Report - Transform Don`t Trash NYC
Transcription
Report - Transform Don`t Trash NYC
TABLE OF CONTENTS 2 5 7 9 12 16 18 20 24 26 27 EXECUTIVE SUMMARY RECYCLING RATES IN NEW YORK CITY’S COMMERCIAL SECTOR ARE ROCK-BOTTOM WHY RECYCLING MATTERS WHY IS NEW YORK CITY’S COMMERCIAL RECYCLING RATE SO LOW? NEW YORK CITY’S COMMERCIAL WASTE COLLECTION SYSTEM IS GROSSLY INEFFICIENT & HIGHLY POLLUTING NEW YORK CITY’S COMMERCIAL WASTE SYSTEM HARMS NEW YORKERS’ PUBLIC HEALTH, PARTICULARLY IN OVERBURDENED COMMUNITIES A HANDFUL OF LOW-INCOME COMMUNITIES AND COMMUNITIES OF COLOR BEAR THE BRUNT OF OUR COMMERCIAL WASTE SYSTEM SOLUTIONS: TAMING THE GARBAGE “WILD WEST” CONCLUSION: NEW YORK CITY AT 70% RECYCLING APPENDIX A: COMMUNITY HAULER SURVEY AREAS ENDNOTES ACKNOWLEDGEMENTS This report and underlying research were produced by core members of the Transform Don’t Trash NYC coalition including the New York City Environmental Justice Alliance (NYC-EJA), ALIGN: The Alliance for a Greater New York (ALIGN), the International Brotherhood of Teamsters, and New York Lawyers for the Public Interest (NYLPI) with Justin Wood of NYLPI as the lead author. Many thanks to Natasha Dwyer and Juan Camilo Osorio of NYC-EJA; Gavin Kearney of NYLPI; Kristi Barnes, Keith Brooks, and Maya Pinto of ALIGN; and Cassandra Ogren and Michael Mignano of the International Brotherhood of Teamsters for their research, review, and contributions to this report. Thanks to Lauren Ahkiam of the Los Angeles Alliance for a New Economy, Hays Witt of the Partnership for Working Families’ Transforming Trash campaign, and Abby Shull of the San Jose Environmental Services Department for their contributions to our understanding of commercial waste systems in leading cities. Dirty, Wasteful, and Unsustainable © April 2015, Transform Don’t Trash NYC. ABOUT US The Transform Don’t Trash NYC coalition is dedicated to transforming New York City’s commercial trash industry to reduce waste and pollution, foster clean and healthy communities for all New Yorkers, and create good jobs. Members include the New York City Environmental Justice Alliance (and its member organizations El Puente, the Morningside Heights/West Harlem Sanitation Coalition, Nos Quedamos, The Point Community Development Corporation, Sustainable South Bronx, UPROSE, and Youth Ministries for Peace and Justice), ALIGN, the International Brotherhood of Teamsters Joint Council 16 & Locals 813, 831 and 210, and NYLPI. DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 1 EXECUTIVE SUMMARY New York City’s sprawling commercial waste system performs significantly worse on recycling and efficiency than previously believed. Under an inefficient and ad-hoc arrangement that developed over the past several decades, hundreds of private hauling companies collect waste from restaurants, stores, offices, and other businesses nightly and truck it to dozens of transfer stations and recycling facilities concentrated in a handful of low-income communities of color. This waste is then transferred to long-haul trucks and hauled to landfills as far away as South Carolina. Previously unpublished studies and new data reveal just how chaotic this system is and make clear that fundamental reform is needed if we are to follow through on the City’s recently adopted commitment to reduce greenhouse gas (GHG) emissions by 80% by 2050. As recognized by city officials, meeting this ambitious but attainable GHG goal will require rapid and substantial increases in the efficiency of our buildings, power production, transportation, and solid waste systems.1 In the solid waste sector, there is tremendous need for improvement and the City will fall far short of the progress it needs to make in reducing the environmental and public health impacts of our garbage if it focuses only on residential recycling while ignoring the failures of a larger, highly polluting and inefficient commercial waste system. As a result of the 2006 Solid Waste Management Plan and the city’s PlaNYC sustainability initiative, NYC has made major public and private infrastructure investments that will reduce the global and local impacts caused by collection and disposal of our residential waste stream, which is handled by the Department of Sanitation (DSNY). While there is still much more to be done, New Yorkers can now recycle plastics, paper, metal, and glass, and curbside pickup of food scraps is available in several pilot neighborhoods. Investment in new municipal transfer stations will allow remaining garbage to be exported via barges and trains, eliminating over 6 million truck miles per year from our local streets and reducing impacts on environmental justice communities disproportionately burdened by the City’s waste infrastructure. 2 Yet even after these improvements, our waste system will remain a major contributor to climate change: emissions of methane and other greenhouse gases from landfills storing NYC waste have been estimated at 2.2 million tons per year, and are probably much higher given new estimates of the amount of waste generated by the city’s business sector.3 The City acknowledged in a 2014 study that achieving the 80x50 goal will require transformational change: DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 2 “Volumes of waste would need to drop as consumers use fewer disposables and manufacturers of goods pay greater attention to packaging. Nearly all organic waste would need to be composted or processed in anaerobic digesters within the region; nearly all recyclable material would need to be recycled; and most of what remains would need to be turned into energy at state-of the-art, low-emission conversion facilities. Only a very small portion of remaining waste would be sent to landfills.”4 While the City has acknowledged that our solid waste system will need to maximize efficiency and sustainability to achieve our GHG goals, a major unpublished 2012 study of the commercial system commissioned by DSNY reveals just how far we are from doing so as recycling rates for businesses are significantly worse than the already low rates previously believed to exist. For this study, DSNY retained Halcrow Engineers, a nationally recognized consultant, to aggregate and analyze data from hundreds of transfer stations and recycling facilities in the region and to estimate the total amount of commercial waste generated citywide through an analysis of employment numbers in each industry. Transform Don’t Trash NYC obtained a copy of this study through a Freedom of Information Law request. Among other things, the Halcrow study found: • New York City’s businesses generate about 5.5 million tons of waste per year – 2 million tons more than previously estimated.5 • The recycling rate for this giant waste stream is only about 25%, significantly worse than the 40% commercial recycling rate published in Mayor Bloomberg’s 2011 PlaNYC update. 