1. What is the relationship between the "New Implementation Schedule for Waste Reduction and Reuse", Table 5-9 in the Update, and the goals of the State’s Solid Waste Management Act for 1997?

2. How do we know that the small collection of initiatives listed here will amount to anything near 9%?

3. How can we be certain that this collection of initiatives will reduce each sector’s waste stream by close to 9% as was shown in the Plan’s table?

4. How much is each initiative expected to contribute towards waste prevention each year?

5. On what basis were the Update’s particular initiatives chosen?

1996 Achieve 7% waste prevention in each sector (residential, institutional, agency, and commercial) through efforts undertaken by the City to prevent waste.

1997 Achieve 9% waste prevention in each sector through efforts undertaken by the City.

2000 Achieve 15% waste prevention in each sector.

2005 Achieve 20% waste prevention in each sector.

1. So, in light of these facts, why isn’t DOS more aggressive in planning, budgeting, and implementing its Waste Prevention program?

2. How can the City ignore such savings (and its own calculations in the Plan) and continue to spend on the order of one million dollars per year on all its waste prevention initiatives combined?

3. Why doesn’t the Update describe the economic and environmental improvements to be gained not only by its proposed minimal program, but also the increased benefits of a more aggressive program?

4. In light of the 1992 Plan’s greater emphasis on residential waste prevention and the above economic arguments, could DOS explain why most of the Waste Prevention staff’s efforts are being expended on non-residential initiatives?

1996 and annually thereafter Account for funds spent on each waste prevention program and tonnages and volumes avoided.

1. How can DOS justify NOT undertaking the pilot research it carefully spelled out in the original Plan and reject residential QBUFs on the basis of a duplicative study which doesn’t shed light on the issues pertinent to NYC?

2. When will DOS stop hiding its report on residential QBUFs and share it with the world?

1996 Design and conduct pilot tests of at least three alternative residential QBUF operational strategies for multi-family buildings in each borough. Report to the public on results and solicit input on design improvements.

1997 If 1996 pilot tests are successful, implement residential QBUFs in multiple-family dwellings.

1997 If 1996 pilot tests in multi-family dwellings show problems, design and complete at least one additional pilot test designed to overcome any problems. Report to the public on results and solicit input on design improvements.

1998 If 1997 pilots are successful, implement residential QBUFs in multiple-family dwellings.

1999 Complete a study of residential QBUFs in each borough and housing type. Provide the report to the public. Institute any modifications to the program to improve the efficiency of the program.

1. How can DOS take credit in the Compliance Report, for having satisfied this milestone by saying that private hauler tip fees were increased at Fresh Kills? The commercial waste simply went out of town when this happened, and no changes in collection fee structures occurred.

2. Why is commercial QBUF only discussed in the Update under recycling and not also waste prevention? DOS’ discussion in the Compliance Report of its QBUF activities demonstrates a lack of understanding of the purpose and method of implementation of QBUFs.

3. If DOS’ raising of tip fees had any direct impact on the amount that commercial customers pay, what is it and how is this information derived?

4. How much commercial waste generation has been reduced via DOS’ QBUF program, which is characterized as a success in the Update (pp. 2-3)?

5. Does DOS consider the quantity of commercial waste exported as a result of raising tip fees to be equivalent to quantity of waste prevented due to this initiative (i.e. tons exported = tons prevented)? Would DOS argue that increased waste export to out-of-City landfills and incinerators would thereby be counted as more waste prevention?

6. Since businesses are not always seeing reduced rates when they reduce the amount of the waste they put out for collection (either through waste prevention or through recycling), shouldn’t DOS work with Department of Consumer Affairs to educate ALL businesses about their legal rights to volume-based collection charges and about how to negotiate contracts with carters to achieve truly volume-sensitive charges? Experience with 1000 businesses over the last decade by Council on the Environment indicates that this method would be successful in making commercial QBUFs work.

1996 Prepare and distribute to all commercial establishments in NYC, an informational booklet which describes clearly and succinctly the current commercial QBUF requirements of private carters, and instructions on how businesses can negotiate volume-based fees with their carters.

1996 Include in the brochure a number at Consumer Affairs for businesses to call if carters do not comply with the commercial QBUF requirements.

