NYC | Reforming the Vision for the Waste System

Case Wyse M.S. Sustainable Environmental Systems Programs for Sustainable Planning and Development Pratt Institute Demonstration of Professional Competence December 16th, 2016 Advisor: Jaime Stein & Alec Appelbaum Technical Advisor: Jessica Quiason

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NYC | Reforming the Vision for the Waste System

Current Inefficiencies in the NYC waste-collection and removal system have resulted in unnecessarily concentrated areas of toxic air-quality emissions and unnecessary quantities of greenhouse gases. These inefficiencies are a direct consequence of the inability of the 2004 waste infrastructure to adapt to the rapid reallocation of waste removal needs brought on by the closure of Fresh Kills Landfill, the last remaining final-destination disposal site within city boundaries. The mayor at the time, Giuliani, allowed for market forces to construct immediate and necessary framework for commercial waste management in the face of this transition. The resulting market forces capitalized on low-income neighborhoods and communities of color for the siting of transfer stations and garages for the relatively low cost of real estate and political resistance; communities already overburdened by other concentrations of environmentally intensive infrastructure.

The City, in response to the rapid escalation of the inequities and wastefulness inherent to the resulting waste infrastructure, produced the 2006 Solid Waste Management Plan, outlining a framework for waste management that relied heavily on the analysis of eight marine transfer stations (MTS’s) for managing the majority of NYC waste export. The planned MTS facilities have still not all been fully realized, and meanwhile, the private carting study has proliferated across geographic scope while consolidating within the industry. Economic efficiency within these business frameworks has encouraged carters to rely on centralized infrastructure to service large-geographic areas, resulting in unchecked, inefficient contributions of air pollution. The most recent attempt by the city to address this systemic incompetence, the 2016 Private Carting Study addresses the waste-retrieval element of the current hauler system by outlining the analysis of benefits produced from a zoned franchise waste-management system where individual haulers would have almost exclusive service rights. While this benefits the entire city by reducing the number of vehicle miles travelled for any hauler to reach their customers, it does not address or analyze alternatives to the current location of commercial waste transfer stations (WTS); most of which are clustered in one of three types of neighborhoods described above. As has been demonstrated by DSNY’s current model, transfer stations such as the North Shore MTS and the Staten Island TS, alternatives exist that can both meet the capacity of their respective borough and intelligently respond to the local negative environmental impacts. Cleaner and more efficient facilities, like these, sited throughout the boroughs could accommodate the planned franchise zones in a manner that would further reduce emissions and Vehicle Miles Travelled by addressing the waste delivery side of the current management system. Furthermore, these benefits would be most impactful to two of the four most, historically and currently, environmentally overburdened communities in New York City.

History

The story of environmental justice and the New York City waste system can be traced further back than the early 70’s, but the landscape for activism dramatically shifted in 2001 when the city delivered its final load of trash to the last remaining landfill within city boundaries, Freshkills on Staten Island.1 At roughly 2,200 acres, Fresh kills originally opened as a temporary location, but once again, cheap economics allowed for the dependence on this disposal option for roughly 50 years. Freshkills, most notable for the sheer scale of which to be noticeable from space, sent ripples through the waste system

1 Martin and Revkin, “THE LAST LANDFILL.”

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upon the announcement of its closure in 1992 (the landfill officially closed in 1996 but reopened briefly in 2001 to accept 9/11 rubble from the World Trade Center). With the economics of their business changed dramatically, these private haulers began building up a network of in-City transfer stations, points from which waste from local collection trucks was transferred to long-haul trucks for export outside of the City.”2 The dumping capacity diverted from waste handled within city boundaries to waste handled outside of city boundaries altered the political and economic landscape of New York City’s waste system irreversibly for the last two decades.