6 Moreover, annual reports filed by private waste companies with the state suggest that recycling by major haulers may be much lower – only 9-13% in 2014.7 NYC is below average in a nation that recycles at a rate of 34.5%, and while we produce more commercial waste than any other US city, we are nowhere near leading cities in commercial waste recycling. Both the Halcrow study and Transform Don’t Trash NYC’s (TDTNYC) own analysis of hauling company and transfer station customer locations show that our chaotic, truck-intensive commercial waste system is not just problematic from a climate perspective – it also harms New Yorkers on a day-to-day basis and squanders important economic development opportunities. NYC streets are inundated with thousands of commercial collection trucks overlapping one another on inefficient collection routes that needlessly subject New Yorkers to the pollution, noise, congestion and hazards of excessive truck traffic. • • TDTNY members conducted a survey of private haulers operating in businesses districts in the five boroughs and found as many as 22 different hauling companies operating on individual commercial strips. Similarly, the 2012 DSNY study examined commercial truck traffic in 13 community districts throughout the City and found more than 25 different private haulers collecting commercial garbage in every one. In Midtown Manhattan, the report identified 79 different haulers collecting garbage. DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 3 TDTNYC also obtained data collected from commercial haulers by NYC’s Business Integrity Commission (BIC) through another Freedom of Information request, which enabled us to map the locations of businesses generating waste in NYC and the private transfer stations to which their waste is hauled after collection. This new data confirms the inefficiency of a system where three-fourths of all waste handled in NYC is trucked to transfer stations in just three outer-borough neighborhoods no matter where it is collected. Private garbage trucks routinely bypass closer facilities with available capacity in order to dump their waste at facilities in overburdened communities in the South Bronx, North Brooklyn, and Southeast Queens, adding significantly more truck miles to a system that is already grossly inefficient. These inefficiencies are endemic to our current commercial waste system and perpetuate poor recycling practices, create unnecessary waste truck traffic and pollution, and contribute to public health and safety problems for millions of New Yorkers. In sum, there is overwhelming evidence that NYC’s commercial waste system underperforms and is in need of transformation. SOLUTIONS Our city can and must do better. A better waste system would dramatically increase business recycling rates, eliminate millions of miles of unnecessary, overlapping collection truck traffic, and site the recycling infrastructure we need as equitably and efficiently as possible. It would lessen air and noise pollution for millions of New Yorkers who live near and walk on commercial streets where garbage is picked up every night, while dramatically lowering GHG emissions caused by trucking our garbage hundreds of miles to decompose in out of state landfills. It would also raise wage, benefit and safety standards in an industry where workers are poorly compensated and exposed to unnecessarily dangerous working conditions.* The Transform Don’t Trash NYC coalition proposes that NYC adopt a zoned collection system, an approach to commercial waste management that has proven successful in other cities. In such a system, commercial waste haulers would compete for the exclusive right to collect waste within designated collection zones over a set period of time. In order to win the right to serve a commercial zone, companies would need to meet ambitious environmental targets, maintain high-road labor standards, and invest in systems and infrastructure to divert recyclables and organic waste from landfills and incinerators. In return, those hauler awarded zones would benefit greatly from a steady, sizable, and dense base of customers. This system would ensure far greater accountability through reporting requirements and more effective public oversight. * Worker health and safety problems will be the focus of a future TDTNYC report. DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 4 RECYCLING RATES IN NEW YORK CITY’S COMMERCIAL SECTOR ARE ROCK-BOTTOM One of the primary findings of the 2012 DSNY/Halcrow study is that recycling rates for NYC’s business waste are even worse than previously thought, and our city continues to lag far behind national leaders like San Jose, Seattle, and San Francisco. Our continued over-reliance on landfilling generates excessive greenhouse gas emissions and squanders the opportunity to develop thousands of good, local recycling jobs for NYC workers. This low recycling rate isn’t simply a function of bad actors in the industry, however – it is endemic to the chaotic, ad-hoc system that NYC has chosen to adopt for commercial waste management. This environment gives private garbage haulers little incentive to invest in better recycling infrastructure, and makes it difficult, if not impossible, for the City to monitor compliance with recycling laws. To overcome a lack of reliable data on the amount and types of waste generated and recycled by businesses in New York City, the City has spent millions on consultants every 8-10 years to estimate the most basic measures of how NYC’s commercial waste sector is performing. The 2012 Halcrow study used waste generation, employment, and recycling data to estimate that New York City's businesses generate 5.5 million tons of solid waste each year, over 4 million tons of which is disposed, rather than recycled.8 The study estimated that for the waste stream generated by NYC businesses – including offices, restaurants, retail stores, hotels, and health care facilities – only 24% of waste is recycled9.† Annual reports filed with the New York State Department of Environmental Conservation by transfer stations and recycling facilities suggest that recycling rates for major portions of the commercial waste stream may actually be much lower. For example, 2014 reports filed by two of the biggest companies hauling waste and operating transfer stations in NYC show recycling rates of only 9% and 13% respectively.10 † Business or trade waste generated as part of daily businesses is often known as commercial putrescible waste because it includes organic or putrescible materials. This is distinct from construction and demolition waste often known as “C&D” which is comprised primarily of inert materials such as concrete and metal. The Halcrow study and this report are concerned with the commercial putrescible waste stream. DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 5 Although the majority of what does get recycled is paper and cardboard, the Halcrow study estimates that a staggering 66% – at least 700,000 tons – of cardboard and paper is landfilled or incinerated every year despite the existence of relatively robust local recycling infrastructure and markets for these materials.11 Recycling of organic material, such as food waste, is far worse. Although organic material comprises about a third of the commercial waste stream, very little is composted or anaerobically digested.12 METAL 6% GLASS 4% OTHER 22% PLASTIC 14% ORGANIC S 27% PAPER 27% COMMERCIAL WASTE GENERATED BY TYPE 14 WASTE DISPOSED BY BOROUGH 13 DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 6 WHY RECYCLING MATTERS Recycling has a dual impact on climate change. First, most waste that is not recycled is buried in landfills where it decomposes slowly, emitting large amounts of methane gas, a climate warming agent 20 times more potent than carbon dioxide.15 Second, producing materials such as paper or metals from recycled feedstock uses much less energy and resources than does manufacturing these products from virgin materials. Each ton of paper recycled, for example, saves 7,000 gallons of water, saves enough energy to power an average US home for 6 months and avoids a total of one ton of greenhouse gas emissions.16 While metals like aluminum don’t cause substantial landfill emissions, aluminum production is highly energy intensive. Recycling aluminum requires 96% less energy to produce than virgin metal and avoids the environmental damage of open-pit bauxite mines.17 Optimal management and recycling of the huge portion of our waste stream comprised of organic substances such as food scraps can also have a large impact. Sustainable methods for handling this waste range from anaerobic digestion of food waste in sealed chambers (similar or identical to waste water treatment methods) to aerobic composting in covered