1997 Complete a citywide study of the commercial sector (by business type, borough, and carter) to determine the extent to which commercial QBUFS are being adhered to.

1998 If the 1997 study shows that commercial rates are not, by volume, uniform, citywide, then undertake a media campaign (radio and TV) to educate businesses.

1998 If complaints and studies show that certain carters are not complying with QBUF requirements, Consumer Affairs must implement an increased enforcement program.

1. What research was done to prove that any institutional QBUF arrangement in NYC would be unfeasible?

2. What pilots were attempted, and which methods explored?

1996 Determine for each municipal and non-municipal institution serviced by NYCDOS a baseline waste generation rate for 1996.

1997 Institute a QBUF arrangement with municipal and non-municipal institutions whereby the City and the institution share (withe NYCDOS) any collection and disposal savings achieved by reducing non-recyclables generation below the 1996 baseline via waste prevention strategies employed by the institution. (Recyclables should be collected for free.)

1. In light of this, why in the Update (pp. 2-3 to 2-4) are Agency QBUFs discussed as only a possibility?

2. Why are agency QBUFs discussed only in terms of potential to increase recycling rates, when a primary purpose of QBUFs is to change purchasing, use, and disposal rates (i.e. waste prevention) by agency generators?

3. Has DOS considered implementing a program to share the cost savings achieved through waste prevention with municipal institutions, whereby any collection, processing, and disposal savings resulting from documented tonnage prevention by each agency, due to waste prevention efforts, would be shared between DOS and the agency?

1. Why does DOS claim credit for its legislative agenda, whereas it has almost nothing tangible to show for its efforts and has repeatedly substituted voluntary programs, which haven’t produced results, for legislative requirements? (Update p 3-3)

2. How has DOS pursued a NYC law to mandate Bring your own Bag signs in stores?

3. Is DOS’ backyard composting program of such size as to provide information and tools by which every residential generator could undertake on-site composting? (That is, has DOS provided funds to purchase backyard composters for those who want them, as is done in other cities?)

4. Why has the City taken three years and still not initiated its grass clippings ban, since this alone could account for at least 1% of the waste stream?

5. How can DOS justify taking credit for providing an economic incentive to businesses to utilize recycled content, citing the State’s emblem program, when this program provides no more than indirect, token economic incentive to businesses, since almost no businesses use the emblems for advertising? Does DOS have figures (total economic incentives) to back up this contention?

6. How does a voluntary program with the Direct Marketing Association, which has unsubstantiated effects on the waste stream, satisfy the milestone to pursue legislation to REQUIRE companies to include means in their mailings for customers to remove themselves from their lists?

7. Why hasn’t DOS supported Intro. 509 which would enact City procurement guidelines to stipulate packaging restrictions as well as require DGS to review its specifications and institute environmental procurement? How can the City claim it has achieved these milestones since this is the only legislation including these stipulations which has had a City Council hearing?

1996 Introduce local legislation to require that a DOS Bring Your Own Bag sign be affixed to each cash register, and to provide economic incentives to businesses which reduce and persons who acquire products which prevent waste (e.g., reusable products, products which consume fewer natural resources in their operation, and products which contain fewer toxic compounds).

1996 Support Intro. 509 which would enact City procurement guidelines to stipulate packaging restrictions as well as require DGS to review its specifications and institute environmental procurement, among other initiatives.

1997 Provide rebates for residents and institutions which purchase composters and composting aids, or which demonstrate construction of a new composter.

1997 Provide rebates for purchase of lawnmower retrofit kits (which aid "leaving it on the lawn").

1997 Advertise rebate programs and institute educational program to each household and institution on the ease and benefits of composting and leaving grass clippings on lawns.

1997 Provide, free of charge, composters and educational materials for any community garden which requests them. Send notice of this program to all community gardens once per year.

1997 Introduce local legislation to require mail-order companies doing business with residents, business, or institutions in New York City to include means in their mailings for customers to remove themselves from their own mailing lists as well as from their name rental lists.

1998 Introduce legislation to promote marketing within New York City of more durable, repairable products, products with longer warrantees, products with less or reusable packaging, and other avenues of waste prevention.

