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Integrated Municipal Solid WastePlanning and Decision-Making in New

York Ci* The Citizens' Alternative PlanMarjorieJ. Clarke

Environmental ConsultantNew York, New York

The 1988 Solid Waste Management Act of New York State requires that alllocalities prepare a 10-year integrated solid waste management plan in order forsolid waste facilities of any kind to be permitted in the state. In response to this,the New York City Departmentof Sanitation has been overseeing the preparationof a 20-year plan since late 1990. The plan was ori inally conceived to include allaspects of the integrated municipal solid waste ( M S ~ierarchy, in priority order:prevention, recyclinglcomposting, waste-to-energylash management, and landfill-ing. The Department of Sanitat~on eld biweekly meetings with members of theCitywide Recycling Advisory Board (CRAB), abody of citizens dul appointed bythe five Borough Presidents, Mayor, and City Council to ensure pub c participationin the solid waste planning and decision-making process. However, the cooperativetenor of the relationship changed when the Clty announced its intention to incor-porate incineration of 68 percent of its municipal and institutional solid waste andrec cle only 25 percent with 7 percent source reduction.

This plan would have violated the New Yoh State Solid Waste ManagementAct's intent, which prioriiizes source reduction, then recycling and composting be-fore incineration. Also, the Act's goal for recyclin and reduction is 50 percent by1997 for all jurisdictions. As a result, members o?CRAB began work on an alter-native 20-year plan which would satisfy the State's requirements. The alternativeplan details an implementation schedule for a comprehensive program of preven-tion, recycling and composting initiatives. I t also provides ustification for it vis-a-visthe projected lifespan of the City's only landfill at Fresh Kills and its proposedincineration program. This paper describes the features of the alternative plan, theimpetus for its creation, the process followed in creating, revising and garneringpublic support for it, and the results achieved by CRAB to promote long-term,integrated MSW planning for New York City.

This paper describes the solid wasteplanning process in New York City, asperceived from the perspective of theNew York City Citywide RecyclingAdvisory Board (CRAB), the officialbody appointed by local governmentstatute to contribute the public's point-of-view. The origin of CRAB and othersolid waste advisory boards, their o p-erations, successes and frustrations arediscussed as are the features of the Cit-y's solid waste management plan,CRAB'S alternative plan, the impetusfor its creation, the process followedin creating, revising and garneringpublic support for it, and the resultsachieved by CRAB to promote long-tenn, integrated municipal solid waste(MSW) planning for New York City.

It is the goal of this paper to show how

citizens' advisory boards can be effec-tive in working with government toprovide meaningful improvements tothe design and effective implementa-tion of integrated municipal solid wastemanagement in all localities, using NewYork City as a case study.

NIMBY andthe Publlc's Desires forWaste Management

The NIMBY syndrome is not, byany means, a new phenomenon. SocialNIMBY has been around for some time(no one really likes to have a prisonnext door). In the solid waste field,NIMBY has been dev eloping steadily,at roughly the same rate as the build-up of the solid waste crisis. At the root

of the problem is the citizen's distrust

of government officials and vice versa.With increasing frequency, as the ca-pacity for solid waste in existing land-

fills has dwindled and the necessity forsiting alternatives has grown, the in-tensity of the N IMBY attitude has alsoescalated. A growing number of grass-roots organizations, upset by the oftenrighteous attitude of the proponents,have generated more information whichcounters that provided by proponentsof specific projects. Too often this hasled to an adversarial situation wherethe under-funded environmentalists andcommunity activists are pitted againstextremely well-funded vendors, solidwaste departments, and their consul-tants in a series of pitched battles, wherethe prime purpose is to defeat the otherside, rather than reach consensus. Theseconfrontations sometimes lead to law-suits. The frequent result is that a re-source recovery plant, a single elementof what should be an integrated, long-range plan consist ing of a mix of wastemanagement facilities and initiatives,becomes the narrow focus of discus-sion. The conseq uence of this is oftenthat the individual facility is delayed,no integrated solution is agreed upon,and the solid waste cris is is intensified.The current situation cries out for greater

cooperation and involvement of thepublic in decision-making.It is often said that the public's in-

terest in the solid waste issue goes nofarther than their own curb. With theMobro garbage barge and accounts ofbackhauling trash in empty food trucksin recent years, the public has becomeaware of the worsenin g solid waste cri-sis. In those communities facing clo-sure of major disposal facilities, thesiting of new ones inevitably draws thepublic's attention. Generally speaking,

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the public's desires are not unreason-able. They want to be assured thatgovernment agencies responsible forwaste management will research andprioritize methods of waste preventionand management, and will choose thosemethods that represent the state-of-the-art and are safe for humans and theenvironment, both now and in the longterm. In addition, the public wants tosee that these alternatives are struc-tured into a well thought out, inte-grated plan and implemented efficiently,cost-effectively and in due time. Thepublic also insists that the agencies in-volved obey both the spirit and the let-ter of enviro nme nt a1 and wa stemanagement laws. Specifically, thepublic is largely in ~g remI en t ith NewYork State's and EPA's hierarchy forwaste management, but it also Wants:

Assurances that all environmen-tal standards are being met at alltimes. Regulatory enforcem ent isseen as chronically and severelyunder-funded, allowing pollutersto make a mockeryof environ-mental laws. Even the usuallycautious development by r ep la -tors of adequate standardsn-quir ing the most up- to-da tetechnologies is seen as under-funded, inadequate and longoverdue.f i e minimumamountof toxicityin stack emissions from MSW in-cineration, if that avenue of man-agement is chosen at all.Regular household hazardouswaste pickups and specialban-dling, disposal and reuse of suchwaste.

* Prioritization and a much higherlevel of governmental commit-merit (i.e., funding, staffing) toresearch planning, and imple-mentation of innovative wasteprevention andvolume source reduction andreuse), recycling and com ~o sti ngmeasures.

Sufficient, dependable ~ommit-n~ en t o learning from thesue-cesses of others and to developexpertise in adapting and devis-ing efficacious implementation ofinitiatives which Promote the UP-Per two tiers of the hierarchy:waste prevention and recycling-

* Increased worker training, certi-fication and safety procedures atincinerators and other wastemanagement facilities and effec-tive monitoring of same by reg-ulatory authorities.

The potential is great for arriving ata result that can be supported by thepublic when care is given to ea rly andfrequent communication of the deci-sion-making process with the publicuntil the process is complete, and ac-tive solicitation and genuineconsid-eration of the views of informed

members of the public, balancing theinterests of all concerned parties.

