In spite of these inescapable facts, the Sanitation Department has never prioritized waste prevention, preferring to spend hundreds of millions of dollars per year on collecting, processing and disposing of waste. The majority of waste management funding (well over $300 million) goes for waste collection, which prevention initiatives would reduce. Another considerable sum (over $50 million) is spent on disposal at Fresh Kills, and this figure is certain to escalate quickly and dramatically in the year 2002 if the City chooses to export most of its waste. In stark contrast, DOS spends a small fraction of 1% of its expense budget (less than $1 million) on waste prevention staff and programs.

In this alternative NYC Waste Management Plan, we show how the City's decision to put waste prevention at the bottom of its priority list actually costs the City more money, squanders precious physical resources, causes greater environmental impacts, and results in the exportation of jobs from New York City. We also provide detailed recommendations, a roadmap, for what the City can do to reap the economic and environmental benefits to be gained by preventing waste.

Waste generation starts with the purchase of products and packaging, and of food, and with the tending of lawns and gardens. The U.S. waste stream consists of roughly 30% packaging, 30% nondurable products (those designed to last less than three years), 15% durable products, 8% food and 18% yard waste. New York City's waste stream varies somewhat from this: as of 1990, New York City's food waste was 13% and yard waste 3% of the total.

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

• the design and manufacturing of products and packaging,
• purchasing habits of consumers, be they individuals, companies or governmental entities, and
• the attention given by consumers to maintaining and extending the useful life of products already purchased

If less packaging is purchased, either because manufacturers find ways to package products using less material or because consumers choose products with less packaging (e.g., buying in bulk, or avoiding single-serving packaging), then there is less waste. If consumers choose to rent, borrow or participate in group purchases, fewer durable products are eventually disposed. Likewise, if more product owners choose to repair and refurbish rather than discard, waste generation is reduced. There are a myriad of strategies -- educational programs, information exchanges, legislative initiatives and economic incentives which can be employed to motivate these changes by designers, manufacturers, consumers and product owners.

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, and products containing potentially toxic by-products, 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. 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. Finally, reducing waste collected reduces or avoids the impacts to New York City's air, water, land and living things of 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 and elsewhere.

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, waste prevention programs of various design and 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. The projects are not fully implemented as yet, but an average of 15% of the waste has already 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 is currently being written by CENYC and INFORM which can be used by these sectors to implement waste reduction practices. The appendices show how these and other waste prevention programs in businesses and institutions have resulted in savings both in procurement and in disposal.

The City’s decision to give waste prevention very low funding priority compared with all other waste management methods is not logical 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, 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. As another example, if an educational program spurs citizens 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. Thus, with the passage of just a few years, the savings engendered by instituting waste prevention initiatives which achieve 9% prevention, will compound, amounting to $100 million in ten years (this according to calculations made by the Department in the 1992 Plan). The return on investment over the ten-year period could approach $100 for every $1 spent. Even if some waste prevention programs cost more than $20 per ton, and in the unlikely event that the City is able to structure a long-term management system involving export which, including collection costs, is less than $200 per ton, these data demonstrate 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 own Plan shows that the investment needed to achieve the 9% waste reduction goal is over $3 million in 1992, rising to over $12 million in 1997, the year 9% is first achieved. The amount of savings to be gained if 9% of the waste stream did not have to be collected, much less disposed, is certainly considerably larger than this figure, no matter what kind of collection, processing and disposal is involved. We need to do more to take advantage of the enormous savings achievable from a comprehensive waste prevention strategy.

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 (less than $1 million per year), consider that even one or two mailings of a single brochure to all residents in the City can 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 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.

Contrary to some frivolous criticism, 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. We have long promoted (with the support of DOS) 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. 509 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. These recommended initiatives are described below, and are supported by appendices.