1. In light of the commitment and reasoning supporting it given this important form of data gathering given it by DOS in the 1992 SWMP, with which the MCSWAB agrees, why has the City not undertaken such a comprehensive, City-wide, subsector, waste generation and composition study to update the one done in 1990?

2. On what is DOS basing the choice, design, planning, timing, etc... of its waste prevention programs if not the information from such a comprehensive study?

1997 Undertake a comprehensive, City-wide, products and packaging-oriented generation and toxics composition study for the residential, institutional and commercial sectors, in different types of housing and different locations within the City.

1998 Based on 1997 study, target product and packaging types for special waste prevention legislative initiatives, educational programs, and economic incentives.

2002 Undertake a comprehensive, City-wide, disaggregated products and packaging-oriented generation and toxics composition study as above. Repeat every five years.

2003 Based on 2002 study, target product and packaging types for special waste prevention legislative initiatives, educational programs, and economic incentives. Repeat every five years.

1. Why were CENYC’s data not cited and used for the purposes of estimation and extrapolation in the Update to the Plan?

2. What waste tonnages and volumes has DOS’ many waste prevention initiatives addressed over the last three years (e.g., for the Dry Cleaners initiative: total dry cleaner hangers and bags given out by each and all dry cleaners in DOS’ Partnership for each of the last three years)?

3. How have the generation rates in each category of product and packaging changed over the last three years among those in the Partnership, those agencies affected by the Mayoral Directive on Waste Prevention, and those businesses studied by CENYC?

Our Proposed Milestones:

1996 and annually thereafter: Determine waste tonnages and volumes that each of DOS’ many waste prevention initiatives (including, but not limited to each business in the Partnership, all agencies affected by the Mayoral Directive on Waste Prevention, and those businesses studied by CENYC) have addressed over the previous three years as well as those tons and volumes which have been prevented, and analyze trends. Report on results to the public.

1. How has DOS distributed each of its waste prevention educational brochures, posters, and other outreach instruments? The committee would like to see numbers of each item distributed over each of the last three years, and to which communities or audiences.

2. If the educational device has not been distributed to or aimed at every New York resident and commuter, what is the size of the intended audience, and on what basis was the audience (and therefore, distribution method) determined insofar as intended effect on the waste stream is concerned.

3. Has DOS conducted any studies to determine or estimate the citywide impact of any of its educational instruments on the quantity or type of waste prevented?

4. Has DOS considered distribution of educational literature to all residents and institutions via Sanitation personnel (either garbage or recyclables collectors)?

5. On what research did DOS choose its primary avenue of designing educational instruments (i.e. information on how to implement waste prevention only)?

6. Why was providing information (e.g., startling environmental statistics) which would motivate people to prevent not a consistent theme in DOS’ educational devices?

Our Proposed Milestones:

1996 Distribute to each household and institution (via Sanitation collection personnel) small cards or stickers (for recycling area within kitchen) indicating items which are recycled and items which CONTAMINATE recyclables. Provide a refrigerator magnet with phone number for reuse center hotline and waste exchange. Provide motivational literature on why (from an environmental and economic point of view) that waste prevention and recycling are important.

1996 Commence construction of a World Wide Web home page containing information on waste prevention, recycling, and composting.

1997 Begin media (radio & TV) campaigns to motivate those who were not initially sold out on recycling and waste prevention, to start doing it. Describe why putting in contamination is to be avoided. Describe why purchasing and maintaining products with waste prevention in mind is in everyone’s best interest.

1997 Complete home page on waste prevention, recycling, and composting. Continue to add new materials and pointers, and update annually. Report annually to the public regarding usage of the home page.

1998 Expand print and media campaigns to addresss additional reasons for recycling and reducing as much as possible. Continue campaigns each year, addressing new areas, and repeating basic information for newcomers to NYC.

Why can’t DOS undertake a pilot with something like shoe boxes which can simply be returned and refilled?

1997 Complete a pilot study to assess operational feasibility, and economic, and environmental costs and benefits of allowing consumers to leave secondary or nonessential primary packaging behind at retail stores, and of requiring that retailers and manufacturers work together to reuse (where possible) and recycle the packaging.

1. Does each member store in the Partnership receive outreach and education as to the agreement with DOS? How does each Association communicate its desire for individual stores to implement waste prevention practices?

2. Shouldn’t this communication and education of individual stores be a part of the project funded by the representative organizations?

