We discuss the true cost of environmental compliance, including New Jersey recycling approvals themselves.
When it comes to starting a recycling business in New Jersey, one of the most complex things to discuss is how much it will cost. I'm not just referring to New Jersey Recycling Approval costs, we get asked about the true cost of environmental compliance at facilities over time. Whether that's a year, 5, 10, or more, understanding the long-term costs of environmental compliance at a recycling center in New Jersey is a tricky thing to answer. Having said that, let's jump in and discuss the ins and outs of the costs of New Jersey recycling permits, approvals, and long-term compliance costs.
New Jersey Recycling Approval Costs
Before we get into looking at other areas of compliance, let's face one thing right off the bat. When it comes to getting a recycling permit or approval in New Jersey, your costs are going to depend on a few things which really boil down to three things: where is your recycling center, what are you going to recycle, and what will you do with that recycled material?
This depends right off the bat because the answers to those questions will steer you towards understanding costs. For example, certain types of "recycling" facilities in New Jersey could spend $0 to start recycling (recycling exemptions, certain instances for Class A facilities, etc.), while other types of recycling facilities could cost $25,000+ just to open, with annual costs again being well over $20,000 every year you're in operation.
The point is, the cost of a recycling approval, permit, or exemption can range drastically.
5-Year Costs for Recycling Facilities in New Jersey
Let's get into the mix of things to illustrate why it's hard to pinpoint a cost. We're going to outline a few hypothetical scenarios of different types of facilities within New Jersey that would need a recycling approval. We are going to skip discussing recycling exemptions since those are free to get, and all types of different industrial or commercial operations around New Jersey could use them.
These types of operations are:
A metal recycling facility;
A concrete plant; and
An electronics recycling facility.
We're also going to include the costs of hiring an environmental consultant to get these things for you or your business. We figure if you're here, you might need help getting into compliance, so we'll outline some of our ballpark prices as well.
And, for each of these examples, we are looking at costs over 5-years, based on CURRENT numbers. As things change and morph, you can expect things to get MORE expensive, not cheaper. This is New Jersey after all!
Environmental Compliance Costs for Class A Recycling Facilities in New Jersey
In this instance, we're going to outline a hypothetical metal recycling facility here in New Jersey.
This facility is going to have
A Class A recycling approval;
A General Air Permit; and
The SM2 Scrap Metal NJPDES Stormwater Permit.
Class A Recycling Approval Costs
Remember, as a Class A facility, you won't need to pay an initial fee to the NJDEP for your recycling approval, nor will you need to pay annual fees to the NJDEP either. Free permit, right?! Maybe, and that depends if you can get the permit on your own.
If not and you need to hire a consultant to obtain the approval for you, you should figure around $4,500 for their time.
You may need additional things to meet local or county approval, such as noise studies, traffic studies, surveying, engineering, or even addressing environmental justice concerns. All of these things could increase the price to get a Class A approval, depending entirely on your situation.
This compliance item has several layers, so let's look at them one at a time.
You can expect to pay around $4,000 for initial consulting fees for your SM2 stormwater permit.
You'll need to pay an annual fee to the NJDEP of about $2,300 and annual training costs of around $150, which over the course of 5 years adds up to $11,500.
You'll need to engage in Best Management Practices (BMPs) which will probably end up costing you $1,000 or so each year, so another $5,000 over 5 years.
You'll need to obtain stormwater samples and send them off to a lab for analysis which will cost you about $500 each quarter, or $2,000 a year, totaling to $10,000 over the course of 5 years.
You'll need to submit those results via DMR reporting, as well as perform quarterly and annual inspections. This is one thing that you could do on your own to save money. Otherwise, if you hired a consultant to do these for you, they'd probably charge about $500 a quarter for each activity, so over the course of 5 years that amounts to another $10,000 for DMR submittals and another $10,000 for inspections.
All said and done, that's a total of around $51,250 for 5 years of compliance under the SM2 stormwater permit.
Total 5-Year Costs for Class A Recycling Facilities
So where does this all get you? Between a Class A recycling approval, general air permit, and SM2 stormwater permit, you should expect to pay in the neighborhood of $60,020 for 5 years of environmental compliance.