piles. While calculating GHG impacts of methods such as anaerobic digestion, aerobic composting, and landfilling is complex, according to EPA estimates every ton of food waste properly composted rather than landfilled eliminates the equivalent of nearly one ton of carbon-dioxide emissions into the atmosphere.18 The combination of avoided emissions through decreased need to produce virgin materials and through keeping material out of landfills is powerful – from this life-cycle perspective, landfilling a ton of waste leads to 30 times more greenhouse gas emissions than does recycling a ton of waste.19 DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 7 While NYC commercial waste haulers dispose of the majority of waste in landfills because they are currently the cheapest short-term option, about 10% of commercial waste is burned in incinerators.20 Often labelled “Waste to Energy” facilities, incinerators present major environmental hazards to the communities surrounding them as they burn materials such as paper and plastics that could be cost-effectively recycled, and are an extremely inefficient and costly way to generate energy.21 An examination of a typical collection truck load from a restaurant route found that 67% was food waste (which could be composted or anaerobically digested), 20% was cardboard and paper (potentially recyclable or digestible) and 5% was recyclable beverage containers (which should have been recycled under existing NYC law). 22 MORE RECYCLING MEANS MORE JOBS Waste Handling Process Jobs per 10,000 Tons of Waste per Year Landfilling/Incineration 1 Composting 5 Recycling Sorting 20 Recycling waste creates far more jobs than landfilling or incinerating it. 23 If New York City were to increase its recycling rate from 24% to 70%, it could create more than 3,000 local jobs processing materials at recycling facilities. Currently, only about 500-600 of these jobs exist in the city according to the U.S. Census Bureau.24 By encouraging local and regional development of recycling-reliant manufacturing industries such as recycled paper mills, we could create an additional 8,000 or more jobs in or near the City.25 DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 8 WHY IS NEW YORK CITY’S COMMERCIAL RECYCLING RATE SO LOW? NYC’s commercial waste system forces a short-term outlook on the waste industry, stifling long-term investments. NYC waste haulers and facility operators are limited by a short-term outlook as they scramble for customers, and their business model is based on trucking garbage to whichever out-of-state landfills are cheapest for them. A City law passed in the 1990s to protect customers from an anti-competitive hauler cartel prohibits haulers from negotiating waste contracts lasting more than two years. The unintended consequence of this is that haulers and the facility operators they rely upon do not have the kind of stable customer base needed to make long-term investments in clean trucks and recycling infrastructure.26 T he new S IM S re cyclin g f acility u ses autom ate d so rte rs to se parate plas tic an d glass in res ide ntial recyclables . Photo: S IMS M unicipal Re cyclin g Co rp. N YC Recent developments in NYC’s recycling programs demonstrate how the City can create the market conditions necessary to generate infrastructure investment and better recycling in the commercial sector. A 20-year RFP and contract to process and resell recyclables collected by DSNY recently led to a $46 million investment in a state-of-the-art Materials Recovery Facility (MRF) on the Brooklyn waterfront by SIMS Municipal Recycling.27 In 2013, the plant began processing all of the plastics, metal, and glass in the City’s residential recycling stream. Because this facility can sort and resell a variety of materials using automated scanning technology, New York City residents are finally able to recycle a variety of food containers and other rigid plastics that were previously landfilled. The long-term SIMS contract gives the City the stability to maintain and expand its recycling programs while allowing SIMS to meet its operating costs by smoothing out volatility in market prices for recyclable materials. This is a marked contrast to the commercial recycling sector where a focus on short-term profits leads haulers to recycle materials only when it is profitable from their perspective and fails to provide the long-term stability needed for investments in better infrastructure. DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 9 New York City has similarly used 20-year contracts with waste exporting companies to create investment in rail transfer facilities that have led to the replacement of long-haul truck export with comparatively efficient train export of residential waste. The disincentives to long-term infrastructure investment that exist in our commercial waste system may actually stall the city’s efforts to recycle commercial food waste. Thousands of commercial kitchens and restaurants in New York City generate a relatively clean, high volume waste stream with high potential to generate energy via anaerobic digestion processing. Local legislation scheduled to go into effect in July, 2015 would require these major food waste generators to separate this waste and contract with a hauler to process it, but the law also makes this requirement contingent on the existence of sufficient organics recycling capacity within 100 miles of the City. Unfortunately, the entire New York City region has much less capacity to recycle food waste than smaller cities like San Francisco, Seattle, and San Jose, and the handful of currently existing composting and digester facilities are capable of processing only a small fraction of the organic waste generated by the businesses that the law would cover.28 Incredibly, the recent shutdown of a single, poorly-managed composting facility in Delaware may delay or scale back the law’s implementation and the progress of organics recycling in the nation’s biggest city.29 This woeful lack of infrastructure stems directly from the instability of our commercial waste collection system: potential developers and financers of organics processing plants require a guaranteed volume of organic feedstock over a sufficiently long period of time in order to justify the upfront costs of creating diversion infrastructure. The current system, with its short-term profit structure, simply cannot provide these guarantees. In order to reduce the tremendous emissions caused by landfilling food waste and to realize long-term savings from energy and avoided transportation costs, the City will need to create much stronger, long-term incentives for waste generators, haulers, and investors to make organics recycling a reality.30 BUSINESSES LACK PRICE INCENTIVES TO RECYCLE Businesses – particularly small businesses – lack clear price incentives to separate recyclable waste, and haulers are likely to encourage customers only to recycle the portions of their waste stream that are most profitable to collect, given the lack of infrastructure and monitoring. In New York City’s system, haulers have an incentive to – and usually do – hide their prices from customers, who cannot easily compare prices from different haulers or determine a fair price for the recyclable portions of their waste. More than 83% of businesses pay a flat, monthly rate for garbage services regardless of how much waste they generate, and cannot easily understand how this price relates to the amount of waste they generate.31‡ Moreover, many businesses are charged the ‡ Problems with price transparency, recycling incentives, and customer service for businesses required to participate in the commercial waste system will be the focus of a future TDTNYC report. DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 10 same monthly rate for garbage