3. Are there data showing waste prevention amounts for each member Association for each year, as they relate to the program? If not, why?

1996 Renew all agreements with Partnership association members requiring that evidence be shown, on an annual basis, that every member store has agreed to carry out the commitments to DOS made by the parent association. Such agreements should also be revised to require hard numbers be provided to DOS regarding the tonnage and volume in each category of product and packaging which is addressed by the commitment (e.g. total numbers and tons of hangers purchased each year) as well as that which is prevented (e.g. numbers and tons of hangers brought back by customers). Costs of the waste prevention program, as well as costs avoided by it, should also be provided. In exchange, DOS can commit to publicize any positive result agreeable to the Partnership member. Any Partnership member which does not renew the agreement and undertake these commitments should be advised that it will not continue as a member.

1997 Solicit 50 new members (associations or businesses) for the Partnership, including businesses in the manufacturing sector. Target businesses where the most waste prevention can be achieved. Continue this on an annual basis.

1997 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.

1. It appears that the 1995 Update refers to the Mayoral Directive as voluntary. The suggestion is that agencies contact DOS for instruction. What happened to the original mandate? Isn’t this a modification in the Plan? How many agencies are participating? How much waste has each prevented (and of what kind)?

2. The first section of the proposed directive on Waste Prevention and Efficient Materials Management Policy says that the inter-agency task-force would meet annually. No efficient task force meets so rarely when a program is getting started. The task force should be meeting quarterly at a minimum if any progress is expected. How frequently has this task force met?

2a. What about the reporting requirements? Which agencies have complied? Is there any savings to the City (in terms of reduced procurement, reduced collections and disposal)? Is there any quantification of waste prevention produced as a result of The Directive? If so, can it be reported? Can it be extrapolated to indicate a potential for waste prevention should each agency do as well as the best agency? Is the best agency doing as well as it could?

3. Which agencies have purchased double-sided copiers or have instituted double-sided copying as a result of the Directive, and what has been the experience with copier downtime, repair records, etc.?

4. Emphasis in the Directive update seems to be on saving paper. What about packaging? What about durable goods and equipment? The two-sided copiers themselves, vehicles, furnishings, computers, etc. could be held to standards, longer warranties, extended service contracts. Will DOS lobby for passage of these sound procurement procedures as contained in Intro. 509?

5. Is an Executive Order different from and more effective than a Mayoral Directive? If so, can the current revision to the Directive be changed to an Executive Order, among other improvements until a local law can be established?

1996 DOS shall Introduce and lobby for local legislation to mandate institution of a comprehensive set of waste prevention requirements at all municipal agencies, as well as requirement that each agency document the effectiveness of each requirement quantitatively (cost per ton, overall cost, percent prevented, etc...) on an annual basis. Such waste prevention practices shall address purchasing, maintenance, and disposition of all types of durables, nondurables and disposables, as well as packaging.

1997 DOS shall issue a comprehensive report on an annual basis to the public describing the policies and practices implemented and describing the quantitative assessments by each institution of the waste prevention policies and practices.

1. Since the City has narrowed its focus to include only "special waste", what will the City tell residents to do with the remaining 40% of the household hazardous waste-(HHW)--other flammable, corrosive, reactive and poisonous substances such as pesticides, fluorescent light bulbs, gasoline, brake fluid, oil-based paints, smoke detectors, photographic chemicals, cleaning solvents, pharmaceuticals, etc.? If the City does not have an alternative, will it be sending a signal to residents that disposing of these substances together with the regular trash is an acceptable practice?

2. The waste prevention educational aspect of Household Special Waste (HSW) programs was not specified in the Update (2.2.4). Will the City emphasize prevention in addition to the recycling of HSW in the pilot?

3. Will the City implement programs which concentrate on HHW prevention and toxicity reduction of household products directed at both the consumer and the manufacturer, particularly since it is not accepting the collection of 40% of the HHW generated in its HSW program? If so, please describe how and when.

4. Will the City continue to conduct an education and outreach program on the prevention of all HHW? As noted in the SWMP (Appendix 4-G, 1.0), "the educational component of the program was useful for educating the public about the hazards of household products and methods for reducing the generation of such wastes."