Overall, it appears, and DOS has indicated to us, that waste prevention initiatives directed towards reducing the residential waste stream, have received a distinctly lower priority for funding than have initiatives to be used in the commercial and institutional sectors. The stated basis for this has been cost of implementation. But the cost of waste prevention initiatives is dwarfed by the cost of other solid waste management methods. And in Chapter 17.2 of the 1992 Plan, the City described in great detail how there are millions of dollars in net savings to be gained by implementing an aggressive waste prevention program: "Based on calculations obtained by modeling the City’s proposed waste-management system with and without these prevention programs in place, the "avoided costs" to the City’s waste-management system due to these reductions are estimated to be in the range of $87 to $92 million in the year 2000, or $700 to $800 million cumulatively between 1992 and 2010 (in 1992 net present value terms)."

As a further indication of the cost-effectiveness of waste prevention programs, DOS states in a number of places (Waste Prevention appendix, Chapter 17 of the Plan, and the Final Revisions to the Plan -- October 28, 1992), that the estimated cost of a prevention program is $20 per ton. The per ton costs of the integrated waste management program, which each ton of prevention would avoid, is estimated to be roughly $200 per ton for systems including and not including incinerators (see Table at 17.3.1). It is easy to figure out that the net savings to the City are many times the expenditure for waste prevention programs. So waste prevention, is by far, a more cost-effective method of dealing with solid waste than any other waste management technology, alone or in an integrated system. It is also far more environmentally benign than other technologies, each of which have collection and processing impacts, and two of which have disposal impacts. Waste Prevention’s environmental benefits of not producing products and packaging are in addition to and far outweigh the environmental benefits of reduced collection, processing and disposal.

1997 and annually thereafter Account for funds spent on each waste prevention implementation program, educational program, and research project, and tonnages and volumes avoided by sector.

The success of an education program lies not only in the crafting of intelligent, motivating educational instruments, but also in their proper distribution. The programs need to be targeted at a variety of individuals (those receptive as well as those who are hostile to the idea of waste prevention; those who are new to the country, as well as Americans), and in a variety of ways (those who commute to work, those who shop, etc...). Waste prevention should be directed at householders as well as schoolchildren.

Waste prevention not only is cheaper and more environmentally benign than waste management, but it also has the potential to create jobs in industries currently in decline, and to create new industrial sectors. Once it was a common practice for shoppers to frequent thrift shops, and to bring in durable products for repair. Nowadays, it is more usual for durables to be thrown away rather than repaired or resold. Rentals are more and more difficult to find. Libraries, which permit residents to borrow rather than buy books, records and videos, receive less and less funding. Even the skills required to repair, refurbish, and maintain durable goods are being lost. We need to reverse these trends and implement measures to teach students the skills of waste prevention, to encourage businesses to adopt waste prevention measures on a wide scale, and to promote the development of industries which specifically aid residents in reducing waste (businesses which repair, refurbish, reuse, and rent durable products).

Products and packaging are manufactured using toxic, flammable, corrosive, and/or reactive ingredients. As long as this is the case, there will be waste with these properties. Though every effort should be made to reduce generation of HHW, it should be of some interest that US EPA has signed a Universal Waste Rule that streamlines regulations for the generation, transport, treatment, storage and disposal of certain wastes (e.g. batteries, mercury-containing thermostats, and pesticides). By granting a conditional exemption from some RCRA Subtitle C requirements, the rule should encourage state and local governments and manufacturers to establish collection and recycling programs, and retailers to participate in them. (Household Hazardous Waste Management News, Vol VI, #25).

In the 1992 SWMP at 7-4, DOS describes how QBUF systems operating throughout the US have produced waste reduction rates of 18 to 29 percent. Prior to the SWMP in 1992 it was well known that residential QBUFs were in existence in towns and cities across the country, and DOS’ consultants included information about the great success of QBUF in the Plan and the Waste Prevention appendix. In 1994 EPA released a major study indicating that thousands of municipalities in the US have increased waste prevention and recycling rates by 25-45% as a result of QBUF programs. Since a reduction of this magnitude in the waste collection, processing, and disposal, would save the City untold hundreds of millions of dollars, and over long periods of time into the future, QBUFs were considered to be one of the most important waste prevention initiatives in the Plan. In the SWMP at p. 20-5, DOS states, "The expansion of the use of QBUF is one of the central recommendations of the waste prevention program". The Waste Prevention appendix also includes QBUFs as an often-repeated requirement of achieving waste prevention for almost every material generated. In fact, the very first recommendation of the Waste Prevention appendix (all 12 of which are characterized as "the most effective waste prevention strategies") is: "Establish Charges for Waste Services Based on the Amount of Waste Generated".

