Operational vs construction and demolition waste management plans

Why it matters

On Victorian projects, "please provide a waste management plan" can mean three different things: a planning document for how the finished building stores and collects waste; a site document for demolition and construction waste; or evidence that you are meeting EPA Victoria duties for industrial waste. If the team treats them as one PDF, the bin room can pass planning while the site still fails its waste duties — or the builder is asked for a construction plan the architect never scoped.

• Developers and builders: planning WMPs get locked into permits. Construction WMPs and EPA duties sit on the contractor and anyone who produces or handles the waste. Scoping both early avoids RFIs and unlawful deposit risk.
• Architects: operational WMPs drive bin store size, access and collection vehicle geometry on the drawings. Construction WMPs rarely change the architecture, but demolition methodology can affect staging and hoarding.
• Building surveyors and site managers: EPA duties apply whether or not a council asked for a C&D plan.

Checked against Victoria Planning Provisions waste standards, CASBE/BESS waste guidance, selected council ESD fact sheets, and EPA Victoria guidance on 5 November 2026 (Australia/Melbourne). Your permit conditions and current council/EPA publications take precedence.

Two plans, one name

	Operational WMP	Construction and demolition (C&D) WMP
What it is for	The building in use: waste streams, bin numbers and sizes, bin store, collection method, vehicle access, ongoing management	Waste produced while demolishing and building: segregation, reuse, recycling, disposal, who hauls what where
Who usually asks	Council planning (application or permit condition); sometimes an ESD/SMP process	Council ESD guidance and some permit conditions; builder / principal contractor for site compliance; clients or head contracts
When it is prepared	With the planning drawings, before or as a condition of permit	Before demolition/site establishment; updated if waste streams change
Primary rules	Victoria Planning Provisions waste standards (for example Clauses 55.05-5, 57.05-2, 58.06-3) plus council WMP guidelines	Environment Protection Act 2017 waste duties and the general environmental duty; EPA industrial-waste guidance; any permit condition that calls up demolition waste; council best-practice diversion targets where adopted
Typical author	Waste consultant or ESD consultant working from architectural drawings	Builder, demolition contractor, or waste consultant with a site methodology

They are complementary. An endorsed operational WMP does not, by itself, discharge EPA duties on the construction site.

For which Victorian councils ask for a planning WMP and at what dwelling count, see Waste management plan requirements by Victorian council. For how a WMP fits the wider development process, see Waste Management Plans: A Developer's Guide.

Who asks for an operational WMP

An operational waste management plan is a planning document. The Victoria Planning Provisions set the baseline:

• Clause 58.06-3 (apartments): waste and recycling facilities designed and managed in line with a WMP approved by the responsible authority (Standard D24). Source: VPP Clause 58.06.
• Clauses 55.05-5 and 57.05-2: for two or more dwellings / residential buildings in the relevant height bands, if the waste storage standard is not met, the design response — which may include a WMP — is in play. Sources: Clause 55.05, Clause 57.05.

Councils then layer their own triggers and templates. Those triggers are tabulated in the council-by-council guide — this post does not repeat that table.

Sustainability Victoria's multi-unit development guidance and WMP template remain useful references for contents (former Sustainability Victoria waste programmes now sit under DEECA): Waste management and recycling in multi-unit developments, WMP template.

Who asks for a construction and demolition WMP in Victoria

A C&D plan is about site works. Victorian councils can and do ask for one — often through ESD / Sustainable Design Assessment in the Planning Process (SDAPP) guidance rather than a separate "C&D WMP" local policy. Verified primary sources:

Source	What it requires or recommends	Diversion / recycling target (exact wording)
CASBE / BESS Waste and Resource Recovery fact sheet (v1, updated 13 Jan 2026) — used across CASBE member councils	Mandatory requirements: "You may be required to prepare an Environmental Management Plan and / or Construction and Operational Waste Management Plan as part of your planning permit application." Best practice also asks applicants to develop a Construction Waste Management Plan and set recycling targets.	Best practice standard: "Adopt a recycling target of at least 70% for all demolition and construction waste." Design advice: "Seventy percent is a minimum target, better practice is a waste diversion target of between 80 to 90% (by mass)."
City of Greater Bendigo SDAPP — Construction and Building Management	"You may be required to prepare an Environmental Management Plan and / or Construction and Operational Waste Management Plan as part of your planning permit application." Council encourages all planning permit applicants to adopt a recycling target for demolition and construction waste.	"A best practice target should be a minimum of 70% (by mass)." Best practice standards: "Adopt a recycling target of at least 70% for all demolition and construction waste."
City of Ballarat — Environmentally Sustainable Design (ESD)	Under Waste and Resource Recovery, qualifying developments must respond to council's ESD policy, including construction waste commitments.	"Committing to recycle at least 70% of all demolition and construction waste."

