Analysis of the NYC Department of Sanitation's
Waste Prevention and Recycled Product Research Project Reports
The NYC Waste Prevention Coalition
October 2000
The NYC Waste Prevention Coalition (NYCWPC) is a participatory, action-oriented network of organizations and individuals dedicated to promoting waste prevention as the most responsible, environmentally sound, and cost-effective means to solve New York City's mounting solid waste problems. Its mission is to encourage the reduction of the volume and toxicity of waste generated in New York City in order to minimize the environmental and economic costs of waste generation, collection, transfer, and disposal, including out-of-state export.
The following contributors prepared the Coalition’s analysis:
Patrick Barnhart, Research Associate, INFORM, Inc
Frieda Bradlow, Vice-Chair, MCSWAB Waste Prevention Committee
Maggie Clarke, Ph.D., Chair, MCSWAB Waste Prevention Committee
Resa Dimino, Sustainable Enterprise, consultant to INFORM
Jen Roth, Research Associate, INFORM, Inc.
Gray Russell, Solid Waste Prevention Program Director, INFORM, Inc.
Barbara Warren, the Organization of Waterfront Neighborhoods and the Consumer Policy Institute of Consumers Union
T a b l e o f R e p o r t s
Introduction
The Draft Solid Waste Management Plan Modification, May 2000 (Draft SWMP), released by the NYC Department of Sanitation last spring included an annotated list of research reports on waste prevention and recycled product purchasing that were scheduled for release by June 30, 2000, but dated Spring, 2000. These reports, held at DOS for more than two years after research was completed and repeated promises for earlier release, are the result of a several year, $3.2 million research project implemented by Scientific Applications International Corporation (SAIC).
Despite the fact that the reports were not issued until September 2000, they should be considered as a part of the Council’s deliberations over the SWMP. It is essential that the City take advantage of the unique opportunity created by the closure of Fresh Kills to reevaluate its approach to waste management and invest in waste prevention, environmental protection and resource efficiency. By doing so, the City can stem the tide of its enormous and growing waste stream and reduce export costs dramatically. According to estimates provided by the Independent Budget Office, the Department of Sanitation’s budget for 2001 will be a whopping $996 million – an increase of nearly 75 percent over the 1997 budget. DOS attributes this increase primarily to the costs of export.
The NYC Waste Prevention Coalition has assembled this brief analysis of the most substantive reports to aid the City Council in its review. This analysis will help identify the useful information the reports contain, and offer ideas on how they can be used to map out an effective waste prevention strategy for the City. The appendices provide direct references in the reports that support the implementation of the Coalition’s Waste Prevention Action Plan, and identify areas that need further investigation or review.
I. Summary
The waste prevention reports present a wealth of useful information. While they are largely presented in a negative context – describing the impacts of viable programs as "a drop in the bucket of total waste" and implying that waste prevention cost savings may actually lead to more waste through rampant consumerism– the data itself tells a different, and much more optimistic story.
A. Key Findings
Last spring DOS Commissioner Farrell testified that the City spends roughly $2 million per year on waste prevention programs. The report on measuring waste prevention estimates that more than 72,000 tons of wastes were reduced in 1998 as a result of City programs. Therefore, waste prevention programs, on average, cost only $27 per ton, not far from the $20/ton (1992 dollars) DOS estimated for waste prevention program costs in the 1992 Plan. And this very reasonable cost is for programs that are, in general, brief, small scale or pilot. If the programs were permanent and City-wide, the costs per ton would likely decrease even more. As a result, in the City’s current context of skyrocketing disposal costs, with the Draft SWMP estimating disposal costs of $95.50 per ton, the savings from waste prevention could be significant. Using existing program costs as a guide, if the City were to reduce five percent of its waste, the savings on disposal costs alone (not including reduced purchasing costs, garbage collection costs, truck maintenance, etc.) could exceed $13.5 million per year.
The reports cite several examples of cities that have implemented residential waste prevention education programs as well as successful programs the City itself has undertaken. Yet, there has been no significant public education on waste prevention in New York City since 1994, and none at all since 1998. Meanwhile, the reports detail that the City of Philadelphia launched a successful waste prevention education program in its inner-city neighborhoods, and that the City of Blaine, Minnesota reduced residential waste by 4.75 percent through targeted public education. And, a regional program in the San Francisco Bay area demonstrated a 20 percent increase in sales of well-packaged products, (less wasteful and/or recycled content packaging) and a decrease in excessively packaged products as a result of a targeted public education. All of these examples point to the viability of the Waste Prevention Coalition’s proposals to invest in community-based residential waste prevention education and outreach.
