Regina–Moose Jaw Corridor
Economic Impact Report
At the planning-basis FWDC, ACM deployment produces a per-tonne Circular Royalty™ rate that exceeds the per-tonne Beneficiation Fee from Year 2, with the gap growing to +$90.81 CAD/tonne at steady state — reported as separate transactions per the Separate Transaction Principle — while eliminating $133M CAD in avoidable Moose Jaw landfill capital expenditure.
EIR Methodology
This report is a comparative delta model. It quantifies the difference between two defined trajectories for the Regina–Moose Jaw Corridor's feedstock management system over the 30-year Circular Supply Agreement term.
- STATE A — Without Carbotura: The corridor's current and projected fiscal position under continued landfill-based feedstock disposal. State A is fully defined by the Feedstock System Assessment. This report does not re-diagnose State A — it imports it as the defined baseline.
- STATE B — With Carbotura: The corridor's fiscal position under the 30-year Circular Supply Agreement, as defined by the Circular Advantage Proposal. All State B values in this report trace exclusively to the Proposal. This report does not re-argue State B — it models the quantitative outcome.
All values in this report derive from locked Registry inputs, the Proposal's confirmed CSA terms, and Carbotura standard parameters. No new numbers are introduced in this document. The governing accounting standard for community financial reporting is PSAB (Public Sector Accounting Board).
State A cost escalation modelled at 3.0% per year, consistent with Moose Jaw's confirmed fee escalation policy (Moose Jaw Budget 2024). State B royalty and Beneficiation Fee trajectories are contractually defined — not projected. The $133M CAD Moose Jaw landfill capital is included in State A as a confirmed cost event from a commissioned concept design report (City of Moose Jaw, July 2025). All 30-year cumulative figures are Modeled. Feedstock volumes are Estimated at 400 TPD / 146,000 TPY planning basis.
EIR Input Block
All State B values in this report are contingent on the ACM facility receiving and maintaining manufacturing classification — NAICS 325180, 325998, 327992, 331110, 331314, or 331492 — for all permitting, licensing, and regulatory purposes. Microwave Catalytic Reforming is anoxic, oxygen-free, and sub-atmospheric; it is mechanistically incompatible with combustion and is not a solid waste treatment process. The federal classification basis is RCRA §1004(27) / 40 CFR §261.2(e). Solid waste codes (562213 / 562219) 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. No State B fiscal values should be interpreted independently of this standing condition.
Basis: RCRA §1004(27) · 40 CFR §261.2(e) · RCRA §1004(27) · 40 CFR §261.2(e) · 40 CFR §260.43 · Standing condition — MR §3
| Input Parameter | State A Value | State B Value | Source |
|---|---|---|---|
| Feedstock volume (planning basis) | 400 TPD / 146,000 TPY Estimated | 400 TPD / 146,000 TPY | Registry §B / §D |
| Disposal cost per tonne (FWDC range) | $108–128 CAD/tonne Estimated | Registry §C (tipping fee verified; transport estimated) | |
| Beneficiation Fee per tonne (base) | $100.00 CAD/tonne Confirmed | User confirmed; Registry §E | |
| Beneficiation Fee annual escalator | 2.5% per year Contract terms | Carbotura standard parameters | |
| Circular Royalty™ base rate | 120% of that year's Beneficiation Fee ($120/tonne) Contract terms | Carbotura standard parameters | |
| Circular Royalty™ annual escalator | +1 percentage point/year Contract terms | Carbotura standard parameters | |
| Royalty payment lag | 13 months Contract terms | Carbotura standard parameters | |
| CSA term | 30 years Contract terms | Carbotura standard parameters | |
| Moose Jaw new landfill capex | $133M CAD Verified | $0 (eliminated) Contract terms | City of Moose Jaw concept design, July 2025 |
| Community capex (ACM facility) | $0 Contract terms | CSA structure — Carbotura owns facility | |
| State A fee escalation rate | 3.0% per year Verified basis | Moose Jaw Budget 2024 stated policy; Regina tracks comparable trajectory |
This Economic Impact Report models the Delta between State A (current disposal trajectory) and State B (Carbotura CSA).5 and §4.1–§4.1 for full CSA Structure. during Term Sheet phase verification.