service regardless of whether they separate recyclables, significantly reducing the incentives for businesses to properly source-separate materials such as paper, glass, plastics, and metal from food waste and other contaminants. A CHAOTIC SYSTEM MAKES RECYCLING ENFORCEMENT DIFFICULT Enforcement of existing recycling laws is difficult or impossible given the huge number of actors in NYC’s commercial waste sector. With 260 licensed haulers in total, authorities such as the Business Integrity Commission (which was created to prosecute corruption and cartel behavior in the private waste industry) struggle to detect illegal activity such as unlicensed hauling, curbside theft of valuable materials (such as cardboard), and improper commingling of recyclable and non-recyclable waste.32 New York City’s existing recycling law has been ineffective in increasing recycling rates. When enacted in 1992, the law was intended to ensure that 50% of the waste stream collected by private carters would be recycled – a goal the city is far from achieving.33 Rather than requiring private haulers to educate customers on how to maximize recyclability of their waste, the law put the onus on businesses to separate materials (although this is almost never enforced). Finally, the law designates as recyclable only those materials for which the costs of recycling are equal to or less than the costs of disposal, from the haulers’ perspective – a requirement that ignores the environmental and health costs of exporting and disposing waste. DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 11 NEW YORK CITY’S COMMERCIAL WASTE COLLECTION SYSTEM IS GROSSLY INEFFICIENT & HIGHLY POLLUTING Six nights a week, an army of 4,200 trucks and more than 5,000 workers is deployed by private hauling companies to collect waste from NYC’s offices, restaurants, factories, and retail stores.34 While this private system removes thousands of tons of waste from our streets every night, it does so in a disorganized and highly inefficient manner.35 About 260 haulers hold licenses to collect commercial waste in NYC, with the 20 largest haulers dominating the market and servicing 80% of commercial customers.36 Many of these haulers’ customers are spread across several boroughs and trucks throughout the City travel on inefficient and overlapping routes. THE NU M BER O F COM M ERCIAL CAR TER S S ERVIC ING BUSINESS CUS TOMERS IN S ELECT NY C COMMUN ITY DISTRICTS DISTRICT MA-1 MA-5 BX-2 BX-4 BX-8 BX-12 BK-4 BK-9 BK-14 QN-1 QN-6 QN-10 QN-14 SI-2 SI-3 CUSTOMERS 2787 13931 1432 1487 930 1691 1363 792 1442 4771 1806 1471 812 1772 1474 inefficient routes. CARTERS 68 79 39 38 30 43 49 43 59 69 48 44 26 31 25 Image: DSNY/Halcrow Engineers, 2012 DSNY’s 2012 study found at least 25 haulers operating in every community district it studied, and 79 different haulers collecting waste in midtown Manhattan alone.37 In 2014, TDTNYC members surveyed 580 businesses along commercial stretches in all five boroughs to gain a street-level understanding of commercial waste collection. Our survey revealed individual blocks in several neighborhoods where collection trucks from 8-10 different hauling companies serviced businesses, and one multi-block commercial strip serviced by 22 different hauling companies. The constant struggle to gain and retain customers leads haulers to operate DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 12 For example, a typical team of two workers operating a truck might collect waste from 70 different restaurants in one night. While a dense customer base would allow these workers to fill their trucks from restaurants in a single neighborhood, in NYC’s open system these workers are likely to drive across multiple neighborhoods and even boroughs to collect the same amount of waste from the same number of restaurants. "There is no route that makes sense in the entire industry. Where I might have a stop here, I don't have another stop for half-a-mile. And then in that half a mile, you have six other garbage companies. You just keep multiplying that all night. The route is not consolidated — it’s spaced out. I do about 70 miles a day.” — Allan Henry, Private Sanitation Driver CLUSTERING OF TRANSFER STATIONS CONTRIBUTES TO INEFFICIENCY With the phasing out of the Fresh Kills landfill in the 1990s, clusters of private waste transfer stations designed to export garbage to out-of-state landfills arose in North Brooklyn, the South Bronx, and Southeast Queens, which together process 75% of the waste handled in New York City today, as well as the Brooklyn neighborhoods of Sunset Park and Red Hook which are home to major commercial waste transfer stations. At these transfer stations, waste is put on long-haul vehicles — mostly trucks — for export to landfills and incinerators across the Eastern U.S. Less than 6 percent of NYC’s waste stays in New York State; instead it travels an average of 272 miles and largely ends up in Pennsylvania, Ohio, and Virginia, with some of it traveling as far as South Carolina.38 Data obtained from the Business Integrity Commission shows how this clustering of waste facilities adds to the inefficiency of the commercial collection system, and results in private garbage trucks driving thousands of excess miles every night to reach their designated transfer station to dump, often bypassing closer stations along their routes. FLA GS DEPIC T PRI VAT E T RA NS FER S TA TION S HAN DLIN G PUTR ES CIBLE, C ON ST RUC TION , AN D FI LL M AT ERI AL. SOUR CE: HABI TAT M AP DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 13 The maps above depict customer locations for 3 of the 14 transfer stations currently handling commercial putrescible waste in NYC. They show that regardless of where waste is generated in the city, it is trucked to transfer stations primarily concentrated in three overburdened communities. For example, waste collected as far away as Coney Island and Inwood is trucked to North Brooklyn, waste collected in Eastern Queens and North Brooklyn is trucked to the South Bronx, and waste collected in Sunset Park and downtown Manhattan is trucked to Southeast Queens. Even in ZIP codes containing large numbers of waste transfer stations, a substantial amount of waste is trucked to distant transfer stations by private haulers. For example, while the North Brooklyn neighborhoods of Williamsburg and Bushwick are home to the city’s largest cluster of transfer stations, 30% of businesses in this area have their waste trucked elsewhere – to the Bronx, Sunset Park, or even New Jersey. Similarly, 19% of South Bronx businesses have their waste trucked elsewhere, despite the presence of large transfer stations. DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 14 In a system with more than 150,000 participating businesses, these excess miles add up: The commercial waste fleet drives at least 50 million miles per year in New York City, and operates far less efficiently than DSNY, which, as the exclusive hauler of residential waste, can use the most efficient possible collection routes. Halcrow estimates that commercial haulers drive about 12 miles to collect each ton of waste (including recycling). In contrast, DSNY fleet reports produce estimates of about 4 miles per ton of waste and recyclables collected.39 DSNY’s 2012 study found that the number of miles driven per ton of waste collected varied by 65% across a sample of three similarly-sized waste companies depending on the locations of their customers, transfer stations, and truck yards. With a high level of redundancy among carters, even the most efficient of these companies is not nearly as efficient as it could be with a geographically dense customer base. 40 DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 15 NYC’S COMMERCIAL WASTE SYSTEM HARMS NEW YORKERS’ PUBLIC HEALTH, PARTICULARLY IN OVERBURDENED