Good morning and thank you for holding this hearing today. I am representing Brooklyn Borough President Antonio Reynoso, who was the prime sponsor of the 2019 legislation that created the Commercial Waste Zones program when he was Chair of the City Council’s Sanitation Committee. He attended last week’s City Council oversight hearing and made his disappointment with DSNY’s rollout of this program clear. Specifically, he made 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, especially given BIC’s updated mandate to consider worker safety and environmental practices as outlined in Local Law 198 of 2019; and
- 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.
Given this, how DSNY oversees its awardees moving forward is urgently important. The proposed rules under consideration today are comprehensive and address many of the issues that the legislation was meant to prioritize, including: worker safety and training, safe streets, condition of trucks, enforcement of routes, and diversion of recyclable and compostable waste from landfill. The Borough President also appreciates DSNY clarifying the rules governing micro haulers, as ensuring their continued ability to operate (and to become subcontractors to awardees) was important in crafting this bill.
It is critical for DSNY to enforce these rules immediately in conjunction with the program’s rollout, and for the agency to take quick and decisive action if any of the awardees are found to be in violation. Borough President Reynoso is also calling for transparency along with accountability. At last week’s hearing, Commissioner Tisch committed to follow up with the Council by sharing awardees’ submitted safety plans. DSNY should go further and make all of the awardees’ submitted plans (including safety, zero waste, education and outreach, subcontracting, etc.) public, so that businesses can review them when choosing between designated haulers.
Thank you again for the opportunity to testify today. We look forward to seeing the program officially begin and working with DSNY to ensure that the law is as transformative to the industry, our streets, and our environment as it was intended to be.