Upon the announcement to close Freshkills, Mayor Giuliani also announced the temporary solution to managing the city’s waste, reliance on the private carting sector and the creative forces of the economy. This decision did not occur out of isolation - increasing awareness surrounding the physical limitations of space for trash within the city and reliance on other municipalities to accept waste can be illustrated by the story of the 1987 Mobro 4000.3 In an article titled “The Most Watched Load of Garbage in the Memory of Man”, three-thousand tons of waste travelled for five months and six-thousand miles, unable to find a dumping point. This ship symbolized the scarcity of landfill space. Despite other factors, this shift in the perception highlights the difficulty that the city and private haulers experienced in exporting waste.4 More-so, new regulations in the 70’s and 80’s forced the closure of a number of toxic landfills and incinerators. Federal law such as the Clean Air Act set new standards for which the waste industry had to quickly adapt. By the early 90’s, all of New York City’s waste was sent to Staten Island, “some 20 barges every day.”5

This commercialization of the private waste stream started in the 1950’s. The Department of Sanitation relinquished control of commercial waste collection and a significant portion of residential waste management to private companies. Largely in the time from the early 50’s to the closure of Freshkills, DSNY retained a certain level of control in providing the low-cost disposal option available through city-based landfills. This wasn’t the first time, Environmental Justice communities were forced to grapple with the fall-out of waste economics; “during the late 1980’s, concerns about preserving capacity at Fresh Kills Landfill cause the City to dramatically raise rates for private haulers to tip there. The story of the Mobro 4000 takes place after the cited increase in tipping fees at Freshkills, which first rose from “18$ to 40$ per ton in an effort to prolong the life span of the landfill.”6 Marking the first point at which private carters were forced to explore alternatives to reliance on Marine Transfer facilities.

2 P.7 DSNY, Solid Waste Management Plan 3 Pasternack, “The Most Watched Load of Garbage in the Memory of Man.” 4 Winerip, Michael. “New Video Series Re-Examines Garbage Barge Fiasco.” 5 Jacobs, Karrie. “Welcome to Freshkills, Local Landfill-Turned-Park.” 6 P. 125 Sze, Noxious New York.

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This transition, alongside the directed effort to breakup mob-waste cartels, incited the eventual dependence on big waste companies such as Waste Management and BFI to rely on focus on economically efficient infrastructure. Unlike other cities, New York City was slow to yield to private carters, and in effect, the distribution of waste infrastructure remained relatively diffuse. Heather Rogers in “The Power of Garbage” cites that, “by the 1980’s when most local haulers in Sunbelt cities were being priced out by emerging national corporations like WMI and BFI, New York City still had almost 500 small companies collecting its commercial discards.”7 This is not to say that WMI and BFI did not want to partake in the largely lucrative waste market within NYC. In fact, “The city produced fully 5% of the country’s commercial refuse and its rates were the costliest nationwide – a tantalizing $1 to

$1.5 billion annual market.”8

This all changed in 1995 with the breakup of mob control, strong political connections and intense corporate interest gradually gave way to what became one of the most significant NYPD undercover operations of the era, citing 114 indictments. Effectively, “by the end of the 1990’s the number of licensed carters fell sharply, by almost 70 percent. And by 2002, the city’s disposal rates were up 40 percent from six years earlier, rivaling the inflated fees of the Mafia cartel.”9 The first couple years of “free competition were met with no single carting company serving more than 5% of the city’s customers.”10 By 2001, Waste Management and Allied controlled approximately 65% of waste transfer station capacity, and by 2004 the South Bronx and Williamsburg were reported as handling 73% of the City’s putrescible waste, two figures that outlined the eventuality for an inequitably distributed impact of waste management.11 To further exacerbate this condition, the 2006 SWMP states, ”with no alternative in-City disposal capacity, DSNY entered into short-term, interim contracts with private companies for the disposal of 100% of the residential waste stream—over 12,000 tons per day.”12

7. P. 110 Mogel, Lize, and Alexis Bhagat. An Atlas of Radical Cartography 8 p. 109 Ibid. 9 P. 114 Ibid. 10 P. 113 Ibid. 11 P. 126 Sze, Noxious New York. 12 P.7 DSNY, Solid Waste Management Plan

