The
NYC Waste Prevention Coalition (NYCWPC)
C/O INFORM, Inc.
New York , NY
PH: 212-361-2400 x226 FAX: 212-361-2412
Analysis of the NYC
Department of Sanitation
Waste Prevention and Recycled Product Research
Project Reports
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
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
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
T a b l e o f
R e p o r t s
I. Summary
II.
Measuring Waste Prevention in
III. NYCitySen$e Summary Report
IV. Characterization of NYC’s Solid Waste Stream
V.
Survey of Waste Prevention Programs in
VI.
Inter-Agency Task Force Action Plan to Encourage the
Use of
VII. Materials Exchange Research Report
VIII. Packaging Restrictions Research: Targeting Packaging for Reduction, Reuse, and Recycled Content
IX. Procurement Strategies Pursued by Federal Agencies and Jurisdictions Beyond NYC for Waste Prevention and Recycled Products
X. Life Span Costing Analysis Case Studies
XI. NYC WasteLe$$ Summary Report
XII. Report Recommendations
XIII. Conclusion
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
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
Ø Waste
Prevention is Cost Effective
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.
Ø Waste Prevention Public Education Works
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
Ø City Agencies Can Benefit
from Waste Prevention
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.
Ø
Business Waste Prevention Programs Offer Significant Returns
For example, the NYC WasteLe$$ program provided savings to participants of nearly $9 million per year – a net present value of $37 million in savings over the life of the project. Clearly, these types of cost reductions help to keep businesses thriving in the City, supporting jobs and adding to our tax base. It is for these reasons that the Waste Prevention Coalition proposes expanding the City’s business waste prevention efforts.
Ø The City Has Many Opportunities to Expand its Waste Prevention Programs
While the City has tested and tried many different waste
prevention programs, the number and scope of its programs is still relatively
small for such a
“DOS has both the knowledge and the capability to develop additional programs, such as a citywide public awareness campaign…. a ban on residential set out of grass clippings…. local quantity based user fees….a high visibility citywide campaign to heighten awareness, provide explicit guidance, and offer incentives and penalties. Above all, the City must lead by example and publicize its own efforts and achievements.” (page 128-129)
Clearly, there is much to be done. Unfortunately, the Draft SWMP does not seize these opportunities.
B.) Flaws in the DOS Approach
The reports are not integrated with the Draft SWMP Modification, May 2000, or with each other. Even though DOS had all of this information when it was preparing the Draft SWMP Modification, that document does not include any milestones or recommended actions based on these reports. And, although they delayed the release of these reports for years, they did not make an attempt to integrate the information from different reports, such as the City$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
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
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.
B.) Waste Prevention Education
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
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.
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.
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:
· the lack of a computer tracking system for goods purchased in the City;
· the lack of a computer system to make used furniture and equipment available to other agencies; and
· the lack of agency capacity to move reusables elsewhere and the cutbacks that have impacted DCAS’ ability to provide pick-up and distribution services.
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.
B.
Lessons
Learned from the NYCitySen$e Project
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)
- Five key areas for initial waste prevention efforts in city agencies were identified:
- a citywide pallet management program;
- a vehicle maintenance oil and filter reduction program;
- an office paper use reduction program;
- an
electronic employee telephone directory program;
- and,
a furniture relinquishment program
- Education and outreach, beginning on the managerial level and extending with seminars and information to 250,000 staff is the first important step.
- DCAS must adhere to its commitment to the development of a purchasing catalog in which those items meeting Federal and State standards for recycled content and lack of toxicity be clearly marked. It goes without saying that this catalog should be issued electronically.
- Funds need to be available setting up and staffing a sophisticated tracking system for exchange, storage, reuse, refurbishing, availability of equipment, furniture, packaging, pallets and scrap. This involves the need for updated dissemination of information.
- Drivers
and trucks, called for in the
- Vendors should be given the opportunity to exchange information on more durable, less toxic, and minimized packaging, plus more returnables, bulk shipment, large refillable tank dispensers where appropriate, and also products with more post-consumer recycled content. This could lead to a system of price-preference in awarding contracts.
- Exploration of more environmentally friendly and economically prudent alternatives to currently used products and practices should become part of the priority of DCAS, DMS and the Mayor’s Office of Operations. To this end, each agency needs an identified coordinator.
- SAIC suggests getting baseline waste information, establishing a reward system for waste reduction, and testing Quantity Based User Fees as an incentive.
- Leasing equipment to be returned for refurbishing to the vendor when the contract expires was discussed as an area for study. In some instances rebuilt or recycled items with the same warranties as new ones might be leased or purchased.