The City$ense report describes opportunities for City agencies to save tens of millions of dollars in avoided disposal and purchasing costs by implementing waste prevention practices. Its recommendations support the Waste Prevention Coalition’s proposals for City Agency waste prevention and demonstrate the need for the City Council to pass Intro 482.
For example, the NYC WasteLe$$ program provided savings to participants of nearly $9 million per year – a net present value of $37 million in savings over the life of the project. Clearly, these types of cost reductions help to keep businesses thriving in the City, supporting jobs and adding to our tax base. It is for these reasons that the Waste Prevention Coalition proposes expanding the City’s business waste prevention efforts.
While the City has tested and tried many different waste prevention programs, the number and scope of its programs is still relatively small for such a World Class City. The consultants acknowledged this in the report on measuring waste prevention, which states:
"DOS has both the knowledge and the capability to develop additional programs, such as a citywide public awareness campaign…. a ban on residential set out of grass clippings…. local quantity based user fees….a high visibility citywide campaign to heighten awareness, provide explicit guidance, and offer incentives and penalties. Above all, the City must lead by example and publicize its own efforts and achievements." (page 128-129)
Clearly, there is much to be done. Unfortunately, the Draft SWMP does not seize these opportunities.
B. Flaws in the DOS Approach
The reports are not integrated with the Draft SWMP Modification, May 2000, or with each other. Even though DOS had all of this information when it was preparing the Draft SWMP Modification, that document does not include any milestones or recommended actions based on these reports. And, although they delayed the release of these reports for years, they did not make an attempt to integrate the information from different reports, such as the City$ense and the Life Cycle reports, which both highlight waste preventing procurement efforts.
The reports are already outdated. There is no data or information newer than 1998.
DOS gives itself a blanket release of responsibility by saying in the foreword to the reports that it does not endorse their recommendations. This causes the reader to wonder: what was the purpose of this exercise, if not to generate recommendations DOS could implement? Further, the City has only minimal staff dedicated to Waste Prevention, giving little confidence in their commitment to this effort.
The savings attributed to waste prevention are understated. Not only do the reports estimate disposal costs at $70 per ton, well below the $95.50 estimated in the Draft SWMP Modification, but also they do not include all of the indirect savings, such as resource conservation, collection cost savings through reduction of truck trips and maintenance, etc.
Several programs that are clearly cost effective, such as the direct mail reduction campaign, have not been continued, and other promising pilots and small-scale programs, like Materials for the Arts, have not been expanded. If the impacts of the City’s waste prevention programs have not been astounding, it is because the programs implemented have had such limited scope.
II. Measuring Waste Prevention in New York City
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.
A. Waste Prevention Program Costs and Benefits
The Waste Prevention Coalition was able to discern the cost of DOS’ waste prevention programs using the information provided in this report, and previous statements by DOS. If the City spends $2 million per year on waste prevention programs, as Commissioner Farrell testified last spring, and more than 72,000 tons of waste were reduced in 1998 as a result of City programs (p. ES 7) 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 will pay an extremely high cost if it engages in long-term waste export contracts that require us to guarantee minimum amounts of waste for export. Such contracts will shut down any further achievements in waste prevention or recycling and will needlessly waste City tax dollars.
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 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 $18 million per year @$95/ton. Assuming a cost of $27/ton for waste prevention education, this reduction would only cost a little over $5 million. 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.
If the City were to reach the minimum original State goal of 8% waste prevention, the savings in collection ($26 million I n 1992 dollars) plus savings due to reduced export (over $21 million) reaches about $50 million savings per year. Surely, just based on economics alone, ignoring the environmental benefits, the City would want to achieve 8% waste prevention, and institute more programs to exceed this level.
Eight focus groups in 1996 indicated city residents could not distinguish between waste prevention and recycling, but that they recognized that waste prevention is important and that they needed to be more informed. However, the City's educational efforts have been tiny.