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Without city restriction, this generally implied that transfer stations and garages began to cluster more densely than ever in the environmental justice neighborhoods cited by Sze. It was this transition, alongside several other city-proposals to site clusters of toxic facilities in neighborhoods in the 1980s and 1990s that shared generally similar characteristics, (low-income, waterfront, industrial, populations of color) that gave way to a number of campaigns, which can be attributed to the birth of the Environmental Justice movement.13 Julia Sze, in her study Noxious New York, The Racial Politics of Urban Health and Environmental Justice, identifies: Williamsburg/Greenpoint, Sunset Park/Windsor Terrace, Melrose/Mott Haven, Hunts Point/Longwood, and West Harlem as neighborhoods where there exist a coincidence of high rates of

industrial water-front properties, populations of color and renters. These four communities share in common not only demographic and land use conditions but a shared history of activism forming the foundational groundwork for defending working-class living conditions and framing environmental systems through the lens of equity. Their impact on the waste system is no exception.

This structural inefficiency and inequity stems from a system that was ill-equipped to adapt and, shortly, reliant on market-driven forces. In the period of time before the closure of Freshkills, two characteristic goals of the current 2016 DSNY Strategic Plan existed in loosely similar form. For these reasons, the argument could be made that the waste system functioned more efficiently before it was required to identify alternatives to the practices of ocean-dumping, incineration and local landfilling. First, relying largely on city-owned facilities, oversight of final dumping practices and internal city waste distribution were decisions that the Department of Sanitations was able to dictate to their infrastructure’s capacity, while insuring that workers in these facilities were guaranteed a baseline standard for public worker health and safety. The second reason, mob control of the private carting industry instituted a de facto franchising scheme in which haulers were provided enforced territory. The various cartels would vie for certain neighborhoods, which were allegedly assigned to prevent territory disputes. Effectively, this prevented multiple haulers (and multiple trucks) from servicing the same street. This system did have its drawbacks, though. For customers at the complete mercy of the cartel

13 P.14 DSNY, Solid Waste Management Plan

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that served their neighborhood, collection fees likely rested at their maximum possible values. Regardless, the development from a mob-ruled private carting market to the current market, dominated by a small handful of international waste carters, is a product of a series of systemic shocks without guided response.

The City’s response to this market came in 2006, heavily pressured by community advocacy groups, including The New York City Environmental Justice Alliance (NYC-EJA) which cofounded the Organization of Waterfront Neighborhoods (OWN), the updated Solid Waste Management Plan (SWMP) outlined a guiding framework from which the City would target “dramatically reducing the number of truck trips and miles associated with disposal of New York City’s waste. Simultaneously, it establishes a cost-effective, reliable, and environmentally sound system for managing the City’s waste over the next 20 years.”14 Under development since its first approval in 1992, the SWMP originally called for the development of the Brooklyn Navy Yard waste incinerator. In its current form, the SWMP represents a far-cry from its initial contents, including a series of long-term visioning guidelines from which the remaining initiatives had been outlined to be carried out citing that, “it [the SWMP pronounced “swamp”] breaks new ground by recognizing commercial waste management as an important public policy issue and takes concrete steps to begin addressing concerns related to it”15 It is the guiding principles taken directly from the SWMP that this paper takes its foundation for analysis of the current efforts of DSNY as well as the current state of the waste collection system. From these principles recommendations based around the further benefit of these principles will be focused on enhancing current plans, research, and infrastructural elements. Furthermore, plans set forth in the SWMP went on to inform major city planning documents such as One NYC and its predecessor PlaNYC. These planning documents, within their overall framework, bring

14 P.1 DSNY, Solid Waste Management Plan 15 P.1 Ibid.

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to light the need to address the health and community impacts felt by the observable clustering of waste facilities.