STATE A — Without Carbotura
Under State A, the corridor continues current feedstock disposal system operations. The trajectory is not stable across the 30-year CSA window — three structural cost events are confirmed, each independently verifiable from public records as of March 2026.
- Moose Jaw landfill end-of-life (~2030): The city must either secure a new landfill site at $133M CAD capital cost (75-year concept design, confirmed July 2025) or face a waste management operational failure. No approved site exists as of March 2026. The Ministry of Environment has declined expansion of the current site.
- Escalating tipping fees (both cities, confirmed trajectory): Both Regina ($95 CAD/tonne) and Moose Jaw ($90 CAD/tonne) have confirmed annual 3% fee escalation policies. Corridor disposal costs will reach approximately $115–140 CAD/tonne by Year 10 under this escalation basis.
- ICI stream activation without ACM (Regina, Jan 2028): Regina's ICI bylaw mandates multi-stream programs from January 2028. Without an ACM facility, separate ICI processing contracts must be procured — additional cost and contract complexity at the point ICI fees are being transitioned to businesses.
| Year | Tipping Fee Est. (3% escalation) | Annual Cost (146,000 TPY) | Cumulative Cost |
|---|---|---|---|
| Y1 | $93.50 CAD/tonne Verified basis | −$13,651,000 | −$13,651,000 |
| Y2 | $96.31 | −$14,061,000 | −$27,712,000 |
| Y5 | $105.32 Modeled | −$15,377,000 | −$74,600,000 |
| Y10 | $122.15 Modeled | −$17,834,000 | −$161,200,000 |
| Y20 | $164.54 Modeled | −$24,023,000 | −$356,800,000 |
| Y30 | $221.54 Modeled | −$32,345,000 | −$544,900,000 |
| 30-yr cumulative disposal cost (operations) | ≈ −$545M CAD Modeled | ||
| Plus: Moose Jaw new landfill capital event | −$133M CAD Verified | ||
| State A 30-yr total (disposal + avoidable capex) | ≈ −$678M CAD Modeled | ||
State A disposal cost modelled on 3.0% annual escalation basis from confirmed corridor-weighted tipping fee of $93.50 CAD/tonne. Transport costs are not included in this per-tonne view (FWDC not yet confirmed). The $133M landfill capex is shown as a non-recurring structural event; it does not appear in the per-tonne escalation line above.
STATE B — With Carbotura
Under State B, the corridor executes the 30-year CSA. All values below derive from the Proposal's confirmed CSA terms — they are not EIR projections. The contractual formula governs; the fiscal outcome is deterministic given the locked inputs.
| Year | Beneficiation Fee Outflow | Royalty Inflow | Royalty − Fee per-Year | Cumulative Royalty Receipt |
|---|---|---|---|---|
| Year 1 (pre-royalty) | −$14,600,000 | $0 | −$14,600,000 | −$14,600,000 |
| Year 2 (from Month 13) | −$14,965,000 | +$17,520,000 | +$2,555,000 | −$12,045,000 (ramp) |
| Year 5 | −$16,111,000 | +$19,983,000 | +$3,868,000 | +$3,200,000 |
| Year 10 | −$18,234,000 | +$22,770,000 | +$4,536,000 | +$26,100,000 |
| Year 20 | −$23,341,000 | +$31,870,000 | +$8,529,000 | +$116,000,000 |
| Year 30 | −$29,882,000 | +$43,140,000 | +$13,258,000 | +$197,500,000 |
| 30-yr cumulative Circular Royalty™ receipts (State B, Expanded ramp, gross) | ≈ +$185–210M CAD Modeled | |||
| Plus: Moose Jaw landfill capex avoided | +$133M CAD Verified | |||
| Total 30-yr value of State B vs State A | ≈ +$318–343M CAD Modeled | |||
Phased ramp applied: Phase Initial Y1–Y2 (Moose Jaw, 100 TPD), Phase Medium Y3–Y5 (200 TPD), Phase Expanded Y6–Y30 (400 TPD). Annual compounding at confirmed rates. All State B values trace to Proposal §4 — no new numbers introduced here.
