Manhattan Citizens' Solid Waste Advisory Board

Waste Prevention Committee

Marjorie J. Clarke, Chair

The Waste Prevention Committee emphasizes, once again, that waste prevention should be the TOP priority as regards solid waste management. Unfortunately, despite the addition of a few lower-level staff and the issuance of an RFP this past year, waste prevention remains as the LOWEST priority as a waste management approach, by any measure, both at the Sanitation Department and at Department of General Services. In fact, DOS is spending only a fraction on waste prevention of what it stated, in the most recent revisions to the Solid Waste Management Plan, it would have to spend to meet the 9% goal by 1997.

Not only is waste prevention at the top of the NYSDEC and USEPA waste management hierarchy because it results in the avoidance of the most environmental impacts, but it also is, by far, the most inexpensive means of dealing with solid waste. With Fresh Kills fast filling up, 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 does awaken 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 have needlessly missed out on huge savings, and polluted its environment, and that of other regions.

Much money can be saved and certain Sanitation functions can be performed better, and in a more cost-effective manner if more attention is focussed on vigorous monitoring and oversight of DOS programs. Investment, now, in pilots and programs designed to maximize waste prevention has been demonstrated by DOS' own figures (Solid Waste Management Plan) to be the most effective means of reducing both the economic costs and the environmental impacts of waste management. This is because, according to the Final Revisions to the Solid Waste Management Plan, presented by DOS to NYSDEC at their request on October 28, 1992, (after the City Council's final review) the total costs for prevention programs for 1995 are $19.16 (say $20) to prevent a ton of waste from entering the DOS management system. But according to the same report, for 1995 the cost to collect, process, and/or dispose of a ton of waste in DOS' integrated management system is $202.65 (say $200). This means that every dollar spent this year to prevent waste will avoid the expenditure of ten dollars next year and every year after that! In fact, if DOS' waste prevention programs are effective in the long term (and we need studies to confirm this), then every $20 spent this year to prevent a ton of waste will result in $200 less next year and in all subsequent years. The Final Revisions to the Solid Waste Management Plan show costs for Waste Prevention programs staying below $20 until 2003, while the total collection and facility costs for non-waste prevention programs rise steadily to over $300 by 2009. In the next ten years the savings due to waste prevention would mount considerably, to as much as $100 million in the year 8% waste prevention is achieved, and the return on investment could approach $100 for every $1 spent.

Despite the huge savings in avoided collection and facility costs successful waste prevention programs could produce, the DOS indicates that it will spend only $1.5 million for waste prevention in each of the next four years vs. 30 to 40 times that amount for recycling and each of the other waste management alternatives. Spending $1.5 million per year barely scratches the surface of the potential waste prevention initiatives; even one or two mailings of brochures to all residents in the City could eat up most of this figure. Certainly, based on the economic argument presented, this allocation of resources needs to be reexamined, and the potential of waste prevention needs to be taken to greatest advantage. Even if the Sanitation Department's estimate of $20 per ton as the cost of waste prevention were overly optimistic, and even if the real cost of waste prevention were as much as five times that much, these cost savings of $100 per ton would mount to over $3.5 million in savings for each percent of the residential waste stream not generated each year.

Maximizing waste prevention will also have the greatest positive effect on the environment of New York City and elsewhere. By reducing the collection of unnecessary nondurable products and packaging, air pollution and traffic congestion is lessened. By reducing the need to recycle (i.e., process and remanufacture) new products from disposable products and packaging, and by reducing unnecessary incineration and landfilling of ash and raw garbage, the City avoids considerable air and water pollution. By reducing our waste generation rate, we also reduce the production of unnecessary packaging and nondurable products, thus preventing some of the depletion of natural resources and the impacts which resource extraction and the manufacturing of such goods and packaging would engender in other localities. And, very importantly, the implementation of waste prevention on a large scale in New York City should result in the reinvigoration of many industries (e.g. repair, rental, resale, reconditioning, and product cleaning/maintenance) benefitting countless local, small businesses.