Histo of Public Partlclpatlon in NewYork r ty

During recent inN~~ yorkCity and other localities the citizensadvisory rnmmittee (CAC) hascomeon the scene, formed and funded byvariom local governmental entities,usually to advise environmental, trans-portation, or sanitation departments.C A C ~ re comprisedof a of in-terested members of the public, r e presenta t ives of envi ronmenta lorganizations having technical knowl-edge and experience as well as peopleRpresenting different constituencies,including representatives of commu-nity baards and the City Council. CA f iare usually appointed and authorizedto become informed about and evalu-ate the merits of specific projects. Theycritique facility plans and environm en-tal impact Statements (El%), and Over-all solid waste management plans and/or policies, and have their input seri-owly considered by government. CAQare also often funded by the local gov-

ernment to hire consultants to assistthem in these tasks.The first Sanitation ~ ~ ~ ~ ~

CAC, for the B ~ ~ ~ M ~~~~ yardwaste-to-energyplant,was establishedjointly by the Brooklyn Borough Pres-ident and the SanitationD~~~~~~~~~( ~ 0 s )n the early 198Os andwas gvenfunding to hire a consultant. wassuccessful in making the initialpro-posals to redesign the facility in orderto improve its aesthetic appeal, requirecontrols to achieve optimum burningefficiency, and include scrubbers, abaghouse and continuous emissionsmonitors. All of these additions haveunquestionably improved the accepta-bility of the plant.

In 1988 the other borough presi-dents established CACs to monitor andadvise the DOS regarding four moreproposed resource recovery plants forthe other boroughs. All were fundedwith $100,000 for the purpose of hir-ing consultants. Immediately, theManhattan CAC, with members fromseveral major environmental organi-zations, broadened the stipulated out-look to all aspects of the solid waste

hierarchy. Subcommittees on sourcereduction, recycling, incineration, ashmanagement and landfilling were ini-tially established.

With this integrated approach inmind, the Manhattan CAC then hireda consulting firm from Boston to in-vestigate, for a portion of the consul-

tant monies available, the specificcontribution that couldbe made to wastemanagement capacity by implement-ing alternative solid waste manage-ment and prevention techniques. Thisconsultant agreed in its proposal to theCAC to produce a number of wojkproducts, including a set of recom-menda tions regarding "types of wastereduction programs, recycling pro-grams, composting programs, and theirimplications for the size of the Man-hattan waste-to-energy facility."' In-stead it produced a report which "is"

"lid planfor city; ratherit is a preliminary survey issuesandoptions which we believe shouldbe

in the processof draftingathis discrep-

ancy, the repon wasreceivedwith dis-appointment by man y memben-

after the of this report,th e CAC's then changedtheir name and were hired by DOS toassist its planning

Since then the ManhattanCAC hashelped develop the mandatory recy-cling law, Local Law 19, passed in1989, and the ensuing municipal re-cycling It originateda proposal (which was funded for twoyears) for DOS to undertake pilot pro-grams to study and experiment withmethods of intensive recycling andWaste prevention education. A city-wide CAC established solely to over-see the intensive recycling and wasteprevention research zones recom-mended research and budgetary prior-ities for over a year.

Establishment of S0lId WasteAd~lSOlyBoards InNew York City

Under New York City's Local Law19, the mandatory recycling law, thecreation of Citizens Solid Waste Ad-visory Boards (SWABS) in each of thefive Borough Presidents' offices wasmandated-3 In add ition to requiring25percent recycling by 1994, Local Law19 in essence renamed the five bor-ough-wide CACs a s S WABs, ex-panded the membership to include awider diversity of citizens, and madethem responsible for advising the Bor-ough Presidents and DOS on recyclingmatters in addition to incineration. Inaddition, a Citywide Recycling Advi-


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Along with the success stories therehave been many frustrations. Somegroups within the governmental de-partments have been more receptive tonew ideas than others. Although aSWAB committee was of the under-standing that the DOS w ould seek outits input before announcing a major newinitiative, this did not always occur.For example, a new DOS Waste Pre-vention Partnership with Business anda subway and bus advertising cam-paign were a complete surprise to theSWAB Waste Prevention Committee,which would have wanted to contrib-ute ideas to improve these initiatives.Other frustrations have resulted whenDOS has not responded to certain re-quests or suggestions. For example,repeated efforts have been made tomotivate DOS to respond to theSWAB'S written comments on theCity's 1990 recycling report (a%-pagecritique with recommendations).

Int rated C de Waste Planning:The% 20-var Plan

Contained in the New York StateSolid Waste Management Act of 1988is a requirement that all planning en-tities in the state (usually municipali-ties) are required to prepare a 10-yearintegrated solid waste managementplan, designed to meet the state's 1997goal of50 percent reduction, recyclingand composting, and 5 0 percent waste-to-energy. A limited amount of stategrants to assist localities in the devel-opment of such plans was to be ad-ministered by the New York StateDepartment of Environmental Conser-vation (DEC). The local plans wereoriginally to be submitted to DEC byJanuary 1, 1990; this allowed com-munities one and a half years to com-ply with the requirement. As a resultof protests by DOS and others, the timelimit was subsequently extended toApril 1, 1991, and since that time, anycommunity without an approved planhas received no solid waste permits.The extension did permit DOS to cir-cumvent the integrated planning re-quirements and complete its applicationfor permits for a new waste-to-energyfacility, the Brooklyn Navy Yard, anda new ashfill, prior to April 1991.

In the case of New York City, thespecter of a freeze on additional newsolid waste facilities was a frighteningpossibility, since much of the 27,000tons per day generated by the City isnow deposited at Fresh Kills, a singlelandfill located on Staten Island. TheDOS had, for some time, recognized

that the capacity of Fresh Kills would

probably be exhausted soon after theyear 2000, and that the need had ar-rived for developing new sites for in-cinerators and ashfills, materialsrecovery facil i t ies, intermediateprocessing facilities, composting sitesand transfer stations. Recognizing theconsequences of delay, but unable tocomply with the deadline, the DOSasked for and received an extension toreceive $2 million in planning grantfunding if DOS were to receive ap-proval on its plan by October 31, 1992.

Work on what has become an in-tegrated 20-year plan began in earnestin the latter half of 1990, and DOSraced through the next year and a halfto meet the deadline. In all, DOS em-ployed 12 consulting firms on varioustasks, including preparation of suchstudies as intensive materials~basedwaste characterization, statistical pro-files of the City, waste export, incin-erator emissions, reports on varioustechnologies including types of Mate-rials Recovery Facilities (MRFs),composting facilities, and incinera-tors, waste prevention techniques,trucking and transportation, and wastegeneration rates. Coordinating the in-formation garnered from these studiesfor DOS is the former consultieg firmfrom Boston which had originally beenthe technical consultant for the Man-hattan CAC. After switching alle-giances in the middle of the consultantcontract with the CAUSW AB,this fm

has contributed considerably to theCity's plan by adapting its Waste Plancomputer software to the City's needs.