Purpose

To determine a framework for equity within the waste system, the system with which equity needs to be established must be defined in scope. Unfortunately, waste equity within NYC does not include waste equity throughout the world. It is a recognized fact that waste must rest somewhere, and often times similar criteria for citing waste transfer stations are utilized to determine the final locations for landfills heavily utilized by NYC’s waste exporting facilities. NYC’s waste can be found in Mexico, South Carolina, Kentucky, and Ohio. While recyclables can travel as far as China.16 Within the scope of this report is the system that exists within the boundaries of NYC.

Specifically, the purpose of this paper is to assess the successes of the capacity of the city to set forth the ideals outlined from the 2006 Solid Waste Management Plan. Research contained within focuses on the capacity for the city to provide a guiding framework to a waste system that has largely been guided by a strategic framework that has, in the past, lacked vision or lagged behind the environmental limitations of the hyper dense environment of New York City’s urban framework. The unplanned impacts that developed from New York City’s waste systems ability to smoothly develop into protecting the well-being of its most vulnerable communities form the basis for improvement outlined in the next few sections. This became a central focus of the DSNY’s forward-facing policy goals in the 2006 Solid Waste Management Plan, and this paper attempts to analyze the current progress by comparing current strategies against the goals set-forth in the SWMP and the concerns raised by all stakeholders engaged in this system. These goals, as progressed and shifted in scope through their implementation via PlaNYC and One NYC generate a prismatic distillation of objectives and guidelines framed within the 2006 SWMP. Additionally, the research contained within also attempts to connect the apparent shortcomings of these goals with potential strategies to address missed opportunities.

Transform Don’t Trash

In developing the framework for analysis of these objectives, and the criteria for assessment of the city’s progress, I received assistance on data access and consult with the coalition of organizations advocating for transformational shifts within New York City’s waste system that address inefficiencies in waste production and management while tying these issues to the well-being of the communities impacted by the waste system. The Transform Don’t Trash (TDT) coalition consists of members from ALIGN (The Alliance for Greater New York), NYLPI (New York Lawyers for the Public Interest, International Brotherhood of Teamsters Joint Council 16, and The New York City Environmental Justice Alliance. Tansform Don’t Trash has been a long-time advocate for equity within the waste system, producing reports such as Dirty, Wasteful and Unsustainable: The Urgen Need to Reform New York City’s Commercial Waste System, Not at Your Service: A Look at How New York City’s Comemrical Waste System is Failing its Small Businesses, Reckless Endangerment: How New York City’s Unsafe Commercial Garbage Trucks Put Us All at Risk, Reforming for a Better Deal: How to Align Cost Savings, Sustainability and Stability in NYC’s Commercial Waste System, and most recently, Clearing the Air. Information from these reports and data provided via TDT’s Freedom of Information Law (FOIL) requests have proven

16 Louiero, Bernardo. “Waste Scenario.”

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invaluable in the development of this study in the face of a lack of accessible detailed public data pertaining to the private carting industry.

Current System

Defining the waste system requires that the waste stream be broken down into a series of source types and waste categories. Currently, two primary streams define the two major systems of management outlined in this report, residential and commercial waste. Managed by DSNY, the residential stream collects waste from residences, schools, and municipal resources. Recent developments have pushed a large quantity of this waste to be managed by rail and barge facilities. While the remaining network of the Department of Sanitation’s waste export facilities are constructed, the remaining waste is exported via contracts with land-based private carter owned waste transfer stations. Commercial waste operates similarly, with the exception that one-hundred percent of waste is managed by these land-based private carting waste transfer stations. The residential commercial waste stream contributed roughly 3.2 million tons of waste in 2015, while the commercial waste stream generated an almost equivalent 3.4 million tons. If the average garbage truck can hold roughly 25 tons of waste, the combined quantity of 6.6 million tons would produce roughly 264,000 truck trip equivalencies in 2015. Additionally, the commercial sector manages construction and demolition waste, which when combined with commercial waste constitutes the largest contribution of NYC’s waste.