COMMUNITIES The negative daily impacts of NYC’s sprawling, inefficiently operated fleet of 4,000 diesel trucks are felt by all New Yorkers, and are particularly acute in the low-income communities and communities of color where private waste facilities and trucks are concentrated. POLLUTION Currently, only 10% of NYC’s 4,281 commercial putrescible garbage trucks meet 2007 EPA emission standards – meaning that the majority of commercial waste trucks on our streets emit significantly greater quantities of harmful particulate matter and nitrogen oxide compared to modern collection vehicles.41 Old waste trucks are common on NYC streets, and emit far more pollution than new models. While a new law requires haulers to update their fleets by the year 2020, implementation of the law may allow haulers to use less effective retrofit technologies for older trucks.42 The law does not require waste haulers to implement alternative fuels such as compressed natural gas or electric trucks, which can significantly reduce the pollution, greenhouse gas emissions, and noise caused by diesel trucks. Diesel emissions have dozens of negative public health effects. The particulate matter emitted by diesel trucks harms lung function, and is linked to the development and exacerbation of asthma and other illnesses.43 The World Health Organization recently declared diesel exhaust a human carcinogen.44 DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 16 PEDESTRIAN AND CYCLIST SAFETY Waste collection trucks are particularly hazardous to pedestrians and cyclists. This is due, in part, to the fact that under the current chaotic commercial system, drivers are pressured to complete their sprawling routes as quickly as possible. DSNY’s 2012 study found a prevalence of “…reverse moves, illegal right turns on red, and even the blatant disregard of one-way street restrictions” by commercial waste carters.45 Unsafe driving practices by waste trucks have contributed to dozens of New York City pedestrian and cyclist deaths in recent years, and commercial waste trucks are among the most dangerous vehicles on our streets in terms of numbers of fatalities per mile.46 Unsafe things I see in the industry are trucks speeding, turning like crazy on the corners, coming on the opposite side of the street, taking red lights and blowing stop signs — those are things that are very dangerous. Another problem is driving on the opposite side — going opposite direction to the traffic. That happens in Manhattan and throughout the whole city and we have had accidents because of that. And many of those companies force the workers to do that. How can you do 500-700 stops at night while observing the proper laws and rules of traffic and speed? It's impossible. — Plinio Cruz, Private Sanitation Driver NOISE Diesel collection trucks can emit up to 100 decibels of noise – the sonic equivalent of a jackhammer or a jet flyover.47 Noise from collection is a concern for all New Yorkers,48 and is acute in communities with clusters of transfer stations. Chronic noise exposure is linked to insomnia, stress, heart disease, and hearing loss.49 ROAD DAMAGE A commercial waste truck runs a red light on Canal Street. Each of these trucks weighs about 33,000 pounds empty50 and causes pavement damage equivalent to 1,429 cars.51 New York City taxpayers bear the substantial cost of repairing the resulting damage to our streets and highways. DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 17 A HANDFUL OF LOW-INCOME COMMUNITIES AND COMMUNITIES OF COLOR BEAR THE BRUNT OF OUR COMMERCIAL WASTE SYSTEM The numerous harms of NYC’s commercial waste management are felt most acutely in low-income communities of color where private waste transfer stations and truck yards are heavily clustered. Trucks collecting commercial waste all over the city converge on North Brooklyn, the South Bronx, and Southeast Queens every day and night, as do the longhaul trucks that export this garbage to landfills and incinerators. SHARE OF PUTRESCIBLE AND CONSTRUCTION WASTE HANDLED IN THREE COMMUNITIES REST OF NYC 25% NORTH BROOKLYN 34% SOUTHEAST QUEENS 9% SOUTH BRONX 32% Garbage trucks are a significant contributor to the high levels of diesel truck traffic and poor air quality associated with these and other industrial facilities in these communities. For example, a traffic study conducted at morning and evening rush hours in North Brooklyn found that garbage trucks constituted 30-50% of truck traffic at various intersections, many of which are in close proximity to homes and schools.52 DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 18 Communities living, working, and going to school near truck routes and waste facilities bear substantial health burdens associated with poor air quality. The South Bronx, which hosts fourteen waste transfer stations,53 has the highest asthma rates in the state, and residents of the Bronx in general suffer the highest rate of deaths by asthma in the state.54 Studies of South Bronx school children have demonstrated that exposure to components of diesel soot from living in proximity to truck routes and highways is directly linked to acute respiratory problems such as asthma attacks.55 Idling trucks next to a park in the Bronx. Photo: Sustainable South Bronx Waste trucks often drive through residential streets in overburdened communities. Photo: Joe Moretti “Living and working in a community that has 14 waste transfer stations on top of a prison, on top of 15,000 trucks for a food market, is oppressive. It’s gasping for fresh air. It’s noise pollution. It’s impinging on your feeling of security, your feeling of just happiness. It’s about ‘Can my kid breathe?’ ‘Can I breathe?’ ‘Can we have a healthy and happy family here in the places we have to live?’ Environmental justice is not an option for us. It is a life and death issue.” — Kellie Terry, Hunts Point, The Bronx The men and women who work in the private sanitation industry also bear outsized health risks associated with antiquated diesel engines, poorly designed infrastructure, and inefficient truck routes. Because they work 8-12 hours per day in close proximity to trucks and machinery, truck operators are likely to experience greatly elevated exposure to toxic components of diesel exhaust.56 These exposures are added to the daily threats of injury and death that make sanitation work one of the five deadliest jobs in the U.S according to the Bureau of Labor Statistics.57 Notably, exposure to pollution is even higher for the many private sanitation workers who experience it on the job and also live in the communities where waste facilities, truck routes, and other industrial uses are concentrated. DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 19 SOLUTIONS: TAMING THE GARBAGE “WILD WEST” New data strongly underscores the fact that our commercial waste system is broken. The 5.5 million tons of solid waste generated by New York City businesses each year are handled by an outdated, haphazard system that was never designed to meet our urgent need to maximize recycling, and has not been held accountable for its local and global impacts. By almost every relevant measure – efficiency, public health, climate impacts, equity, and safety – the current system fails our city. Fortunately, NYC can benefit from the experiences of other innovative cities that have adopted a proven approach to commercial waste management. Often called “franchising,” this approach gives haulers exclusive collection rights in defined zones of a city through a competitive bidding process that can be leveraged to produce enforceable commitments on recycling, working conditions, efficiency, pollution reduction, and equity. INCREASING RECYCLING Seattle is one example of a city that has successfully used exclusive waste collection zones and long-term (11-15 year) franchise agreements to continually improve its commercial recycling rate. Seattle’s system incentivizes both customers and hauling companies to maximize source-separation of recyclable waste. Businesses pay significantly lower monthly prices for compost service than they do for garbage service58 and receive free limited collection of dry recyclables from the city,59 while the two hauling companies that service Seattle’s businesses receive bonuses for maximizing business participation in the composting program and for reducing the amount of garbage disposed in landfills annually.60 Since Seattle began its commercial composting program in 2006, food and yard waste recycling has improved the City’s overall recycling rate from 50% to 63%, and new mandatory composting laws promise to drive this rate even higher in the near future. 