To address implementation of QBUFs, in the 1992 SWMP a feasibility study involving pilot-scale field testing and data gathering on how waste quantities and compositions are affected by residential QBUFs, is discussed repeatedly as being an important component of its waste prevention efforts (see pp. 7-4, 7-7, 16-5, 19-5, 19-8, 19-23). This explains why DOS committed in the Plan to undertaking pilot-scale field testing here in NYC; we needed to test, and possibly invent, many alternative methods and components of strategies for undertaking QBUFs in a densely populated urban area.

The 1992 SWMP at p. 7-7 describes how the City should "develop and implement a charge system" for institutions as a method of achieving waste prevention. The SWMP’s Waste Prevention appendix (pp. 82-88) delineates in nearly every category of material the percentage of reductions which would result from implementation of QBUFs in institutions. But then in the Compliance Report, DOS has found institutional QBUFs to be unfeasible and has taken credit for implementing the milestone.

In order to implement certain waste prevention programs and economic incentives, and to design effective waste prevention educational initiatives and legislation, DOS must pursue carefully designed research studies.

DOS states (page 2-9 of the Update) that there is no way to measure the impacts of waste prevention (i.e., volume and weight reduction, costs, and cost savings), when DOS has helped finance a number of studies which have already been completed by the Council on the Environment, which document actual cost savings and volume of waste prevented as a result of businesses and institutions having implemented well over 100 specific strategies. Since City agencies can also implement these strategies, these data from institutions and businesses could have been used and extrapolated to estimate at least some of the positive impacts in the commercial and institutional sectors caused by waste prevention programs DOS has implemented to date. These data can also be valuable in projecting the positive impacts of instituting these strategies in the commercial, institutional and City agency sectors in future years.

In the 1992 SWMP at p 20-1, DOS states: "Procedures will be designed and implemented to develop and/or monitor the following types of data": "Waste Generation and composition. New studies to update the existing one will be required on a regular basis." "There are several objectives which future waste generation and composition studies should serve. They can document waste-prevention impacts.... They can help to design more effective prevention programs if product categories, as opposed to material categories only, are tracked....The City can conduct future waste-generation studies using the same subsector residential, institutional, and commercial categories that were used in the 1990 study... In future composition studies, particular attention should be directed at the identification of product categories that can be used in designing, implementing, and monitoring waste-prevention programs."

Certainly every five years the waste can be expected to change significantly enough to affect the success of proposed waste prevention programs. And a study less comprehensive than the materials (or recyclables) -oriented one conducted in 1990, which included not only generation sector, but also housing type, and population density, cannot be expected to show accurately the generation of products and packaging in the waste stream. DOS is now conducting a limited waste characterization study.

1. Based on 2003 study, target product and packaging types for special waste prevention legislative initiatives, educational programs, and economic incentives. Repeat every five years.

DOS has chosen to begin a voluntary program with the Mail Preference Service, to provide (upon request) postcards for people to send to MPS to ask that they be removed from unwanted mailing lists. But the Plan indicated DOS was committed to undertake a mandatory program.

While DOS reviewed the German "green dot" system and decided it was good, they rejected it because of our variation in packaging and labeling requirements state to state. But certainly, the variability of packaging and labeling requirements across the country was known before DOS undertook this evaluation.

