Most construction and demolition (C&D) diversion ordinances include a requirement that a waste management plan (WMP) or waste management form (WMF) be completed and submitted prior to the beginning of a project. A WMP or WMF is essentially a plan that estimates how much C&D debris will be generated by the project and describes how the materials will be managed. This will require a project applicant to estimate how much C&D material will be generated and to consider how, where, and how much they will divert.
A jurisdiction can designate a set time period for an applicant to complete and submit the WMP prior to starting a project, as well as a set time period that a WMP official has to approve or disapprove a WMP. Jurisdictions can also look at the option of granting approval of the WMP by default in the event that the compliance official fails to take action on a WMP within that specified time period.
Job Permit Number
If a WMP is required for a permitted project, you may want to consider including the job permit number in the WMP, as well as requiring that any documentation provided to demonstrate diversion compliance include the job permit number to avoid fraudulent use of invoices or receipts from previous projects. You would also want to ask for details on how the waste generated for any given project will be diverted, as well as what specific types of material will be targeted for diversion.
For demolition projects, the WMP could also include the applicant’s plans for deconstruction and salvaging activities prior to demolition, since many demolition projects are potential sources of C&D debris that could be recovered by deconstruction and salvaging activities prior to demolition. Sufficient time would have to be allowed in the project’s specifications, however, to allow for diversion activities to take place prior to demolition (for example, time for deconstruction) or prior to construction (or example, time for salvaging after demolition).
The City of Castro Valley includes the following language related to deconstruction in the WMP section of its C&D diversion ordinance:
“Deconstruction: In preparing the WMP, applicants for building or demolition permits involving the removal of all or part of an existing structure shall consider deconstruction, to the maximum extent feasible, and shall make the materials generated thereby available for salvage, prior to recycling or land-filling. This can also include the sale or donation of these items.”
Also, any recovered or salvaged C&D debris from a demolition, remodel, renovation, or new construction project could also be included in the calculation for meeting the ordinance’s diversion requirement.
Types of Information in a WMP
Types of information listed in a WMP could include:
- Project name and address.
- Job permit number.
- Building type.
- Project cost.
- Size (square feet).
- Applicant’s name and contact information including address.
- Type of permit or project (construction, demolition, renovation, deconstruction, land clearing and grading).
- Calculation of deposit [for size or cost, etc.].
- List of materials and estimate of amounts to be generated for each material type.*
- Estimate of amount diverted (can separate into reuse & recycling categories) vs. amount to be landfilled.*
- Recycling facilities receiving materials.
- Disposal facilities.
- Hauling company.
- Signed statement of intent to divert.
- Application signature.
*Not all jurisdictions may have the resources to evaluate the accuracy of an estimated amount of materials to be generated by each project and/or for each material type for each project. It may also be difficult and time consuming for permit applicants to be able to estimate these amounts with any accuracy if the jurisdiction does not have standard conversion factors. An alternative to requiring estimates is to require that the applicant identify in the WMP which materials they will target, and where they will take their material.
Another alternative to requiring diversion estimates and confirmation that those estimates have been attained is to have a certification program for the C&D recycling facilities in the surrounding area. This will simplify the process of determining compliance, as it allows a project applicant to simply provide documentation that they used a particular diversion facility that has been certified to divert a particular percentage of incoming material. That eliminates the need for the applicant to obtain and submit weight tickets from the diversion facilities they used to show compliance with the ordinance. The City of San Jose has a good example program.
In addition to a WMP or WMF, a final report is often required prior to the return of the applicant’s deposit. Final reports may also be required for the receipt of a final inspection and Certificate of Occupancy. A final report is very similar to the WMP or WMF, except that it reflects actual tonnage amounts in place of estimates, and provides backup documentation to support the amounts of claimed diversion tonnage.
The final report may include the following as supporting documentation:
- Job permit number.
- Weight tags.
- Gate receipts.
- Invoices at all points of materials movement (i.e. generation, recycling, reuse and disposal).
- Invoices directly from the recycling facility or service provider.
- Documentation from Certified Recycling facility (i.e., a jurisdiction-approved facility).