Pre-redevelopment audit or site waste management plan
The audit records what exists in the building before demolition. The waste plan forecasts and controls what the build produces. Most demolition schemes need both, in that order.
Choosing between a pre-redevelopment audit or waste plan is a false choice on most demolition-and-rebuild schemes, because the two documents cover different halves of the same problem. The audit is a survey of what already exists on site and what can be recovered from it. The site waste management plan is a forward-looking control document for the waste the construction works will generate. One looks backwards at standing material, the other forwards at arisings.
Councils increasingly ask for both, and they ask for them at different moments. Getting the sequence wrong is what costs money, because an audit commissioned after the building has been stripped records nothing useful.
What each document records
A Pre-redevelopment Audit inventories the materials and components in the existing building and structures: the structural frame, facade materials, roof coverings, internal fit-out, mechanical and electrical plant, and anything of salvage value such as bricks, timber, stone or period joinery. For each it records quantity, condition, likely contamination and a recovery route: reuse in situ, reuse elsewhere, recycling or disposal.
A Site Waste Management Plan forecasts the waste streams the project will produce, sets targets for diversion from landfill, names who is responsible for each stream, and records actual arisings against the forecast as work proceeds. It is a live document, updated on site, rather than a one-off survey.
The confusion arises because both talk about tonnages and both end up quoting diversion percentages. The difference is in the subject. The audit is about a building that exists. The plan is about a process that has not happened yet.
Existing materials against future arisings
Put crudely, the audit tells you what you are about to throw away and the plan tells you what you will do with it.
| Feature | Pre-redevelopment audit | Site waste management plan |
|---|---|---|
| Subject | Standing building and structures | Project waste streams over the build |
| Timing | Before demolition or strip-out | Before works start, updated throughout |
| Prepared by | Surveyor or circular economy consultant, on site | Principal contractor, usually |
| Output | Material inventory with recovery routes | Forecast, targets, responsibilities and actual arisings |
| Typical trigger | Policy on circular economy or a demolition condition | Council condition or contractor procedure |
An audit that finds 40,000 reusable facing bricks and a steel frame in good condition changes the demolition method statement. It may also change the design, if the architect can take the recovered material into the new scheme. That only works if the audit lands early enough to influence both.
Timing before and during demolition
The audit has to happen while the building is intact and accessible, and it should be co-ordinated with the asbestos survey required before refurbishment or demolition work under the Control of Asbestos Regulations 2012. The same visit, the same scaffold, the same opening-up. Doing them separately means paying twice for access.
The waste plan starts before the first skip arrives and continues to the end of the works. Where a council conditions one, the condition normally requires submission and approval before commencement, then retention of records for inspection.
So the order is: audit, then design decisions on reuse, then demolition method statement, then waste plan, then works. A scheme that commissions the audit after the asbestos strip has begun has already lost the internal joinery and most of the fit-out.
Reuse, recovery and disposal routes
Both documents use the waste hierarchy, and both are judged on how far up it they manage to push material. Prevention first, then preparing for reuse, then recycling, then other recovery, then disposal.
The audit is where reuse is actually won or lost. Once material is in a skip it is at best a recycling story, and crushed concrete used as sub-base counts for less in policy terms than a steel section reused as a steel section. Auditors should record what can be recovered and, just as usefully, what is needed to recover it: careful deconstruction rather than machine demolition, storage space on site, testing for structural reuse, and a buyer.
That last point is the honest constraint. Reclaimed material without an identified destination usually ends up crushed, and an audit that lists recovery potential without naming a route is describing an aspiration rather than a plan.
How each supports circular economy policy
In London, referable applications are expected to produce a Circular Economy Statement under London Plan 2021 policy SI 7, and the supporting Greater London Authority guidance expects a pre-redevelopment audit where an existing building is being demolished. The audit is the evidence base and the circular economy statement is the argument built on it.
Outside London the picture varies. Some local plans carry their own circular economy or sustainable construction policies, some rely on the NPPF's general support for resource efficiency, and some ask for nothing beyond a standard demolition condition. Check the adopted local plan and the validation list before deciding either document is optional.
The Site Waste Management Plans Regulations 2008 were revoked in England in 2013, so there is no longer a statutory requirement to produce one. Councils continue to require them by condition, and most principal contractors keep one regardless because it drives down disposal cost. Nobody should cite the 2008 Regulations as a live legal duty in England.
Conditions and monitoring
Expect condition wording that requires the audit before demolition and the waste plan before commencement of construction. The two conditions catch different phases and a demolition-only condition will not secure the waste plan.
Monitoring is where these documents usually fail. A waste plan with forecast tonnages and no actual figures recorded against them is not discharging anything. If the condition requires records to be maintained and made available, the contractor needs a person named and a monthly rhythm, otherwise the data is reconstructed from weighbridge tickets at the end and nobody trusts it.
Where demolition itself needs consent, that is a separate question again. In a conservation area, or on a listed building, the demolition consent regime runs alongside the waste documents, and we have set that out in a piece on demolition in a conservation area and what consent applies.
Commissioning them in sequence
- Confirm from the adopted local plan and validation list which of the two the council requires, and whether a circular economy statement is triggered.
- Commission the pre-redevelopment audit alongside the asbestos refurbishment and demolition survey, before any strip-out.
- Feed the audit's recovery routes into the design and the demolition method statement.
- Have the principal contractor produce the waste plan using the audit's material quantities as the starting forecast.
- Name the person responsible for recording actual arisings and set the reporting interval.
- Keep the records in a form the council can inspect, because the discharge application will ask for them.
Where a wider operational waste strategy is also required for the completed building, that is a third document again, and a Waste Management Strategy covers storage, collection and servicing rather than construction arisings.
PlanScope can draft the reporting structure for each of these, cite the policy basis and mark every quantity as still to be confirmed until survey data is supplied. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. For specialist technical reports, qualified professional input may be required.
This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it.
Frequently asked questions
Is a site waste management plan still a legal requirement?
Not in England. The Site Waste Management Plans Regulations 2008 were revoked in 2013, so there is no statutory duty to produce one. Councils still require them by planning condition on many schemes, and most principal contractors keep one anyway because tracking waste streams reduces disposal costs and supports discharge of the condition.
When should the pre-redevelopment audit be carried out?
While the building is intact and accessible, and ideally on the same visit as the asbestos survey required before refurbishment or demolition under the Control of Asbestos Regulations 2012. An audit commissioned after strip-out has begun records far less, because internal joinery, fittings and plant have usually already gone.
Do both documents apply outside London?
It depends on the adopted local plan and the council's validation list. London Plan policy SI 7 and the supporting Greater London Authority guidance drive the audit requirement for referable schemes in London. Elsewhere some local plans carry circular economy or sustainable construction policies, and some councils rely on a standard demolition condition instead.
Who prepares each document?
The audit is usually prepared by a surveyor or circular economy consultant who visits the building and records material quantities and condition. The waste plan is usually produced and maintained by the principal contractor, because it needs to be updated as work proceeds and records actual arisings against the forecast.
Does a pre-redevelopment audit guarantee material will be reused?
No. An audit records recovery potential, but reuse depends on deconstruction method, storage space, structural testing and an identified buyer or onward use. Recovery routes listed without a destination usually end in crushing and recycling, so the audit is most useful when it names where the material will actually go.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.