Currently DSNY’s reliance on waste export facilities can be depicted geographically, each of the zones demonstrated below represents the typical geography for waste managed by each of the facilities highlighted by a circle. These circles are then sized according to the quantity of waste managed by tons per day. Operating effectively as a franchised system, the DSNY waste disposal network relies on routing efficiency to maximize performance within their waste collection network. In this case, waste does not represent a commodity but the removal represents a public service. Maximizing tax dollar

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input stands to benefit from the most efficient retrieval and removal of residential waste. This data is available via the city’s open data access portals and can be readily analyzed.

Alternatively, the commercial waste collection network can be best modelled via a series of ovals depicting the central tendency of customers served. Below we see the top 20 carters anonymously analyzed and identified in the 2016 Private Carting study. Each oval represents an overall geographic area of the customers served by any hauler’s oval. That is, the theoretical carter based in Brooklyn may serve a customer in both Staten Island and the Bronx, while relying on a transfer facility in the South Bronx. The number of overlaps demonstrated by these ovals highlight the intense likelihood that trucks serving these customers may inevitably cross routes and effectively double vehicle miles travelled in daily

operations. One account of a sanitation driver working in the commercial fleet, taken from Transform Don’t Trash’s Dirty, Wasteful & Unsustainable: The Urgent Need to Reform New York City’s Commercial Waste System, highlights the intense irregularity inherent to this waste service system, "There is no route that makes sense in the entire industry. Where I might have a stop here, I don't have another stop for half-a-mile. And then in that half a mile, you have six other garbage companies. You just keep

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multiplying that all night. The route is not consolidated — it’s spaced out. I do about 70 miles a day.”17 DSNY, with data provided by the Business Integrity Commission (BIC) attempted to model the variation in possible number of vehicle miles travelled. By piecing together, the number and location of customers served, DSNY produced maps detailing the total of Vehicle miles travelled. Below the results demonstrate where concentrations exist along major transportation corridors.18

Private Carting Study, 2016

Outlined as an initiative within the original 2006 Solid Waste Management Plan and identified as an objective again in OneNYC, the Private Carting Study’s existence and framework for reform within the commercial waste system represents a significant opportunity for improvement on a system that weights the immediate economic benefits and competition over environmental externalities. That is, in development from the closure of Freshkills, the commercial waste system grappled within the economic framework of economic efficiency to determine infrastructural siting as well as market competition to determine the geographical layout of its system. With the advent of franchised zones in other major US cities and their cited benefits. NYC’s Private Carting Study was able to make the case

17 P. 12 Transform Don’t Trash “Dirty, Wasteful & Unsustainable: The Urgent Need to Reform New York City’s Commercial Waste System.” 18 Pg 19 Private Carting Routing analysys

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for implementation of a franchised zone within NYC. Furthermore, in modeling the number of vehicle miles travelled within the proposed zones, created the hypothetical framework necessary to generate a forecast of the achievable benefits within this systemic shift. As a symbol of the opportunity to reform this inefficient system, the Private Carting Study’s access to the uniquely inaccessible commercial waste data presents the opportunity to assess benefits of all elements of this system.

Unfortunately, the scope of this study focused only on the distribution of customers in the scenario that each franchised zone received exclusive service from a single carter. These zones are demonstrated below.19 While it was necessary to include transfer stations to define the end of each waste route, it was not proposed as a point of analysis that the transfer stations utilized could be redistributed.

The resulting quantity of vehicle miles travelled generated from this analysis demonstrated benefits perceivable in every single neighborhood in NYC. Specifically citing a 56% reduction in asthma and cancer-inducing PM2.5, 51% reduction in PM10, 59% reduction in toxic carbon monoxide, 62% reduction in Nitrogen oxides, and a 64% reduction greenhouse gas carbon-dioxide equivalencies, the analysis contained within demonstrates the invariable local environmental benefits that could be achievable in this alternative to the current private carting system network. 20 The resulting map, scaled to reveal more clearly the areas still disproportionately impacted by vehicle miles travelled, can be seen below.

