Waste and recycling development applications – Know this before you start

waste facility planning

Planning for waste and recycling facilities requires a special set of knowledge. The application is less about the built form and more about sustainability, environment, waste policy, regulations and social licence.

Due to higher environmental risk, most development applications (DAs) for waste and resource recovery require a licence, setting them apart from other more traditional DAs for shopping centres, car parks, housing etc.

The Environment Protection Authority (EPA) administers the licence during operations, and also has a role in the planning assessment process. The EPA scrutinises the application’s environmental performance and has authority to refuse or grant consent (with conditions).

If you are a waste service provider or are setting up a related facility, there are some key aspects to consider:

Who is preparing the application?
This is not a normal DA. The consent authority doesn’t just care about the physical form, but also cares about what waste goes in, what products come out and what risks are involved. You should therefore use a specialist planner who understands waste management.

Is a licence required?
Licencing thresholds in New South Wales vary with location, the material type and the process. Licences are required, not only for waste processing and disposal, but also for waste storage, such as stockpiling materials within a shed.

What are the likely emissions?
The application needs to accurately identify the potential for environmental harm or unpleasantness – such as odour, dust, noise or leachate. Specialist reporting is recommended as it provides a reliable analysis of the potential risk.

What types of environmental controls can be implemented?
Some control measures are physical, such as dust suppression, bunding, wheel wash, biofilters, noise walls, or sprinklers. Others are management tools, such as environmental management plans, protocols, and staff training.

Is essential waste infrastructure incorporated into the design?
Examples include: weighbridges, adequate stockpile areas for incoming and outgoing materials, hardstand, a ‘tip and spread’ area for construction and demolition (C&D) waste, fire services etc. Keep in mind that materials storage and processing is usually required to be wholly within a building.

What reporting obligations are there?
In general, the EPA requires that the throughput of licensed facilities is reported monthly. Other reporting may include waste tracking, the reporting of incidents, and the provision of records.

Do I know how to operate under a Resource Recovery Order and Exemption?
Resource Recovery Orders and Exemptions allow products to be used on land or as a fuel. Orders and Exemptions have sampling and testing requirements, and constraints on both the materials received and the end use. A Specific Order and Exemption can be granted if the general ones do not suffice. The development application should demonstrate that, if orders and exemptions apply, the applicant understands how to use them.

During the application process, the EPA (and any other consent authority) is given 40 days to provide comment. Further information is often requested, which could lead to delays in the application being approved.

Anticipating the EPA’s concerns upfront will save time and angst.

For further information, contact info@mraconsulting.com.au

Esther is a Principal Environmental Planner at MRA Consulting Group, specialising in waste and resource recovery development applications and licensing.

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