By contrast, DOS has spent considerably more for recycling education, and while this program could be significantly improved, it is clear that DOS employes several types of educational approach, and several are targeted citywide (e.g., TV, radio, subway ads, billboards, mailings). Recycling involves changing only one behavior (separating recyclables from trash), but waste prevention involves several including: purchase of less wasteful products and packaging (more durable, less disposable, more recyclable, remanufactured products, longer warrantees), proper care/repair/salvage of durables, donation/resale of unwanted durables).
As a result, waste prevention education requires commensurately more effort to achieve the same level of understanding and behavioral change. Furthermore, some waste prevention activities save the resident money (e.g., purchase in bulk, making repairs rather than purchasing a replacement, donations result in tax deductions, sales of unwanted products result directly in savings), other waste prevention activities may seem to cost more. Purchase of durable products and services (e.g., diaper service, sponges, dish towels) to avoid the purchase of many disposables, is more expensive in the short term, but provides better quality, and investments are paid off in the long run. USEPA has touted the use of quantity-based user fees (QBUFs) to give people economic incentives to change their behaviors, since doing so will save them money. Education coupled with QBUFs produces the best results.
Since every ton prevented saves the City far more than every ton recycled, expenditure of more for waste prevention education will be a good investment in the long run. That Minnesota took the effort to measure the effectiveness of its waste prevention program allows New York City to estimate savings due to avoided export (and reduced collections in the long run if routes can be lengthened). A reduction of 5%, as done in Minnesota with just four mailings, would reduce the waste exports by hundreds of tons per day, hundreds of thousands of tons per year, saving the City millions of dollars per year. Surely waste prevention education could be done for that or less.
It can thus be concluded that to address these issues multi-media and multi-approach education, coupled with quantity-based user fees (economic incentives) are needed to advance waste prevention actions by residents. Further, since the focus groups indicated that there were insufficient opportunities to purchase reduced packaging, initiatives to encourage manufacturers to design and market less wasteful products and packaging should be pursued.
C. Review of Specific DOS Programs
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 more actively promoted citywide, 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 (the NYC Stuff Exchange, previously referred to as the Reuse 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 DOS-collected residential waste stream that the City should be immediately focusing on given the closure of Fresh Kills.
The Measurement report only evaluated DOS’ existing waste prevention programs, so the findings in the consultant’s evaluations of city agencies for the NY City$ense Program, despite documenting incredible waste prevention benefits were not included.
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.
In the DOS-supported WasteLe$$ program, DOS invested $7 million and the positive benefits amounted to over $37.3 million in net present value to participants. This is the kind of favorable ratio of investment to return we want to see for future waste prevention programs.
Bottom line is that readers should cut through the distortions in this report to see that it clearly demonstrates that waste prevention programs are cost effective and valuable to City residents, businesses, and institutions.
III. NYCitySen$e Summary Report
Stunning, but not surprising, in this section of the SAIC report to the DOS were the number of opportunities to reduce waste in City agencies. This very predictable, limited look at a small segment of 11 Mayoral Agencies revealed a potential for waste prevention that could easily finance any needed programs and still save the City much more.
The Waste Prevention potential at DCAS is astounding with its $600-700 million purchases annually, its procurement catalog, its central storehouse and its surplus warehouse. DCAS is also responsible for 600 city leases for 20 million sq. ft of property. These leases can aid or hinder waste prevention and recycling activities.
Despite some serious criticisms of both the protocol and the design of the study, there are an enormous number of areas for positive focus. For example, the fruitful examination and subsequent recommendations regarding the DOS maintenance garage could be expanded to the Fire Department, the Police Department and any other entity with a number of vehicles. SAIC found however, that there was no mechanism in place to exchange information between agencies about successful programs. Incidentally, SAIC found that it is much easier to ascertain and measure the results of an individual program than the overall agency effort.
Also, despite a number of problems associated with the research and city agency cooperation, this Report’s major contribution is that it identifies MAJOR unnecessary waste generation and therefore waste prevention opportunities that if utilized would yield incredible savings to the City of New York. The savings identified by this very brief look at city agencies are so significant that if realized they could fund the entire Waste Prevention Coalition Program.