- The City’s contract with Lexmark for copiers was extensively discussed. Not only must a second piece of equipment be bought to make the recommended process of duplex copying possible, but the recycling of toner cartridges with any other supplier is not available. Aside from the purchases made by DCAS, each agency can order from the Staples catalog. Discussions with Staples on preventing waste, such as delivering in returnable, reusable containers, proved fruitless.
- Using dishwashers in agencies where they exist and buying them for others where they do not, would save an enormous amount of largely unrecyclable waste now collected from agencies and institutions throughout the City at great expense fiscally and environmentally.
- We are in the electronic age. Paper use and the many ways it could be reduced were repeatedly described in the document. Many agencies do not communicate or disseminate information electronically. The few examples given were a mere drop in the proverbial bucket.
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.
IV.
Characterization of
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
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
V.
Survey of Waste Prevention Programs in
This report provides an overview of interesting and
successful waste prevention programs in thirteen cities, three counties, and
two states from across the
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
For example, the City of
Examples illustrated in the report also show that some
cities’ budgets for their waste prevention programs are substantially higher
than
Many of the programs
reported from other areas are very similar to those proposed by the
Further, the approach proposed by the NYC Waste Prevention
Coalition (
The City of
Many of the other programs
listed in this report are comparable to the proposals made by the Waste
Prevention Coalition, and provide possibilities that
VI. Inter-Agency Task Force
Action Plan:
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.
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
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
These strategies include:
- using the Waste Prevention Coalition’s recommended Community-Based Coordinators to work with City food establishments to reduce packaging;
- following the lead of communities such as Seattle and San Francisco in establishing the purchasing requirements for city agencies recommended in Intro 482; and
- approving a tax on excess packaging like the City of
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
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
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
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.
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:
· 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
The reports also described many positive initiatives that can be used to inform City policymaking. They 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
· Enacting environmental procurement policies (Intro. 482 addresses this).
·
Adopting Quantity-Based User Fees (see below)
for pricing waste services “to achieve the level of industry and consumer
behavior change necessary for substantial reductions in the
· Providing ongoing public education, starting a multi-media campaign to educate the public about a citywide materials exchange, taking care to devote sufficient time and effort to ensure success, and communicating the monetary benefits of using materials exchanges.
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
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.,
The NYC Waste Prevention Coalition recommends the following six-part QBUF Plan:
1. First, determine how much is the net cost for garbage services (collection, transfer and export) and recycling services (collection and marketing – sum) per person or household. Show this figure as a line item on the real estate bills of home and building owners, with educational leaflet, to show people that we have been paying for garbage services all along. In fact, it would be even better to show how much garbage services cost 5 years ago as well as the present costs, along with a description of the reason why (i.e. export), and an indication of how much less it would cost if we reduced and recycled more.
2. Research ways that other cities have successfully instituted QBUFs (a) where no separate charges had been made for garbage in the past; and (b) where there are apartment buildings.
3. Perform a pilot test of a QBUF system in single- and two-family homes to optimize a program for NYC.
4. Institute QBUFs in low-density areas of the City.
5. Undertake a pilot test of QBUFs in multi-family dwellings. Try out different bag, tag, can systems; vary the cost/benefit, educational materials, etc.
6. Institute QBUFs in high-density areas of the City.
XIII.
Conclusion
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
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.
Appendix A
WASTE PREVENTION ACTION PLAN
In the spring of this year, the New York City
1. Community Based Waste Prevention
- Community
Based Waste Prevention/Recycling Coordinators
Coordinators would perform education and outreach in the City’s 59 community districts serving as accessible sources of information on waste prevention and recycling to residents, businesses, schools and other institutions in their districts.
·
“
· “The City of Blaine, Minnesota conducted a targeted public education campaign…Waste generation in the target zone decreased by 4.75 percent, after adjusting for reductions due to recycling” (Measuring Waste Prevention, p. 19).
·
· In regard to municipalities’ responsibility for reducing packaging waste “the City of New York can act as a driver for more environmental products…by educating the City’s large consumer base” (Packaging Waste, p. 18).
- Community
Based Waste Prevention Projects
A $7 million grant fund to finance community-based waste prevention projects, such as community reuse centers and vocational reuse programs. The Waste Prevention Coordinators could oversee the projects, or they could be performed by other organizations.
· The consultants found that if the NYC Stuff Exchange was expanded to be City-wide, 4,994 tons of waste would be reduced. This highlights the probability of residents utilizing reuse resources and supports the Coalition’s proposals for community based waste prevention projects. (Measuring Waste Prevention, p. 41).