In practice, that means:

1. Council ESD guidance asks for demolition/construction waste detail inside or beside the planning package (often as a Construction and Operational Waste Management Plan).
2. Permit conditions can call up a construction waste management plan before works start.
3. Contract / client requirements (head contract, ESD commitments, or a voluntary rating tool such as Green Star — name the tool only if the project actually uses it; this post does not offer those ratings as a Makao service).
4. EPA duties apply anyway. Even when no council document is titled "C&D WMP", anyone who produces or handles construction and demolition waste in Victoria must meet industrial-waste duties under the Environment Protection Act 2017.

EPA Victoria treats waste from building and road construction, renovation, demolition and repairs as industrial waste. Duties include classifying the waste, meeting transport and deposit rules, and sending it only to a place authorised to receive it. Higher-risk streams can be priority waste or reportable priority waste (for example some treated timbers, e-waste, and contaminated soils depending on classification). Sources: Understand your waste obligations and duties; EPA Publication 1834.1 Civil construction, building and demolition guide.

NSW comparison (state level only): In NSW, councils commonly require a site waste minimisation and management plan with the development application covering demolition, construction and ongoing use, under the NSW EPA "Waste not" model Development Control Plan chapter. Source: NSW EPA — Waste planning in development applications. That pattern is more uniformly embedded in NSW DCPs than in Victorian planning schemes, where C&D detail more often arrives via ESD/SDAPP guidance and permit conditions.

The general environmental duty sits over both

Separate from the named waste duties, section 25 of the Environment Protection Act 2017 sets the general environmental duty: anyone whose activities create a risk of harm from pollution or waste must eliminate or otherwise reduce that risk so far as reasonably practicable. Source: General environmental duty.

On a construction site that means planning for spills, dust, sediment, storage, and waste segregation is not optional "nice to have" paperwork — it is how you show you thought about risk. An operational WMP for the finished building does not replace that site duty.

What goes in each plan

Operational WMP (planning) — typical contents

Drawn from Sustainability Victoria's MUD guidance and common council templates (confirm against the responsible authority's current guideline):

• Expected waste and recycling streams and volumes for the development in use
• Bin types, sizes and numbers (and organics where required)
• Bin store location, area, height, access, ventilation, wash-down and drainage
• Collection method (council kerbside vs private), frequency, and collection point
• Truck / vehicle access and swept paths where private collection or on-site collection applies
• Separation of residential and commercial waste in mixed use
• Who manages the system after occupation (owners corporation, building manager)
• Scaled plans that match the architectural set

C&D WMP (site) — typical contents

Aligned with EPA industrial-waste thinking, CASBE/BESS construction-waste advice, and common site WMPs:

• Demolition and construction waste streams (concrete, brick, timber, metals, plasterboard, packaging, hazardous/priority wastes, soil)
• Estimated quantities and a recycling / diversion target (Victorian best practice starts at 70% by mass; better practice 80–90% where the council or contract sets it)
• On-site segregation and storage (skip layout, bunding, weather protection)
• Licensed transporters and receiving facilities (lawful place) for each stream
• Classification approach for soils and any priority / reportable priority wastes
• Roles and responsibilities (principal contractor, subcontractors)
• Monitoring, records, and what happens if unexpected contamination is found

For stream definitions beyond C&D, see 10 Common Waste Streams in Australia.

When you need which (and when you need both)

Project situation	Operational WMP	C&D / EPA site controls
Multi-unit or apartment planning permit in a council that lists a WMP trigger	Usually yes	EPA duties yes; formal C&D plan if council ESD guidance, permit or contract requires it
Small alteration with no planning WMP condition	Often no	EPA duties still apply to any industrial waste you produce
Demolition-only permit	Maybe not (no new building in use)	Yes — classification, transport, lawful place; often a site WMP
Staged development	Often one operational WMP per stage or as council guidelines require	Site plans per stage of works
SMP / ESD report mentions waste	Operational waste usually sits in or beside the SMP; still produce a council-ready operational WMP when triggered	Construction waste may be referenced; site team still owns EPA compliance

Common mix-ups that delay permits

• Submitting an operational bin-room plan when the RFI asked for construction diversion rates and lawful-place destinations.
• Assuming an SMP waste paragraph replaces a council WMP template — many councils still want the WMP as a separate, drawing-linked document.
• Leaving C&D targets out of the tender — CASBE/BESS guidance is clear that recycling KPIs need to be in the waste management plan so tenderers price them.
• Ignoring EPA classification for soils and treated timber because "council didn't ask for a C&D WMP".

How Makao can help

Makao prepares planning (operational) waste management plans for Victorian developments, coordinated with ESD/SMP packages where needed. For construction-stage plans, we can set the diversion targets and stream strategy that sit in the SMP or tender documents — the builder still owns site implementation and EPA compliance. Start with Waste Management Plans, or ask about an SMP package that covers waste with the rest of the ESD response.