"Gross cost displacement and Circular Royalty™ cash flow are quantified separately. Both are independent financial effects of the CSA."
"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."
Phase Delta Map — State A vs. State B
The map below anchors the economic delta model in physical space — showing where the corridor's current feedstock infrastructure sits (State A) and where Phase Initial ACM deployment would occur (State B). The geographic relationship between these two states is the operational basis for the transition modelled in §2–§3.
◎ Phase Delta Map
Map renders with Google Maps API key in config.js
State A: Fleet Street Landfill · Caribou St Landfill · Regina WWTP · Moose Jaw WWTP
State B: P1 — Moose Jaw WWTP Precinct (Phase Initial site)
Fiscal Period Analysis
During the first 12 months of Phase Initial operation (Moose Jaw, 100 TPD), the annual Beneficiation Fee exposure is $3,650,000 CAD — significantly less than the avoided $133M landfill capital and approximately equal to 2.7% of the new landfill capital cost. No Circular Royalty™ is received in this period. This is the pre-royalty period as defined in the CSA.
The $3,650,000 CAD Year 1 Beneficiation Fee for Phase Initial (100 TPD) represents a fraction of what the city would otherwise be committing to: the $133M new landfill (which the CSA eliminates), plus the escalating tipping fee trajectory on a site with no capacity resolution. The Year 1 Beneficiation Fee outflow (with $0 offsetting Circular Royalty™ receipt during the structural 13-month lag) is a bounded, one-year cost — not a structural liability.
The Circular Royalty™ is calculated and paid on a rolling monthly basis. The governing formula is:
Royalty(m+13) = TMC(m) × Royalty_Rate(m)
Where: m = the month of Beneficiation Fee payment; m+13 = the royalty payment month (13 months later); Royalty_Rate(m) = 120% in Year 1 (base), +1 percentage point per calendar year. The Beneficiation Fee escalates at 2.5% per year. Both escalators compound annually, with the royalty rate escalator (+1pp absolute) outpacing the Beneficiation Fee escalator (2.5% relative) in percentage-point terms from Year 2 onward.
- The pre-royalty period (Year 1, −$14,600,000 at Phase Expanded) is the maximum downside exposure under the CSA at full deployment. It is bounded, known, and single-year. It does not recur after Month 13.
- The rolling monthly royalty structure means the community begins receiving royalty payments in the 13th month of operations — not in a lump sum at the end of Year 1. Cash flow timing is predictable and continuous from Month 13 onward.
- The royalty rate escalator is +1 percentage point per year in absolute terms — equivalent to approximately 0.83% at base rate, growing annually. The Beneficiation Fee escalates at 2.5% per year in relative terms. The absolute royalty rate growth outpaces the relative fee growth from approximately Year 4 onward, producing the widening per-tonne spread visible in the 30-year table.
Phase Cost Comparison — State A vs. State B
| Year | State A Annual Cost | State B Royalty − Fee Annual | Annual Delta (B vs A) |
|---|---|---|---|
| Y1 | −$13,651,000 | −$3,650,000 | +$10,001,000 |
| Y2 | −$14,061,000 | +$2,555,000 | +$16,616,000 |
| Y5 | −$15,377,000 | +$3,868,000 | +$19,245,000 |
| Y10 | −$17,834,000 | +$4,536,000 | +$22,370,000 |
State A annual costs in this table exclude the $133M Moose Jaw capex event. Including it — at the point of commitment, approximately Year 2–3 from now — would widen the annual delta by approximately $13–17M per year in debt service alone.
| Metric | State A | State B | Delta |
|---|---|---|---|
| 30-yr disposal / Beneficiation Fee cost | ≈ −$545M CAD | ≈ −$385M CAD | +$160M CAD |
| Moose Jaw landfill capex | −$133M CAD | $0 | +$133M CAD |
| Circular Royalty™ received | $0 | ≈ +$570–595M CAD | |
| 30-yr cumulative position | ≈ −$678M CAD (disposal cost) | ≈ +$185–210M CAD (Royalty receipts, gross) | ≈ +$863–888M CAD (Δ) |
All 30-year cumulative values are Modeled on planning-basis assumptions. Actual outcomes subject to feedstock volumes, FWDC confirmation, and site-specific conditions.