Investing in the Waste Prevention Coalition’s program proposals would not only enable implementation of the recommendations for City Agencies but would also facilitate expansion to institutions receiving free City waste collection and simultaneously provide for a number of projects that will prevent waste in the residential sector. The Waste Prevention Coalition Action Plan provides a budget of $16.38 million for City Agencies, quasi- Mayoral Agencies and Institutions (at full implementation, in year four). Implementation of just the projects identified by SAIC in this report and just for City agencies would obtain savings surpassing the dollar amount requested by the Waste Prevention Coalition. A summary of the Waste Prevention Action Plan and budget is provided in Appendix A.
Given the incredible findings in this report, the longer the City delays in funding and implementing a full fledged waste prevention program, the longer it will take to realize these considerable savings, the longer we will be tolerating incredible waste in government, and waste to the taxpayers with significant costs to needed government services and programs, many of which have suffered from the budget axe in recent years.
A. Key Findings
Highlighted are just a few of the findings that demonstrate the waste prevention potential that has been hidden to date, and explain some of the barriers the City confronts.
SAIC found that only the dollar amount of purchases is tracked and not the actual goods purchased. This stymies waste prevention efforts and the most cost- effective side of waste prevention—the purchasing side. Not noted by the consultants is the obvious danger of theft of government property in any system with inadequate tracking. The Waste Prevention Coalition Action Plan includes the development, installation and management of a computer tracking system.
The consultants identified several problems that relate to operations at DCAS that severely hamper waste prevention in City Agencies. These are:
It should be noted that some types of supplies have expiration dates and if not used by a certain date, they become obsolete. Allowing goods to become obsolete could be an overall significant financial loss for the City, although the consultants did not quantify this. Many agencies have no means of moving unwanted goods away, whether they be obsolete supplies, or used furniture and equipment, other than by trashing them. The only way to prevent this type of problem is a computer tracking system that would identify these kinds of goods and target them for use by another agency before the expiration date arrives.
Pallet Discard Management
One of the five recommended waste prevention activities was in the area of better Pallet Management. SAIC said City agencies may be discarding 279,882 pallets per year or 7697 tons at a cost of $1.27 million a year. All pallets received by city agencies have an $8 deposit on them, yet city agencies are throwing away many of these perfectly good pallets. If all of the above pallets are discarded, agencies are paying $2.24 million in pallet deposits a year.
A similar problem exists concerning 55-gallon drums, which were also found piling up at agency locations and being trashed. The deposit on drums is $20 and agencies are supposed to arrange for pick-up from the vendor. Unfortunately we have no idea how many drums the City uses.
The trucks and drivers in the Waste Prevention Coalition proposal would enable pick-up and return of used pallets and redistribution of furniture and equipment.
Office Paper Use Reduction
SAIC also recommended extensive office paper reduction activities. Examples of possible paper use reduction are the 90-100 forms used by the Financial Information Services Agency, and the 600 forms used by The Human Resources Administrations to service its clients.
At DEP the use of electronic telephone directories saved over $14,000 in paper and printing costs. This savings extrapolated to all city agencies could save over $660,000.
Vehicle Maintenance
Millions of dollars of potential savings reside in the area of maintenance of the city’s vehicles—from oil changes and filters to detergents used to wash vehicles – as is demonstrated in the discussion of the DOS garages (p. 56). The Department of Sanitation instituted extended preventive maintenance concerning oil and oil filter changes to a 60 day cycle. The analysis of using this program for 4197 vehicles out of 5582 in the DOS fleet, resulted in 212 tons of waste avoided and $657,527 annual savings. If one were to extrapolate from this success to the 25,000 vehicles operated by the City, savings could be as high as $3.9 million.
Lack of Recycling Programs
The report also documents the lack of proper recycling programs in city agencies. This includes the city’s failure to provide pick-ups for all the targeted materials. The costs of failing to maximize recycling are quite clearly laid out under the discussion of the Taxi and Limousine Commission. The one day sort estimated an annual generation of 11 tons of recyclables, which will cost the City approximately $1100 to export, and with a recycling program achieving only 50% recovery, it would cost the City only $830 total for both recyclable processing and export. This small example however, demonstrates that City agencies could achieve a 25.5% savings by increasing recycling.