Technical Worklng GroupTo address the massive integrated

waste planning effort being undertakenby HHC, DOS, and the NYC Depart-ment of Environmental Protection (forsewage sludge management), the latestdevelopment in New York City's CACactivities has been the new CitywideCACs. There have been several city-wide CACs advising various depart-ments of City government on issues ofintegrated waste management, sludge,combined sewer overflows and medi-cal waste. CRAB, though mandated bythe 1989 Local Law 19, was not for-mally established until 1990 due to de-lays in appointing members. CRABoriginally consisted of members of theborough SWABs, citywide sludgeCAC, medical waste CAC, but it hasnarrowed its focus to MSW. All theCACs oversaw the development of andreviewed and critiqued the interagencyeffort to characterize the City's medi-

cal, sludge, and solid waste streams

and prepare a comprehensive, 20-yeaintegrated management plan accordinto the solid waste hierarchy, maximizing source reduction and recycling iall media, as required by the State DEC

As part of the effort to produce it20-year plan, DOS organized regulameetings with a subcommittee of CRAconsisting of members of the SWABand other interested citizens, to inforthem of developments in the plan anlisten to comments and suggestionsThese Technica l Working Grou(TWiG) meetings began in Januar1991 and continued until August 199As with the case of the HHC publiparticipation process, an effort wamade to proceed in an organized fashion with earlier meetings encompasing the overall s tructure andassumptions to be used in developinthe plan, with succeeding meetings focusing on refinement of assumptionand narrowing of the field of choicebased mainly on such criteria as coand tonnage diverted. Although lists oemissions and effluents produced beach form and system of waste management were presented, and the original planning process structure includea role for total environmental impacvis-a-vis the narrowing of alternativethis vital step was not integrated intthe process, at least during the timthat the TWiG met with DOS.

Though the goals in this public paticipation process were similar to thosimplemented by HHC the year beforthe DOSITWIG meetings and the oveall process differed significantly fromthe HHC counterpart, to the detrimeof the DOS process. The latter effowas several times larger than that oHHC, in terms of waste stream to bmanaged and consultant effort, anDOS was initially attempting to complete the entire process of creating first draft report within five monthprobably due to the fact that the DOeffort began a year after the HHCprocess. Thus, the three-hour TWiGmeetings occurred twice as often as thHHC meetings (every two weeks), anthe amount of materials given to thTWiG members for review at eacmeeting was roughlythreeto four timesthat provided by HHC's consultantIn addition, the meetings were alwayheld on weekday mornings, whiclimited the number of potential participants. The numerous handouts (typcally on the order of ten) were usuallgiven out on the same day that thcomments on them were to be discussed. Though minutes of the meeings were often taken, their preparatio

and distribution were frequently de

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sory Board (CRAB) consisting ofmembers appointed from the fiveSWABs was mandated. The purposeof these bodies is to provide oversightof the implementation of Local Law19, and to provide oversight and inputinto various aspects of the solid wastemanagement planning process for the

City, including review of the DOS an-nual recycling plan.The SWAEk and CRAB interact with

such public and private agencies suchas the City Departments of Sanitation,City Planning, and Consumer Affairs,the State Department of Environmen-tal Conservation (DEC), the Mayor andCity Council among others. The pur-view of the SWABs andCRAB hasgrown to include review and responseto the appropriate agencies regardingnew and existing programs, researchpilots, policies and budget matters.Representatives of these governmentalbodies routinely address the SWABsand CRAB regarding the sta tus of pro-grams and budget matters, and havelistened to comments by the members.On many occasions, the Boards andtheir committees have been proactiveby preparing recomm endations on cer-tain issues (e.g., recycling and wasteprevention-related procurement, thedesign of waste composition studies,needed research programs, etc.).Committees of the Manhattan SWABhave recommended new directions andinitiatives for DOS's nascent wasteprevention program, and new educa-tional practices and priorities to im-prove the effectiveness of its recyclingprogramsby convening forums to ex-plore market-related issues. On otheroccasions, the Boards have held edu-cational forums on various topics ofconcern (e.g., incineration and ashmanagement, procurement and recy-cling market development). These havebeen quite successful in attracting largeaudiences.

Members of each SWAB are citi-zens who live or work in each respec-tive borough (Manhattan, Brooklyn,Queens, Bronx and Staten Island), andwho have been appointed by the Bor-ough President and City Council.Members serve for one year, attendingSWAB meetings every month or twoplus subcommittee meetings, and pro-vide their services free of charge.Lo-cal Law 19 requires that the SWABsconsist of citizens with a variety of af-filiations such as environmental andcommunity groups, Community Plan-ning Boards (there are 59 in the City),tenant and real estate management as-sociations, private waste collection and

recycling firms, retail organizations,

and economic development corpora-tions. Though balance is an importantcriterion in the establishment of a co-operative advisory or standard devel-opment committee, it is clear that theprocess by which a policy is developedis also of'critical importance to the na-ture and eventual wide acceptance of

the result.In order to organize the work of theSWABs, the Manhattan SWAB, as oneexample, has established several com-mittees, some of which include mem-bers of the other SWABs. At present,standing committees address the fol-lowing issues: waste prevention (anInterSWAB committee), residentialrecycling, commercial recycling, in-stitutional recycling, markets and eco-nomic development (an InterSWABcomm ittee), long range waste planningand oversight, facility siting, buildingdesign (to accommodate recycling),communications and legislation/lob-bying. Issues addressed by these com-mittees and the Board as a wholeinclude maximizing the efficiency ofcollection, composting systems, edu-cation and enforcement policies, inter-agency cooperation and solid wastedisposal options.A steering committeeconsisting of committee chairs, vicechairs and other members who wish toattend the monthly meetings sets thedirection for the SWAB.

In late 1989 members of the bor-ough SWABs and others were invited

to form a new CAC to review and pro-vide input into the New York CityHealth and Hospitals Corporation's(HHC) portion of the City's long-rangeintegrated solid waste plan. Duringmonthly meetings which took place inthe evenings in 1990 and early 1991,HHC and their consultants (Waste Techand Konheim & Ketcham) presentedresearch in a clear, logical sequence,providing opportunity for response, andrecording the reactions and alternativeproposals. Minutes of each meeting in-cluded the contributor of each idea, andwhich ideas were and were not adoptedalong with respective explanations.Participants were able to discuss per-tinent ideas directly with the consul-tants between meetings. The researchprocess was repeatedly refined as a re-sult of this public participation process.Each new written draft was proposed,usually well in advance of the meetingat which it was to be discussed, gen-erally allowing participants sufficienttime to review the information andprepare their responses.

Although not all the ideas put for-ward by the public were adopted, the

final report's emphasis on volume waste

prevention measures was probably in-creased due to the clear mandate fromthe participants. In addition, a newsection on "fuel clead$g", or toxicwaste prevention measures, was addedas a direct result of putdic input intothis process. Most of the participantsdid not come away with the perception

that the results were an unreasonableproduct of the process or that they hadbeen railroaded.

Having continuous public input intodecision-making in solid waste is im-portant not only because the public canultimately affect a planned facility sit-ing adversely, but also because thepublic is in a unique position to affectthe ultimate success of source reduc-tion and source separation efforts byinfluencing participation. CACs areuseful not only in providing the pub-lic's viewpoint on these issues, but theycan also help design local solid wasteprograms to be more effective, and evencreate siting criteria acceptable to alarger cross-section of the public.Government agencies would be pru-dent to pay heed to aCAC's view be-cause of these points.

