The Manhattan SWAB, and its Waste Prevention Committee which co-authored Intro. 482 by combining environmental procurement provisions with the 1996 Mayoral Directive on Waste Prevention in City Agencies, enthusiastically endorse Intro. 482, its goals, and measures designed to move the City government towards instituting more environmentally sound procurement practices and waste prevention practices in the agencies.

Reasons for that support are outlined below:

1. Waste Prevention is the most cost-effective way of dealing with solid waste, because collection, processing and disposal costs are reduced or avoided altogether, in the first year of investment, and usually well into future years with little continuing investment.
2. Waste Prevention is by far the most environmentally benign way of dealing with solid waste -- preventing its generation in the first place, and avoiding the air and water pollution and congestion associated with collection, transfer, export and disposal options.
3. Waste Prevention, like recycling, can expand economic development, creating jobs and expanding tax revenue in industries that design and manufacture durable, recycled content, recyclable, less toxic and less packaged goods, and in other industries that repair, refurbish, restore, and otherwise extend the useful life of durable goods.
4. Waste Prevention is the management alternative most preferred by the State and Federal governments, environmental organizations and increasingly, business, because of its environmental advantages, and since methods of generating less waste often result in procurement savings over time.

In spite of these inescapable facts, the City has never prioritized investments in waste prevention, preferring to sink hundreds of millions of dollars per year into collecting, processing, disposing, and now exporting millions of tons per year, much of which consists useful resources that could have been retained in the City. The majority of waste management funding (well over $300 million per year) goes for waste collection, which prevention initiatives, such as Intro. 482, would reduce. Another considerable sum (over $150 million per year) is spent on export of the City's waste, which is currently a mixture of recyclables, repairable items, disposable products, food and yard waste, and waste (materials that are currently not recyclable or repairable). This figure has already begun to escalate, and will likely continue to rise after the year 2002 when the City will export 80% of its waste. In stark contrast, the City spends a small fraction of 1% of its Sanitation expense budget ($1-2 million) on waste prevention staff and programs. The City is literally throwing away tons of resources and hundreds or thousands of jobs, and considerable tax revenues.

Intro 482, one of many legislative and programmatic steps the City could take, is an important first step to invest in redirecting the City away from exporting 80% of what it calls "waste", towards improved resource utilization via environmental purchasing of less wasteful products and packaging, and via repair and judicious use of products the City does purchase.

Waste generation starts with the purchase of products and packaging, and of food and tending of lawns and gardens. The NYC waste stream consists of roughly 35% packaging, 30% nondurable products (those designed to last less than three years), 15-20% durable products, 14% food and 3% yard waste.

Reduction in the generation of waste can be accomplished by changes in

• the design and manufacturing of products and packaging,
• purchasing habits of consumers, in this case governmental agencies, and
• the attention given by City agencies to maintaining and extending the useful life of products already purchased

Intro 482 addresses all three areas by changing specifications to encourage purchase of less packaging, purchase of durables in place of disposables, changing office practices to conserve nondurables (e.g., consumable office supplies), and better conservation of durables (e.g., via repair, better warehouse management).

Intro 482 also has a positive effect on recycling economics in NYC. By buying a larger proportion of products and packaging that are recyclable, the City will generate less waste (i.e., unrecyclable materials). By requiring more purchases of products made from recycled materials, the City will serve as a powerful market for recyclable materials that the City collects. By buying a larger proportion of product in bulk, or otherwise using less packaging, the City saves in disposal costs. If the City replaces nondurable products with more durable ones, not only is less waste generated, but there are savings in procurement costs, since the durable products last a long time. If the City chooses to lease durable products, or participate in group purchases, where expensive, infrequently used durable products are shared among offices or agencies, fewer durable products are purchased and fewer are eventually discarded (saving money on both ends of the deal). Likewise, if the City chooses to repair and refurbish rather than discard, waste generation is reduced.

Why is it necessary to have planning and reporting requirements in the bill?

In order for the City to move towards achievement of the goals of this legislation, it is important to require that the agencies delineate plans for developing and implementing specific, new waste prevention practices and procurement changes in an organized way. To assess the degree to which these goals have actually been achieved and the rate at which the agencies have achieved (or not achieved) them, it is important to delineate reporting requirements clearly. Reports can point out areas where there is a need for improvement; plans keep the City on track to bigger and better improvements in the future.

New York City can learn from other government agencies. We need to look no farther than the MTA, which just two days ago announced that it would modify its procurement practices such that 50% of its new bus fleet every year would consist of natural gas-burning vehicles. Such a move will, in time, produce a huge improvement in ambient air quality at ground level where millions of New Yorkers have been forced to breathe toxic organics and metals-laden fine particulate matter emitted from diesel buses. Though Intro 509 of 1995 proposed set-asides (specified purchasing percentages and timelines) such as this for City environmental purchasing, Intro 482 is more conservative in its approach. If a more bold approach is desired, the Council may want to evaluate resurrecting provisions from Intro. 509.

