COMMENTS ON WASTE PREVENTION AS PRESENTED

DRAFT COMMENTS ON WASTE PREVENTION AS PRESENTED IN THE NYC COUNCIL RESPONSE TO THE FRESH KILLS TASK FORCE REPORT
Waste Prevention Committee

Manhattan Citizens' Solid Waste Advisory Board

November 12, 1997

It becomes immediately evident that Council wishes to promote a stronger commitment to waste reduction than did the Task Force. NYC Council is a legislative body, which in this report has supported the approach of putting waste reduction measures into law. Many of us have long felt that codification into law is the only way to secure permanent waste reduction procurement and practices. Not least among these is Intro 509 dealing primarily with City Agency procurement. We urge you to pass Intro 509 at your earliest opportunity and we wholeheartedly agree with taking a legislative approach to preventing waste, as part of an integrated strategy of research and education, legislation, incentives, reporting and enforcement.

With respect to The Mayoral Directive 96-2 on City Agency Waste Prevention Practices, Council recognizes the many good features. We have also applauded this Directive, and in fact, have suggested that it and some new initiatives be codified into law. However, the focus of the Directive is largely limited to paper-related waste prevention practices, whereas the potential for preventing waste in City agencies is far greater. As one example, the City could save resources by instituting a computerized tracking system for reusable items (computers, furniture, etc…) in its warehouse, which is accessible to those in City agencies. We hope that you will introduce and support the new legislation that we and the Manhattan SWAB submitted recently to your committee.

Besides passing legislation to require and track environmental procurement and waste prevention practices by City agencies, there is a great need for other forms of legislation to help the City reduce the amount of waste created by its residents, institutions and businesses. These include:

Advance Disposal Fees (ADFs) were recommended to DOS by its consultants as a means of assessing the designers and manufacturers of "problem" products a fee ostensibly to offset increased expenditures by the City for waste treatment and disposal and their impacts. Problem products can include those containing toxic constituents (e.g., batteries), to tires, to disposables, to overly packaged goods.

Junk Mail legislation can be structured to ensure that senders of junk mail must include a postpaid card to remove the recipient from the mailing list. The cost of the cards and the postage would provide an incentive to the mailer to keep lists pared down. The target of such legislation would not only include senders of catalogs, but other forms of direct mail as well.

The Council's report recommends elimination of sales taxes on mulching mowers. We agree, but this meritorious concept should also apply to other durable items that encourage prevention of waste (e.g., double-sided copiers and printers, printers that use less quantity and less toxicity of toner).

Intro 509 is targeted towards increasing recycled content and reducing the volume of City purchases. In addition to these concepts, broad-based environmentally sound purchasing also includes reducing the quantity of toxic constituents in items purchased by the City, as well as purchasing durable items that conserve energy and water. Legislation is needed to address these issues.

The Task Force and Council reports make other good recommendations as regards business practices to reduce waste. By way of suggestion, it may be more effective and equitable to require all stores to charge a minimum amount for each bag taken at markets rather than giving credit for bags not taken. Further, take-out food establishments could be required to charge customers if they want more than a very limited amount of paper napkins, plastic utensils, and for condiments and double bagging. Council could require that signs describing the charges and their waste prevention objective must be hung at or near each cash register.

Council should request and support New York State legislation to reduce packaging of products entering NYC. Packaging constitutes about a third of the waste stream, and new ways are being developed every year to produce overly packaged goods.

The notion of making each City Agency in some way responsible for the amount of waste it generates to be sound. Since simply charging agencies might backfire, resulting in more requests to Council for funding for garbage removal, and no incentive for waste prevention practices, perhaps it would be more effective to give incentives for reducing waste generation. If the savings to the DOS, by virtue of reduced garbage pickups and reduced need for disposal, could be split by DOS and the agency, then the agency would have a greater incentive not only to implement waste prevention practices, but also environmental procurement, and recycling. The City could implement a system, whereby the department would credit each city agency’s budget a fixed amount for each percent reduction in per employee waste volume disposed over a base year; or if the agency produced more waste, the city agency’s budget could be charged a fixed amount for each percent increase in per employee waste volume collected.

Finally, we address one major area omitted in the Task Force's report as well as Council's preliminary response to it. There is, without a doubt, a large potential for waste reduction in the residential sector of the City. As we have in the past, we still urge Council to support institution of the following programs and incentives:

1- Locating City Swap Centers strategically in as many Community Boards as possible, will serve many purposes including a place for: dropping off unwanted but potentially useful items that others might want, picking up those items others don't want, dropping off household hazardous waste, providing residents referrals to neighborhood businesses that can repair, refurbish, or rent durable items, and providing education about waste prevention opportunities and about recycling, just to name a few. Hennepin County, which has achieved a nearly 50% recycling rate, has two such County-run reuse centers.