Success Stories/Frustrations

Among the success stories of theSWABs and their predecessor com-mittees are the development and im-plementation by the Department ofSanitation (DOS) of several pilot re-

search programs. Over the last few yearsintensive recycling collections (includ-ing mixed paper, mixed plastic, foodwaste, and household hazardous waste,as well as newspapers, magazines,corrugated, metals, glass, and plasticconta iners) have been studied in thePark Slope neighborhood of Brooklyn.Many of the recommendations madeby the Commercial Recycling com-mittee were included in the City's finalcommercial recycling regulations, im-plemented starting November 1991.DOS educational brochures on wasteprevention and residential and com-mercial recycling have included rec-ommendations from the SWABs. Toincrease recycling participation in afairer, more effective manner, a rec-ommendation was made in a recentbudget year by the SWABsICRAB andadopted by the City, which resulted ina decrease in funding for recycling en-forcement personnel with a wncomi-tant increase in recycling educationalstaff. As a result of this recommen-dation, the DOS requested dozens fewerrecycling enforcement personnel forFiscal Year 1991 and instead requested

more recycling education staff.- -AIRI WASTE Vol. 43 April1993 455


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tons per day of new recycling capac-ity.5 TO generate this quantity of re-cyclable~,DOS targeted 45 percent ofthe waste stream, despite their ownwaste composition study that deter-mined 75 percent of New York City'swaste stream consisted of recyclableand compostable materials as defined

by DOS' current curbside and pro-posed intensive recycling programs.DOS further assumed that only slightlymore than 5 0 percent of the recycla-bles targeted would be collected, re-sulting in a 25 percent recycling rate.In addition, an 8 percent waste pre-vention figure was mentioned. Moresignificantly, the DOS plan was to in-clude new waste-to-energy capacityamounting to 10,000 tons per day, or68 percent of the total waste streamplus additional landfilling of ash.

Cltlzen's Alterative Plan

Plan PreparationIt was the decision to announce, at

this stage in the development of theDO S plan (i.e., before all the ramifi-cations of the alternative scenarios hadbeen explored), that the scenario withthe highest amount of incineration andthe lowest amount of recyclinglcom-posting would be chosen, which gen-erated swift outrage by most membersof the TWiG. Thus, a day after theSanitation Commissioner's announce-ment, members of the TWiG beganpreparing an alternative integrated solidwaste plan that would achieve the NewYork State goal of at least 50 percentreduction, recycling, and compostingby 1997. Concurrently, a lawsuit againstDO S for past failure to meet the City'smandatory recycling goals and re-quirements was launched by CRAB,the Natural Resources Defense Coun-cil, and others.

Using the alternative scenario de-veloped by the chair of CRAB as abasis, the TWiG committee immedi-

ately began to deci& on a unifyingphilosophy and flesh ou t the details ofthe alternative plan. T he diverse groupsrepresented in the working group in-cluded environmental groups opposedto any incineration under any circum-stances and those not so categoricallyopposed, as well as Borough Presi-dents' office liaisons, consultants, andother SW AB members. Despite thedifferences, the group came to accordearly regarding the shape of the alter-native plan. It was agreed that the gro upwould formulate a plan by which theCity would quickly, over the next four

to five years, establish an aggressive,

integrated program of many waste pre-vention initiatives, intensive recycling

1 and composting, addressing wastes from1 all types of generators. The alternative1 plan would specify not only the details1 of this integrated program, but also aI detailed timetable of milestones overI each fiscal year until 1996. It wa s rea-

soned that if incineration were to beplanned as part of the program at theoutset, it would limit the potential forintensive prevention, recycling, and

1 composting, since incinerators must befed wastes at the rated capacity o r they

I will not be economically viable.1 In the three-month discussions lead-

ing up to completion of the draft, the1 proposed integrated system evolved1 considerably. The draft recommended1 an expanded effort into designing and1 implementing waste prevention legis-1 lation and economic incentives, ex-

pansion of recycling to include many1 more materials than was then done in1 New York into all districts, and im-1 plementation of food and yard wasteI composting. Much increased emphasis1 was placed in the areas of market de-

velopment, particularly in theNew YorkCity area, for recycled and compostedproducts, a much more targeted public

Table 111.

education program, government procurement of recycled products and mordurable products, and a research program to study methods of increasinthe amounts of waste diverted due towaste prevention, recycling and composting. Discussions concern ing thalternative plan also produced agree

ment that at the end of FY 1996, as-suming the intensive non-incinerationprogram was implemented as aggressively as planned, the progress (i-e.participation and diversion rates, marketing of materials, potential for further diversion, etc.) should be evaluateto determine if disposal options woulbe necessary. Since the City's onlylandfill, Fresh Kills, may be filledwithin ten to 1 5 years, and the exporoption is likely to be blocked soon duto federal legislation, the incinerationoption might become necessary for portion of the waste stream.

The f m t draft of the alternative plana 60-page report eventually called"Recycle First," was completed inDecember 1991 and immediately endorsed by over40 public officials fromNew York City. At the completion ofthis first draft, the Recycle First committee, w hich had been exclusively en

New York City "Recycle First" Plan

A. Prevent Production of Waste1. Prevent Waste Up Front2. Halt Production of Co-Mingled Trash3. Facilitate the Reduction of Difficult-to-Recycle Items and the Reduction, Recovery

and Proper Disposal of Toxic Components

B. Maximize the Quantity of Recycling and Expand the Program Citywide1. Operate Reduction, Reuse and Recycling Programs Citywide with Stable, Predict-

able Budgetary Support2. Build Improvement in Reduction, Reuse and Recycling Over Time into the Man

agement Plan3. Target the Maximum Quantity of Recyclable Material in the Waste Stream4. Separate Recyclables at the Sourceso as to Facilitate Marketing and HouseholdParticipation and Minimize Inconvenience5. Design the Waste Management Program to MinimizeCosts6. Site Recycling Facilities Expeditiously and While Minimizing Environmental Impac

C. Pursue an Aggressive Market and Economic Development Program1. Take Steps to Enlarge the Regional Market for Recycled Materials to Assure Succes

of a Comprehensive Recycling Program in New York City2. Structure the Waste Management Program to Support Local Economic Developmen

D. Use the City's Remaining Landfill Space Prudently and Defer Decisions About In-vestments in Incineration1. Defer Decisions on Incineration until the Cityhas Fully Implemented a Gnnpre-

hensive Reduction, Reuse, Recycling, and Composting Program2. Reduce Waste Going to Fresh Kills Landfdl3.

Phase Out Exporting the City's Trash Problem to SomewhereElse

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Table I. DOS waste management scenarios as of July1991.Waste Management Scenario # Trucks

1. High Quality Recyclables Collection/Refuse forWTE 2 trucks2. WetDry Collections withWTE 1 truck, 13. High Quality/Organicflefuse/WTE 3 trucks compartment(s)4. Wet/Dry 1 truck, I5. High Qualitymefuse withMWP 2 trucks compartment(s)6. WetDryMrTE 1 truck, 2 compartment(s)7. High QualityIOrganicsmefuse 3 trucks8. High Quality/Wet/Dry/WTE 2 trucks9. Wet/Dry/WTE 2 trucks

10 . Wet/Dry 1 ruck, 2 compartment(s)11. High Quality/Wet/Dry 2 trucks12. Wet/Drv 2 trucks

layed by weeks, and little attempt wasmade by DOS or its consultants to ad-dress each recommendation specifi-cally, and in writing as had HHC'sconsultants. This occurred despite re-peated requests from the TWiG mem-bers for more meaningful feedback.Thus, the commentary by the partici-pants had to be instantaneous, and basedon a cursory review of the handoutsand a hurried discussion of only a fewof the handouts by the consultants.