The Federal Government's procurement agency, GSA, has implemented "Planet GSA", a program to buy green, build green, drive green, and save green (see http://www.gsa.gov/planetgsa/). The "buy green" program addresses environmental procurement. As early as March of 1999, all direct delivery and schedule sales were for 30% post-consumer copier paper. The "build green" initiative ensures that new buildings are a model for sustainable development, using recycled content, as well as other conservation measures. King County, (Seattle) Washington also has a large environmental procurement establishment: see http://www.metrokc.gov/procure/green/index.htm for further information about their extensive program.

In addition to legislation to improve environmental procurement and wastes prevention in City agencies, there are a myriad of strategies -- educational programs, information exchanges, other legislative initiatives and economic incentives that can be employed to motivate these changes by designers, manufacturers, and consumers. The MCSWAB hopes that more of these will be actively pursued soon, not only by City agencies, but also addressing the much larger residential waste stream, to reduce the extent to which the City exports, reduce environmental impacts, and save the City money.

Intro 482 has numerous provisions that would eventually change the way agencies purchase, maintain, and consume the products they purchase. The MCSWAB has consulted with the Brooklyn SWAB and concurs with the few brief modifications in definitions and provisions the BkSWAB is recommending to fill gaps and improve the bill. Should the Council wish to make the legislation even more comprehensive, the MCSWAB stands ready to contribute new ideas for additional or stronger provisions.

What makes waste prevention the most economically viable means of dealing with solid waste? Waste prevention programs are best designed around waste audits, or composition studies to determine the quantity of packaging and product types present, and a new waste audit industry has developed over the last several years to help businesses reduce waste. In addition to waste audits, various waste prevention programs aimed at different aspects of the problem (design and purchasing of packaging, disposables, toxics) have likewise been implemented over the last several years.

Waste Prevention projects in New York have shown that significant potential exists for reduction in waste volume and operating costs. The Council on the Environment of New York City (CENYC) has conducted pilot studies in waste prevention in fourteen organizations including City schools, colleges, government agencies, and various businesses. Within a short period, an average of 15% of the waste had been reduced. The CENYC studies have provided effective strategies that are cost-effective for the organizations to implement. Waste volume, disposal labor, and carting costs are reduced. Greater still are the savings the organizations receive in strategic purchasing. The studies funded by the Department of Sanitation (DOS) and the State Department of Economic Development have resulted in significant waste reduction and should be applied to all institutions and government agencies being serviced by DOS. A guidance waste prevention manual for schools, government agencies, and organizations was recently completed by CENYC and INFORM which can be used by these sectors to implement waste reduction practices.

The City’s decision to give waste prevention very low funding priority compared with all other waste management methods does not make sense when one considers the fact that waste prevention will, for a relatively small investment, avoid larger expenditures on collection and disposal costs (and waste export, should that be looming in our future). As tons of waste are prevented, collection trucks, personnel and eventually even garages, as well as processing and disposal facilities, can be stretched farther. Processing, treatment and disposal costs associated with the construction and operation of solid waste management facilities can also be reduced if the City moves aggressively to implement waste prevention.

Furthermore, it is important to bear in mind that waste prevention investments not only avoid collection and disposal costs in the first year in which they are implemented, but the savings extend out into the future, more than making up for the initial investment. For example, once an office installs e-mail capability, the amount of paper used plummets, not only in the first year, but in all succeeding years. The expenditure on equipment occurs once; the savings recur year after year without much further expenditure (except reinforcement education). As another example, if an educational program spurs citizens (or office employees) to start buying items packaged in bulk, carry their own shopping bags, and stop buying so many disposable products, waste is prevented the first year, and this same waste stream will be prevented in all future years without further expenditure as long as the new behavior is maintained.

With an integrated solid waste management system, as recommended in the 1992 NYC Solid Waste Management Plan, each ton of waste produced in 1992 and in all subsequent years, which is collected, processed, treated, and/or disposed has a cost of $200 per ton rising to $300 per ton in twenty years. The estimate of costs for waste prevention programs in the same Plan is quite low by comparison. The City published in 1992 that waste prevention programs would cost about $20 per ton, or one-tenth of the cost of an integrated waste management system. Once programs and legislation are in place and a portion of the waste stream has been prevented, approximately $180 per ton is saved for every ton prevented -- not only in the first year, but in every year thereafter.