61 DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 20 70.0% SEATTLE COMMERCIAL REC YCLING TRENDS Annual Commercial Waste (TONS) 200,000 63% 61% 150,000 65.0% 61% 59% 60.0% 100,000 50,000 0 52% 2006 55% 55% 2008 2009 Commercial Recycling Rate 250,000 55.0% 53% 2007 2010 2011 2012 2013 Commercial Disposed Garbage Commercial Non-Organic Recycling Commercial Composted Commercial Recycling Rate 50.0% San Jose recently transitioned from an open-market commercial waste system like NYC’s to an exclusive zone approach and Los Angeles is in the process of doing so, making their experiences especially relevant. These large cities both struggled with the same problems NYC faces: low business recycling rates, inefficient collection systems, and a lack of transparent data on amounts of waste generated and recycled by haulers serving the business sector. After announcing competitive RFPs for 15-year contracts to collect and process all commercial waste generated in the city, San Jose was able to attract investment in state-of-the-art infrastructure that has eliminated the practice of direct disposal at the landfill. Impressively, this new system tripled the commercial diversion rate within the first year of implementation:62 DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 21 90 80 San Jose Target LA Target 70 60 50 40 US Recycling Average 30 NYC Commercial (2009) LA Commercial (2010) 20 10 0 San Jose Commercial Baseline (2010) 2009 2010 San Jose Franchise Starts (2012) 2011 2012 2013 2014 2015 2016 2017 With the guarantee of a long-term, reliable stream of commercial recyclables and organic food waste, San Jose successfully leveraged substantial private investment to construct a state-of-the-art recyclables sorting facility and an anaerobic digestion and composting plant specifically designed to process organic food waste from the city’s commercial sector. When completed, this plant will be able to process over 700 tons per day of food waste (an amount greater than the total organics recycling capacity of the NYC region), create 1.6 megawatts of electricity, and produce a compost-like end product which can be sold as organic fertilizer.63 Meanwhile, under their agreement with the city, San Jose’s exclusive hauling company is required to meet rigorous recycling targets, provide all businesses with consistent recycling education and support, and charge customers standardized rates. The city’s ability to control the destinations and quality of the waste streams produced by the approximately 8,000 businesses in the commercial sector has been key to realizing rapid development of Sa n Jose ’s new a na er obi c dige stion a nd recycling and green energy facilities. City of San Jose staff involved composti ng fa ci li ty wi ll be a bl e to proce ss in creating this new system have stressed that exclusive collection 270, 000 tons pe r year of c ommerc ial orga ni c wa ste. zones are fundamental to this success: “Haulers can’t finance P hoto: Ze ro Was te Energy De si gn infrastructure development to recycle without a guaranteed customer base and revenue stream…because these facilities are very expensive.”64 DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 22 Los Angeles recently decided to adopt an exclusive zone system and is currently evaluating competing proposals for collection from eleven different zones designated by the city. LA is requiring private haulers to submit rigorous recycling plans for each zone, and at a minimum these bids must include a plan to reduce tonnages of disposed waste by 63% by 2025, and include a plan to collect and recycle source-separated organic waste and recyclables from each business.65 Anticipating the guarantees of stable quantities of uncontaminated food waste that will be generated by these requirements, organics processing companies have already begun to explore investments in the Los Angeles area and are partnering with haulers on their proposals.66 ELIMINATING OVERLAPPING TRUCK ROUTES In cities the size of Los Angeles and New York, which have similar land areas, exclusive collection zones can significantly reduce the pollution and negative health impacts of waste collection by requiring haulers to create rational routes to serve efficiently located customer bases. As part of an environmental impact assessment of its new commercial waste system, Los Angeles conducted a detailed analysis of truck miles driven under its current open-market system versus the proposed new exclusive zone system and concluded that the City could reduce truck miles traveled by 16% by implementing rational commercial collection zones (pictured at left), an absolute savings of 1.7 million collection truck miles per year. 67 Even with the requirement that haulers do separate collections for source-separated organic waste and recyclables – intended to minimize cross-contamination and maximize recycling – the City expects to reduce truck miles by 2% (180,000 miles per year) compared to the current system. The City’s analysis determined that requiring separate collection of organics and recyclables under an open system with inefficient overlapping routes would expose Angelenos to 5 million more truck miles every year than providing the same service under its new, zoned system. The exclusive collection zones are fundamental to a high-performance recycling system, and will enable Los Angeles to substantially boost commercial diversion rates while still reducing the pollution, expense and other negative impacts of collection truck traffic. DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 23 CONCLUSION: NEW YORK CITY AT 70% RECYCLING Leading cities like San Jose, Seattle, and Los Angeles show us that with sufficient political will, diverse urban economies can build high-performance commercial waste systems. New York City has taken a crucial first step by adopting a goal to reduce emissions 80% by 2050 and recognizing that relatively quick transformational changes in key sectors, including solid waste, will be required to attain it. Improving our 25% recycling rate for putrescible commercial waste to 70% within the next few years is an ambitious, but attainable goal that we must achieve to hit our larger climate change targets. Doing so would have a major impact on greenhouse gas emissions and would make New York a leader among global cities seeking to transform their economies through investment in climate change prevention and mitigation. It would also provide immediate local benefits to NYC businesses, workers, and communities. In the long-term, we will need to go even further to complete our path to an 80% reduction in greenhouse gas emissions - we will need to reduce consumption and recycle nearly all of our residential and commercial waste. A commercial waste system redesigned to meet these short and long-term goals will need to include: • • • • Major investments in infrastructure for sorting traditional recyclables (high-technology, highvolume materials recovery facilities (MRFs) designed to separate