Because the materials were so muchmore voluminous, and the time pro-vided to digest them so much shorterthan that provided in the HHC process,it was ensured from the beginning thata less thorough review by the partici-pants woqjd be possible. The TWiGmembers were invited to submit com-ments in writing subsequent to the in-

itial discussion date for a particulartopic, but as most of the participantswere volunteers with other job respon-sibilities, such written responses wererelatively few. But, as with the case ofthe oral comments provided by TWiGmembers, most of the written com-ments were not answered. Though dataon the costs of incinerators providedby a TWiG member were accepted byDOS and used in subsequent calcula-tions, most of the other written com-ments prepared by TWiG memberswere never answered, despite frequentreminders. In one case, a detailed al-ternative scenario prepared by the thenChair of both the Manhattan SWABand CRAB, and submitted beginningin February 1991, and resubmittedseveral times with revisions, was notseriously addressed to the satisfactionof the TWiG members.

In contrast to the HHC process,where the participants not only knewwho all the City's consultants were,but were also able to discuss issues ofconcern directly with them, the TWiGmembers were repeatedly denied a listof the 12 consul ting firms and to which

researcwplanning tasks they had been

assigned. Since DOS' main consultantmade almost all of the presentations,even when the materials being dis-cussed were not written by them, in-teraction between the TWiG and theother consultants was nonexistent. Inaddition, TWiG members asked sev-eral times for a schedule of meetingagendas; this was also denied on sev-eral occasions.

Impetus for an A h a t i v e Plan4By July 1991 after seven months of

these intensive meetings with DOS therewere 12 possible solid waste systemscenarios being discussed. These aredepicted in TableI. For each scenariothe number of tons per day, numberand acreage of facilities needed, cri-teria emissions produced (plus HCl),

system costs per ton, collection costsper ton, facilities cost per ton, totalcost, and percentages recycled, com-posted, burned, and landfilled werepresented. Half of these scenarios in-volved construction of 2250 tons perday of waste-to-energy capacity(WTE)and ash landfilling for 1000 tons perday along with non-incineration recy-cling and composting alternative meansof waste management. The other sixinvolved various combinations ofMRFs, mixed waste processing facil-ities (MWP), n-vessel composting fa-cilities ([VC), and landfiffls. Though this

oup of scenarios, most ofwhichs a l a r g e fa been selected by the con-sultants, at least two scenarios thatmembers of the TWiG had proposed

were missing: (1) High Quality Re-cyclable~,Organics,MWP and (2)HighQuality Recyclables, Organics,MWP,and WTE. The system costs for eachof the 1 2 scenarios, most of which fellin a range from$200 to $300 per tonwere presentedas ranges usually vary-ing within a range of$40 to $50 per

ton for each scenario. Thus, many ofthe cost ranges for each scenario ov-erlapped, making selection of the mostinexpensive alternatives less obvious.

From all of the many waste preven-tion initiatives available (including alarge number mentioned in the initial50-page report byDOS' consultants),DOS decided that only four waste pre-vention programs were worthy of im-plementation. This was despite theconsultant's estimate that the wasteprevention program was, by far, themost economical part of a solid wastemanagement system, costing only $26per ton MSW prevented. In June, theManhattan SWAB'S waste preventioncommittee produced several dozenwaste prevention initiatives for DOS'consultants to evaluate, but DOS chosenot to resoond to the committee on thisissue. Thk waste prevention target wasoriginally 8.25 percent, and then sub-sequently reduced to 7.5 percent in July,and then to 7.3 percentin October 1991without substantive explanation.

Though the reasoning behind thenarrowing of the selection had not beenclear to everyone, and efforts contin-

ued to haveDOS' consultants analyzethe missing two scenarios, by later inthe summ er of 1991 the list of 12 scen-arios had been narrowed to five pos-sibilities corresponding to scenarios1to 5 in Table I. These, and the per-centage of the waste stream expectedto be handled by waste prevention, re-cycling, composting, incineration andlandfilling are described in Table 11.As with the 12 scenarios listed in Ta-ble I, the cost ranges for each of thesescenarios overlapped considerably.

On September5, 1991 the Com-missioner of the Department of Sani-tation announced at a hearing of theNew York State Legislative Commis-sion on Solid W aste Management thatthe City's plan would propose 3,000

Table II. DOS cenarios asof Aurmst 1991.'

~e&cled 22 15 22 15 31Composted 0 25 13 25 32Landfilled 16 22 16 52 29Waste Prev. 7.5 7 .5 7.5 7.5 7.5* T h e

f i s t threecolunuis sum to over100% became of the extra generatedby incineration.

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1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001

End of Flscal Year

Center for Ulc B l w Natural Syatcma

- - -Flfiurs1. RecycleFirst Waste ManagementSystem developedover time.

gaged in writing up to this point,diversified into two groups. The activepart of Recycle First was now a newlobbying arm, consisting of represen-tatives from many large grassroots en-vironmental organizations, which metevery few weeks to design and imple-ment the campaign to persuade gov-ernment officials to adopt the RecycleFirst Plan. The original group of au-thors met in April and May 1992 toamend Recycle First to include newinformation prepared by consultants tothe Manhattan SWAB and to makechanges necessitated by the City's firstdraft Plan.

Detaiis of the RecycleFlrst PlanThe Recycle First Plan features the

following basic principles of wastemanagement (see Table 111): an analy-sis of the impact of delaying imple-mentation of incineration on Fresh Killscapacity; sections on waste streamcomposition; education; markets forrecyclables and compostables; com-mercial sector and alternative collec-t ion methods and processing

technologies; a description of the com-ponents of a comprehensive waste pre-vention, recycling, and compostingplan; and a description of the inciner-ation philosophy. Among the many ta-bles and graphs in the report is Figure1, which illustrates the evolution of in-tegrated solid waste management inNew York C ity over the next ten to15years, assuming the Recycle First Planis followed. The Recycle First Plan endswith an extensive, point-by-point im-plementation schedule for the wasteprevention, recycling and compostingprograms, facilities, legislation, andother initiatives throughFY 1996.

