October 17, 2000

I am Maggie Clarke, an environmental consultant and Chair of the Waste Prevention Committee of the Manhattan Citizens' Solid Waste Advisory Board, and steering committee member of the Manhattan SWAB, the Citywide Recycling Advisory Board, and the NYC Waste Prevention Coalition.

First, I will continue to provide analysis of the SAIC reports, with a review of the Waste Prevention Characterization and Waste Prevention Measurement reports, and then conclude with a list of recommendations for specific waste prevention milestones to the City's Solid Waste Management Plan, compiled from all our reviews of the SAIC reports.

The Waste Prevention Characterization report was a disappointment. Since 1989, while DOS was undertaking a 46-material sort, the MCSWAB's Waste Prevention Committee had been asking for a waste characterization report for New York City's waste that is product and packaging - based, not just assessing recyclable materials. We needed this information to help design and perfect waste prevention programs targeted to reduce durable and nondurable products and packaging. We wanted a study of New York City's waste stream because we saw that in the 1990 DOS study, there were major differences between our waste and that of the country as a whole. For example, yard waste is 3% here, but 20% elsewhere; food waste here is almost double the national average.

In 1995 DOS asked the Waste Prevention Committee for a list of products and packaging to study for this report (see below). We provided a list, along with an estimated percentage of several categories in the national waste stream, using EPA figures. While the SAIC report addresses many of these categories, no current New York City-specific information was gathered; most of it was extrapolated from the old EPA national figures, and some extrapolated from the City's 1990 materials characterization study. This study could have been done by the Waste Prevention Committee itself for a fraction of the cost! We still need an accurate and current enumeration of products and packaging types in New York City to optimize the design of our waste prevention programs.

We measure the City's "waste" stream (half of which actually consists of recyclables disposed in the trash) as well as several categories of recyclables on a monthly basis, and by district. We measure these things to evaluate program effectiveness, in an effort to optimize operations. If we had no idea of how much waste or recyclables we were generating in different areas, and just sent the trucks out randomly, most of the stuff would remain on the curbside for a long time! We use measurements to order trucks, deploy Sanitation workers, draft export contracts, and market recyclables. No one argues that we shouldn't measure waste or that we shouldn't try to optimize our Sanitation programs. In fact, measurement and optimization are critical to minimizing costs. The same is true for waste prevention programs.

Earlier you heard testimony regarding the cost of DOS' waste prevention programs. We were able to estimate this from the SAIC reports. If the City spends $2 million per year on waste prevention programs, and more than 72,000 tons of waste were reduced in 1998 as a result of City programs, DOS' waste prevention programs then cost only $27 per ton. Compare this with the cost of export, at $95.50 per ton. That's a savings of almost $70/ton. Why should the City choose export at more than triple the cost of preventing waste? These figures also make it quite clear that the City must not engage in long-term waste export contracts that require us to export minimum amounts of waste. To do so will shut down any further achievements in waste prevention or recycling and will cost the City money needlessly.

But waste prevention not only saves the City money by avoiding export costs. In the City's 1992 Solid Waste Management Plan, (pages 17.2-2 to 17.2-3), the City estimated that in the year 2000, just over 8% waste prevention would be achieved, and this would amount to approximately 600,000 tons a year.  The avoided costs to the City's collection system were estimated to be at least $26 million per year. Just think of how we could develop and perfect waste prevention programs with an annual budget of $26 million.

The SAIC reports state that "the New York City Department of Sanitation (DOS) has undertaken a wide range of ambitious waste prevention initiatives", and also that "the waste prevented is a mere drop in the total bucket of waste".

It's no wonder. Many of the City's waste prevention programs were designed to be limited to extremely small sectors of the commercial economy (e.g., Dry Cleaning, Chinese restaurants, Materials for the Arts), not available to the vast majority of New Yorkers, and hence have small potential for waste prevention. For example, the Recycle A Bicycle program (which the SAIC study did not even measure) could be expanded to citywide and expanded to address repair of other durables, such as electronics, computers, furniture and appliances. Instead of focusing programs on just hangers and bags in dry cleaning stores, it could have tried to address retailer packaging in all retail stores. Instead of focusing on just napkins and condiments in Chinese take-outs, it could have focused on all take-out and deli restaurants. Instead of focusing only on a limited backyard yard waste composting program (where a small fraction of homeowners get composters and instruction on yard waste composting), if the program were citywide and included food waste composting, the effectiveness of the money spent on the composters would rise.