Using the export and recycling processing costs provided in the report, we looked at the increased recycling tonnages from June 1999 to June 2000. If this 13% increase in recycling had not been collected because there was no weekly recycling program in the City and was instead exported at $100 per ton, it would cost the city $4.758 million annually in export costs. Instead, largely due to the institution of weekly recycling, the City is instead receiving $321,000 in annual revenues. These revenues are primarily due to paper because the increased recovery of paper overwhelms the cost of processing the mixed containers.
City agencies perceive that waste services are provided at no cost to them and with limited resources from budget cutbacks and little upper management support they have difficulty focusing on waste, which is not part of the main mission of the agency. The lack of cooperation and attention given to this project by City Agencies was surprising in light of the Mayoral Directive. The limited nature of the study--a one day look at selected operations within some agencies following a questionnaire survey that few responded to--means that the absence of baseline information regarding waste generation in city agencies will continue. Desperately needed are extrapolation of findings to similar operations citywide, high level waste prevention coordinators within each agency and agency waste prevention plans and a means of holding agencies accountable. SAIC suggests exploring fees and incentives.
Granted, almost no funding has been dedicated to waste prevention since 1992, so numerous unrealized opportunities are to be expected.
However, recycling has been a requirement for the entire city, so why should city agencies not be recycling? City employees would learn how to recycle, and the public would see the example set by city agencies when visiting city public buildings. School children would see recycling in their schools and bring the message home. This priceless educational message would also reduce the generation of waste to be exported.
Waste prevention is still the forgotten stepchild, even in the face of huge export costs for garbage. The Council should remember that this Department of Sanitation said we would never be able to reach a 20% recycling rate and more recently it maintained before the Council that there was no point in moving to weekly recycling because there would be no more recyclables to collect. Actually there were approx. 80,400 tons more recyclables collected for the year ending in June 2000.
C. Highlights of Consultant Recommendations
Note: The Waste Prevention Action Plan agency waste prevention activities would enable implementation of all of these recommendations. (See appendix A)
Since this project was concluded some two years ago, we do not know which, if any, of the recommendations were implemented. The latest environmental procurement report from DCAS (for FY97 and FY98) was woefully inadequate and inaccurate, as was presented to the Council in hearings last spring.
Intro 482, now before the City Council, would go a long way towards implementing the suggestions of SAIC in the NYCitySen$e Project. It includes many of the 12 recommendations discussed above. It is the goal of the Waste Prevention Coalition to see it passed.
The NYCSen$e Report glaringly confirms the opportunities available if waste prevention were institutionalized in NYC operations. The numerous findings are the tip of the iceberg of what is possible. With such a time and resource limited effort only the most obvious opportunities are noted, yet the potential savings are astounding. Funding a substantial and ongoing waste prevention effort would provide programs in all city agencies, quasi-Mayoral agencies and institutions that receive free collection as well as a program for city households.
The Waste Prevention Characterization report was a disappointment. Since 1989, while DOS was undertaking a 46-material sort, the Manhattan Citizen Solid Waste Advisory Board's (MCSWAB) 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 MCSWAB Waste Prevention Committee for a list of products and packaging to study for this report (see Appendix B). 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 1993 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.
This report provides an overview of interesting and successful waste prevention programs in thirteen cities, three counties, and two states from across the United States.
It should be noted that two significant areas were missing from this report: a review of any legislation that addresses waste prevention across the country; and a review of PAYT (Pay As You Throw) Programs, which have been shown to reduce waste significantly.
The Executive Summary explains that over half of the surveyed cities have separate budgets for waste prevention programs, and that funding for them can be "derived from a variety of sources". The examples cited offer New York City innovative funding mechanisms for implementing programs that are both effective and affordable. They demonstrate that if the will to create the programs is strong, sufficient funding is possible.
For example, the City of San Diego has established partnerships with the local utilities and organizations such as the San Diego Zoo as a means to obtain funding for residential waste prevention programs. In San Antonio, Texas, the local water board supports San Antonio’s household hazardous waste prevention program. The City of Milwaukee participates in a regional waste reduction campaign that receives state funding and is then matched by the municipality through in-kind costs.
Examples illustrated in the report also show that some cities’ budgets for their waste prevention programs are substantially higher than New York City’s. For example, Seattle’s waste prevention program budget is $750,000. With a population of 540,000, that equals $1.38 per person, the equivalent of a $10.4 million waste prevention program budget for NYC. This is right in line with the waste prevention program budget proposals offered by the New York City Waste Prevention Coalition.