· Materials for the Arts receives goods from residents as well as businesses, clearly illustrating the potential for reuse and material exchange programs at the neighborhood level. The program in 1998 saved DOS $41.50/ton for disposal costs and most likely at present saves more than the projected 2000 savings of $62.88/ton due to the increase in waste disposal costs since the time this report was completed (Measuring Waste Prevention Programs, p. 66). Materials for the Arts also accrues savings to its clients due to reduced need to purchase new products and materials.
·
New Threads, a
·
·
2. Waste Prevention in City Agencies and Institutions
- Waste
Prevention in the Department of City-Wide Administrative Services
Seven staff people responsible for the increase in recycling and waste prevention activities within City agencies and to increase the purchase of recycled and waste preventing products. In addition, the City’s Agency Surplus Materials Reuse program would be expanded and made more efficient.
·
“Expand and enhance waste prevention and
recycling education [in City agencies].
City Agency Commissioners and upper management at Agencies, Boards, and
Commissions are key to motivating City employees and to raising awareness of
the fact that preventing waste can reduce purchasing costs and decrease the
cost to collect, transfer and export waste to out-of-state facilities” (NYCitySen$e
Project Summary, p. 118). The
Coalition’s staff recommendations include a Deputy Director for Waste
Prevention within the Mayor’s Office of Operations.
· “Commit resources to assist the Department of Citywide Administrative Services to identify and provide less wasteful products and services. DCAS could consider offering a list of recycled content, energy efficient, or reusable products available…evaluate the merits and feasibility of making trucks and drivers available to the DCAS Office of Surplus Activities to provide transportation services” (NYCitySen$e Project Summary, p. 119-120). The Coalition’s staff recommendations include environmental purchasing coordinators. The proposal also calls for trucks and an electronic inventory tracking system.
·
- Waste
Prevention Technical Assistance to Public Institutions and City Agencies
A waste prevention technical assistance center staffed with waste audit/prevention specialists serving public institutions. The Center would also serve as a clearinghouse of information on waste prevention in the public sector.
· “Examine the merits and feasibility of assisting Agencies in establishing a formal waste prevention training plan…examine the feasibility of assisting Agencies to incorporate waste prevention an recycling achievements as one of the performance indicators for Agency management” (NYCitySen$e Project Summary, p. 119).
· “The audit consisted of a physical sort of all waste and recyclables generated by the operation(s) during a specified 24-hour period” (NYCitySen$e Project Summary, p. 9). The audits conducted under the CitySen$e project were extremely limited in scope and duration. The waste prevention staff funded through the Coalition’s Technical Assistance to City Agencies program would be able to conduct more comprehensive and meaningful waste audits to identify opportunities for waste prevention.
- Revolving
Capital Funds for Waste Prevention
Two capital funds of $5 million each to be used for implementation of waste prevention projects identified through waste audits. One fund would be for City agencies or quasi-city agencies and the other would be for private institutions that receive free waste collection from the City.
· Department of Environmental Protection could, “Repair/replace photocopy machines that cannot readily produce double-sided copies” (NYCitySen$e Project Summary, p. 34). The capital cost necessary to implement this recommendation could be funded through the Revolving Capital Fund.
·
Agencies could establish an enhanced pallet
management program. In order for the
program to be effective, baseline data is needed (NYCitySen$e
Project Summary, p. A-3). This
research could be funded under the Revolving Capital Fund.
·
- Waste
Prevention in the Health and Hospitals Corporation
Six waste prevention coordinators within the Health and Hospitals Corporation responsible for the supervision and implementation of waste prevention practices and procurement with NYC’s public hospitals. These measures would reduce the volume and toxicity of waste generated.
· The Health and Hospitals Corporation generates approximately 257,325 tons of waste each year, of which packaging makes up 30 to 60 percent. If there was only a 10% participation rate for implemented waste prevention programs, 7,720-15,440 tons of waste each year could be prevented (NYC WasteLe$$ Summary Report, p. 54). This would result in a savings of $737,260-$1,474,520 each year.
- Waste
Prevention in Schools
Eliminate the use of disposable food service trays in the cafeterias of the 201 NYC public schools that have unused dishwashers.
3. Composting and Organic Waste
Prevention
A.
Backyard Composting and Organic Waste Prevention
Increase Department of Sanitation’s outreach and promotional efforts to encourage backyard composting and organic waste prevention activities.
· “The Department of Sanitation has not initiated a comprehensive effort to evaluate or quantify the full waste prevention and cost savings impacts of the ongoing compost initiatives undertaken by DOS-funded staff at the Botanical Gardens” (Measuring Waste Prevention, p. 105). If the composting program was expanded, staff could complete this important task as well as increase the amount of organic waste prevented through intensified outreach and public education efforts.