5. Will the City incorporate a reuse component in the HSW pilot program, such as a paint swap? In the 1991 Park Slope HHW pilot program, 725 gallons of usable paint was processed by a local paint company and donated to local groups (SWMP, Appendix 4-G, ii).

6. Is the City planning to expand the HSW program to include other HHW in the future? Is the City applying for special grants or looking at outside funding sources and in-kind contributions for such an expanded program for this year and in the future? If not, why? The 1991 Park Slope pilot HHW program demonstrated that "outside funding and in-kind contributions can be obtained to assist the Dept. HHW management efforts. Corporate support should continue to be sought from companies whose products and services may have a positive impact on the environment." (SWMP, Appendix 4-G, iii)

7. As suggested in the SWMP (Appendix 4-G, viii), is the City pursuing City or State legislation similar to legislation enacted in Vermont and Iowa? If not, why? "Laws in these states). Laws serve to raise funds for dedicated funds for HHW collection, and also educate consumers about HHW at the retail level." For example, the City could mandate that all gas stations hang signs informing customers where to bring used oil for recycling.

8. Does the City maintain a HHW hotline? Will the City give out information on the reuse of HHW such as paint on the telephone "hotline" service under development for connecting consumers with reuse centers?

9. Does the City's procurement guidelines promote the use of non-toxic/less-toxic products? Does the city promote/require the use of rechargeable batteries for use in city agencies to extend the useful life of this "special" waste? Does the City require the use of non-toxic alternatives to the standard toxic fertilizers, pesticides, rodenticides, cleaning products, etc. by City agencies and institutions (e.g. Parks Department, Housing Authority, etc)? If not, why? Using toxic products generates toxic wastes, which contaminate the landfill, recyclables, and compostable materials and should be avoided.

9. Was the 1993 milestone, as noted in the SWMP (p. 19-20), to implement a battery-exchange program in Health and Hospitals Corporation facilities ever carried out? If not, why?

10. The consultant report for the Drycell Battery Outreach, Education and Management Pilot Project conducted in Park Slope was to be completed in Spring of 1995. What were the results and recommendations? Could you please send us a copy of the report? Will the City institutionalize this drop-off battery collection program throughout the City? If not, why? Is this the same pilot program that is described on page 47 Appendix 4-G of the SWMP: "The Department of Sanitation is planning a pilot program to collect button and nickel cadmium rechargeable batteries through local retailers and institutions which will give DOS information on the feasibility of collecting and marketing these batteries"? If so, does the Park Slope pilot include other types of batteries besides button and rechargeable? If this is not the same program, has or will DOS be implementing this pilot program as described above?

11. What is the status of Commissioner Dougherty’s unprompted suggestion, made at a Manhattan SWAB meeting early in his tenure as Commissioner, that DOS garages be used as permanent drop-off sites for some types of Household Hazardous Waste?

1996 Institute a pilot program establishing one permanent household hazardous waste dropoff center within a Sanitation garage for each borough. Advertise this pilot program to all residents in the dropoff site catchment areas via brochures distributed by Sanitation collection personnel.

1997 Produce and distribute to the public a report which assesses any problems and successes of each dropoff site and recommends improvements in education and operations.

1997 Introduce local legislation requiring all retailers of household and automotive batteries to accept batteries, providing rebates to consumers; as well as requiring that retailers charge a meaningful deposit on the sale of all household and automotive batteries.

1997 Introduce local legislation requiring that all retailers of motor oil be required to display a sign informing consumers where to bring used oil for recycling.

1997 Introduce local legislation requiring that DGS and city agencies purchase less toxic or nontoxic products and packaging where currently such alternatives are available. ("Toxic" includes heavy metals, solvents, pesticides, and other pollutant precursors.)

1997 Institute a battery exchange within all HHC facilities.

1997 Prepare information on alternatives to purchase and use of toxic products and packaging and distribute this via print and media campaigns, as well as via the new DOS reuse hotline.

1998 Introduce local legislation requiring retailers selling hazardous household products to pay a permit fee (as well as comply with mandatory shelf labeling requirements and to disseminate information on HHW).

1998 Institute a city-wide program establishing permanent household hazardous waste dropoff centers within all Sanitation garages. Advertise this program to all residents. Implement recommendations as proposed in 1997 assessment.

