Alternative (to EPA) Financial Assurances Calculator for Construction and Demolition Waste

By on December 7, 2022

DR ELIZABETH GIBSON, General Manager of the CMPA provides an update on EPA Financial Assurance calculator requirements for Construction and Demolition waste.

EPA Financial Assurances (FA) for Construction and Demolition Waste (C&D) was reported in Sand & Stone April/May 2022 issue 122 ( and the potential demise of the C&D recycling industry due to unrealistic financial assurances that would make the industry unviable overnight if they were applied. EPA also did not recognise any value to the C&D recycled product despite being a requirement in the specifications set by the Department of Transport.

After consultation with EPA and CMPA Members, Ricardo Energy Environment & Planning was appointed by CMPA to develop an alternate financial calculator.

The CMPA represents businesses that produce construction materials. This includes quarries that produce products from virgin and recycled materials and processors that solely recycle C&D waste. Mostly this falls into the category of Solid Inert Waste (SIW) however not all SIW is suitable for reuse in construction.

The risk profile of these operators is low:
• Financial – product sales to stable, local, growing markets
• Environmental – materials are not combustible, leachable nor contain hazardous chemicals
• Social – diversion from landfill, use in sought after infrastructure

Materials received typically include:
• Concrete
• Bricks
• Rubble
• Asphalt
• Waste rock (clean fill)

Figure 1 Resource Recovery Model

The primary products include:
• Crushed materials
• Road base (various VicRoads class materials)
• Recycled asphalt (RAP)
• Green concrete

Secondary products include:
• Metals (e.g., steel)
• Cardboard
• Plastic

• Mixed waste includes unsorted loads and loads with >5% contamination
• Waste is often received free of charge provided it is source separated
• Primary products are typically collected by the customer. If delivery is needed this is typically a separate surcharge on top of the product’s sale price.
• Some wastes contain minor quantities of secondary products for example waste concrete is likely to contain steel reinforcing which is removed and sold separately
• Transport costs to other facilities also needs to be covered

CMPA response to EPA comments on the first version of the alternate FA calculator.
• FA calculator applies to source-separated (not mixed waste) demolition waste which is almost exclusively non-combustible
• The FA Calculator has been reworked to allow recording of different waste materials using default or user-specified rates, different contamination levels and different destinations for secondary materials
• The Sales costs are calculated by product so that higher value products can be differentiated from others
• The risk profile of the operations is low across all waste types. Combustible materials (secondary plastic and cardboard) are only received incidentally – i.e., as contamination of other incoming materials. Volumes are therefore low (<1%).
• The Calculator now allows the user to select different contamination levels for different waste streams
The EPA indicated verbally that they were “comfortable” with the revised alternate FA Calculator which recognised the value of the C&D waste/product. However, the EPA then focused on plastic waste. It was agreed between CMPA Members and EPA that a site visit would be useful which will be held at the end of November beginning of December 2022 before a decision was made on the Alternate FA calculator. Note The paddock rock evidently classified as a waste under the EP Act 2017) issue has not yet been resolved.

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