2- Teaching repair courses (for appliances, electronics, furniture, etc…) in vocational schools (modeled after the "Recycle a Bicycle program") could go a long way towards reinvigorating a collapsing reuse/repair industry, encouraging economic development in the establishing neighborhood businesses, and keeping at-risk youth off the streets while improving their opportunities for gainful employment, not to mention waste prevention. We also recommend other school programs focusing on how to reuse (e.g., home economics and "shop"), as well as why (e.g., science and civics classes).

3- DOS' waste prevention education efforts have been largely aimed at educating businesses, which already have commercial QBUFs, and hence, the incentive to reduce on their own. There have been some subway ads and booklets, but these have reached few New Yorkers over a short time period. Since waste prevention can be achieved in so many ways, and it requires a change in the way people think about the things they buy and use, much more education is necessary. Experience with DOS' previous prevention and recycling educational programs has shown that outreach over limited time frames has not been sufficient to produce a long-lasting or dramatic effect. What has been shown to be effective is the use of many media at one time, in an intensive blitz, such as the Mayor's office has used to advertise his tax-free weeks. Everyone in the city was bombarded with this message over a short period of time, from every quarter, and much of the advertising was free, as news articles and stories. Little attempt has been made to create media events to advertise prevention or recycling. We recommend the implementation of six-month multi-media blitzes focusing on individual waste prevention concepts.

4- The DOS reuse hotline has been long-awaited, and would answer such questions as, "I have a framistam with lots of use left in it. Where can I donate it?" and "I have a widget that needs repair. Where can it be fixed"? We would also like to see establishment of a City materials and used products exchange, not only for industrial businesses, as DOS has promised us for years, but also for the office sector and for residences.

5- Quantity Based User Fees (QBUFs) exist in thousands of communities across the nation. DOS' first waste prevention consultants (hired for the first Solid Waste Management Plan) considered residential QBUFs a cornerstone of their waste prevention recommendations. It is a far more equitable system for funding solid waste collection and management than is the flat tax system we have, where each person is charged the same amount via taxes, regardless of the amount of garbage they produce. No one would argue that everyone should not pay the same amount for telephone or electrical service, since we all don't use the same amount of service. The City is now making the transition to water metering, again to make the charges more equitable and to encourage water conservation. In the same way "Pay as you Throw" systems encourage waste prevention and recycling. According to EPA, the establishment of QBUFs in 2,000 U.S. communities reduced solid waste by 25 to 45%, increasing recycling as well. Indeed there are challenges associated with changing from a tax-based to a fee-based system, but with the experience of thousands of cities and towns in making this transition, there are also viable solutions we can use here. A first step towards this would be itemization of garbage collection in home and building owners' tax bills. Then, instituting QBUFs first to owners of residential buildings, be they one and two family homes or apartment buildings (the Seattle Model) is not so complicated. Owners would be educated to the fact that they no longer pay taxes for solid waste management, and that they now pay on the basis of amount of non-recyclable wastes discarded. And once QBUFs have been established for home and building owners, assessing charges to tenants could be explored. Our best information from the EPA indicates that technology is becoming available for garbage metering in hi-rise buildings. Since Council has on two occasions previously required older technology chute-based solid waste management systems for apartment buildings, the next logical step is to move towards systems that facilitate recycling and waste prevention. Funding for pilot programs should be allocated to research the best ways to ease the transition to residential QBUFs.

6- Along with Council, we eagerly await the results of the ongoing SAIC studies that will give us many more ideas of just how NYC can reduce its waste significantly and how to assess the causes of reduction in waste generation. We believe that reports should be issued to the advisory boards every six months on every research program DOS undertakes.

7- Finally, since waste prevention has the greatest potential to save the City money (ton for ton) and reduce environmental impact, it must be given an elevated status in both DOS and DCAS as the two responsible agencies (e.g., in DOS this means Assistant Commissioner level status). This elevation must include increased allocations targeted for research, education and outreach, staff, and technology.

We hope that Council can support passage of the legislation described here as well as funding of these educational, research, and incentive programs. Furthermore, we urge the Council to codify in law timelines by which time these measures must be implemented by DOS and the other relevant agencies. If an aggressive waste prevention program is not implemented in all waste generating sectors, starting now, we will soon all have to pay as much as $200 per ton to have otherwise preventable / reusable items collected and shipped off to landfills and incinerators elsewhere. Surely this is not a scenario we want to pursue.