Since Waste Prevention is at the top of the hierarchy, the Administration and the Council should aim to fund this as a top priority item in the overall DOS budget. A mere $1.5 million is not a serious commitment, when viewed in light of the tens of millions given to each of the other management components (collection, processing, marketing, incineration, and landfilling). It is also important to note that the portion of the City's Solid Waste Management Plan which describes how much tonnage prevention programs will prevent over the 20-year period which the plan covers, states that the costs for the waste prevention programs were to escalate (along with tonnage prevented) from over $3 million in 1992 to over $12 million in 1997, when the 9% waste prevention target is first achieved. Thus, it is clear that DOS is ignoring its own planning figures, and might be jeopardizing its ability to meet its 9% waste prevention goal stated in the Plan. Over the next couple of years the City must accelerate rapidly its funding commitment to reflect the multitude of programs, pilots, research, educational, and grant programs, which have already been identified by the InterSWAB Waste Prevention Committee and DOS' own Solid Waste Management Plan consultants as being beneficial investments in waste prevention. Though the efforts made, thus far, by the fledgling waste prevention group at DOS have been largely in the right direction, the unit is woefully understaffed to develop, conduct, and oversee the broad range of studies, pilots, programs and initiatives that it must in order to achieve significant waste prevention, much less implement these in a city the size of New York. In the following sections our specific recommendations for waste prevention programs and initiatives are described in more detail.

Both Toronto and Philadelphia (and New York, to a limited extent) have provided funding for community and nonprofit organizations to perform various functions to promote recycling and prevention of certain components of the waste stream. Philadelphia pays groups $25 per ton to serve as repositories for recyclables. This benefits not only the City of Philadelphia, because their collection costs are reduced, but also the community group. Toronto's program has worked with many groups on projects ranging from waste prevention and recycling pilot studies and surveys to educational projects. This concept can and should be applied here. Groups which can demonstrate waste prevention (e.g., by providing resale or swap outlets, waste exchanges -- electronic or otherwise, facilities for or vocational training to increase repair of difficult-to-repair items, rental opportunities for rarely-used items) and document tonnage prevented, could be rewarded and remunerated. This concept can also be applied to reducing waste toxicity (e.g. separation of household hazardous waste). The rate of remuneration to the group by the City could be higher per ton for toxics prevention to reflect the avoided costs of health and environmental impacts caused by toxics disposal, and for pollution controls and cleanup. The DOS should be actively searching for ways that their staff can be inexpensively augmented by community and nonprofit groups, who have expertise and knowledge of neighborhoods which DOS staff lack.

Educating the public about how they can implement waste prevention measures in their purchases, in their homes, and businesses has barely been addressed, thus far, by the DOS. A guide for residents was prepared, but was not distributed to everyone in the City, and a guide for business has not yet been completed. The subway campaign has been uneven, at best, in some cases resulting in difficult-to-read ads with too much information, or non-specific messages on fuzzy backgrounds in other cases.

There is a great need for a number of neighborhood centers to provide the opportunity for residents and businesses to receive knowledge about the range of practical ways to reduce and reuse their waste generation, as well as the facility to swap reusable items. At such centers, which would optimally be storefronts centrally located in each of the 59 community board districts, the DOS could have all their literature available for distribution, a person trained to answer questions, displays depicting the lifecycle impacts of disposable products and packaging, and environmental shopping education, and lists of waste prevention businesses in the district (e.g., rental shops, repair shops, thrift shops, cleaners, refurbishers, sellers of reconditioned items, etc....). Such centers could house a program to ensure that used clothing, which does not enter the thrift market or swap meets, which community groups could organize periodically, is otherwise reused or resold, or given away to recipients of public assistance and nonprofit organizations. The centers could also be repositories for household hazardous wastes and recyclable items not currently collected curbside in the district. In serving as collection repositories, the centers could function as buy-back locations. The centers could either be run and funded entirely by DOS, or DOS could provide seed money to community or nonprofit groups to get such centers started, and then offer dollars/ton for documented waste prevention and recycling, and dollars/customer educated (documented by visitor logs). Having permanent, well-known, established locations for all these functions could only help DOS to foster waste prevention, as well as management of household hazardous waste and other recyclables.

Such reuse centers could be phased in over the next couple of years, first by establishing pilot facilities, evaluating their success, making modifications, and finally replicating the successful result citywide. It is clear, though, that the campaign to advertise the existence of and opportunities offered by these reuse centers would have to be thorough and long-term, in order to realize maximum effectiveness.

A Waste Prevention Loan Program is needed to promote and enhance waste prevention and reuse in the private and institutional sectors. Such loans could be used, for example, to assist institutions and businesses in acquiring equipment which would result in a lower quantity of waste generated (e.g., dishwashers, double-sided copiers, etc...) and to develop replicable methods of redesigning and/or auditing businesses. Other worthwhile projects would include assistance to schools and companies to encourage design of environmentally-sound packaging and products. This program would feature no- or low-interest loans to help especially small businesses afford capital expenses required to implement waste prevention measures. Funding for the first year of the program would eventually be recycled to benefit more businesses, and hence future costs of the program should decline over time.

