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Let’s Really Transform NYC’s Private Waste System


After more than two years of pandemic-related delays, New York City is finally poised to reform the largest commercial waste system in the country.  

But the truly transformative potential of this step will depend on the details of the 10-year contracts negotiated by the City Department of Sanitation (DSNY) and the waste industry after companies' responses to an extensive request for proposals are submitted on July 15th. This is an historic opportunity to both decrease waste, air pollution, and our carbon footprint and increase safety on our streets, justice for workers, and equity for overburdened communities. 

First, some background. Local Law 199, the city’s Commercial Waste Zones (CWZ) Law was enacted in 2019 after years of advocacy by Transform Don't Trash NYC - a coalition that brought frontline workers, environmental justice communities, safe streets advocates, and climate activists together. Our goal: more efficient, sustainable, and equitable practices in collecting and recycling more than three million tons per year of commercial waste generated by New York City's massive business sector. 

For the first time, the dozens of private waste hauling companies now traversing city streets as they collect waste from about 100,000 businesses citywide will be organized into a rational collection system based on 20 geographic zones. As conditions for operating in their assigned zone(s) they will need to meet a series of long-overdue safety, customer service, and environmental standards.   
Because the current commercial waste system is so grossly inefficient and nontransparent, we expect the CWZ system to make some rapid improvements as it kicks in over the next two years. For example, zoned collection is expected to eliminate up to 18 million unnecessary diesel truck miles from our streets – the equivalent of driving a garbage truck to the moon and back 37 times – simply by enabling haulers to operate shorter, more efficient collection routes.  

Transparency and data collection in the private waste industry will also improve, as licensed haulers will for the first time be accountable to enforceable, long-term contracts with the City. We anticipate that safety standards in the industry will also improve as companies that have failed to make basic improvements (such as installing side guards and safety cameras on trucks) exit the market, and collection zones are awarded to more responsible actors. 

However, Mayor Eric Adams and his administration will need to use this opportunity push for more fundamental changes in the sprawling commercial waste system if they are serious about addressing a spiraling climate crisis and longstanding community demands for environmental justice and equity.   

To realize the full promise of Local Law 199, the City should: 
Use incentives, service improvements, and data to reduce landfilling and incineration of commercial waste as rapidly as possible. 

Overall, our city has moved backward on waste reduction and recycling goals since the start of the pandemic. Residential composting programs have been halted and frozen, recycling rates have declined, and enforcement of a major new rule requiring food-related businesses to enroll in composting services has been delayed until late July. 
In the commercial sector, it's difficult to measure the scope of the waste disposal problem, as data from private waste facilities is sparse and relies heavily on self-reporting by the industry [footnote on DEC and expected CWZ gains. However, zero waste activists have consistently documented that large amounts of edible food and usable items are being disposed in black bags and dumpsters by retail and food businesses.  

Changing this behavior and implementing good reuse and recycling systems is low-hanging fruit for cutting emissions. We estimate that New York City could avoid a whopping two million tons of greenhouse gas emissions annually by bringing commercial recycling and composting rates up to those in Seattle, which has a robust and efficient collection and recycling system. 

To enable these gains, the price schedules to be negotiated in the CWZ contracts need to create strong incentives for businesses to reduce waste, donate usable and edible products, compost, and recycle to the maximum extent possible. To implement successful waste reduction and recycling programs, businesses will require new levels of customer and staff education, logistical support, and access to convenient food rescue and recycling services.   

In addition to traditional, truck-based hauling services, the CWZ program also should ensure that businesses across the city have access to a full array of expert waste auditors, local  "micro-hauler" composting services, and food rescue services, and that businesses are fully supported and encouraged in adopting innovative approaches to waste reduction. 
And make implementation of the CWZ system a way to improve air quality, safety, and equity for historically overburdened communities.   

Commercial waste hauling and processing facilities continue to create grossly unequal burdens for communities where transfer stations, recycling facilities, and diesel truck yards are clustered. DSNY's most recent report on waste equity shows that over two-thirds of the city's commercial waste stream travels through the South Bronx and North Brooklyn. 

The forthcoming CWZ contracts should create opportunities and strong incentives for haulers to instead utilize the City's existing marine transfer stations and barge-based recycling facilities as much as possible, to further reduce diesel truck miles and the huge volume of waste traveling through environmental justice communities. 

The upcoming CWZ contracts should also include enforceable provisions to begin a transition to zero-emissions garbage trucks at a pace and scale that will accelerate domestic production of these vehicles and achieve zero-emission by 2035, in sync with overall City and State goals. 
Finally, CWZ contracts can leverage investments in cleaner and safer waste processing facilities to reduce air pollution, noise, hazards, and odors for adjacent communities and for workers, and ensure that hiring and workforce development opportunities are first targeted to local disadvantaged communities that have borne the brunt of pollution from solid waste and other fossil fuel infrastructure.   

 In the coming months, City Hall, DSNY, and the Business Integrity Commission (BIC) overseeing private waste haulers need to speak with one strong voice to achieve much higher standards and major investments in waste reduction, green infrastructure, and equity. Now is the time to fully realize the transformational vision behind Commercial Waste Zones.


Justin Wood is the director of policy at New York Lawyers for the Public Interest, a founding member of the Transform Don’t Trash NYC coalition.  

Photo courtesy of: Transform Don’t Trash NYC