· The City of San Antonio, TX has encouraged citizens to participate in yard waste prevention programs such as Backyard Composting and Don’t Bag It, through local government cable TV and an innovative door hanger publicity campaign. Three times a year, door hangers are placed at individuals’ households promoting the composting programs (Survey of Waste Prevention Programs, p. 25-26).
B.
Institutional In-Vessel Composting Pilot Program
Install multiple small scale in-vessel composting systems for food waste/organic material from hospitals, colleges, nursing homes and large cafeterias. Test mixed waste composting systems, either within or outside the City, to evaluate the feasibility of composting as an alternative to export.
4. Waste Prevention in the
Private Sector
A.
Technical Assistance to Help Businesses Prevent
Waste
Multiple component program that expands the WasteMatch program, a materials exchange service for NYC businesses, develops a waste prevention technical assistance center staffed with waste audit/prevention specialists serving private businesses, and establishes a $5 million capital fund to finance investments to foster waste prevention and reuse in the private sector.
· “Wa$teMatch can be expected to raise the waste prevention and recycling awareness of the business community. [Wa$teMatch] benefits the City by helping businesses to become more competitive and sustainable” (NYC Materials Exchange Roundtable, p. 3).
· Philadelphia “established pollution prevention and waste reduction programs to develop simple, creative ways for businesses…to voluntarily reduce the amount of waste they generate on site” (Survey of Waste Prevention Programs, p. 23).
· Phoenix Clean and Beautiful provides programs for the commercial sector such as: paper use reduction, packaging reduction and materials exchange (Survey of Waste Prevention Programs, p. 24).
· Milwaukee, WI provides a variety of waste prevention services to businesses including: business waste reduction kits, guides, brochures, industry-specific fact sheets and online information services. Business mentors also offer technical assistance to other businesses seeking waste prevention advice through the Be SMART Business Line (Survey of Waste Prevention Programs, p. 20).
· Seattle, WA operates the Business and Industry Recycling Venture which provides technical assistance to businesses in the area through a variety of strategies including: Construction, Demolition and Land Use Initiative, Waste Wise Packaging Database, Law Firm Waste Reduction Network, industry specific fact sheets, and direct mail reduction campaign (Survey of Waste Prevention Programs, p. 37).
B.
Technical and Financial Assistance to Recycling,
Reuse and Remanufacturing Businesses
Two staff positions responsible for the fostering of the attraction, development and expansion of recycling, reuse and remanufacturing businesses and create a $5 million fund for reuse, remanufacturing and recycling projects in New York City.
· “Recycled-content products are often produced by new companies…The minimal financial resources of a new company producing recycled-content products should not preclude having the appropriate tests performed and filed for their products, which will serve to enhance their products’ reputations” (Recycled-Content Building Materials, p. 16). The proposed $5 million grant could fund these types of activities.
5. Waste Prevention Measurement,
Evaluation and Research
A.
Residential Quantity Based User Fee (QBUF) Pilot
Project
Allocate money to design, test and evaluate a high-rise garbage meter for use in pilot residential program that would charge tenants and building owners for garbage collection and disposal services according to the quantity of the service they use.
· “To achieve the level of industry and consumer behavior change necessary for substantial reductions in the New York City solid waste stream,…politically challenging initiatives, such as quantity-based user fees, are needed” (Measuring Waste Prevention, p. ES9).
· “Packaging in the municipal solid waste stream can be reduced [by] consumers choos[ing] to buy products with the least packaging. Municipalities like New York City [should] continue to develop and expand programs targeting [consumers by] adopting pay-as-you-throw pricing” (Packaging Roundtable, p. 18).
· San Jose, CA has a “pay as you throw” program for both single and multiple family dwellings, which is considered a motivator to prevent waste. “The rate charged for citizens who live in multiple family dwellings is based on the size of the building’s dumpster used for trash collection. All individual inhabiting the building, therefore, pay the same fee, which is included in their rent” (Survey of Waste Prevention Programs, p. 32). The garbage meter pilot program proposed by the Coalition would help determine how best to implement pay as you throw programs in New York City.
B.
Measurement, Evaluation and Proposal of Waste
Prevention Programs
Staff position to develop a methodology and annually evaluate each waste prevention program, incentive, law, directive or other measure.
· “Waste prevention measurement is a worthwhile undertaking. Despite the stated obstacles to and limited experience in measuring waste prevention, DOS recognizes a number of factors reinforcing the push to develop and refine measurement approaches” (Measuring Waste Prevention, p. 128