The 2026 SWMP should be a visionary document that cements NYC as a global leader in sustainable and equitable waste management practices. However, in its current form, it primarily represents business as usual. As the former Chair of the City Council’s Sanitation Committee from 2014-2021, and now as Brooklyn Borough President, I have a long history with these issues and a responsibility to my constituents to push for transformative change.
First, I want to note that DSNY’s lack of outreach and engagement for this plan’s creation was unacceptable. DSNY leadership testified at the City Council that there was no dedicated funding for outreach on this draft, and so the agency held only one virtual info session. Thankfully, the city’s Solid Waste Advisory Boards (SWABs), advocates, and the City Council have stepped up where DSNY has failed to ensure that New Yorkers knew about this plan and had the opportunity to share their ideas.
My comments are informed by my experience and the feedback shared at both the City Council’s and SWAB’s hearings and meetings over the last few months. My priorities for the 2026 SWMP include:
Waste Equity
The 2006 SWMP was transformative in that it incorporated advocacy from NYC’s environmental justice (EJ) communities, who pushed back on the overconcentration of private waste facilities and the associated air quality and street safety burdens in their neighborhoods. The 2006 Plan outlined the shift of DSNY’s waste processing from private facilities to City-run Marine Transfer Stations (MTSs), a vision that has now been mostly realized. As the 2026 Draft notes, the MTSs “have reduced long-range truck traffic and associated climate and air pollution by containerizing and transporting municipal solid waste (MSW) via barge and rail, more fuel-efficient modes of transportation that avoid congested highway bridges and tunnels.”
In 2018, the City Council passed my Waste Equity legislation, decreasing the amount of permitted waste capacity in three overburdened communities: North Brooklyn, the South Bronx, and Southeast Queens. According to the 2026 Draft, this “resulted in a decrease in material managed at affected private transfer stations by nearly 3,000 tons per day.” (That is equivalent to about 214 fewer private waste trucks in these communities daily.) However, as this map from the Office of the NYC Comptroller shows, concentration of waste facilities in only a few communities remains an issue:
The 2006 SWMP proposed allowing barge export of commercial waste at the MTSs; however, 20 years later, despite ongoing advocacy from EJ communities, DSNY still does not allow it. Worse, according to Council Member Sandy Nurse, sponsor of the bill that would require it, DSNY has refused to conduct the necessary environmental review. The more waste we can send to these facilities, the fewer dangerous and polluting long-haul trucks on our streets. Additionally, because the MTSs are operated by DSNY, we know we don’t have to worry about the usual concerns with private facilities, such as compliance with maintenance regulations and worker protections. DSNY must finally codify a plan to allow commercial waste at the MTSs as part of the 2026 SWMP.
Additionally, DSNY must address the EJ implications of concentrating its organics processing through anaerobic co-digestion at the Newtown Creek Wastewater Recovery Facility in Brooklyn Community District 1 (CD1), which already has the highest permitted waste processing capacity of any community district citywide. The Waste Equity law included an exemption for recycling and organics; however, large-scale co-digestion of organics at wastewater recovery facilities was not envisioned at the time. Analysis in our 2025 report Expanding Composting in New York City: The Case for Passing and Implementing Intro-0696-2024 indicates that DSNY’s plans to scale up co-digestion could add approximately 40 more trucks per day to the streets in CD1, undermining the goals of the Waste Equity law.
Importantly, Local Law 85 of 2023 requires DSNY, as a part of the 2026 SWMP, to “include a plan to maximize the usable composting of organic waste collected.” The 2026 Draft notes that 73% of separated organics collected by DSNY were “recovered for beneficial use,” however appears to include co-digestion in that calculation. Because it creates increased emissions and toxic byproducts, co-digestion is not nearly as beneficial a use as traditional composting. To comply with the law, the Final Plan must “describe the amount of organic waste collected and sent to composting facilities to be processed into usable compost” (emphasis added).