The waste prevention program en-visions an ambitious combination ofI local, state and national initiatives to1 be carried out by a new, separate of-

fice of waste prevention at DOS. Suchstrategies would include legislative in-itiatives, economic incentives, govern-ment procurement requirements andother government policies to encour-age the manufacture and purchase ofmore durable products and less pack-aging. Because packaging, nondura-bles, durables and compostablesconstitute nearly 100 percent of thewaste stream, and all of these com-ponents can be addressed by waste

I prevention initiatives, waste preven-I tion is the first level in the RecycleI First Plan. The recommended goal forI waste prevention is 15 to 20 percent.I To accomplish this goal, aggressive1 consumer education programs, di-

rected at residential and commercialsector target items, and designed tochange product purchasing, productmaintenance, and reuse habits to min-imize residential waste generationwould be developed. Measures to re-duce toxic substances in the waste

stream (e.g., metals, chlorine, fluo-rine, sulfur, and nitrogen, whichbe-come air and water pollutants upondisposal of MSW) are also included inRecycle First's recommendations. Inaddition, significant reductions in themanufacturing and purchase of pack-aging and disposable products such asdisposable diapers, which account forover 3 percent of New York City'swaste stream, would be pursued. Tofoster the development of additionaltechniques for m inimizing waste gen-eration, Recycle First proposes a com-prehensive waste prevention researchprogram including a new product/

packaging-oriented waste characterization study and pilot tests to determine the efficacy of various educationaprograms designed to reduce wastgeneration.

The intensive source separation program is based on a four-container system for: (1) paper products such acorrugated, newspaper, and magazines; (2) other high qualityrecycla-bles such as metals, glass, and plasticontainers; (3) food and yard wastefor composting; and(4) dry residue.One truck with two compartmentswould collect the first two recyclablegroups, which would be brought to anintermediate processing center for further separation into individual recyclable categories; another truck with twcompartments would collect the restThe comwstables in the second truckwould be' brought to a composting facility, and the dry residue, includingany unseparated refuse, would bebrought to a mixed waste processinfacility. Household hazardous wastewould be picked up and managed separately.

Based on the DOS' ambitious materials-oriented waste characterizatiostudy conducted in 1989, the targewaste stream for these materials includes at least 75 percent of the NewYork City waste ~t r e a m .~hough theplan assumes initially high rates ofcontamination in the first years of thefour-container separation system,gradual improvements in the effi-ciency of source separation would beexpected over time, diminishing contamination to a small quantity by 200(see Figure 1).

Manhattan SWAB'STechnicalConsultant Report

The Recycle First plan was pre-pared in a short time (three months) bycitizens and environmental professionals, most of whom were volunteeringconsiderable amounts of time. Be-

cause there was insufficient time toun-dertake the research necessary to searchthe country and world for case studieswhich would endow the study with anappendix of supporting evidence anddocumentation, the Manhattan SWABresolved in November 1991 to expendup to $15,000 of its remaining$30,000to hire a technical consultant to pro-vide this technical support to strengthenthe plan and enhance its feasibility inthe eyes of DOS and DEC. Since itwas expected that DOS' first draftwould be completed by the end ofMarch, the SWAB'S consultants'timeframe was to be short, and thepp -- pp- - - - - - - - - - - - - - - - - - - -AIR & WASTE Vol. 43 Aprll1993 459


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SWAB moved to expedite the hiringprocess.

Though the SWAB'S technical con-sultant committee submitted a brief draftRFP to DOS by December 20, DOSdelayed its comments until almost threeweeks later. Another delay of almosttwo weeks by DOS in initiating a con-

tract between SWAB and the new con-sultant, Resource Recycling Systems,occurred. This occurred due to theunusual DOS-proposed subcontractingarrangement through DOS' currentconsultant (the SWAB's original con-sultant). As DOS began transmittingcertain appendices to its plan in Feb-ruary 1992 and completed the plansubmission by March 31, efforts weremade by the SWAB to persuade DECto schedule a review of the RecycleFirst Plan and its supporting documen-tation concurren t with the C ity's plan,in spite of the DOS-induced delays tothe SWAB's report.

Issued in April 1992, the 125-pageconsultant's report has dozens of casestudies which describe exist ing munic-ipal programs, legislation, and otherinitiatives in six areas: waste preven-tion, public education, recyclab les col-lection and processing, composting andmarket development. The case studieslikely to be most applicable to an ur-ban setting such as New York werechosen. Detailed information regard-ing waste diversion rates, programcosts, methods and ease of implemen-

tation, problems, and successes dem-onstrate the validity of the case studyinitiatives. Though the original inten-tion had been to use the report as sup-porting documentation for RecycleFirst, the materials contained thereinwere also used to support commentsby CRAB and SW ABs targeting defi-ciencies in the DOS plan.

CRABINRDCLawsuit AgainstNYCDOS

Entering into and shaping, or com-plicating, the solid waste planning

process (depending on whose view-point you subscribe to) has been theCRAB/NRDC lawsuit. CRAB hadstanding in the suit because it has theduty to review DOS' recycling pro-gram annually under Local Law 19.As a result of the City's decision to cutback on funding for the recycling pro-gram duringFY 1991 and 1992 duetoa general fiscal crisis, DOS failed tomeet a number of requirements man-dated by Local Law 19, including thatthe City:

Recycle 1400 tons per day by

April 1991, and higher recycling

levels through 1994. (As of mid-1992, only 1000 tonslday was re-cycled.)Site a minimum of ten buy-backcenters with some in each bor-ough. (By that time only one fa-cility had been sited.)Produce a citywide recycling plan.

(The City produced a preliminaryreport in 1990, but nota plan.)Implement citywide deposit orreclamation programs fordry-cellbatteries and tires. (The City hasdone nothing in this area.)

In order to meet Local Law 19'srequirements over the next few years,the City would have had to expand re-cycling from the 29 districts it servedthen to all of the total 59, and fromthe three to six materials curren tly col-lected at curbside to more than s ix ma-terials. That the recycling program was

nearly terminated entirely in June 1991and only restored to partial fundingcaused these failures in recycling im-plementation.

According to the decision by aManhattan State Supreme Court jus-tice, filed February 6, 1992, the Citydid violate Local Law 19 because thelaw states 23 items which the City"shall" include in its recycling plan,and numerous other instances in whichthe statutory language is unambiguousin its requirements. Therefore, the courtissued an order of mandamus, direct-ing the DOS Commissioner to complywith the provisions of the law withina reasonable time.'

Rde of the CityCouncliA new player in the solid waste

planning arena has been the CityCouncil. Though the Council had al-ways had an effect on planning via ap-propriat ions for the Sanitat ionDepartment's budget, andin fact nearlyeliminated the recycling program forfiscal year 1992 due to fiscal crisis, theCouncil is now taking a more proac-tive role. In March 1992, at the urgingof the Recycle First Coalition (the lob-bying arm), which includes membersof CRAB and the SWABs, the Councildeveloped a bill, Intro. 131, and votedunanimously to give itself the author-ity either to approve or prevent the Cit-y's plan from being submitted to NYSDEC. The Council also decidedto holdpublic hearings and hire its own con-sultant to assist in the review of theCity's voluminous plan (several hundredpages with over 10,000 pages of ap-pendices). The SWABs, City Admin-istration, and DEC applauded this

development, since it isrecognizedthat

without sufficient and timely funding,no solid waste plan of any kind couldbe implemented.

