As chair of the waste prevention committee, I take this opportunity to thank the Commission for making it a high priority to examine closely the implementation of the Solid Waste Management Act in the State. Our written testimony includes a detailed vision of long-term planning for waste prevention, including specific milestones and an annual schedule for implementation. We also outline what we consider to be deficiencies in the NYC Plan Update, and we show specifically how waste prevention has saved businesses and institutions large sums of money, not just in avoiding disposal costs, but also in reducing procurement expenditures.

In the Final Revision to the Plan issued in late October, 1992, a table known as Document 25 spelled out in considerable detail for the 20-year planning period the tonnage of waste which would be prevented by City programs, as well as the total costs, the costs per ton, and the percentage of total waste prevented, all on an annual basis. Annual projections were also made for recycling, composting, incineration and landfilling.

The original Plan projects the costs of waste prevention programs at $20 per ton, remaining stable throughout the 20-year planning period, whereas the cost to collect, recycle, compost, and/or dispose of waste was pegged at $200 per ton rising to $300. 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, then every $20 spent this year to prevent a ton of waste will result in $200 less next year and in all subsequent years. 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. This kind of return is more than enough to finance not only an entire waste prevention program, but also a vigorous recycling and composting system. If one of the State’s criteria for a desirable waste management method is cost-benefit ratio, then waste prevention would surely be at the top of the list.

In 1992 the City’s Plan was replete with appendices on every aspect of solid waste management one could imagine. The Waste Prevention appendix outlined dozens of programs, economic incentives, legislation and other measures which were designed to reduce waste generation. Happily, the 1992 Plan projected that the State’s 1997 waste prevention and recycling goals of 9% and 41% would be achieved on time, with waste prevention rates rising steadily until then. However, in the 1995 Update, there is not only no mention of the previous tonnage and cost projections, the State’s goals were abandoned as a central focus of the plans put forth. There are no estimates of waste prevented this year or in previous years.

Over the last few months the Waste Prevention Committee has reviewed the Compliance Report and the Update in light of the many previous commitments made in the 1992 Plan, and in light of what waste prevention programs were actually implemented by DOS over the last 3 years. Unfortunately, we found that DOS has not accomplished initiatives for which it has taken credit in its reports. What’s worse, the Update is no longer primarily a planning document, detailing and substantiating how it will achieve the State’s Goal of 10% waste prevention by 1997. This is because of the City’s inexplicable decision to abandon Waste Plan, a computer program which the City bought at great cost to project future tonnages prevented, recycled, etc... and program costs. Instead of sticking with the commitments in its original Plan, and the Plan’s methodology, the City’s current documents back away from many milestones proposed in 1992, instead focusing on justifying how partial measures constrained by fiscal cutbacks, should be satisfactory. There is no indication how or whether the State’s goal will be reached by the few weak measures the City plans to undertake. Further, waste prevention measures for the residential sector have been reduced to a few voluntary measures. Pilot and research studies which DOS commited to undertake in 1992 and which are essential to planning effective waste prevention programs have not been done. Furthermore, the few waste prevention milestones which do remain in the City’s Plan are phrased in such a way that measures will be studied or evaluated, but not necessarily implemented.

If this isn’t enough, the State law doesn’t stipulate that localities must make commitments to implement any minimum level of effort, nor can the DEC enforce that localities live up to any of the commitments they do make. As a result, here in NYC, the City has never implemented most of the recommendations made in its own Appendix to the 1992, it has backed away from implementing some of the milestones in the Plan’s Chapter 19, and it has produced an Update which lists a handful of vague milestones, from which we have no idea how much waste will be prevented. Most of these are measures merely to be explored or studied sometime between now and 2002.

Thus, we strongly urge that Commission recommend that the legislature add some teeth to the Solid Waste Management Act so that local planning has an even chance to achieve the State’s goals. Specifically we recommend that the Act require that