Environmental Compliance Costs for Class B Recycling Facilities in New Jersey
In this instance, we're going to outline a hypothetical ready-mix concrete plant here in New Jersey, which also operates a commercial concrete crushing operation on-site. This facility is going to have
A Class B recycling approval;
A Pre-Construction Air Permit (PCP); and
An Individual NJPDES Stormwater Permit.
Class B Recycling Approval Costs
Right off the bat, this is where things get EXPENSIVE.
Your initial fee to the NJDEP for a Class B approval will cost $5,281, and for a consultant's help, you could figure $15,000. Right out of the gate, you're looking at $20,000+ to get the approval. And, that's not including additional considerations (which we discussed above, things to meet local or county approval, such as noise studies, traffic studies, surveying, engineering, or environmental justice concerns).
Then, add on your annual NJDEP fees of $13,854 every year, which over the course of 5 years is another $69,270.
Let's assume you need to make a modification to your Class B recycling approval. One permit modification will cost $2,400, and if you get help from a consultant for the modification, you'll need to pay another $2,500 or so, so let's round that up to $5,000 and add that to the 5-year cost calculation.
Finally, you'll need to pay a 5-year renewal fee at the end of the 5 years, which will cost $960. Once you've shelled out this amount of money, you probably want to keep your business running, right?
All said and done, you should expect to pay around $95,911 for 5 years of compliance with your Class B recycling approval.
Pre-Construction Air Permit (PCP) Costs
Let's pivot to air permits again. Imagine that you have 3 pieces of equipment (such as concrete crushers) that all need to be covered under your PCP air permit.
Your initial NJDEP fee, including one of the crushers, will set you back $2,730. Then, you'll need to pay an additional $1,280 to cover your other two crushers ($640 each). A refined risk assessment will cost around $3,500, and costs for a consultant's help with all of this around another $2,500.
You'll also need to pay a 5-year renewal fee of $1,370, and then another $750 for the other two crushers ($375 each).
Here's where things get funny (and not in a HAHA way). Permit reviewers at the NJDEP can include things in your permit for virtually any reason. In fact, we've seen them ADD in onerous requirements time and time again, which can end up costing a facility big time. For example, you may need to conduct semi-annual engine testing on each of your three crushers. Let's say that those tests cost $1,250 apiece, for a total of $37,500 (10 times over the course of 5 years for each of your 3 crushers).
In total, you'll pay around $49,630 over the course of the 5 years for compliance with your PCP air permit in New Jersey.
Individual NJPDES Stormwater Permit Costs
Over 5 Years
Finally, the costs for an individual stormwater permit in New Jersey. This one is a little tricky, as individual permits vary in price pretty drastically. So, just keep in mind that actual costs could be higher or lower than the numbers we'll use here.
An initial consulting fee for help with your individual stormwater permit will probably be in the neighborhood of $5,000.
You'll need to pay an annual fee to the NJDEP, figure around $4,100, which over the course of 5 years amounts to $20,500.
You'll need to pay about $150 each year for training, and about $1,500 each year towards Best Management Practices - so over the course of 5 years, figure $750 for training and $7,500 for BMP implementation.
Again, you'll need to obtain stormwater samples and send them off to a lab for analysis, which will cost you about $500 each quarter, or $2,000 a year, totaling to $10,000 over the course of 5 years.
And again, you'll need to submit those results via DMR reporting, as well as perform quarterly and annual inspections. If you hired a consultant to do these for you, they'd probably charge about $500 a quarter for each activity, so over the course of 5 years that amounts to another $10,000 for DMR submittals and another $10,000 for inspections.
That's about $48,750 over the course of 5 years for your individual stormwater permit costs.
What about the Concrete Products Manufacturing (CPM) NJPDES stormwater permit??
If you know anything about stormwater permits or the concrete industry in New Jersey, you might be thinking that there's a stormwater permit specifically made for that industry. Why not use it? The simple answer is you can't use the CPM stormwater permit because:
The CPM permit is ONLY for a concrete plant, not a facility that features a concrete plant AND a recycling facility. A co-located operation kicks you out of CPM stormwater permit criteria.
And, because it's expired! It's been expired since October 31, 2013. That's right, a 5-year stormwater permit has been expired for over 8 years as of writing this article. Since the permit is expired, you can't get covered under it any longer. Don't hold your breath waiting on the NJDEP to reissue this permit anytime soon...