Funding is requested to permit DOS to establish a Business Resource Exchange and Computer Bulletin Board to foster the exchange or sale of reusable or repairable goods by small businesses and nonprofits. Under this program DOS would also establish and maintain an extensive database of repair, reuse, rental, and resale facilities in the private sector, to be used by individuals or businesses. This database shall be continually updated and available for free. It will provide the background information necessary to develop initiatives to foster this sector.

As is discussed in Chapter 20 of the Solid Waste Management Plan, funding is needed to permit DOS to commence a products/packaging and toxics-oriented solid waste generation and composition study. Such a study would identify, characterize and quantify who generates which products and packaging items, and the many categories and subcategories of products and packaging items that may become the subject of waste prevention initiatives. The purpose of the study would be to optimize the design of such initiatives. (The City's materials-based waste composition study, conducted in 1989, is only suitable for designing recycling and composting programs; waste prevention programs and initiatives are based on products, not materials). Also, since the waste stream changes over time, especially as the City's recycling and composting programs evolve, this type of study should be repeated every three years.

Funding is requested to permit DOS to conduct an annual survey of the viability of the various sectors of the waste prevention industry. The results of these surveys would detail problems, needs, DOS follow-up to address needs in each subsector. This information would be available in the Computer Bulletin Board discussed above. In connection with this study, DOS and EDC shall commence a study of economic development costs and benefits to the New York City economy to be derived from the implementation of each of various local governmental measures to assist the reuse industry, and from the implementation of other waste prevention initiatives. In this study DOS and EDC shall investigate reasons for decline of repair, thrift, resale industry and determine methods for fostering the industry.

Funding is requested to permit DOS to work with Department of Consumer Affairs to ensure implementation of annual waste and rate audits in the nonprofit, commercial, and institutional sectors.

Funding is requested to permit DOS to monitor and calculate the waste (volume, weight, toxicity) of wastes avoided by each waste prevention program or initiative it and other city agencies introduce, the gross and net costs of each such program, and should distribute to the public an annual report describing the previous year's activities, progress, waste prevention achieved, problems encountered, and future plans (short and long-term). All waste prevention activities of all businesses in the Waste Prevention Partnership should also be addressed annually using this procedure.

As suggested above, the DOS' waste prevention education initiatives are in need of improvement and/or expansion. Funds are needed to ensure that the booklets on waste prevention and toxics reduction to every resident and business employee in the City. Public Service ads specifically for waste prevention, should be developed and aggressively marketed for TV and radio. Subway, bus, and commuter rail ads should be expanded, improved, and regularized. Waste Prevention tips and educational message regarding lifecycle impacts of consumption should be developed for more transit and billboard ads. Posters should be developed for apartment buildings' recycling areas. Leaflets should be developed for utility bills. Funds are needed for the expansion of the "Bring Your Own Bag" program citywide. DOS should also develop and distribute a short film describing the virtues of waste prevention with handy tips to movie theaters to be used as short clips before major features.

DOS should investigate inexpensive means of producing and distributing up-to-date free advertising directories for repair, reuse, resale, thrift, etc... shops by neighborhood. (The Reuse Guide recently published by the DOS is only a "how to use the phonebook" guide. No actual listings of waste prevention businesses are included. The Seattle Reuse guide could serve as an illustration of how "neighborhood guides to waste prevention businesses" could be prepared.

DOS should also institute a system, whereby Municipal Housekeeping Mini-courses could be given, in several languages, to all newcomers to New York City, perhaps in a mobile interactive exhibit which could teach the three R's to a segment of the population that is often missed by more typical education methods.

Funding is also requested for continued support for Recycling/Reduction educational staff directed by the Manhattan Borough President's office and each Community Board-district.

For the last couple of years DOS has undertaken to work with businesses to encourage them to design and implement methods to reduce the waste they generate. So far the program has only a handful of members, and these have had a limited impact on the waste stream to date. For example, the DOS' work with the Chinese Restaurant association (to limit the use of disposable condiments) has been limited to Chinatown for the most part. Also, the Dry Cleaner's Association did start a program to have hangers reused and disposable bags avoided by use of a reusable clothes case, but this has also not yet been implemented citywide. Further, the Waste Prevention Committee gave a list of specific recommendations regarding the criteria for selecting new members and retaining existing members of the Partnership to DOS many months ago, but it is unclear whether these, or any other firm requirements are being applied to businesses joining the Partnership.

Assuming that stringent criteria are applied to new and continuing members of this Partnership, assuming that more businesses are recruited so that there are sufficient bona fide members of the Partnership, and assuming that DOS (or a volunteer or community group) does sufficient monitoring to ascertain that promises made by the businesses are actually being implemented, this concept can be a beneficial component of the DOS' waste prevention program. However, at present, it does not appear that any of these three criteria have been met. DOS needs to have considerably more resources to implement this program properly.