Many of the programs reported from other areas are very similar to those proposed by the WPC. For example, in King County, Washington, the heart of their extensive and successful residential outreach and education is the Master Recycler/Composter Program, which involves residents who encourage their neighbors to practice waste prevention, recycling, backyard composting, and safe management of household hazardous wastes. This program is very much like the community-based waste prevention/recycling coordinators proposed by the WPC.
Further, the approach proposed by the NYC Waste Prevention Coalition (WPC) – that the City should contract with local community-based organizations to implement waste prevention and recycling outreach and education programs—is supported by the experiences of many other municipalities documented in this report. Over half of the survey respondents use independent contractors to set up or implement waste prevention programs.
The City of Philadelphia provided funding to a pilot program established with a local non-profit environmental organization, the Clean Air Council, which then created a commercial waste assessment program for local businesses, similar to the waste audit / prevention specialists suggested by the Coalition.
Phoenix Clean & Beautiful, that city’s Keep America Beautiful affiliate, oversees their commercial waste prevention programs, including waste assessments, paper use and packaging reduction strategies, as well as a materials exchange for local businesses which is similar to the NYC WasteMatch program which the WPC proposes expanding.
Many of the other programs listed in this report are comparable to the proposals made by the Waste Prevention Coalition, and provide possibilities that New York City’s leaders can use to design comprehensive waste prevention programs that would be incorporated into a model, sustainable solid waste management plan for our future. (See Appendix A)
VI. Inter-Agency Task Force Action Plan: Recycled-Content Building Materials
This report provides a number of recommendations promoting the safe use of recycled-content materials in City construction projects. Unfortunately, most of the recommendations are outdated.
The Task Force’s report was completed in 1997, but neither the 1993 Mayoral Directive and Memorandum to All Construction Agencies nor the 1997 Executive Order of the NYC Department of Buildings was mentioned. Moreover, there was no mention of which recommendations, if any, had been implemented in the three years since the Task Force met. The Department of Design and Construction’s High Performance Building Guidelines, a highly praised document published in 1999, was only mentioned in passing.
This report missed some clear opportunities for benefiting the City. The most notable refers to the Materials and Equipment Approval process. The report stated very clearly that New York City’s Building Code does not discriminate against recycled-content materials (as long as the materials meet the necessary performance standards), but that market forces do play a major role in limiting their widespread use. This is attributed primarily to the high cost of conducting product testing necessary for code approval, especially for new companies with minimal financial resources. The consultants note that this fact should not preclude having the appropriate tests performed. Unfortunately, all too often it does. This is precisely the type of situation that the Waste Prevention Coalition’s proposal for Technical and Financial Assistance to Recycling, Reuse and Remanufacturing Businesses could fund.
Another simple element missing was a list of all recycled-content building materials that have been approved. The construction industry, as the report states, is one of the City’s largest consumers of materials, and thus potentially represents a major market for recyclable materials recovered from the City’s waste stream. Providing a simple list of available, approved products is a clear and simple opportunity for the City to facilitate the use of recycled-content building materials.
VII. Materials Exchange Research Report
The stated purpose of this report was to support the launching of the Department of Sanitation’s Wa$teMatch program designed to encourage the industrial reuse of non-traditional materials. While the report did offer innovative and valuable examples of traditional reuse and recycling transactions, such as pallets and sawdust, it did not highlight many examples of "non-traditional" ones, such as odd lot materials. The report did not discuss any of the materials exchange successes happening in NYC through the LIC LDC. Furthermore, it is questionable why research was not conducted to support other DOS funded material exchange programs such as the NYC Stuff Exchange and Materials for the Arts.
Nonetheless, the report illustrates that material exchange programs are useful and successful, providing ample support for Wa$teMatch, a program the Waste Prevention Coalition proposes be expanded to reach its full potential. Unfortunately, DOS has made no commitment to continue funding Wa$teMatch after its initial 5-year term expires in 2001.