Since its inception, the City’s waste prevention programs have been directed primarily at commercial waste prevention. We believe that since businesses have a sufficiently large, built-in economic incentive to benefit from self-imposed procurement and usage practices to promote waste prevention of the commercial waste stream (i.e., Commercial QBUFs), without the City spending its meager waste prevention budget on the commercial sector. Furthermore, the administration of commercial QBUFS falls within the purview of the Dept. Of Consumer Affairs. DOS needs to show a far greater commitment to residential and institutional waste prevention measures, as these are the sectors which do not already have the QBUF incentive to reduce waste generation. Therefore, DOS should reduce the amount of its staff resources devoted to commercial waste prevention, and make the time it does spend in this sector result in greater beneficial impacts on the purchasing and usage behaviors of New York City residential households.

To increase its impact on the waste streams resulting from businesses, DOS should change the nature of its programs away from being purely voluntary, and more towards mandatory requirements. For example, the Waste Prevention Partnership, described below, requests businesses to make commitments to start programs or procedures to reduce waste, but does not enforce them in any way. Instead of just asking for an open-ended commitment from dry cleaners to take back hangers and offer reusable bags, DOS should require that dry cleaners participating in the Partnership provide DOS and the SWABs with annual reports of efforts made and monies spent on the program, as well as tonnages of hangers, bags, etc... given out, received, and disposed each month.

Another way for DOS, and the City as a whole, to increase the measures businesses can take to reduce waste generated in the residential sector, is via legislation. For example, a local statute requiring that all supermarkets (or retailers) either charge a fee for shopping bags or provide a rebate to those bringing their own, and to advertise which option they employ on a sign on the front window, and at each cash register, would eventually significantly reduce the quantity of plastic and paper bags appearing in the residential waste stream. Legislative initiatives are described below.

DOS reports working with groups representing thousands of businesses. There is very little hard quantification of waste prevented by the effort. The requirement of membership in the Partnership includes reporting waste prevention amounts as they relate to the program.

We have noticed no change in the behavior of local businesses in the partnership. For example, it is still common practice in many Manhattan neighborhoods for Chinese restaurants to blitz large areas with take-out menus frequently. Beyond that, when they deliver to a caller's home, they include napkins, utensils and double bagging. Neighborhood dry cleaners do not appear to be promoting hanger returns in many neighborhoods.

It is an accepted concept that even a small financial investment promotes a "membership" to a greater level of commitment. But, we have seen no evidence that all of the individual stores are aware of, much less consent to carry out, the commitments made by the parent associations which are members of the Partnership.

1. Produce and distribute to the public, on an annual basis, a report describing the waste addressed and prevented by each Partner, as well as costs and costs avoided.

On page 7-7 of the 1992 SWMP DOS laid out a blueprint for how the City would institute commercial QBUFs, working with the Consumer Affairs Department, thereby making private carting fees to commercial generators more volume sensitive. But instead, DOS takes credit in the Compliance Report for having satisfied this milestone by saying that private hauler tip fees were increased at Fresh Kills.

On p 16-3 of the 1992 SWMP DOS states that the City’s near-term MSW waste-prevention activities will focus on implementing backyard composting program for all low-density neighborhoods, and on promulgating regulations that prohibit the collection of grass clippings and their disposal at City facilities, and a large number of additional programs, policies, and regulations. On p. 19-7 of the SWMP, DOS pledges to pursue the following legislative initiatives: (1) mandating signs in certain retail stores discouraging use of bags, (2) providing economic incentives to businesses that produce and consumers who acquire products that prevent waste, and (3) requiring companies that send direct mail to include means by which addressees can remove their names from lists. ONLY IF progress towards adoption of these measures were insufficient, did DOS pledge to work with other cities in a coalition to develop model legislation. But, according to DOS accounts, this coalition has not produced viable results, since consensus on nothing but weak measures has been attained.

Advance Disposal Fees were considered in 1992 by DOS and its consultants as one of the most important strategies for reducing waste generation, as evidenced by frequent mentions in the Plan and the appendix. But ADF’s are not brought up in the 1995 update reports.