DSNY will thus need to identify sites within the five boroughs where organics can be processed through traditional composting methods. Composting locally has economic benefits for our communities, avoids the environmental pitfalls of co-digestion, and presents the opportunity to site facilities more equitably. Doing so will require inter-agency coordination, especially because, as the 2026 Draft notes, “The shrinking of manufacturing zones with vacant parcels has made it more challenging to site waste infrastructure.” DSNY should begin collaboration with the Department of City Planning to ensure that future plans include sufficient space to support such facilities in all five boroughs. Our report, which includes analysis of where new compost facilities could be sited across the city, is attached as an addendum to these comments.
Commercial Waste Zones
The legislation that I am most proud of from my time as Chair of the City Council’s Sanitation Committee is Commercial Waste Zones (CWZ). This program addresses myriad issues with the private carting industry by limiting vehicle miles traveled (improving both air quality and street safety); increasing enforcement to prevent dangerous driving, poor fleet conditions, mistreatment of workers, and other violations; and increasing diversion of waste from landfills by incentivizing recycling and organics collection.
However, DSNY significantly delayed the program’s implementation and made major changes, prioritizing price over all other factors when selecting carters, and creating a years-long rollout plan that further delays reforms. The plan that we created was carefully crafted to incentivize recycling and diversion rates, good jobs, and clean fleets. Meanwhile, delayed implementation has meant more unnecessary vehicle miles traveled, more unsafe working conditions for transfer station employees, and more dangerous trucks on our streets, as carters delay investments due to uncertainty. The agency’s claim that the original plan would cause costs to skyrocket is not borne out by the findings of their own environmental review, which showed that increased efficiencies would offset any increased costs for the carters.
Additionally, at the beginning of the program, the City Council and Mayor negotiated to allocate 38 staff specifically dedicated to CWZ plus funding for outreach and marketing in the budget. However, according to DSNY’s most recent Biennial SWMP Update (revised in November 2025), the Bureau of Commercial Waste had only 12 full-time staff, with 10 Sanitation Police Officers assigned to CWZ enforcement.
I encourage DSNY to revisit CWZ as part of the 2026 SWMP, with goals of:
- speeding up the program’s rollout;
- imposing high enforcement standards that remove bad actors from participating;
- revisiting the awardees’ Zero Waste Plans to ensure compliance;
- making the Zero Waste Plans public so that businesses have more information than price to evaluate when choosing between carters; and
- increasing headcount for the Bureau of Commercial Waste, including more resources allocated to outreach, education, and communication with carters.
Diversion of Waste from Landfills
As Sanitation Chair, I worked closely with DSNY to support the de Blasio administration’s stated goal of sending zero waste to landfills by 2030. However, the city’s diversion rate continues to hover at 18.5% as of the most recent Mayor’s Management Report, only slightly up from the previous five years and well under DSNY’s stated goal of 23% and the long-term goal of keeping 100% of recyclable waste out of landfills.
Zero Waste Act
Unfortunately, DSNY has used creative means to get around compliance with the Zero Waste Act (2023 City Council legislation meant to increase diversion). These laws require DSNY to establish at least one community recycling center in each borough and at least 30 organic waste drop-off sites citywide, with at least three in each borough. Yet DSNY has argued that they can meet this bill’s mandate through use of drop-off bins that send organics to be co-digested with wastewater. The Act also established the permanent curbside residential organics collection program and required penalties for non-compliance beginning in April 2025. The City implemented such penalties, quickly rolled them back, and has yet to reinstate them, removing the incentive for residents and property managers to participate in the program. The 2026 SWMP should commit DSNY to good faith compliance with all tenets of the Zero Waste Act.