VIII. Packaging Restrictions Research: Targeting Packaging for Reduction, Reuse, Recycling and Recycled Content
This report is an interesting review of policy strategies that can be implemented to reduce packaging waste. Unfortunately, the report, still in draft form, concentrates on policy changes that must be adopted by either the State or Federal Government downplaying the much-needed strategies that can and should be adopted by the City of New York.
These strategies include:
According to the Characterization report, packaging represents a considerable portion of the City’s waste stream. It is therefore a breach of responsibility for the City to discount actions and strategies to reduce the amount of packaging generated and wasted here.
IX. Procurement Strategies of Federal Agencies and Jurisdictions Beyond NYC for Waste Prevention and Recycled Products
Unfortunately, there is not a lot of useful information in this report. Of greatest concern is that, despite the bold headlines on every page, the report does not explore the relevance of the programs profiled to New York City. In fact, New York City is only mentioned once (other than the page headings) with a very minimal recommendation (p.16).
The report does not put any of its information on other programs in the context of the City’s procurement requirements and does not even mention that under Local Law 19 the City is supposed to purchase the 54 products listed in the EPA’s Comprehensive Procurement Guideline. In fact, the report only mentions the guideline in passing and ignores its relevance here and elsewhere.
Like many of the other reports, the information on procurement programs is very outdated. The profiles miss some world renowned "winners," such as the programs in King County, WA, Alameda County, CA, and the States of Massachusetts and North Carolina. Also unmentioned is the State of New York’s program, a strong program that is directly applicable here since City agencies are allowed to purchase off state contracts.
Further, most of the program components described as "innovative," such as the use of energy star computers, are not, while truly innovative programs were overlooked entirely. For example, the profile of the US Postal Service fails to mention the impressive environmental purchasing program in place at the USPS garages right here in the City, where they use retread tires, re-refined oil, and antifreeze, and reused oil and air filters, among other things, and save millions of dollars every year
X. Life Span Costing Analysis Case Studies
This brief report examined the importance of looking at not just the purchase price of a product but also at how a product is used in the real world to determine its true cost impacts. Only 10 products were selected. It is not quite clear why these particular 10 were selected, however life span cost analysis is obviously useful from an overall cost perspective. For example, in the NYCitySen$e Project the DOS noted that one detergent they were buying was not effective and had to be used at a higher concentration. As a result, the actual use of the product showed that what appeared to be the cheaper product, based solely on purchase price, actually ended up costing the city more money.
It should be particularly noted for readers of this consultant report that the units vary dramatically from product to product. Therefore, savings may be given for all city agencies (as is the case for toilet paper), for one area of an agency, or for a single item (like a park bench in the analysis for plastic lumber).
Long-life antifreeze will save 50% annually regardless of fleet size. Despite its higher initial cost, replacement on a five-year rather than a two-year cycle saves money.
Two-way envelope use by the Dept. of Finance alone would save $90,881 per year over mailing one envelope with another inside.
Synthetic motor oil for MTA buses vs. virgin motor oil would save $727.06 per bus, or $2.6 million for the fleet.
Use of Recycled Plastic Lumber for park benches vs. wood saves almost half the cost over a lifetime, $3.26 vs. $6.07. This is true because despite the higher cost of plastic lumber it lasts much longer- 50 years vs. 6 years. The writer of this review urges some caution here since these products have not been available for a long time and different manufacturers may produce different grades of plastic lumber. This is the sort of thing that needs a pilot.
Type of Sorbent used for spills by DOS could save between $3,000 and $5000 while avoiding the generation of almost 9 tons of waste.
Toilet Paper – switching to a certain type of controlled dispensing system could save the City $106,167 per year.
These were just a few of the products examined. We were surprised and disappointed not to see the reusable or permanent oil filters mentioned here. These oil filters were discussed in the NYC WasteLe$$ report in the detailed review of La Guardia airport. While we were not provided with detailed calculations on the savings for an entire fleet, we were told that the payback period for the investment in these filters at $75 each is less than 2 years, just including the comparison to disposable filters, not including the costs of hauling disposable oil filters. The City pays a $40-50 per drum for hauling away used disposable oil filters.
The benefits of life span cost analysis are quite clear, and the City needs research capacity to undertake these sorts of reviews. The analysis of recycling tires into road paving material would be an important one given the reported benefits of long life, less maintenance, reduced noise and frost heaving. (These benefits were reported elsewhere in a BioCycle Journal article.)