19 P. 22 DSNY. “DSNY Private Carting Routing Analysis.” 20 P. 17 DSNY. “DSNY Private Carting Routing Analysis.”

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While vehicle miles travelled can demonstrate an image of the resulting impacts particulate matter contributions, they don’t serve to highlight the health impacts experienced by the populations local to the truck route contributions. Furthermore, the contributions of most heavily travelled routes in this study imply that lower Manhattan remains to the most impacted area in New York City. Though traffic of all kinds is known to be an issue for this neighborhood, shifitng the analysis away from vehicle miles travellled to include other environmnetally impactful infrastructure, or including within this framework the neighborhoods with the highest rates of illnesses associated with environmental conditions produced by these concentrations could further demonstrate a framework from which to anlayze impact.

When comparing the rates of respiratory hospitalizations to the clustering waste transfer stations, the correlation becomes readily apparent. Respectfully, this comparison can not be decisively linked as other environmentally mpactful facilities also populate the neighborhoods with the highest incidinces of respiratory hospitalizations, but the definition of waste transfer stations as a critical source of local respiratory irritants should be recognized within the framework of any study linked to the original goals of the 2006 Solid Waste Management Plan.

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In 2006, the incorporation of community input into the development of a strategy focused on the alleviation of disproportionate community burdens in the face of the upheaval of the waste system represented a landmark case for the development of equity framework within NYC. Specifically, the goals outlined within the 2006 Solid Waste management plan are born from the original guidelines of

7 Guiding Principles of the 2006 Solid Waste Management Plan

Recognize the environmental issues surrounding waste Treat each borough fairly Rely on sound business principles to increase efficiency and reduce cost Be realistic and be able to be implemented quickly Look forward, allowing for future innovation Be reliable Be built collaboratively

Without making assumptions about the applicability of each of these principles and how they are to be referenced in the development of the proposals initiated by this policy framework, the plans produced from the 2006 SWMP include within a specific set for the Commercial Waste Sector. These initiatives, specifically outline goals targeting the inequitable distribution of waste and its corresponding infrastructure. Included:

Redistribute/limit capacity in the communities with the greatest concentration of waste transfer stations.

Implement new siting regulations. Enforce new operational regulations. Perform a traffic analysis to reduce transfer trailer traffic on selected truck

routes.

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Increase and restructure fees associated with transfer station permits, with proceeds to be used for training and enforcement of new regulations.

Issue a procurement to assess the feasibility of providing the West 59th Street MTS for commercial waste and continue to seek new transfer station sites in Manhattan.

Leverage DSNY export contacts for barge and rail export of commercial waste. Conduct a Commercial Food Waste Disposal study.

Contained within the framework of the initiatives proposed and the guiding principles is a staunch outline for highlighting the disproportionate impact of health burdens produced by the inequitable distribution of intensive waste management infrastructure. Despite the overall benefits expounded by the Private Carting Study, perhaps the most significant opportunity to remediate the disproportionate burden of waste infrastructure lies in the siting or usage of the current land-based commercial waste transfer stations.

Currently, conditions within the two neighborhoods most impacted by the waste system demonstrate the inequitable treatment of vulnerable populations. Though all health concerns within these neighborhoods cannot be entirely attributed to clustering of waste facilities, the clustering of other facilities, and the known interrelationships of health conditions associated with byproducts of these industries suggest a strong correlation between the two. With 17 of the 88 community districts housing at least one waste transfer station and the majority of these transfer stations appearing in two community districts, the fundamental distribution of this infrastructure could be argues as unequal. Beyond this the utility of this infrastructure further broadens the divide between those who must tolerate high waste burden and those who enjoy the privilege of avoiding the brunt of one of the smelliest resources in The City.

