This testimony is written follow-up to comments that Borough President Reynoso gave in person at the June 3 hearing. Regarding Commercial Waste Zones, he hit three main points:
- DSNY putting a 40% weight on pricing in the RFP evaluation undermined the spirit of the law, which was specifically and thoughtfully designed to address safety and environmental justice.
- It is unacceptable that the RFP process allowed bad actors such as Cogent to receive zone awards. BIC testified that is it not in their mandate to consider worker safety; however this contradicts Local Law 198 of 2019, which added language requiring them to: “establish and enforce standards for service and for the regulation and conduct of businesses licensed or registered pursuant to this chapter, including but not limited to… environmental, safety and health standards, including but not limited to traffic safety requirements and environmental and safety requirements for vehicles used in the collection, removal, transportation or disposal of trade waste.”
- Starting with a pilot program rather than with full rollout of the plan is concerning. The legislation does not envision a pilot program, and doing so threatens to undermine the program if it is not executed well.
For his full comments, please refer to the hearing transcript.
Borough President Reynoso wishes to submit the following comments on Intro 696 for the record:
Intro 696 would require the Department of Sanitation to establish 180,000 wet tons of organic waste composting capacity in each borough. Now that the Zero Waste Act, which mandates curbside pickup of residential organic waste, is in the process of being implemented, it is in our city’s best interest to develop our ability to process compost locally using traditional composting methods.
Commissioner Tisch testified that this bill would be too costly to implement and that the space required would be too large; however, it seemed she did not consider that DSNY could comply with the legislation by utilizing a mix of small, medium, and large sites in each borough, rather than having to identify five sites “the size of Ellis Island.” The fact is, according to the latest Mayor’s Management Report, DSNY collected 105,600 tons of organic material in 2023, and this was before the full implementation of curbside pickup to all five boroughs. Additionally, Commissioner Tisch testified that she would like to see new legislation that would expand the mandate for source separation of organics to all commercial businesses. With full implementation of both, our organics processing needs will only expand in the coming years.
DSNY has acknowledged this by issuing a request for businesses to propose new organics processing capacity in the region. However, both anaerobic digestion and long-distance trucking present issues that traditional composting does not.
While any diversion from landfill is better than none, traditional, aerobic composting is the preferred method from an environmental impact perspective, according to the EPA. This is because anaerobic digestion creates two byproducts: biogas and biosolids. Biogas is primarily methane, a greenhouse gas that gets burned into the atmosphere if it is not captured for reuse. Biosolids are the solid byproduct of processed sludge. According to DEP, New York City produces about 1,400 tons, or 600 truckloads, of biosolids per day at its wastewater treatment plants, and much of it ends up in landfills. Therefore, the current practice of organic waste processing would not satisfy the City’s goal of sending zero recyclable/reusable waste to landfills by 2030.
Borough President Reynoso supported the pilot program at the Newtown Creek Wastewater Treatment Plant that sought to capture methane and redistribute it into the city’s heating system; however, he has been disappointed by the years of delays in implementation and failure of the system to function reliably. Additionally, the pilot program is adding more waste trucks to the streets of North Brooklyn, an environmental justice community that still processes more trash than any other area of the city. The Borough President fought hard to pass Waste Equity legislation to reduce the number of waste trucks in North Brooklyn (as well as the South Bronx and Southeast Queens) and this program undermines that effort. The Borough President is also very conscious that developing more processing capacity outside the city potentially means higher costs for the City, more long-haul trucks on the roads, and increased emissions in other environmental justice communities. We must tackle our capacity challenge with a priority for environmental justice and equity, and with robust community engagement that involves New Yorkers in the siting process.
Intro 696 challenges us to meet the moment with a solution that is fiscally and environmentally responsible. Processing organics locally, utilizing a mix of large, medium, and small-scale facilities managed by the City, non-profits, and other small business would create green jobs for New Yorkers and ensure we have a sufficient supply of local compost for our parks, rain gardens, community gardens, and street trees. Our office is supporting the Solid Waste Advisory Boards in their efforts to create a site feasibility analysis, and we look forward to sharing the results with DSNY and working together to implement this bill.