XI. NYC WasteLe$$ Summary Report
This project focused on business sectors in NYC representing a large percentage (73%) of NYC’s economy. Nine business sectors were analyzed in detail, a website of information was developed along with newsletters, and seminars were conducted. The website is available at www.nycwasteless.com.
The nine sectors are: airlines and airports; restaurants; retail food; manufacturing; retail; wholesale; stadiums and convention centers; schools; and, hospitals. Detailed audits of participating businesses were also done and clearly this was a major effort launched by the City. Such detailed audits need to be conducted for agencies and institutions in NYC.
Notable successes include Eagle Electric, which eliminated its entire waste stream of plastic scrap because a reuse market was found resulting in annual revenue of $69,000. The Jamaica Food Market is composting its food waste at a savings of $6,500 per year. US Airways at LaGuardia was discarding wood pallets that they discovered could be used in their trucking operation at JFK with savings of $40,000 per year.
However, it is clear that the project was very ambitious and may have asked too much of partners, or failed to anticipate some business issues which affect participation in any time limited project. Important lessons were learned and the detailed recommendations in the report should make for better implementation of waste prevention with businesses in the future.
XII. Report Recommendations
The NYC Waste Prevention Coalition has provided the Council with a detailed set of recommendations constituting a 5-year plan for waste prevention (see appendix A). 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 (residents, businesses and agencies), as well as composting, QBUFs and measurement.
A few summary recommendations by the consultants 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:
The reports also described many positive initiatives that can be used to inform City policymaking. They include:
Quantity Based User Fees
Quantity Based User Fees (QBUFs) – a system where residents and waste generators are charged based on the amount of waste they generate, rather than taxed for waste collection – has proven to help communities around the country reduce waste and recycle more. DOS has neglected to pursue this route, even though DOS’ own waste prevention consultants also recommended this in 1992. We encourage the Council to direct DOS to find opportunities to implement at least some pilot projects or limited QBUF programs.
Quantity-Based User Fees are used in over 5,000 cities and towns in the US, and this number has been building over the last decade. Research has shown that QBUFs increase recycling diversion rates, since recycling is usually either free or low-cost in QBUF systems, and is therefore cheaper than throwing recyclables in the garbage. 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.
Research has shown that economic incentives to change behavior, such as QBUFs, if
instituted along with a vigorous education program to indicate how and why to change
purchasing habits, product repair and maintenance habits and product disposition habits
(e.g., donations, sales, gifts), will be the most effective way to encourage waste
prevention. A few states (e.g., Minnesota) require QBUF pricing strategies.
USEPA has been pushing for this and will be hosting a "QBUFs in Urban Areas"
Workshop with Cornell Cooperative Extension and DOS on Dec. 11 at EPA’s offices in
New York City. Members of the City Council, including Sabini and Leffler have been
asking DOS why this method has not been pursued here in NYC.
The NYC Waste Prevention Coalition recommends the following six-part QBUF Plan:
Taken without DOS’s negative overtones, the Waste Prevention Research reports present useful information that can help to fashion a cost-effective and viable waste prevention agenda for New York City. Even though there are deficiencies in the documents, they show many ways in which waste prevention will save the City money.
Regardless of their deficiencies in analysis, the DOS reports support the implementation of the Waste Prevention Coalition’s proposed programs for residential, city agency and business waste prevention. 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.)
It is important to note that in the Draft New York State Solid Waste Management Plan, 1999-2000 Update, the State not only emphasizes that "to reduce the amount of waste generated’ is the first order of preference in the management of solid waste…" it also states that the DEC has "chosen to direct its resources toward advancing waste reduction efforts, rather than attempting to merely quantify waste reduction achievements" (p. 8).
The Council would be well advised to follow the State’s lead by emphasizing waste prevention first, through implementation as well as program evaluation. These reports confirm that waste prevention works. The Council has the opportunity to demonstrate leadership by reducing waste and saving taxpayer dollars by investing in waste prevention. Your choice is to continue to study and deliberate, or Just Do It!
Nearly a decade ago, this Council forced the DOS to make recycling happen after they sat before you and said it couldn’t be done. You proved them wrong on that count and you can do it again. The Waste Prevention Coalition urges you to take action to implement waste prevention now.