Other DOS prevention programs are only pilots or studies of individual businesses (CENYC waste assessments, Training of LDCs), and others have been conducted at such a small scale that most city residents are unaware of them (e.g., waste prevention education, grocery store outreach, unwanted direct mail reduction, botanical gardens composting). One program (Stuff Exchange, previously referred to as the waste prevention hotline) was delayed for many years and is still in pilot stage. Several of the programs occurred over a very short period of time (less than a year), hence the total amount of waste prevented is further reduced. Perhaps most important, most of DOS' waste prevention programs have not targeted the residential sector.

Thus, waste prevention from this bunch of programs cannot be considered to be anything close to the full potential for waste prevention in NYC, and the exercise of aggregating the impacts (Chapter 3) merely shows an aggregate of tiny programs.

The Measurement report is an extremely biased report from another standpoint. It starts from a premise of using quantitative benefit/cost analysis to evaluate DOS' waste prevention programs. However, it analyzes, in depth, the costs to the City for business waste prevention, which shows no benefit to the City since DOS does not collect commercial waste. When DOS originally decided to focus its waste prevention efforts on businesses, many on the various advisory boards questioned the wisdom of this, because it is the residential waste stream that the City should be immediately focusing on given the closure of Fresh Kills.

NY City$ense Program, despite documenting incredible waste prevention benefits ­ in purchasing costs and waste disposal- and the likelihood that these benefits could accrue to other city agencies of government, were not recorded in the Measurement report.

The Council on the Environment for NYC performed waste assessments for a number of businesses and institutions in NYC where DOS collects the waste, but this report incorrectly assumes the sector is all private and thus that no cost savings would accrue to the City from this program.

No attempt is made to extrapolate waste prevention measures to other similar institutions or agencies where there would be a clear benefit to the City. Under the Botanical Garden Composting projects, there is no evaluation of the cost savings that have accrued to the city from the large grasscycling and leaf composting programs at NYCHA sites and community gardens.

A detailed cost analysis is done for the Material for the Arts Program. MFA in 1999 received and distributed 500 tons of donated materials and durable products at over $400 per ton cost for the city ($200,000 per year). The value to DOS was less than a half million dollars in avoided export costs, but the value of these free goods to recipients was more than $3 million.

The NYC Stuff Exchange, delayed for many years, also has a detailed cost analysis based on future projections of use by NYC residents. The net annual cost to DOS is estimated to be $52,544, although savings to all participants is estimated at $41 million.

The City's total waste prevention budget has amounted to $2 Million or less each year, this translates to less than twenty-five cents per person per year. Assuming that the whole budget is dedicated to education, this wouldn't even cover the cost of postage for one mailing to everyone. DOS has written several booklets about waste prevention, but they are sent only to special groups (e.g., certain types of businesses), and are available only if residents ask for one. But an educational program in Minnesota that sent four mailings to residents resulted in almost 5% waste prevention after accounting for increased recycling. A reduction in NYC garbage export by 5% of 13,000 tons per day (650 tons) would reduce export costs by $225 million per year @$95/ton. Even a program half as successful as the one in Minnesota would pay for itself and other programs many times, and would constitute a sound investment.

Bottom line is that readers should cut through the distortions in this report. In the DOS-supported WasteLe$$ program, DOS invested $7 million and the positive benefits amounted to over $37.3 million in net present value to participants. This is the kind of favorable ratio of investment to return we want to see for future waste prevention programs.