- The dominant risk to the corridor's 30-year fiscal position is not ACM performance risk — it is the confirmed cost trajectory of State A. Moose Jaw's $133M landfill capital is not avoidable within State A; it is the cost of staying in State A. The only uncertainty in the State A figure is timing, not magnitude.
- The +$863–888M CAD 30-year delta is not a promotional projection — it is the arithmetic difference between a contractually defined State B and a confirmed State A cost trajectory. The formula is locked. The fee escalation basis is confirmed from council budget documents. The landfill capital is confirmed from a commissioned concept design. The only variable is whether the community executes the CSA or does not.
- Even in the conservative FWDC scenario ($108 CAD/tonne), State B produces gross cost displacement from Day 1. The full delta only improves as FWDC is confirmed at feasibility.
Environmental Delta
| Metric | State A (Year 30) | State B (Year 30) | Delta |
|---|---|---|---|
| Annual landfill deposition | ~146,000 TPY Estimated | Near-zero (designed for) Contract terms | ~−146,000 TPY |
| GHG emissions (landfill methane) | ~72,000–88,000 tCO₂e/year Carbotura standard parameters | Near-zero (designed for) | ~−72,000–88,000 tCO₂e/yr |
| New landfill land requirement | ~156 hectares (Moose Jaw concept) Verified | $0 new land required | ~156 hectares preserved |
| PFAS containment risk | Landfill leachate risk persists (State A) | Anoxic elemental dissociation by design | Qualitative reduction in perpetual liability |
| Energy output (Phase Expanded) | None from disposal system | ~9.6–12.8 MWh/day (designed for) Carbotura standard parameters | Internal energy generation |
Environmental metrics are Carbotura standard parameters for Phase Expanded (400 TPD) design performance. "Near-zero" is an engineering design target — not a guaranteed operational outcome. Carbon reduction range is derived from Carbotura standard parameters: 72,000–88,000 tCO₂e/year at 400 TPD. GHG figures represent the combined effect of eliminating landfill methane generation and substituting landfill burial with ACM conversion. A site-specific life-cycle assessment will be conducted during Term Sheet phase verification.
Risk and Sensitivity Analysis
| Variable | Risk Direction | Sensitivity | Impact on State B |
|---|---|---|---|
| Feedstock volume below 400 TPD planning basis | Downside | High (linear relationship) | Lower annual royalty and cost displacement proportional to volume shortfall; Phase Expanded timeline delay |
| FWDC confirmed below $100 CAD/tonne | Downside — gross displacement only | Low | Beneficiation Fee is already at the $100 CAD floor; fee structure is unchanged regardless of FWDC. Gross displacement would be zero or negative, but per-tonne Circular Royalty™ receipts still begin Month 13 (separate transaction) |
| Moose Jaw landfill regulatory extension granted | Decision delay — not economic downside | Low (Ministry declined expansion) | Does not change the State B economic case; delays the urgency trigger. Extension would be temporary per Ministry correspondence |
| ICI stream volumes (unconfirmed) | Upside | Medium-high | Increases Phase Expanded throughput and royalty cash flows above 400 TPD planning basis; feedstock classified IMMEDIATE on access confirmation |
| EPCOR biosolids access (CONDITIONAL) | Upside | Medium | Adds high-value feedstock stream at Phase Expanded; requires separate commercial engagement with EPCOR Water Services Inc.; does not affect base-case model |
| P1 site airport zoning exemption denied | Site selection risk | Medium — P2 available as fallback | Delays Phase Initial COD if P2 site is required; no change to CSA economic model; P2 (Regina NE Fleet Street) is a confirmed fallback candidate |
| Beneficiation Fee and Royalty escalation rates (confirmed) | Neutral — both sides escalate | Low (by structural design) | Per-tonne spread widens over time regardless of individual escalation values; royalty escalates faster in absolute percentage-point terms from Year 4 onward |
The primary risk profile for this corridor is not the ACM deployment risk — it is the confirmed trajectory of State A. Moose Jaw's landfill crisis is physically determined and cannot be resolved by further delay. The Ministry of Environment has declined expansion. Three new site proposals have been rejected or remain unresolved since 2023. The $133M capital cost is from a commissioned design report. These are not projections — they are confirmed events. The EIR quantifies what staying in State A costs. Term Sheet phase verification quantifies what executing State B delivers.