Total 5-Year Costs for Class B Recycling Facilities
What will this cost you? Figure between a Class B recycling approval, PCP air permit, and individual stormwater permit, you should expect to pay around $194,291 for 5 years of environmental compliance at a concrete plant in New Jersey.
Environmental Compliance for Class D Recycling Facilities in New Jersey
In this last instance, we're going to outline a hypothetical New Jersey based consumer electronics recycling facility. This operation is going to have
A Class D recycling approval;
A General Air Permit; and
A 5G2 (Basic Industrial) General NJPDES stormwater permit.
Class D Recycling Approval Costs
Over 5 Years
Again, here's where things get pricey.
Your initial fee to the NJDEP for a Class D recycling approval will run you $5,233, and if you want help from a consultant, that's another $17,000 or so.
You'll also need to pay an annual fee of $19,281 each year, so over the course of 5 years, it'll be $96,405 in annual fees.
Finally, you'll need to pay a 5-year renewal of $3,140 at the end of the 5-year period.
Over 5 years, that's around $122,278 for your Class D recycling approval costs.
General Air Permit Costs
Over 5 Years
Let's say you only have one piece of equipment, such as a hard drive shredder.
You'll need to pay $885 to the NJDEP for your initial general air permit fee, and another $885 for a 5-year renewal at the end of the 5-year period. For a consultant's help with your general air permit, you should expect to pay around $2,500.
Altogether, that's about $4,270 for 5 years of compliance with your air permit.
The good thing about computer recycling facilities is that they're (usually) all indoors, meaning you can take advantage of New Jersey's simplest and easiest stormwater permit, the 5G2 Basic Industrial General Permit. In this case, let's imagine that you hire a consultant to help out with your 5G2 stormwater permit needs, but you decide to do your annual and monthly inspections on your own.
The initial fee for your consultant's help will probably run about $3,000.
You'll need to pay an annual fee to the NJDEP of $800, which adds up to $4,000 over the course of 5 years.
You can figure about $150 a year for Best Management Practices, and another $150 a year for training costs, totaling to around $750 for BMPs and $750 for training over 5 years.
Since you decided to perform monthly and annual inspections yourself instead of hiring a consultant, you won't need to pay any consulting fees for inspections.
And, since the 5G2 permit does not have any monitoring requirements, you won't need to pay for any sampling and analysis costs or DMR submittals.
That's a total of around $8,500 for 5 years of compliance under your 5G2 permit.
Total 5-Year Costs for Class B Recycling Facilities
I hope you're sitting down for this.
Between a Class D recycling approval, general air permit, and a 5G2 (Basic Industrial) stormwater permit, you should expect to pay around $135,048 for 5 years of environmental compliance.
What about other types of recycling facilities?
There are other types of recycling facilities out there. Class C recycling facilities, recycling centers that hold multiple types of recycling approvals, industrial and commercial operations that hold one or more types of recycling exemptions, you name it.
The point is, it's impossible to cover them all. And, it's impossible to estimate costs over a 5-year basis for them all. It all depends on where you're located, what you're recycling, the industry, and your overall business.
Needless to say, getting into the recycling game in New Jersey isn't cheap.
What about other environmental compliance items?
There are PLENTY of additional environmental compliance items and costs that could impact your business. From SPCC Plans to Tier II CRTK Reporting to TRI Reporting and more, there are numerous other things that could cost you several thousands of dollars. Some compliance items have higher up-front costs, while others have virtually no upfront cost, but could cost you hundreds or thousands of dollars every year.
And, when it comes to getting your recycling approval from the county or state, you'll need to demonstrate compliance right out of the gate. You can't submit an application to the State of New Jersey's DEP and pretend not to know about other requirements!
Additional New Jersey Recycling Approval Help
When it comes to getting into compliance in New Jersey, it's not easy. That goes double for recycling facilities in New Jersey! If you're having trouble, need help, or just have questions, you aren't alone.
If you need help obtaining a recycling approval or anything else related to your company's environmental program, and need the help of an environmental consulting firm with a proven track record, reach out. Even if we can't help, we’ll do our best to steer you in the right direction. Feel free to contact us at firstname.lastname@example.org, click here to contact us, or give us a call anytime at 888-RMA-0230 to learn how we can help your operation deal with environmental regulations and recycling approvals in New Jersey.