The NYC Waste Prevention Coalition has provided the Council with a detailed set of recommendations constituting a 5-year plan for waste prevention. Though originally prepared as budget recommendations, they fit neatly as specific yearly milestones into the City's long range solid waste management plan. Our recommendations include expansion of a range of current pilot or small-scale programs to be citywide, and adaptation of successful programs from other cities, covering all three waste-generating sectors, as well as onsite composting, QBUFs and measurement.

Though SAIC describes some good programs, methodologies, and practices that are used successfully elsewhere, they stop short of making recommendations in several of the reports. We note that no data or citations after 1998 occur in the reports. Maybe positive recommendations were removed during the last couple of years while the reports aged at DOS. In addition, DOS has required the consultants to honor a five-year gag order starting after the reports are complete, not revealing earlier drafts of these reports to anyone. What do they have to hide? To avoid this in the future, we need a sunshine law whereby draft reports would be routinely available for scrutiny. San Francisco has such a law on the books, and we would be happy to provide you a copy.

A few summary recommendations by SAIC reiterate some made by our Coalition earlier this year, and by the Waste Prevention Committee even earlier.

The SAIC's overall recommendations include the following:

• Waste prevention is worth undertaking, maximizing program effectiveness
• Significant achievements in waste prevention will require local, as well as state and federal initiatives; and

• Waste prevention activities that make good common sense, such as general education and reminders, should be supported even if they cannot be measured

Some of the other positive initiatives SAIC described include:

• Utilizing life-cycle costing in making purchases so that the full costs of buying and maintaining a product over time are taken into account. As one example, buying synthetic motor oil saves money and conserves resources over time vs. purchase of virgin motor oil.

• Imposing an advance disposal fee on products and packaging that are particularly voluminous or difficult to dispose: e.g., white goods and tires, excessive packaging, and disposable products.

• Utilizing existing authorizing legislation to tax problematic forms of packaging

• Purchasing products containing minimum recycled content standards set by those in the forefront (e.g., the Federal government and California).

• Instituting Quantity-based user fees "to achieve the level of industry and consumer behavior change necessary for substantial reductions in the New York City solid waste stream". But DOS has been reluctant to pursue this route, even though DOS' waste prevention consultants also recommended this in 1992. EPA studies have shown that QBUFs are the largest factor in increasing recycling (even more than going to weekly pickups), and with sufficient well-designed education, QBUFs facilitate waste prevention behaviors on the part of consumers.

The Packaging report states (p. 5) that SAIC researched several other approaches undertaken in other jurisdictions and made recommendations to DOS, but only a small subset of these are present in the final report.

The Packaging Roundtable report lists many things that NYC can do:

• Enacting environmental procurement policies (Intro. 482 addresses this)
• Adopting Quantity-Based User Fees for pricing waste services
• Providing public education

The Materials Exchange Roundtable report lists more possibilities:

• Start a multi-media campaign to educate the public about a citywide materials exchange, taking care to devote sufficient time and effort to ensure success
• Communicate monetary benefits of using materials exchanges

The WasteLe$$ Report lists methods for improving the efficiency and success of business waste prevention programs in several sectors. (p. 7) For example, in the hotel sector:

• Purchase products in bulk
• Specify returnable crates as transport packaging
• Implement composting of restaurant food waste
• Eliminate disposable utensils in cafeterias
• Donate excess unserved food to City Harvest

Even though there are deficiencies in the documents, they show many ways in which waste prevention will save the City money. There is considerable overlap of the recommendations that remain in the reports with those proposed by the Waste Prevention Coalition, and it is hard to understand why NONE of them appeared in the Solid Waste Management Plan. (In fact there are no waste prevention program milestones at all in the City's Plan.)

We urge the Council to reject any Plan that does not include an ambitious program to reap the cost savings of waste prevention, and to work closely with DOS on a new Plan that contains a series of milestones for every year.

We also recommend that the Council carefully examine the length and any guaranteed delivery of waste to export contractees, as long-term contracts and contracts specifying minimum tonnage for export will have the effect of quashing waste prevention and recycling efforts, costing the City more in the long run.

Finally, we urge prompt passage of Intro 482 as a start towards environmental procurement and waste prevention in City agencies.