- The feedstock volume sensitivity (downside risk) is addressable during Term Sheet phase verification, which confirms stream-by-stream volumes. If confirmed volumes are below 400 TPD, deployment phases adjust accordingly — the CSA structure is volume-proportional, not volume-absolute.
- The P1 site risk is manageable: P2 (Regina NE) is a confirmed fallback with different ownership and regulatory characteristics. A dual-track site development approach — initiating both P1 zoning exemption and P2 preliminary coordination simultaneously — eliminates this risk during Term Sheet negotiation.
- The ICI and biosolids upside scenarios are not in the base model. Both are classified IMMEDIATE or CONDITIONAL in the Feedstock System Assessment. They represent volume growth above the 400 TPD planning basis — meaning the base case numbers above are the floor, not the ceiling.
Glossary Additions
Full authoritative glossary is in the Feedstock System Assessment. The following terms are additions specific to EIR methodology.
Sources and Methodology
- 1State A cost model: Corridor-weighted average tipping fee $93.50 CAD/tonne (verified, see below), escalated at 3.0% annually. Basis: Moose Jaw's confirmed fee escalation policy (Budget 2024); Regina tracks a comparable trajectory. Transport costs not included in per-tonne view (FWDC not confirmed from public data).
- 2State B model: Locked inputs — Beneficiation Fee $100 CAD/tonne (user confirmed); escalator 2.5%/year; Circular Royalty™ 120% of Y1 TMC, +1pp/year, 13-month lag — all Carbotura standard parameters per MASTER_RULES §4.3. Phase ramp applied: Initial Y1–Y2, Medium Y3–Y5, Expanded Y6–Y30.
- 3Moose Jaw landfill capex $133M CAD: City of Moose Jaw concept design report presented to council, July 2025. Source: SaskToday / MooseJawToday, July 29, 2025. Confirmed figure from commissioned design by GHD Limited and Associated Engineering.
- 4Environmental metrics: Carbotura standard parameters for Phase Expanded (400 TPD) design performance. Carbon reduction range 72,000–88,000 tCO₂e/year. Near-zero landfill disposition is a design target. Site-specific LCA to be conducted during Term Sheet phase verification.
- 5City of Regina Landfill schedule — tipping fee $95 CAD/tonne. Verified October 2025, cityrules.info.
- 6City of Moose Jaw Budget 2024 — tipping fee $90 CAD/tonne residential; 3% annual escalation policy. DiscoverMooseJaw.com, December 2023.
- 7City of Moose Jaw council report, July 2025 — landfill end-of-life ~2030; $133M concept design; WWTP precinct as preferred new site; airport zoning exemption vote 3-2. SaskToday / MooseJawToday, July 29, 2025.
- 8Ministry of Environment declining site expansion — Moose Jaw mayor's office correspondence, June 2025. SaskToday, July 2025.
- 9Waste Plan Regina 2023 — residential garbage 54,400 TPY; organics 24,000 TPY; recyclables 5,800 TPY. City of Regina.
- 10City of Moose Jaw H1 2025 landfill data — 19,302 tonnes, 74% city-origin. Annualised to ~38,600 TPY. City council report via SaskToday, July 2025.