The City's own 1992 Solid Waste Management Plan shows that the investment needed to achieve a 9% waste reduction goal was over $3 million in 1992, rising to over $12 million in 1997, the year 9% would have first been achieved had the City actually made these investments. The amount of savings that would have been gained if the City had achieved 9% waste prevention, was roughly $90 million in one year (in 1992 dollars). We need to do more to take advantage of the enormous savings achievable from a comprehensive waste prevention strategy. Thus, with the passage of just a few years, the savings engendered by instituting waste prevention initiatives that achieve 9% prevention, will compound, amounting to a few hundred million in ten years. If waste prevention programs keep generating savings based on front-end investments, the return on investment over the ten-year period could approach $50 for every $1 spent. Even if some waste prevention programs cost more than $20 per ton, and even if the City's export costs, including collection costs, is less than $200 per ton, these data indicate that waste prevention deserves a much higher funding priority than it has received. Well considered investments in waste prevention will pay off handsomely.

The City's current, shrinking waste prevention effort barely scratches the surface of the potential waste prevention initiatives that can produce results. To see how small a figure the City spends on its entire waste prevention effort, consider that even one or two mailings of a single brochure to all residents in the City can nearly equal the annual waste prevention budget. Certainly, based on the Department's own economic argument, this allocation of resources needs to be reexamined, and the potential of waste prevention needs to be fully exploited.

In addition to the obvious fact that waste prevented need not be collected, treated, and is not subject to disposal or export costs, there are further benefits. Savings begin in production (for example, reduced packaging) and continue through the markets to the consumer). New York City government itself is a huge consumer and could save many millions in purchasing as well as through DOS in reduced collection and disposal costs.

Waste prevention also carries with it the possibility of job creation. While some manufacturing and production jobs might be eliminated, service, repair and reconditioning jobs are increased. The Waste Prevention Committee has long advocated the creation of repair / swap facilities in each Community board. Young people trained in vocational schools to recondition small appliances and furniture could eventually result in the increase in small businesses similar to these centers. Left over paint (a disposal problem) could be sold for small jobs to grateful handymen/women, and given away to nonprofits.

Job creation exists for many industries, including repair businesses, rental shops, thrift and other resale stores, cleaning establishments, spare parts manufacturing, and others. The types of jobs created can span the range of skill levels, including jobs in training, management, unskilled labor, and entrepreneur. The Council on the Environment has shown in its pilot projects the enormous savings that waste prevention has provided to the businesses and large institutions it studied. Such savings can be achieved by all businesses, institutions, as well as by City government offices and facilities. The implementation of Intro. 482 would, very quickly, produce enormous savings in purchasing and in collection and disposal costs.

Since one aspect of waste prevention, reuse, depends on businesses that promote product longevity, anything the City can do to encourage reuse will promote development of these industries. It is for these reasons that we argue strongly that investments in waste prevention must be increased. Initiatives in the areas of research, education, programs, measurement, legislation, and reporting, are of the highest priority.

To summarize, businesses that supply durable, reusable, less toxic, less packaged, and/or recycled content products / packaging to the City, derive economic benefit if the City were to favor purchases of environmentally sound products and packaging. These benefits could include more money for the business due to more sales to the City, growth for the business in addition to sales of these goods to the City (and more taxes for the city as a result of the growth in the business). Such growth of such a business would also likely increase jobs in the City (and tax receipts by the City). The increased jobs always have a multiplier effect in the economy, adding to more jobs and tax receipts. Opening up such a large market to purveyors of such goods could also be a stimulus for new businesses to start up (more jobs / more tax revenue).

Why was waste prevention (sometimes called source reduction and reuse) placed at the top of the EPA and many states' solid waste management priority lists in the late 1980s? Waste prevention is at the top of the NYSDEC and USEPA waste management hierarchy because it results in the avoidance of the most environmental impacts. When procurement or shopping practices are changed to minimize the purchase of overly packaged products, disposable and nondurable products, products containing potentially toxic by-products, and maximize purchase of products with maximum recycled content, the benefits to the environment are diverse and considerable. By the same token, instituting practices to maintain and extend the useful life of products reduces the rate at which such products are produced and disposed, thereby producing the same kinds of benefits as changes in procurement. For example, purchase of a few durable goods can replace the purchase of hundreds or even thousands of disposables. New York City generates roughly 400 tons of disposable diapers on a daily basis. Since cloth diapers can be reused 50 to 60 times on average, the waste prevention achievable by encouraging diaper services is clear. When fewer disposables are manufactured, fewer natural resources are logged, mined and otherwise extracted, and are thereby conserved for the future. Also, the environmental impacts to air, water and land associated with extraction activities are avoided. Additionally, transportation of resources, and processes to refine and manufacture the nondurable products are reduced or avoided, along with the environmental impacts from these processes.

Reducing consumption of nondurables and excess packaging reduces the need for collection of these nondurable products and packaging for processing or disposal. As a result, waste prevention reduces air pollution from collection vehicles as well as traffic congestion and the associated asthma impacts. Finally, reducing waste generation reduces or avoids the impacts to New York City's air, water, land and living things resulting from processing and disposal (i.e., recycling, landfilling and export). Thus, maximizing waste prevention will have the greatest positive effect on the environment of New York City with some spillover benefits to other localities.