Future of Sold Waste Plannlng InNew York City

Public participation in solid waste

decision-making processes in New YorkCity has gone through two phases: fm t,disregard and impatience with the pub-lic by government, and second, a pe-riod of anxiety and annoyance with thepublic. Neither has led to constructivedialogue or impressive results. Thepublic participation process for the HHCmedical waste plan began to create anew era of trust and cooperation, butthe experience with DO S nearly haltedthat progress.

In large measure, the public interestcommunity supports the solid wastehierarchy, particularly the waste pre-vention and recycling elements whichare designated as first and secondpriority. However, in order to makethe hierarchy a reality and abate thesolid waste crisis, there is a need forconsiderable research, development anddemonstration such as that outlinedabove, in many areas - particularlysource reduction, reuse, recycling, andfood and yard waste composting- ta level at least as great as that alreadycommitted to incineration, ash andlandfilling strategies in the past. In ad-dition, there is a great need both for

respect by government agencies for theincreasingly knowledgeable public andfor a greater spirit of trust and coop-eration between the two.

In order for public decision-makingto become more efficient, public inputfrom all interestedaffected parties mustbe sought out, encouraged and re-spected. To foster widespread publicparticipation and cooperation, policyCACs should be integrated into thestructure of all agencies of govern-ment. In this way , planning will havethe benefit of all points of view andthere will be a better chance that, itwill be more integrated and innova-tive, with the final results of greateracceptability to the public.

What does the future hold in storefor solid waste management in NewYork? It was clear that the David andGoliath struggle set up by the DOS an-nouncement of 68 percent incinerationin September 199 1 was going to con-tinue between the CRAB/SWABs andDOS unless and until DOS restored thegood faith extant prior to the Commis-sioner's September 1991 announce-ment. Though the court's issue of

mandamus in early 1992 might have

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made DOS address recycling imple-mentation more seriously, the C ity in-stead asked the City Council to delayand possibly weaken the requirementsof Local Law 19. However, at the sametime, DOS told CRAB that it intendedto ask the Council for funding to ex-pand the recycling program such that

six materials (metals, glass, plasticcontainers, newspaper, magazines andcorrugated) will be picked up through-out Manhattan by September 1992, andthroughout the Bronx by December1992, Queens by 1994 and Brooklynby 1995.

In the meantime, the City Comp-troller issued four reports critical ofMSW incineration and supportive ofrecycling: "Bum, Baby, Bum: Howto Dispose of Garbage by PollutingLand, Sea, andAir at Enormous Cost,"January 1992; "Fire and Ice: HowGarbage Incineration Contributes toGlobal Warming," March 1992; "ATale of Two Incinerators: How NewYork City Opposes Incineration in NewJersey While Su pporting It At Home,"May 1992; and "What Goes AroundComes Around: Good News AboutRecycling Markets," June 1992.An-other report, "Setting the RecordStraight: A Fiscal Analysis of the Cityof New York's Solid Waste Manage-ment and the Proposed Brooklyn NavyYard Incinerator," publish ed by theNew York Public Interest ResearchGroup in May 1992, presented cost

analyses of the City's various solidwaste programs, and criticized the ac-curacy of DOS' cost estimates, andwhat they considered the ill-conceivedpolicies and unexpected cost burdensengendered thereby. These documentsraised a number of important issues,but were largely seen as political innature. It is not certain how these havealtered or will shape DOS' approachto integrated waste management. DOS,in the Solid Waste Management Plan'sResponse Document, rebutted both theComptroller's reports and the NY-PIRG report.

Not insignificantly, since early Feb-ruary 1992 DOS has had a new Com-missioner who has shown a willingnessto listen carefully to a lternative view-points, and has indicated a greater tol-erance for the startup problems and costsassociated with such desirable newtechnologies as waste prevention, re-cycling and composting. Since her ten-ure in office began, a number ofdecisive policy changes have been madewhich have changed the face of theSanitation Department. Perhaps themost noteworthy is that the relative

status of recycling and waste preven-

tion was raised within the organizationby elevating the Director of RecyclingPrograms to Assistant Commissionerof the new Bureau of Waste Preven-tion, Reuse, and Recycling. At the sametime a new Waste Prevention group wasauthorized, and will, before too long,include five full-time professionals as-

signed to it. At a CRAB-sponsoredwaste prevention forum in December1992, DOS announced an array of wasteprevention programs which are eitherunderway or in the planning stages.

Both the reorganization within DOS,to elevate prevention, recycling, andcomposting, as well as the appoint-ment of a director of waste prevention,had been recommended for years bythe advisory committees. Accelerationof the long-awaited curbside recyclingprogram exp ansion for all six m aterialsinto all of Manhattan and the Bronxbefore the end of 1 992 was also pro-posed. Also, the first draft of the DOS20-year plan adopted one of the rec-omm endations of Recy cle First: delayimplementing d isposal strategies (i.e.,the construction of the Brooklyn NavyYard incinerator) until 1996 . The firstdraft Plan also included a few of therecommendations made by the city-wide W aste Prevention Committee, in-cluding the execution of a products,packaging, and toxics-oriented wastecomposition study for New York City.

During the summer of 1992, be-tween the issuance of the first draft of

the City's Plan at the end of March andthe end of August, three sets of CityCouncil hearings took place. In Mayeach of the joint DOSICouncil hear-ings in the five boroughs attractedhundreds of attendees, scores of whomgave testimony, and many more hold-ing signs protesting the proposed NavyYard plant. Aside from the advisoryboards and the citizenry, many majorenvironmental, community, business,and trade groups (some from outsidethe City) presented testimony. Muchof the debatein the public hearings wasfocused on making the plans for wasteprevention, recy cling, and compostingmore ambitious, comprehensive, andvisionay, as well as on the incinera-tionlash management issue. Morehearings were heldin July after the DO Srevised the first draft based on NYDEC's and the public's comments.Subsequently, and into early August,numerous private negotiation sessions,primarily between representatives of theMayor's office, the Sanitation Depart-ment and the City Council, took place.Later in August, unbeknow nst to mostof the SWAB and C RAB members and

some Recycle First committee mem-

bers, and to the dismay of the latter,several representatives of the RecycleFirst committee met, on a few occa-sions, with Council staff to work oncompromise language. The last CityCouncil public hearings occurred at theend of August after the Council final-ized changes to the Plan. Although

some of CRAB'S and SWABS' goalswere not realized in these final nego-tiations (e.g., immediate closure of thethree existing, antiquated, pollutingincinerators, and increased funding forwaste prevention commensurate withits place on the hierarchy), some of theCouncil's changes included recom-mendations made by CRAB and theSWA BS and their com mittees:

Shutdown of two of the threedecades-old, antiquated inciner-ators at Greenpoint, Brooklyn andBetts Avenue, Queens by 1995and retrofit of the third old incin-erator at Southw est Brooklyn.Abandonment of the plan to dis-pose of ash from any new incin-era tor (~ ) t the Fresh Kills landfillin Staten Island; new contract foran out-of-city ashfill for at least5 years.Further acceleration of curbsiderecycling programs in Queens andBrooklyn by September 1993.Pilot programs in FY94 in a va-riety of residential neighbor-hoods to test recycl ing andcopposting additional materialsthrough a four-sort process, suchas that recommended in RecycleFirst.Requirement that the four-sortpilots and curbside recycling ex-pansion be fully completed be-fore financing is sought for theBrooklyn Navy Yard plant (con-struction would begin in 1996).Advancement by one year of theHigh-Quality Recycling Programwhich includes 25 materials, thedevelopme nt of waste preventionlegislation, institution of a pro-gram to m onitor recycling partic-ipation rates, markets, and newtechnologies, as well as con-struction of the Manhattan andQueens MRFs.

