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Carbotura — Mandate Proposal

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Mandate Proposal

Carbotura

Municipal solid waste, converted to investment-grade raw-material cashflow. A multi-decade securitisation, lending, distribution and trade mandate.

Confidential · Issued by EPC
Section 1 — Proposition

The mandate

We are seeking a single Tier-1 Main Book Holding partner for the multi-decade roll-out of Carbotura. The mandate spans securitisation, balance-sheet retention of risk-retention tranches, M&A advisory, IPO, private-wealth distribution, and physical commodity offtake across the recovered-materials stack.

The unit module
The standard build unit is a 100 tonne-per-day (tpd) module, which throughput-equates to approximately 35,000 tonnes per year at 96% utilisation. Every reference to a “facility” or “facility-equivalent” in this proposal is one such 100 tpd / 35,000 t-yr module.
Programme size
US-wide roll-out targets approximately 5,000 facility-equivalent sites (i.e. 5,000 × 100 tpd modules), staged across four phases over 30+ years.
Capex anchor
$100m capex per 100 tpd / 35,000 t-yr module, contingency-loaded. Per-module steady-state EBITDA target $30m / yr on seven revenue lines, of which the largest is municipal Total Material Conversion (TMC) fees under long-term Circular Offtake Agreements. Senior debt amortisation indicatively 10 years at 5%, indicative DSCR ~2.3×.
Counterparty credit
Investment-grade municipal credit anchors gate-fee cashflow. Major-metro counterparties (NYC, Cook County, DC, Boston, Phoenix-Maricopa, San Francisco, San Diego) carry Aaa/Aa1 GO ratings.
Mandate cost
$50m primary commitment to confirm exclusive Main Book Holding terms across six heads.
Decision window
10 days from receipt of this brief; an accelerated 10-week tail to first benchmark issuance.

The full proposal expands each of these into terms-of-engagement, downside cases, sensitivity bands, and counterparty diligence. This page is the cover and reading guide; the proposal PDF and financial model are downloadable from Section 8.

Section 2 — Counterparty fit

Why we have approached a Tier-1 first

The mandate requires balance-sheet, distribution, structuring depth and a commodities trade book under a single roof. We have identified a small set of institutions that combine these capabilities at the required scale; this brief is delivered to one at a time.

Balance-sheet capacity
Underwriting $1.5–$2bn benchmark MSW-backed Securities (MSWBS) tranches at 6–8 week cadence at full ramp.
Securitisation desk
Deep US ABS bookrunner relationships with Moody’s, S&P and Fitch; capacity to define a new ABS sub-asset class anchored by municipal counterparty credit.
Institutional distribution
Coverage of insurance, pension, sovereign and central bank reserve accounts — the natural buyers of senior MSWBS paper.
Private wealth book
Secondary distribution channel for mezzanine and equity tranches, and for the eventual Carbotura IPO.
Commodities trade
Physical and financial capacity in metals, polymers, hydrogen, food-grade CO2 and recovered fibre.
Climate alignment
Existing public commitments on real-economy decarbonisation; MSW diversion is a measurable circular-economy outcome, not a disclosure narrative.
What the offer is to JPMorgan

Economic value. Six bank-revenue lines on a normal product set, applied to a multi-decade originated programme. Indicative envelope $15–30m per benchmark tranche per year at steady state, across an estimated 250 tranches over the platform life, plus IPO bookrunner economics, M&A and capital-markets advisory, hedging income, and commodities-trade margin on the recovered-materials offtake.

Brand position. JPMorgan, by anchoring Carbotura, defines a new US ABS sub-asset class — municipal-counterparty-backed circular-manufacturing securities. Rating-agency precedent, distribution book, structuring template and regulatory engagement all migrate from the anchor bank to subsequent issuers in the asset class.

Future business. Carbotura is the MSWBS pillar of the EPC ABS Factory programme. The same architecture is now live across the parallel pillars: CBS (Conservation) and FBS (Forestry) mandate proposals are issued; LBS (Litigation) is operative. The bank that anchors Carbotura is structurally positioned for the parallel mandates — under the same six-line revenue stack and the same Quantitative Growth thesis.