1. Does the City have any plans to implement any ADFs? If not, what research has DOS done which has lead it to exclude ADFs from its plans, since ADFs were cited throughout Appendix 4-G of the SWMP as being able to prevent 1-2% of the solid waste stream generated in the City? Why is it not considered to be a modification to the original Plan for ADF’s to be left out of DOS’ programs?

2.. As stated on page 16-3 of the SWMP, "the City will continue to research and monitor ongoing waste prevention, legislation and issues. These will include legislative proposals, proposals to expand the materials covered under ...packaging and product taxes/fees..." Could you please describe the efforts the City has undertaken in relation to packaging and product taxes/fees--ADFs?

3. Has the City raised the issue of ADFs in its participation with the Conference of Mayors, since this is a national issue as well as a local one? If yes, what was the result? If not, why was the issue not raised?

1997 Complete a study of possible local initiatives and legislation involving the advance disposal fee concept (i.e., charging manufacturers, distributors, and/or retailers for marketing products and packaging which are disposable, contain toxic constituents, are packaged excessively, etc... based on the volume and toxicity of waste generated).

1998 Introduce local legislation, based on the 1997 study, instituting the ADF concept, to reduce the packaging, toxicity, and disposibility of products marketed in NYC.

1. The Council on the Environment found that 53% of the Grand Central Post Office waste stream consists of undeliverable bulk mail. Besides seminars, what is the City doing about reducing the amount of locally generated and distributed direct mail? Locally generated and distributed direct mail is not affected by the Mail Preference Service (MPS).

2. Would the City consider requiring mailers to participate in the MPS system, since a voluntary system would cover such a small fraction of all businesses? If not, why?

3. Is the City pursuing its 1994 milestone, as noted in the SWMP (page 19-7), of promoting local and/or state legislative initiatives requiring all direct mailers to provide toll-free number or some other means for requesting to be removed from the mailing list such as self-addressed postcards? If not, why? If so, describe the initiatives?

4. Is the City promoting the restructuring of postal rates for reducing junk mail as recommended on page 58 of Appendix 4-G of the SWMP? If not, why?

5. Would the City consider the idea of holding the U.S. Postal Service responsible for the solid waste management costs to the City of the "junk mail" problem? If not, why?

6. Would the City consider initiating and supporting legislation that requires that undelivered mail goes back to the mailer at the cost of the mailer? If not, why?

1996 Complete a study of the Mail Preference Service postcard campaign to determine the type and amount of unwanted mail which has been avoided as a direct result of this campaign in NYC. Distribute to the public.

1996 Commence lobbying for restructuring of postal rates for reducing junk mail. Continue until rates have been restructured. Report to the public annually on lobbying efforts and results.

1996 Commence lobbying for legislation that requires the undelivered mail be returnable to the mailer at the cost of the mailer. Continue until this has been achieved. Report to the public annually on lobbying efforts and results.

1997 Introduce local legislation requiring that all direct mailers doing business with consumers in NYC provide an invitation to customers to remove their names from the mailing list and the name rental list, as well as either a postage-paid postcard or a toll free telephone number for this purpose, in each catalog or piece of mail distributed to consumers in NYC.

1997 Commence charging the US Postal Service for the City’s costs in collecting and disposing of undeliverable junk mail delivered to NYC.

1. How has the City worked with "other cities to establish a multiple cities coalition to develop model waste prevention legislation to be adopted by the legislatures of the cities in the coalition", as it stated it would do in on page 19-7 of the SWMP, if there was not sufficient progress towards the adoption of State or Federal waste prevention measures by 1994?

2. Is there a proposed legislative package from this Coalition, and if not, why not?

3. Does DOS consider that there has been sufficient progress towards the adoption of State or Federal waste prevention measures? If so, please specify the State or Federal waste prevention measures adopted, for which DOS lobbied.

4. How are the information being gathered and initiatives arising from this Coalition being shared with the public? Can DOS make its data and reports (in general) available to the public on the Internet?

1996 and annually: Complete a report detailing lobbying efforts and results of such efforts with respect to the State and Federal legislatures, the US Conference of Mayors’ Source Reduction Task Force, and other bodies. Include in this report information gathered from the Task Force and other sources.