Forecast and reconciliation in a site waste plan

A site waste management plan forecast is the part of the document that earns its place. Everything else is policy wording. The forecast says, before a skip arrives, how much of each waste stream the project will produce, at which stage, and where each stream goes. Reconciliation then compares that forecast against the weighbridge tickets and transfer notes, which is what turns the plan from a submission exercise into a cost control tool.

The Site Waste Management Plans Regulations 2008 were revoked in England on 1 December 2013, so there is no longer a statutory duty to prepare one. Councils still require them by condition, clients still require them, and the underlying duty of care never went away.

Why a forecast is required even though the regulations were revoked

Three separate obligations keep the document alive.

The duty of care under section 34 of the Environmental Protection Act 1990 requires anyone producing, carrying or disposing of controlled waste to take reasonable steps to prevent its escape, transfer it only to an authorised person and complete a written description. The Waste (England and Wales) Regulations 2011 add a duty to apply the waste hierarchy and to declare that it has been applied on each transfer note. Neither of those is discretionary.

Planning conditions requiring a Site Waste Management Plan are now common on major schemes and on any site where demolition is involved. The condition usually requires the plan before works start and a completion report afterwards, which makes the reconciliation enforceable.

Assessment schemes form the third driver. Where a project is pursuing an environmental assessment rating, the waste credits depend on a forecast, a diversion target and evidence of what was actually achieved. The plan is the audit trail.

Forecasting waste by stream and stage

Build the forecast as a matrix: streams down the side, project stages across the top. Fill it with quantities in tonnes, with volumes only where a stream is actually measured by volume.

The streams that matter on a typical residential or mixed-use site:

• Excavated soils and stones, usually the largest single quantity by weight.
• Inert demolition arisings: concrete, brick, block, tile.
• Hazardous waste: asbestos-containing materials, contaminated soil, fluorescent tubes, oils, treated timber.
• Timber, metals and plastics from strip-out and construction.
• Plasterboard, which has to be kept out of mixed biodegradable waste because of the restrictions on gypsum in landfill.
• Packaging, which is small by weight and large by volume, and which drives skip numbers on a fit-out.
• Mixed general waste, the stream to be minimised because it is the most expensive to dispose of and the hardest to divert.

Then split by stage: demolition and strip-out, excavation and substructure, superstructure, fit-out, and external works. The stage split is what tells the site manager how many skips of what type to order in which month, and it is the reason the forecast is useful rather than decorative.

Quantify from the drawings and the pre-demolition information rather than from a rate per square metre. A measured take-off of the existing building, informed by a survey, gives a number you can defend. A benchmark figure gives a number you cannot.

Where excavated material is to be reused on site, deal with it under a materials management plan with a qualified person's declaration rather than inside the waste plan, because the legal mechanism is different and conflating the two creates problems at inspection.

Reuse and recycling targets

Set a diversion target at the outset and express it clearly, usually as a percentage by weight of non-hazardous waste diverted from landfill. The figure varies by client and authority, so take it from the condition or the client brief rather than assuming a standard.

Then plan how it will be met, stream by stream. Segregation on site beats mixed collection and off-site sorting on diversion rates, but it needs space, and on a tight urban site there may be room for three skips rather than seven. Say which it is in the plan, because an unachievable segregation strategy undermines the whole document.

The material reuse opportunities are identified earlier, in the survey of the existing building. That exercise is covered in the guide to pre-redevelopment audit content for material reuse, and its findings should feed the forecast directly rather than sitting in a separate report nobody opens.

Carriers, transfer notes and the duty of care

The administrative layer is where enforcement actually happens, and it is simple to get right.

Classify waste properly. The gov.uk technical guidance on waste classification sets out how to assign List of Waste codes and assess hazardous properties, and a wrong code on a consignment note is the kind of error that is easy to make and awkward to explain.

Check the receiving facility as well as the carrier. A registered carrier taking material to an unpermitted site does not discharge the duty of care, and the producer remains in the chain.

Reconciling actual against forecast

Reconciliation is a monthly habit, not an end-of-project exercise. Keep a single register with one row per transfer note, recording date, carrier, receiving site, waste stream, code, tonnage and disposal route, and total it against the forecast each month.

What the reconciliation reveals is usually one of three things. A stream larger than forecast, which points to a survey that missed something or to over-ordering on site. A stream going to mixed general waste that was supposed to be segregated, which is a site discipline problem. Or a disposal route different from the one assumed, which is a procurement problem.

Each has a different fix and each costs money if it runs for six months unnoticed. The commercial case for the plan is largely here: skip hire and landfill tax are a real cost line, and the register is the only place the trend shows up early.

At practical completion, produce a short completion report: forecast against actual by stream, the diversion rate achieved, the reasons for variance, and the lessons for the next project. That report is what discharges the condition.

Reporting to the authority on completion

Read the condition wording before assuming what is needed. Conditions vary between a requirement to submit the plan before commencement, a requirement to submit a completion report within a stated period after practical completion, and a requirement to make records available on request.

Where a completion report is required, submit the summary rather than the whole register, with the register available on request. A twelve-page table of transfer notes does not help a case officer and delays the discharge.

One honest caveat: some authorities impose a waste plan condition and never follow it up, so the completion report sits undischarged for years. That becomes a problem on sale, when a purchaser's solicitor finds an outstanding condition on the title search. Discharge it even if nobody chases.

Where the plan overlaps the construction management plan

The two documents answer different questions and often get merged badly. A Construction Management Plan deals with how the site operates: working hours, delivery routes and times, wheel washing, dust and noise control, parking for operatives, and neighbour liaison. The waste plan deals with what leaves the site as waste and where it goes.

Two overlaps need coordinating. Vehicle movements for waste removal are part of the construction traffic figures in the management plan, so the skip numbers in the waste forecast should match the movement numbers quoted to the highway authority. And dust from demolition and material handling is a management plan matter driven by the quantities in the waste forecast.

On larger schemes a circular economy document adds a third layer, setting retention and reuse targets upstream of the waste plan rather than disposal routes downstream, which is why a Circular Economy Statement should be drafted before the waste forecast rather than after it.

Keep them as separate documents with cross-references. Officers consult different teams on each, and a merged document gets two sets of comments on the same pages.

You can see where the waste, construction and circular economy documents sit alongside each other in the full report index.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.