Marjorie J. Clarke, Ph.D.

Steering Committee, NYC Waste Prevention Coalition

Chair, Waste Prevention Committee, Manhattan Citizens' Solid Waste Advisory Board

May 22, 2000

The Waste Prevention Coalition, the CRAB, and Manhattan SWAB recently testified before you about the economic and environmental benefits of instituting a five-year program of waste prevention initiatives, ranging from educational and training programs to onsite composting to agency and business incentives to reduce waste generation.

The Solid Waste Management Plan is an equally important tool for achieving meaningful waste prevention in this city. State law (the Solid Waste Management Act of 1988) prioritizes waste prevention in an integrated hierarchy of solid waste solutions, calling for 8 to 10% waste prevention by 1997. It also requires New York City to have an up-to-date Ten Year Plan of action milestones for achieving the integrated plan. New York City has utterly failed on both counts. In February of 1999 NYDEC issued its comments on the City's Solid Waste Management Plan, recognizing that the City has failed to prioritize waste prevention, instead giving it a small fraction of 1% of the resources given to all other waste management solutions. Despite the fact that waste prevention is the only means by which the City could offset the rising environmental and economic costs of waste management and export, since 1992 the City has pursued a small fraction of the recommendations made by us and by the City's first waste prevention consultants. If the City had followed its own 1992 Solid Waste Management Plan, it would have achieved 9% waste prevention by the State's deadline, and in the year 2000 would have been saving the City $90 Million per year in avoided waste collection and disposal costs. Most of the programs, policies, legislative initiatives, and economic incentives originally recommended, and new ones presented in our testimony over the years, can still be instituted if only they would be put into the Plan, and funded.

Upon close inspection of the new, ongoing, and implemented plan milestones in Tables 3.1-1, 3.2-1, and 3.3-1, it is clear that the City has no plan at all for waste prevention beyond extending a couple of small programs for the next couple of years. The ongoing milestones are so vague as to be meaningless. The City has failed to justify the three-year delay in fully implementing the reuse hotline. The City has taken credit for implementing several waste prevention reports, which no one outside the Department has ever seen, despite our periodic requests for all reports, and the Department's occasional promises (one made at a CRAB meeting over 2 years ago) to provide them. It has also taken credit for "considering", "exploring", and then discarding initiatives without actually implementing anything. The City, by issuing this Plan and EIS without issuing the waste prevention studies, is trying to railroad the Council into approving an export plan without needed data on a clearly viable alternative management strategy for a significant portion of the "waste" stream (i.e., repairable durables, preventable packaging, needless throwaways, and recyclables). Requiring that these valuable resources be exported is costly and unnecessary.

The following two charts indicate the magnitude and increasing trend of export-based waste management costs in New York City as a result of the Fresh Kills closure. For a comparatively minor investment in some waste prevention measures over the next five years, monetary benefits would accrue. The programs would pay for themselves by the fourth year, and would pay back previous investments by the sixth year.

Notes: These charts presume:

Export and Collection Costs are assumed to rise by only 1% per year.

Since waste prevention is the most environmentally sound and responsible waste solution, we in the Waste Prevention Coalition, the CRAB, Manhattan SWAB, and its Waste Prevention Committee, recommend strongly that the City commit to a serious waste prevention strategy as part of this Plan. Eight years have passed with little to show for it. There is much work to be done.

• There should be several, specific, measurable action commitments for each year of the required ten-year planning timeframe.
• There should be a sufficient number of commitments in each year to achieve the State's 10% waste prevention goal in five years and 20% in ten years for each of the 3 major generating sectors (residential, institutional, commercial).
• The City should report annually to the Council and advisory boards on the costs of each waste prevention program, the tonnage prevented by that program, the avoided costs of collection and disposal of that tonnage, and the other avoided costs (or benefits) of the prevention program (including, but not limited to: avoided/reduced purchase costs, savings in health care costs, value added to the City's educational programs, etc.)
• The City Council should conduct annual oversight hearings on the solid waste management plan, insisting that the City provide documentation proving the achievement of each commitment and measurement of waste prevention achieved.
• The City Council should ensure that there is sufficient funding for the City to conduct waste prevention programs, pilots, studies, etc. specified in the Plan.
• The Plan should include, at a minimum, the Waste Prevention Coalition's 5-year budget priorities, including waste prevention coordinators, reuse centers, vocational durables repair programs, and DCAS environmental purchasing coordinators and computers (see next table).
• The City should conduct pilots and studies to transition from our current system where there is no economic incentive for people and City agencies to reduce waste generation, to a system whereby quantity-based user fees (QBUFs) or user incentives are utilized to fairly charge for solid waste services. USEPA has shown that in over 5,000 U.S. cities and towns, a 45% increase in prevention and recycling has resulted from institution of QBUFs. It is the single most potent program for waste prevention. This transition should be completed in five years.
• The City should conduct pilots and studies to determine how best to maximize onsite composting of food and yard waste by all types of generators within the residential, institutional and commercial sectors. Such studies should also aim to determine how to optimize collection and composting of food and yard waste from high-rise generators.
• The Plan should include a commitment to support Intro 482, the environmental procurement and agency waste prevention practices bill, and to specify a program over the next ten years for local legislation to institute advance disposal fees, excessive/toxic packaging fees, sales tax credits to businesses that reduce waste generation, and other waste prevention legislation.