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Of the 17 neighborhoods that house a commercial land-based solid waste transfer station, only one handles as much as 10,000 tons per day. The next three communities below that handle as much as 5,000 tons per day, and the remaining 13 handle roughly the equivalent of these top 4. These conditions underscore the importance of continuing to pursue the goals set forth in the 2006 SWMP.

These goals were carried forward as a basis for pursuing the implementation of the Private Carting Study. In OneNYC, three initiatives directly address the goals identified within the framework of the Private Carting Study,

Goal 1: New York City will have the best air quality among all large US cities by 2030.

Initiative 4 proposes that reduction in emissions of the city fleet and private truck fleet would prove instrumental in addressing this goal.

Goal 2: “80x50”, New York City’s greenhouse gas emissions will be 80 percent lower by 2050 than in 2005.

Initiative 3 connects to the third goal to reduce greenhouse gas emissions.

Goal 3: “Zero Waste” New York City will send zero waste to landfills by 2030.

Initiative 8 proposes the most far reaching impact opportunity, the goal to reduce commercial waste disposal by 90 percent by 2030.

Effectively reducing the overall input to this system could feasibly produce the greatest benefits to all communities impacted.

Framed within the context of equity, OneNYC carries the original goals of PlaNYC with the self-ascribed addition of addressing inequities throughout The City. Citing these three goals as the most substantive approaches to remediating the waste system’s inequitable burden suggest that the problem’s identified

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in the original 2006 SWMP were not far-reaching enough to capture the greatest opportunity for impact, complete reduction of waste. While this is true, one could make the argument that this discounts the initiatives and transitional framework attainable within the context of the Commercial waste system recommendations of the 2006 SWMP.

In exploring opportunities to distribute the most inequitable distribution of the waste system within NYC’s borough boundaries, deeper inspection of the ties between the residential and commercial waste streams reveal an opportunity to reallocate the role of waste destination management to DSNY. In 2004, DSNY proposed the analysis of a series of Marine Transfer Stations capable of representing the destination facilities for residential waste. These facilities, listed below, collectively exceed the necessary tonnage to accommodate waste from both the collective residential and commercial waste streams. Though not all of these transfer stations ultimately were realized, their eventual implementation could outline the opportunity to fulfill the infrastructural requirements necessary to return DSNY to a role capable of system oversight.

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While New York City remains a unique case in many respects, the overall success of franchised waste systems in other major US cities have proven to be encouragement and inspiration for NYC. In particular, Seattle’s careful implementation of contract based requirements for combined residential and commercial collection within franchised zones, provided the city an opportunity to address the working conditions of sanitation workers and an opportunity to insure delivery of a percentage of waste to city facilities.21 Recording trivial impact to the carters and dramatic increases in efficiency alongside a rate reduction of 8% to customers suggests that similar approaches could be applied through the reapportionment of contracts and zones in the NYC decision making progress.

In conclusion, the framework for analysis of the 2016 Private Carting Study outlines a plan for addressing one of the most inefficient elements of the current Private Carting Industry, while analytically falling short of a significant portion of the waste system. Further analysis of the siting of waste transfer stations, the allotment and requirement to deposit waste in city facilities, and the ultimate implementation of industry-worker safety standards could prove to be significant areas of opportunity for the city to expand on the Private Carting Study to address the original guiding principles set forth in the 2006 Solid Waste Management Plan. Effectively, much of the research and programming currently exists. With Environmental Impact Assessments in completion for bringing online Marine Transfer Stations with capacity to manage the additional waste needs posed by a separated commercial waste stream. The residual impacts felt by a system divided through the unforeseen long-term impacts of market forces could be addressed in this period of transition. Legislation such as Intro. 495, which mandates a cap on the percentage of waste sent to any given neighborhood, could serve as the policy framework for transitioning towards a more equitable waste system, while capitalizing on the market forces that could generate interest from all stakeholders may prove the most effective means for generating an equitable waste system.

21 DSNY. “DSNY Private Carting Marketing and Cost Analysis.”

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