Although many im provements wereultimately made in the City's Plan, andcertainly the City had come a long wayfrom the September 1991 announce-ment to bum 68 percent of the City'swaste, the final plans for waste pre-vention, recycling, and compostingwere not considered by the advisoryboards to be nearly as comprehensiveor am bitious as those proposed in Re-

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cycle First. The City's final plan setsa goal of 9 percent waste preventionby 2000. As proposed by Systems Aand B in the City's Plan, the percent-age of the remaining tons recoveredfor recycling and composting fall intothe following categories: residential andinstitutional recycling, commercial re-

cyclable~, aper, and mixed waste, bulkrecycling, and recyclable materials re-moved in the Refuse Derived Fuel(RD F) portion of incinerators, andamount to a total of only 32 percent.However, the existence of the plan asit is, with an implementation schedulespecifying the construction of MRFsand other waste prevention, recycling,and composting capacity, unquestion-ably lays the groundwork for the Cityto direct a sustained effort towards im-plementing a more integrated approachto managing its municipal solid wastes.

The last word on this issue camefrom the State DEC, which receivedboth the City's plan and CRAB'S Re-cycle First plan for initial review inSpring 1992. DEC was constrained toreview all New York State municipal-ities' plans against the guidelines setforth in the Solid Waste ManagementAct, including specific requirementsabout source separation programs to beimplemented by September 1992 as wellas the 50 percent reduction and recy-cling goal to be attained by 1997. AsDEC had, on several occasions in thepast, refused to approve the complete-

ness of the City's permit applicationfor the Brooklyn Navy Yard Waste-to-Energy facility because of its inade-quate recycling program, it was not in-conceivable that DEC would requirethe City's plan to be more ambitiousin its approach to reduction, recyclingand composting.

In response to the initial draft Planissued in March, DEC gave DOS over70 pages of comments, pointing outomissions and inconsistencies, includ-ing that the City's Mandatory Recy-cling law (Local Law 19) contradictsState law which requires businesses toseparate source recyclables on-site. Thishas since been rectifiedby the new Citylaw. On September 1, 1992 DEC re-ceived the Council-revised DOS Plan,and in subsequent correspondence notedsome deficiencies and stipulated thatnumerous additional modifications bemade including that:

The financial commitment madeby the City to undertake full im-plementation of the Plan must bemade clearer and more defini-tive.There are insufficient staff to im-plement the Plan.The Plan is really a ten-year plan,

and thus, the second ten-year pe-riod should be specified in moredetail.The decision tree approach to de-scribing which alternative plan-ning scenarios will be followed,which DOS used to cover un-known circumstances in the plan-ning process, needs clarification,and that the options and sched-uling, as well as factors, criteriaand methodology for using thedecision tree be clarified.Certain additional categories ofrecyclables and processible wastes(e.g., de moliti on, householdhazardous) be quantified.The impact of City-ownedprocessing facilities on privateprocessing capacity be assessed.Amendments to local law to aidin the implem entation of the Planneed to be specified.The Plan should commit to un-dertaking stack testing of theCity's incinerators to the extentthat federal, state, and local laws,and permit requirements stipu-late.

After a month of negotiations onthese points, DEC approved the City'sSolid Waste Management Plan on Oc-tober 28, 1992, three days before thedeadline.

Since this time CRAB and theSWABS have continued to meet, as istheir mandate fromLocal Law 19. Theircontinuing responsibility is to provideoversight on DOS' activiti es as regardssolid waste managementin general, toprovide advice to the respective Bor-ough Presidents regarding DOS' activ-ities, to work with the Council to ensurethat sufficient funding is made avail-able to pursue integrated waste man-agement to the fullest extent, to holdforums with invited speakers, period-ically, on topics of current interest, toeducate the community, to monitor thetiming, adequacy, and efficiency ofimplementation of a l l parts of the City's

Solid Waste Management Plan, and torecommend pilots, and rese a~ch andpolicy initiatives which would im-prove the efficiency and efficacy ofDOS' waste prevention, recycling, andcomposting programs.

References1. Energy Systems Research Group, Inc., et al.,

"Review, Evaluation and Development of the SolidWaste Plan for the Borough of Manhattan, City ofNew York," a proposal submitted to Citizens Ad-visory Committee on Resource Recovery and theEnvironment in New York County, May 9, 1988.p. 25.

2 . Tellu s Institute, el al., "Solid Waste ManagementIssues and Options for New York City: A reportto the Manhattan Citiz ens' Ad visory Committee onSolid Waste." March, 199 0 p. 1 .

3. Local Laws of the City of New York for the year1989, Number 19. Chapter 3 Solid Waste Recy-cling, signed into law April 14, 1989.

4 . NY C Department of Sanitation. Information pre-s e n a n this seclion was draft, as of Summer 1991.(1) Comparison of Effects of Differential Waste-Prevention Rates on Alternative Solid Waste Man-agement Systems. (2) Cost Comparison Summary- Alternative Solid Waste Management Systems.

5. "Testimony of Steven M. Polan, Commissioner,New York City Department of Sanitation beforethe Legislative Commission on Solid Waste Man-agement and Assembly Committee on Envimn-mental Conservation,'' New York, NY September5, 1991.

6. "Wasteplan Generation Report for New York CityWastestreams," 1/7/91, Tellu s Institute, Inc., forNYC Department of Sanitation.

7. E.A. Adams. "Recycling Program Ordered Ex-panded - Failure to Fund Project Deemed Imma-terial," New York Law Journal, New York, NYFebruary 5. 1992, p. 1.

About the AuthorM.J. Clarke is currently an environmentalconsubnt in New York City. During the

time period described in this paper sheserved in various leadership positions inthe solid waste advisory boards and com-mittees, including chair of the M anhattanCitizens' Solid Waste Advisory Board(MCSWAB), chair of the MCSWAB'scommittees on Waste Planning and WastePrevention, Executive Committee mem-ber of the Citywide Recycling AdvisoryBoard (CRAB), mem ber of the TechnicalWorking Group (TWIG), and member ofthe steering committeesof the writing andlobbying arms of Recycle First. Between1984 and 1988 she worked for the NYCDepartment of Sanitation as their spe-cialist in the area of resource recoveryemissions and state-of-the-art emissioncontrol technologies. Her address is 17 95Riverside Drive, #5F, New York, N Y10034. This manuscript was submittedfor peer review on August 22, 1992. Therevised manuscript was received on Jan-uary 28, 1993.

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iswm planning and decision making

Documents