Section 3 — Platform

The technology and the seven revenue lines

Carbotura is a tech-enabled circular-manufacturing platform. The proprietary process — Waste-to-Circular Manufacturing (WtCM) — uses the Recyclotron™ Multiphase Microwave Reactor with Microwave Catalytic Reforming, and the RevCon™ Valorization Ladder. EcoGraph™ is the carbon product line. Zero combustion. Zero landfill emissions.

Output composition per tonne MSW input
Output composition per tonne of MSW input. Weighted-average gate value approximately $1,260 / tonne (steady state, US average prices, source: company model; price benchmarks per LME, Argus, IHS Markit and ICIS as cited in the proposal).
Revenue lineIndicative scale
1. Total Material Conversion (TMC) fees — tipping-fee equivalent under 30-year Circular Offtake Agreements$45–150 / t
2. Strategic materials sales — graphite, EcoGraph™ carbon, recovered metals, fibre, polymer feedstock$1,260 / t avg
3. Green hydrogen from organic fractionmarket + 45V
4. Recovered distilled watertail-end
5. Food-grade CO2~$200 / t
6. Section 45V hydrogen production tax credit$0.60–3.00 / kg H2
7. Section 45Q sequestered-carbon tax credit$85 / t CO2
Critical mineral relevance

Output products include synthetic graphite (~$20bn global market, ~70% currently sourced from China) and rare-earth-equivalent recovered materials. Domestic production aligns with bipartisan US critical-minerals policy and is independently eligible for IRA Sections 45V and 45Q.

Section 4 — Addressable market

United States — potential, sourced from public data

The figures below describe the size of the potential opportunity using independent published sources. They are not a forecast of facilities the partnership will build — they describe what the market could absorb at full saturation. Phasing, off-take, permitting and counterparty contracts gate actual deployment.

LayerQuantumSource
US MSW generated~265 Mt / yrUS EPA, Advancing Sustainable Materials Management: 2018 Tables and Figures
Residual after recycling & composting~172 Mt / yrEPA 2018 (calculated as generated less recycled / composted)
Implied 100 tpd-equivalent saturation~5,000 facilitiesAuthors’ arithmetic on EPA residual figure ÷ 100 tpd × 365 × 0.94 utilisation
State residual concentrationtop 10 states ~62% of residualEREF, Analysis of MSW Management Costs and Practices 2023
Top 10 metro coverage~43% of US population, 1,224 facility-equivalentsUS Census 2023 MSA estimates; SWANA Tipping Fee Survey 2023 for gate-fee bands
US MSW residual addressable funnel
Residual addressable funnel: 265 Mt generated → 172 Mt residual → ~5,000 100 tpd facility-equivalents at full saturation. Source: EPA 2018, EREF 2023, authors’ arithmetic.
Top 10 US metros by facility-equivalent count
Top 10 metros — the Phase 1 anchor cohort: 1,224 facility-equivalents at saturation, ~$92bn cumulative capex, 43% of US population. Source: US Census MSA 2023; SWANA 2023.
Counterparty credit

State diversion mandates — California SB 1383, Massachusetts 310 CMR 19.017, Washington SB 5022, New York LL 97 (where adjacent) — create the legal basis for long-dated municipal offtake. The structural feature that makes the asset class new is municipal General Obligation backing of an industrial cashflow.

Section 5 — Bank economics

How the mandate pays the bank

The economics rest on six revenue lines drawn from the bank’s normal product set, applied to a long-duration originated programme. There is no balance-sheet alchemy and no novel regulatory treatment. The figures below are constructed bottom-up from published US bookrunner economics and are stress-disclosed in the financial model.