plastics, glass, metal, and paper with minimal cross-contamination). Major investments in organics recycling (anaerobic digestion and/or composting facilities that can produce fertilizer and clean energy from commercial food waste sources such as restaurants, food processors, and markets). A collection system that minimizes truck miles through geographically dense collection zones, and rationally and equitably located waste processing facilities. A reporting system that generates reliable data on the amounts of waste generated, recycled, landfilled, and incinerated, enabling New York City to ensure compliance and accurately assess our performance with respect to greenhouse gas emissions and other key indicators. While a 21st century commercial waste system will need to reflect the unique constraints and opportunities of our urban geography, such as scarcity of land for siting new infrastructure, and extremely dense commercial districts, the key features of the exclusive collection zone systems adopted by leading cities would offer enormous benefits to New Yorkers: • Trucks from multiple companies would no longer leap-frog each other every night to collect waste. These gains in efficiency would in turn enable us to maximize the recyclability of our paper and food DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 24 waste through source separation, while simultaneously realizing decreases in truck traffic. Communities throughout the city – and especially those near truck routes and waste facilities – would benefit from reduced traffic, noise, and safety hazards. • • Haulers would compete for the right to serve customers in designated zones via a bidding process. Successful bidders would be required to meet rigorous environmental targets, maintain high-road labor standards, and charge affordable, transparent prices that reward businesses for waste reduction and recycling. In return, the bidder would benefit significantly from a large, stable, and dense base of customers. By extending exclusive collection rights over a number of years (typically 10-15), the city could require haulers and their bidding partners to make long-term investments in better recycling infrastructure, cleaner trucks, and better working conditions for employees. To meet recycling targets, haulers would be required and incentivized to provide ongoing education to business customers about how to maximize the recyclability of waste, and haulers would in turn submit detailed, verifiable data to the City on amounts of waste collected, recycled, and disposed. Our City’s oversight system could be reoriented toward real-time monitoring of recycling performance, customer education, and waste prevention programs. Given the tremendous volume of waste generated by New York City businesses, a 70% commercial recycling system would redirect massive flows of materials and energy away from landfills and incinerators and into our regional economy. This would mean that: 68 • More than 500,000 tons per year of organic food waste currently disposed could be anaerobically digested to produce a clean source of biogas for New York’s energy grid and/or composted to create organic fertilizer. Composting 70% of our commercial food waste would eliminate the equivalent of 260,000 tons of carbon dioxide (CO2) per year.69 • Over 160,000 tons of office paper and 165,000 tons of cardboard currently disposed would be recycled, saving over a 100 billion gallons of water, and saving enough energy to power 160,000 American homes for one year.70 This improvement in paper and cardboard recycling would eliminate 1 million tons of CO2 per year, equivalent to the emissions of 220,000 passenger cars. • Overall, our city would lower carbon emissions by 2-4 million tons of CO2 per year, the equivalent of taking 400,000 – 800,000 cars off of the road. Private sanitation trucks currently travel more than 50 million miles per year on our local streets and highways. By rationalizing our chaotic collection system, we can eliminate millions of these unnecessary miles, and ensure that the savings from transforming this wasteful system are used to pay for a cleaner and safer commercial waste system. DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 25 APPENDIX A: COMMUNITY HAULER SURVEY AREAS TOTAL NUMBER OF BUSINESSES SURVEYED (SUMMER, 2014): 756 4 8 9 10 11 2 3 7 1 12 13 5 1 Hunts Point 2 S oundvie w 3 Mo rrisania 4 Me lrose 5 Williams burg 6 S unse t Park 7 Mo rn in gside Heigh ts 8 Uppe r East S ide 9 Midto wn 10 He rald S quare 11 Financial Dis trict 6 14 12 As toria 13 Jackson He ights 14 Graniteville DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 26 ENDNOTES 1 See City of New York, “New York City’s Pathway to Deep Carbon Reductions, Mayor’s Office of Long-Term Planning and Sustainability,” 2013. Available at: http://s-media.nyc.gov/agencies/planyc2030/pdf/nyc_pathways.pdf 2 City of New York, “PlaNYC 2014 Progress Report.” Available at: http://www.nyc.gov/html/planyc2030/downloads/pdf/140422_PlaNYCP-Report_FINAL_Web.pdf 3 New York City Mayor’s Office, “Inventory of New York City Greenhouse Gas Emissions,” December 2013. Available at: http://www.nyc.gov/html/planyc/downloads/pdf/publications/NYC_GHG_Inventory_2013.pdf 4 City of New York, “New York City’s Pathways to Deep Carbon Reductions,” p106. 5 Halcrow Engineers, PC, “New York City Comprehensive Commercial Waste System Analysis and Study, Technical Memo 1a,”Aug 2012. Memo 1a at p. 39. (hereinafter “Halcrow Study”) 6 DSNY’s 2004 comprehensive commercial waste study estimated diversion at 29%. The PlaNYC update released in 2011 cited a commercial waste recycling rate of 40%, but did not include methodology or explain which waste streams were included in the estimate. Available at: http://smedia.nyc.gov/agencies/planyc2030/pdf/planyc_2011_planyc_full_report.pdf, p. 137. 7 Source: 2013 and 2014 transfer station and recycling facility annual reports filed by integrated hauling companies including Action Environmental and Mr. T Carting/Hi-Tech Resource Recovery. Analysis of tons received, tons disposed, and tons recovered/recycled shows that only 10-13% of waste processed by these companies is recycled. Facility reports are available at: ftp://ftp.dec.ny.gov/dshm/SWMF/ 8 Halcrow Study, Memo 1c. 9 The estimate is 26% if an estimate of commercial and residential landscaping waste is included in the calculation. 10 See endnote 7. 11 Halcrow Study, Memo 1c, Table 15. 12 The DSNY/Halcrow study does not include an estimate of food waste currently recycled by composting or digestion, other than Fat/Oil/Grease recycling which tends to be done by specialty recyclers. Some NYC transfer stations report delivering separated food waste to compost facilities in annual reports submitted to NYS Dept. of Environmental Conservation, but do not specify whether these tonnages were from residential or commercial waste streams. The amounts of compost reported by these transfer stations are minimal, ranging from .2% to 3.5% of total waste tons received. DEC transfer station reports are available at: ftp://ftp.dec.ny.gov/dshm/SWMF/ 13 Halcrow Study, Memo 1c, Table 11. 14 New York City Mayor’s Office of Long-Term Planning and Sustainability, “Sustainability and Solid Waste: Doubling New York’s Recycling Rate by 2017,” 2013. Available at: http://waste.ccac-knowledge.net/sites/default/files/CCAC_images/City%20Assessment%20-%20New%20York%20City,%20USA.pdf 15 US Environmental Protection Agency, “Overview of Greenhouse Gases,” Available at: http://epa.gov/climatechange/ghgemissions/gases/ch4.html Accessed on April 8, 2015. 16 US Environmental Protection Agency, “Paper Recycling,” Available at: http://www.epa.gov/osw/conserve/materials/paper/basics/ Accessed on April 8, 2015. 