In addition to the above, the Waste Prevention Partnership should be expanded to include work with the distributors, manufacturers, and especially designers of packaging and other problem products to develop better designs from an environmental point-of-view. At this point, these very important influences on the waste stream are not included in the Partnership. Including product and packaging designers will facilitate keeping them up-to-date with practices that do less environmental harm. Similarly, the City should encourage that waste prevention principles are taught in the design schools, if necessary by developing and providing information materials which could be used in curricula. DOS should be more involved with professional organizations and trade shows in this area. The liaison could also work with designers to minimize "built in" product obsolescence.

The Partnership should also encourage industry to utilize more universal (and therefore, replaceable) parts in durable products so as to foster the repairability of those durables. The widespread lack of availability of inexpensive spare parts shall also be investigated and corrected. Finally, DOS should establish a liaison and task force to work with manufacturers to increase the reuse (backhauling) of transport, and in some cases, primary packaging.

Since the DOS' grant from NYSDED will provide assistance in the conduct of waste audits and development of waste prevention plans only to "targeted offices", funding is requested so that DOS can expand its technical assistance programs to promote waste prevention procurement and practices in the institutional and commercial sectors. DOS should also have adequate funding to issue copies of its new Business Waste Prevention Guide to all businesses.

Funding is requested so that DOS can establish Awards for superior products and packaging innovations and Booby Prizes to environmentally unsound product and packaging innovations. Both would serve to encourage industry research and development.

Funding is requested so that DOS can monitor new instances of individually wrapped packaging and overpackaging (so that this might be discouraged directly by interaction with manufacturer).

With the issuance of its RFP in mid-1993, DOS commenced the process by which a systematic, though limited study, of federal, state, and local waste prevention laws, rules, regulations, policies, guidelines, programs, and business case studies would be studied by a team of chosen consultants. This is good news; unfortunately, the time frame for producing results is over a three year period starting from the issuance of the contract, which will not be until 1994. While the Waste Prevention committee had recommended that DOS pursue such a study, it would be a mistake to limit DOS' future waste prevention programs, legislative initiatives, policies, etc... to those featured in the consultant's study. This is particularly true since the minimum number of entities studied is only 10 governments and 10 businesses. In addition to implementing successful waste prevention initiatives recommended by their consultants, DOS can also combine successful parts of other jurisdictions' ideas and innovate some concepts of its own, developed in-house and by the Solid Waste Advisory Boards, and evaluate and refine the ideas by means of pilots, surveys, and other forms of research at the local level.

Therefore, funding is requested to permit DOS to expand its in-house capability of tracking and adapting, for use in New York City, waste prevention programs, economic incentives, and legislative developments from all over the world, and to lobby in Albany and Washington for passage of laws and regulations which would assist waste prevention efforts in New York City. Since education and research will only go so far in changing the way products are designed and marketed, DOS should, in addition, be provided sufficient funding to seek adoption of an aggressive set of legislative initiatives at the local, state and federal levels (e.g., quantity-based user fees, advance disposal fees or taxes on packaging and disposable products, requirements for labeling of toxic constituents, warrantees and other measures of product durability, packaging costs, and product/package ratios, elimination of subsidies to virgin materials, mining, logging, and other extraction processes, and per ton fees on disposal).

PROGRAM FOR WASTE PREVENTION PROCUREMENT

In its 1993 RFP the DOS has requested the consultant team to undertake comparative analyses of the ultimate cost to the City of purchasing various goods, taking into account their amortized life-span costs (i.e., replacement, maintenance, and solid waste management costs borne by the City). While this is a very important endeavor, the RFP falls far short of what is necessary for DGS to commence a real program of purchasing items based on life-cycle costing. The RFP calls for analysis of a minimum of only 10 pairs of products! Since DGS procures hundreds or thousands of products, this merely scratches the surface. In order for DGS to structure an implementable procedure, it will need to develop, or have a consultant develop, the life-cycle costing analysis for all the products and packaging it procures. In addition, since the RFP did not require that pollutant precursor or toxics content of goods and packaging be gathered or assessed, this information will be necessary for use in any procurement method which takes waste prevention into account. For this reason, DGS will require additional funding to finish the job the DOS RFP will begin.

In addition to developing a procedure for and implementing new procurement procedures including lifecycle costing, the DGS should immediately commence an inventory of all the durable products (and their condition) in their warehouses, and design, purchase, and install a computer system and computerized bulletin board, so that the reusable resources are properly utilized.

In order to have current, accurate information about the waste stream with which to refine existing programs and design new ones, funding is requested to permit NYC DOS to hire staff to research and produce an annual waste prevention report which includes the following:

1. Progress in the last year towards established goals.