  1. Bookrunner / structuring fees on senior issuance Indicative 50–75 bps on $1.5–2.0bn benchmark senior tranches. Per-tranche fee economics: $8–15m.[1]
  2. Risk-retention and residual-tranche income Under Regulation RR (17 CFR Part 246) the sponsor or arranger retains a 5% economic interest. The retained piece earns the residual / first-loss yield over the deal life and is held to support skin-in-the-game alignment, not to generate Basel HQLA. Indicative steady-state retained-tranche cash yield: 8–14% gross on the retained notional. Important caveat: the retained equity-style strip on a securitisation under SEC-SA / SSFA can attract risk-weights up to 1,250% (dollar-for-dollar capital) per CRR III Art 261 / US Basel III endgame. After CET1 cost of capital absorption the position can be break-even or capital-negative on a risk-adjusted basis; treated here as alignment cost, not standalone income source.[2]
  3. Construction lending Senior secured construction loans to project SPVs ahead of take-out by the ABS, priced to a spread over the bank’s cost of funds. Specialised-lending risk-weights under CRR III Art 122a / 153(5) and the US Basel III endgame slotting framework span a wide band: 80–100% Strong / stabilised, 100–130% Satisfactory, 190–250% Weak / pre-operational. Pricing accordingly is reflected in the financial model.[3]
  4. Hedging and ancillary derivatives Interest-rate, FX and commodity hedges on construction draws, off-take pricing, and 45V / 45Q monetisation. Indicative ancillary fee envelope per tranche: $3–6m / yr.
  5. M&A and capital-markets advisory Equity raises and acquisitions across the 30-year platform build; eventual IPO bookrunner economics. Lumpy but material: indicative IPO economics on a $5–10bn float, $30–50m bookrunner share at standard gross-spread bands.
  6. Physical and financial commodities trade Recovered-materials offtake intermediation across graphite, recovered metals, polymer feedstock, food-grade CO2, and hydrogen credit monetisation. Trade-margin economics depend on positioning and not modelled here.
Indicative bank revenue per benchmark tranche, steady state
Indicative bank revenue per benchmark tranche, steady state. Bookrunner fees + risk-retention yield + construction NIM + hedging + advisory. Indicative range $20–40m per tranche per year; total programme economics scale with the issuance pace and the bank’s share of subsequent deals.
What this proposal does not claim

The retained risk-retention tranche is not High-Quality Liquid Assets (HQLA) at any level: under LCR Delegated Regulation (EU) 2015/61 Article 7(2) and the US LCR rule (12 CFR Part 50), retained own-issuance securitisations are excluded from HQLA. We do not assume capital relief via significant risk transfer (SRT) under CRR Articles 244–245 on the retained piece. Investor-purchased senior MSWBS paper held by third-party institutions may qualify under LCR Article 13 as Level 2B, subject to structural and concentration tests — that benefit accrues to the buyer, not to the bank as issuer. References to a “multi-trillion lending stack” or undifferentiated Basel III leverage that appeared in earlier drafts have been removed.

Section 6 — Phasing

Build-out phasing

The programme is phased over 30+ years. Phase 1 is the top-10 metro anchor cohort; Phase 2 extends across the next 50 metros; Phase 3 secondary states; Phase 4 international.

Build-out phasing across four phases
Indicative facility count and cumulative capex by phase. Phasing is conditional on permitting, off-take signings, IRA credit determinations and bank book capacity at each issuance window.
Section 7 — Platform position

Carbotura within the four-asset-class family

Carbotura is the MSWBS worked example of the wider AiGLe-graded RWA ABS family set out in The Quantitative Growth Thesis. The same securitisation infrastructure that delivers QE-equivalent dilution under MBS works identically when applied to underlying assets that build new productive base. Same machinery. Inverse economic effect.

ClassUnderlyingIssuer / guaranteeCapital treatment
LBSLitigation portfolios (ATE-floored)SPV + ATE insurer credit enhancementAlternative credit
CBSConservation programmes (perpetual)Sovereign-issued / sovereign-guaranteedBasel III HQLA L1 · 0% RW where the security qualifies as a direct sovereign obligation in domestic currency under LCR DR Art 10(1)(c) / CRR Art 114
FBSForestry programmes (full-rotation)Sovereign-issued / sovereign-guaranteedBasel III HQLA L1 · 0% RW where the security qualifies as a direct sovereign obligation in domestic currency under LCR DR Art 10(1)(c) / CRR Art 114
MSWBS — CarboturaIndustrial waste-to-resource conversionVariable issuer class — federal / state / municipal-revenue / corporateHQLA L1 / 0% RW under federal guarantee; otherwise municipal- or corporate-credit RW per issuer class
The capital-pool form — structural innovation

Senior-tranche proceeds ($1–2bn benchmark) enter a bankruptcy-remote SPV holding a capital-pool corpus invested in HQLA-eligible instruments under a published Mandate (AiGLe Criteria Paper No. 3). The corpus serves as collateral for construction-loan facilities funding the facility build; programme operations are funded annually from corpus returns; senior coupon is serviced by post-stabilisation operating cashflow; corpus is preserved for the life of the structure. Three structurally distinct credit instruments per issuance — senior MSWBS tranche, construction-loan facility, capital-pool corpus — each priced at the appropriate risk.

