); escalator 2.5%/yr; user-confirmed at $75/ton Year 1.
Circular Royalty™ formula: Royalty(m+13) = TMC(m) × Royalty_Rate(m); 120% base; +1pp/yr escalator; 13mo lag; rolling monthly. All per locked Carbotura standard parameters.
Phase sizing: User intake — 100 / 200 / 400 / 1,000 / 2,000 TPD over 60 months from Phase Initial COD. Employment: Carbotura standard FTE-per-TPD ratios. Timeline: Carbotura standard deployment schedule (T0 + 24mo Phase Initial COD). Environmental: Designed-for basis per Carbotura standard ACM performance specifications.
Operator verification: Google Places lookup (April 2026); corroborated against operator websites and public municipal solid-waste records.
BEIR Glossary Additions
Full document-suite glossary in Deployment Study Appendix D. EIR-specific terms:
- Gross Cost Displacement — State A FWDC obligation that no longer accrues under State B because feedstock redirects to ACM. Displaces State A cost; does not flow to treasury as a revenue item.
- — A differential between two independently reported gross transactions: the Beneficiation Fee the community pays (outflow) and the Circular Royalty™ Carbotura pays (inflow), read alongside avoided disposal (cost displacement, not inflow). It is not a netted position and does not represent a single community obligation. Reader-derived from three gross items.
- Pre-Royalty Period — Months 1–12 (Year 1) of Phase Initial operations. TMC paid; $0 Royalty due to 13-month lag.
- Royalty Ramp Period — Months 13–24 (Year 2). Rolling monthly Royalty payments begin and ramp to full run-rate.
- Steady-State Period — Year 3 onward. Royalty exceeds TMC on a per-ton basis structurally.
- Delta Model — Comparative analytical framework quantifying State A → State B transition. Does not re-diagnose State A or re-define State B.
★Basis of Presentation
This EIR quantifies the State A → State B transition for Ward County, North Dakota over a 30-year horizon. All State A figures are sourced from the Deployment Study. All State B figures are sourced from the Proposal EIR Input Block. No new figures are introduced here. Each value is classified by confidence tier.
| Parameter | Value Applied | Basis | Confidence |
|---|---|---|---|
| Phase Initial 100 TPD / 36,500 TPY | COD Q2 2028 · T0 + 24mo | User-confirmed; Carbotura standard deployment schedule | Locked |
| Beneficiation Fee Year 1 = $75/ton | Escalating 2.5%/yr | User-confirmed at engagement intake | Locked |
| State A FWDC Ward County = $82/ton | Escalating 3.5%/yr | North Dakota regional gate rate median + collection increment — modeled | Estimated |
| Phase Initial 30-yr combined fiscal benefit | ~+$210M | — | Estimated |
| Phase Expanded combined fiscal benefit | ESTIMATED +$3B+ | Modeled — full Tier 3 partnerships materialized; conditional | Estimated · Conditional |
| Operator verification | City of Minot, City of Bismarck, and City of Grand Forks (each independently municipal) ×3 | Google Places + municipal facility records, April 2026 | Verified |
Unresolved Data Gaps
- Ward County stream-specific FWDC — resolved at Deployment Study contract review.
- T0 confirmation — Council authorization date.
- Tier 3 partnership entity-specific commitments — inter-jurisdictional coordination 2026–2028.
- North Dakota NDDEQ permit timeline — pre-application engagement at Deployment Study.
- Manufacturing classification confirmation.
Confidence tiers: Locked = user-confirmed or contractually standard Verified = sourced to named public record Estimated = Carbotura-modeled with stated methodology Provisional = pre-Term Sheet-Study placeholder.