Containerization and Save-as-You-Throw
DSNY should also commit to including options for recycling and organics in its waste containerization program. New York City is long overdue for citywide, on-street, shared waste containers, which will bring our city in line with dozens of major cities globally. However, failing to include recycling and organics in these containers is a missed opportunity. DSNY’s Future of Waste report recommended including bin space for all three types of waste, and DSNY is now rolling out three-section bins at schools. Yet the agency intends to use landfill-bound-trash-only bins for the citywide rollout. According to the Center for Zero Waste Design, “creating equally convenient waste drop off areas for trash, recycling, and organic waste leads to higher diversion rates.” We must make it as easy as possible for residents to source separate recycling and organics, and having three separate methods for disposal is confusing, unnecessary, and leaves unsightly recycling bags on our sidewalks.
As DSNY moves containerization forward, it should also consider two important things: first, canners – the people who remove cans from the waste stream and take them to redemption centers – provide a service that increases diversion from landfill, and they must not be locked out of the containers. Second, a smart containerization plan should be tied to a Save-as-You-Throw model based on bin or bag size to incentivize separation of recycling and organics. This is in line with the 2026 Draft’s recommendation to “study incentive-based waste management policies.”
Public Housing
The 2026 Draft seeks to create opportunities for waste diversion for residents of New York City Housing Authority (NYCHA) buildings, most of whom do not have access to brown bins for organics collection. In addition to the strategies laid out in the Draft, innovative programs provide models that DSNY should expand. For example, Gotham Food Pantry partners with NYCHA Resident Associations so that residents attending free food distributions can also drop off their food scraps for composting. This provides an opportunity to educate residents about the value of composting and how to separate their organic waste. Some residents can also drop off at farms and compost sites on their campuses through Green City Force and Compost Power. These models have proven successful, and more residents could benefit from their expansion.
Schools
The 2026 Draft also seeks to expand single-use plastic waste reduction initiatives in schools. NYC schools generate more than 80 million pounds of refuse every year, and while all schools now separate food scraps as of May 2024, contamination (putting material in the wrong bin) remains an issue, especially with plastic in the food waste stream. Cafeteria Culture provides a successful solution in their pilot program that ran at P.S. 15 in Red Hook from 2022-2023. It included three interventions: Plastic-Free Lunch Day, which addressed plastic food packaging; a Reusables Intervention, partnering with local organizations for four weeks to provide reusable cutlery and cups and wash them; and Mindful Choice Meals, which allowed students to choose their own options for a complete meal. They found that through these replicable programs, they could reduce food waste by up to 50% per student and plastic waste by up to 99% per student. The City can control its own procurement regulations, so expanding these programs could be an easy and impactful win for DSNY.
C&D Waste
Construction & Demolition (C&D) waste makes up more than 60% of the city’s solid waste stream, according to the NYC Economic Development Corporation, so it is positive that the 2026 Draft considers reuse of C&D materials. However, there is an opportunity to expand this idea. Much of the waste generated by C&D projects can be recycled or reused, including carpet, scrap lumber, steel, concrete, and ceiling tiles. One example that advocates have suggested to incentivize this practice would involve DSNY working with the Department of Buildings to require companies to submit a waste management plan requiring a certain amount of diversion per project in order to receive a demolition permit.
Community Composting and Waste Reduction
Finally, I want to express my support for two policies outlined in the 2026 Draft: First, it is heartening to see DSNY codify its commitment to supporting community composting. These facilities play a critical role in a comprehensive organics diversion system by: diverting millions of pounds of food waste from landfills every year; providing free compost to the Parks Department, community organizations, street tree maintenance, school gardens, Botanical Gardens, and community gardens; creating jobs; and playing a critical role in educating youth and the public about the value and mechanics of composting. Second, the best way to keep waste out of landfills is to not produce the waste in the first place. I am pleased to see DSNY express its support for packaging reuse and reduction, including a pilot NYC program and support for State legislation on Extended Producer Responsibility (EPR) and updating the Bottle Bill to increase diversion.
Thank you again for the opportunity to weigh in on this important Draft 2026 SWMP. I look forward to working with DSNY and DEC to create and implement a robust and transformative plan.