Why this matters for the bookrunner

Traditional financing forms produce closed transactions. The capital-pool ABS Factory form produces standing financial infrastructure: a graded asset class, a repeatable issuance pipeline, a captive sovereign-wealth-fund corpus, and Basel III-eligible senior tranches. The same underlying transaction generates four structurally distinct revenue streams under the ABS Factory form — project-finance economics on the construction loan, ABS economics on the senior tranche, wealth-management economics on the corpus, and secondary-market / clearing economics on the resulting trading flows — each properly priced, each captured by a single institutional counterparty if the relationship is established at the start of the issuance pipeline.

Asset-class family schematic
The AiGLe-graded RWA ABS family. Carbotura is the MSWBS worked example. CBS and FBS mandate proposals live; LBS portfolio operative (five live AAA-graded certificates).
Section 7B — Scope of this proposal

What sits in mandate, what sits in DD

This document is a mandate proposal. It sets out the structural opportunity, the bank’s economics, the architecture and the heads of terms. It is not a due-diligence pack and does not attempt to substitute for one.

In scope (mandate)
The six heads of terms, $50m primary commitment, 30-year term; the unit economics, programme phasing, six bank-revenue lines with regulatory caveats; the TAM and counterparty-credit thesis sourced from EPA / EREF / US Census / SWANA; the Quantitative Growth platform proposition.
In DD (post-mandate)
Carbotura HoldCo audited financials and operating-asset evidence; signed municipal Circular Offtake Agreements and counterparty register (named cities, permits, contract tenor, gate-fee bands, GO ratings); technical DD pack on the Recyclotron™ / RevCon™ / EcoGraph™ / Microwave Catalytic Reforming stack; independent price benchmarks per output stream; tax-credit eligibility opinions on IRA Sections 45V and 45Q; counsel-issued jurisdictional opinions on the MSWBS issuance programme.
Parallel review
The DD pack is segmented for parallel review across JPMorgan’s securitisation, credit, ESG, commodities, private wealth and corporate-banking lines so confirmation-of-capability work runs concurrently rather than sequentially. This is consistent with the ten-day decision window: the mandate is confirmed first, DD runs against the confirmation.
Section 8 — Process

Decision and artefacts

Confirmation of terms is required within 10 days of receipt. The accelerated tail targets first benchmark issuance within 10 weeks. The full proposal, financial model and term-sheet skeleton are below.

Mandate timeline
Decision in 10 days, accelerated tail to first benchmark issuance ~10 weeks.
Mandate documents

Issued under your accepted Confidentiality Undertaking. Each download is logged.

Editable proposal (DOCX)

[1] Bookrunner / structuring fee bands derived from Refinitiv ABS league-table data 2022–2024 for senior US ABS issuance ≥ $1bn notional. Actual fee on any specific tranche subject to negotiation, market conditions and competitive process.

[2] Retained risk-retention requirement: 17 CFR Part 246 (US sponsor risk-retention rule); residual tranche cash yield is illustrative and depends on structure, attachment and detachment points, and underlying performance.

[3] Specialised-lending risk-weight bands per Basel III endgame proposal (US OCC / Federal Reserve / FDIC NPR, July 2023) and CRR III (Regulation (EU) 2024/1623). Specific RW depends on supervisory slotting category, project status and rating availability.

Sources cited above: US EPA, Advancing Sustainable Materials Management 2018; EREF, Analysis of MSW Management Costs and Practices 2023; US Census 2023 MSA estimates; SWANA Tipping Fee Survey 2023. Commodity price references: LME, Argus, IHS Markit, ICIS as cited in the proposal annexe.