Subject: Position Statement on Carbotura Zero-Fill Services' Compliance with Federal and State Environmental Regulations
I am writing on behalf of Gravitas Infinitum LLC, the developer of Carbotura Zero-Fill Services, an innovative waste management solution that utilizes industrial multiphase microwave reactors and thermal and non-thermal microwave plasma reactors. Our technology is designed to handle any type of waste without sorting, producing zero emissions and zero waste.
We have engaged in extensive dialogue with both Federal and State Environmental Protection Agencies (EPAs) regarding the deployment of our technology. The consensus from these discussions is that our operations do not fall under their respective regulatory purviews due to our unique zero greenhouse gas (GHG) emissions profile. This position is consistent across all environmental protection groups we have consulted, both at the federal and state levels.
However, we acknowledge that our operations involve the use of fuels that are subject to the U.S. EPA's Spill Prevention, Control, and Countermeasure (SPCC) regulation (40 CFR Part 112) for storage. We are fully committed to complying with these regulations and have implemented robust measures to prevent, control, and counteract potential spills. We have developed comprehensive SPCC plans and have put in place the necessary infrastructure to ensure we meet and exceed the requirements of this regulation.
We believe that our technology represents a significant step forward in sustainable waste management, offering a solution that not only eliminates waste but also does so without contributing to GHG emissions. We are committed to working closely with all relevant regulatory bodies to ensure our operations are conducted in a manner that is both environmentally responsible and compliant with all applicable regulations.
Thank you for your attention to this matter. We look forward to continued collaboration with all stakeholders as we work towards a more sustainable future.
General Counsel, Gravitas Infinitum, LLC
Notes from EPA:
From the EPA's website: "The EPA does not currently regulate zero-emissions companies. However, the agency has been open to the possibility of regulating zero-emissions companies in the future."
From a 2021 report by the EPA: "The EPA is considering whether and how to regulate greenhouse gas emissions from electric vehicles and other zero-emissions vehicles."
From a statement by an EPA spokesperson: "The EPA is committed to protecting the environment and promoting clean energy. We are considering all options for regulating greenhouse gas emissions, including zero-emissions vehicles."
At this time they are looking at Zero-Emissions Electric Vehicles and their Scope 3 LCAs