On page 19-6 of the SWMP, among the specific components of the Plan that DOS has committed to undertake, we read--"Issue a Mayoral Directive mandating office waste prevention in city agencies and designating of a waste prevention coordinator in each administrative unit. The directive will address procurement practices and office procedures, such as two-sided copying..." In the Mayoral Directive on Waste Prevention, agencies are asked to provide data on waste prevented. These data can also be used to quantify the impact of this Directive on agency waste prevention efforts. Since all agencies did not respond equally well to this Directive, the data can also be used to estimate the potential waste prevention were all agencies to respond as well as the best agency, and therefore, the room for improvement.

Long-range thorough proposals for waste prevention policies, legislation, and programs have been developed by the Manhattan Solid Waste Advisory Board as well as by the DOS itself as early as 1991. However, relatively low public awareness about waste prevention exists, and (therefore) pressure on public officials and agencies to implement these programs and policies has been lacking. A "culture" of waste prevention needs to be promoted and committed to before significant programmatic initiatives are put into place. The City should develop a higher profile means of communicating the waste prevention information using a variety of approaches and targeted to the range of audiences which need to hear the messages.

{We need some more objectives (bullets) here -- e.g. get a commitment from the Mayor to use his office for WP blitzing} -- "Mayor’s Daily waste prevention moment", contests to design these "moments".

{Also, waste prevention proposals need to be presented in a way to highlight the economic benefit to the city} -- use of new terminology (Precycling), or campaign themes (Put Your Garbage Can on a Diet), and pitched by better spokesmen (Yankees, Bette Midler, etc...)

In 1988 the state Solid Waste Management Act required municipalities to institute plans to achieve 8-10% waste prevention by 1997. In its original Solid Waste Management Plan DOS committed to achieving a goal of 9% by 1997, and related the waste prevention initiatives to this 9% prevention rate. However, since then, DOS has not seriously followed up on any of the major initiatives in its plan to achieve this goal, and has not attempted to measure the prevention achieved by programs it has implemented. The foregoing pages list a number of educational, research, programmatic, and legislative measures that will assist DOS in achieving and going beyond its modest 9% waste prevention goal.

1. Achieve 20% waste prevention in each sector.

With Fresh Kills fast filling up and set to close, we fail to understand the lack of urgency not only to complete all the waste prevention requirements in the Solid Waste Management Plan on time, but also to commit to a full-scale program to develop and pursue research, education, pilots, economic incentives and disincentives, legislative requirements, and monitoring on many fronts, over and above the quite limited and tentative Plan requirements. Unless the City wakes up to the windfall of environmental and economic benefits to be gained by reducing the waste stream, waste prevention may never realize its full potential as a waste management solution, and the City will not only have missed out on huge savings, but will have polluted its environment and that of other regions as well. Establishing waste prevention at the top of DOS's priorities is of utmost importance. Investment, starting now, in pilots and programs designed to maximize waste prevention is the most effective means of reducing both the economic costs and the environmental impacts of waste management for New York City.

Plan Milestones -- Year-by-Year List of Recommended Waste Prevention Initiatives and Goals to be implemented over the next several years (done)

Waste Prevention proposals contained in the 1992 SWM Plan Appendix (which were never carried out by DOS) (not done)

Economic Assessment of Waste Prevention --

CENYC summary reports, 1995, 1996. (done)

LICBDC INWRAP Program achievements (done)

Letter to Council Finance Committee (done)

Proposed Legislation

Intro. 509 -- Environmental Procurement by City Government (done)

Intro. 509 Background document (done)

Quantity-Based User Fees (QBUFs) (partially)

Labeling (done)

EDF's Waste Prevention Fund (done)

Advance Disposal Fees (ADFs) (partially)

Educational Programs

Print media (partially)

Electronic media (partially)

Public Schools (not done)

Institutions (done - FY97 testimony)

District Waste Prevention & Education Centers (done)

Backyard Composting Programs (not done)