17 US Environmental Protection Agency Region 10, “Reducing Greenhouse Gas Emissions Through Recycling and Composting,” May 2011. Available at: http://www.epa.gov/region10/pdf/climate/wccmmf/Reducing_GHGs_through_Recycling_and_Composting.pdf 18 Estimate derived from comparisons of landfilling and composting food waste using the US EPA WARM Model. Available athttp://epa.gov/epawaste/conserve/tools/warm/Warm_Form.html 19 Tellus Institute with Sound Resource Management, “More Jobs, Less Pollution: Growing the Recycling Economy in the U.S,” 2011, p46. Available at: http://www.tellus.org/publications/files/More_Jobs_Less_Pollution.pdf 20 New York State Department of Environmental Conservation Transfer Station Annual Reports for 2013. Tonnages sent to landfill and incinerator destinations were analyzed for four major NYC putrescible transfer stations which handled 100% commercial waste in 2013. 21 Global Alliance for Incinerator Alternatives, “Myths vs. Facts about Waste to Energy,” February, 2012. Available at: http://www.noburn.org/downloads/Incinerator_Myths_vs_Facts%20Feb2012.pdf 22 RW Beck for NYC Economic Development Corporation, “Hunts Point Anaerobic Digestion Feasibility Study,” July 2010, p. 2-12. Available at: http://www.nycedc.com/sites/default/files/filemanager/Projects/Hunts_Point_Peninsula/HuntsPointAnaerobicDigestionFeasibilityStudy.pdf 23 Tellus Institute with Sound Resource Management, “More Jobs, Less Pollution: Growing the Recycling Economy in the U.S.” 2011. 24 US Census Bureau, “American Community Survey, County Business Patterns,” 2012. Available at: http://www.census.gov/econ/cbp/ 25 Estimates of jobs per ton of waste processed are from the Tellus Institute report (see Endnote 19). Estimates of tons disposed and recycled are from Halcrow Engineers, Technical Memorandum 1c, Tables 5, 12, and 15. 26 NYC Business Integrity Commission, “Customer’s Bill of Rights.” Available at: http://www.nyc.gov/html/bic/html/trade_waste/customer_info_rights.shtml 27 New York City Economic Development Corporation, “Sims Municipal Recycling Facility,” January 8, 2015. Available at: http://www.nycedc.com/project/simsmunicipal-recycling-facility, Accessed April 8, 2015. 28 Halcrow Engineers estimates that NYC’s food and accommodation sector alone produces 428,000 tons per year of organics. Current capacity at regional facilities is less than 150,000 tons per year. See Benjamin Miller and Juliette Spertus, “Encouraging the Development of Organics Processing Infrastructure for New York City’s Waste Stream,” New York League of Conservation Voters, October 2012. Available at: http://www.nylcv.org/sites/nylcv.civicactions.net/files/Organics_White_Paper.pdf DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 27 See also RW Beck, “Hunts Point Anaerobic Digestion Feasibility Study,” July 2010. Available at: http://www.nycedc.com/sites/default/files/filemanager/Projects/Hunts_Point_Peninsula/HuntsPointAnaerobicDigestionFeasibilityStudy.pdf 29 Erik Engquist, “Recycling Reprieve for Food Businesses.” Crains Business Insider, Dec. 9, 2014. Available at: http://www.crainsnewyork.com/article/20141209/BLOGS04/141209844/recycling-reprieve-for-food-businesses 30 The City has estimated that anaerobic digestion would save $60/ton compared to landfilling organic waste when energy production and future rising costs of landfills are taken into account. “New York City’s Pathways to Deep Carbon Reductions,” p. 107 31 Price Waterhouse Coopers, LLP. Unpublished Study of Price Regulation of New York City Commercial Waste Hauling for New York City Economic Development Corporation. September 26, 2014. 32 John Metcalf, “Inside the Surprisingly Lucrative World of Cardboard Theft,” CityLab, July 13, 2012. Available at: http://www.citylab.com/work/2012/07/insidesurprisingly-lucrative-world-cardboard-theft/2761/ 33 New York City Administrative Code, Title 16-306 “Private Carter-Collected Waste” 34 Licensed truck figure from MJ Bradley and Associates, “New York City Commercial Refuse Truck Age-Out Analysis,” September, 2013. Available at http://www.edf.org/sites/default/files/EDF-BIC%20Refuse%20Truck%20Analysis%20092713.pdf. List of trade waste haulers licensed by BIC is from http://www.nyc.gov/html/bic/downloads/pdf/pr/licapproved.pdf. 35 There is evidence that NYC has never had a very efficient private waste system. As long ago as the early 1990s, the Dinkins administration recognized that in addition to high prices, organized crime cartels in the commercial waste sector created a ”crazy-quilt system in which you can have a dozen [haulers] operating inefficiently in one block.” See Selwyn Raab, “Plan to Revise Trash Pickup for Businesses,” New York Times, March 5, 1992. 36 TDTNY Analysis of the 2014 BIC Customer Registry, obtained via Freedom of InformationL request. 37 Businesses are required by law to display a window decal showing the name of the BIC-licensed hauler collecting their waste and/or recyclables. TDTNYC surveyors were able to inspect these stickers to determine the number of haulers operating on each block in commercial strips throughout the City. 38 TDTNYC analysis of disposal destinations for major transfer stations using 2012 NYS Department of Environmental Conservation Waste Transfer Station Annual Reports. Reports available at: ftp://ftp.dec.ny.gov/dshm/SWMF/ 39 Halcrow estimates of commercial miles per ton range from 11.9 to 19.0 depending on haulers and computer models of routes (See Halcrow Study, Memo 3, Tables 1 and 2.) Notably, hauling companies refused to share GPS or mileage data which would have allowed direct comparisons. An alternative estimate of commercial efficiency can be developed from MJ Bradley’s 2013 study of the commercial waste fleet age. With each truck driving an estimated 12,000 miles per year, total fleet mileage would be 51 million miles per year, yielding about 9.3 miles driven per ton. MJ Bradley and Associates, “New York City Commercial Refuse Truck Age-Out Analysis,” September 2013. Estimates of DSNY miles per ton are derived from publicly available fleet reports available at http://www.nyc.gov/html/ops/downloads/pdf/fleet_report.pdf and http://www.nyc.gov/html/dcas/downloads/pdf/fleet/fleet_local_law_38_DSNY_2012_final_report_3_25_2013.pdf 40 Halcrow Study Memo 3 at p. 11. 41 MJ Bradley and Associates, “New York City Commercial Refuse Truck Age-Out Analysis,” September, 2013. 42 New York City Local Law 145 of 2013. 43 Jerrett M, Shankardass K, Berhane K, Gauderman WJ, Kunzli N, Avol E, et al, “Traffic-related air pollution and asthma onset in children: A prospective cohort study with individual exposure measurement.” Environmental Health Perspectives, 2008; 116(10): 1433-1438. See also: Kim JJ, Huen, K, Adams S, Smorodinsky S, Hoats A, Malig B, et al. Residential traffic and children's respiratory health. Environmental Health Perspectives, 2008; 116(9): 1274-1279. 44 American Cancer Society, “World Health Organization Says Diesel Exhaust Causes Cancer,” June 15, 2012. Available at: http://www.cancer.org/cancer/news/worldhealth-organization-says-diesel-exhaust-causes-cancer 45 Halcrow Study. 46 Charles Komanoff, “See a Pattern of Deadly Dump Trucks? Don’t Bother Federal Safety Officials.” Streetsblog.org. 13 July 2010. Available at: http://www.streetsblog.org/2010/07/13/see-a-pattern-of-deadly-dump-trucks-don%E2%80%99t-bother-federal-safety-officials/. 47 Inform, Inc,“New York City’s Commercial Waste Hauling Fleets: An Opportunity for New York City to Ensure Cleaner, Quieter Waste Collection Operations.” Feb 2006, p. 8. Available at: http://www.informinc.org/reportpdfs/st/INFORM%20NYC%20Commercial%20Waste%20Haulers%20Report%28final%29.pdf 48 In 2012, more than 700 Manhattan residents called 311 to complain about garbage truck noise. See: http://karlsluis.com/newyorkcitymaps/nyc_noisemap_1.png 49 Hammer et al, “Environmental Noise Pollution in the United States: Developing an Effective Public Health Response,” Environmental Health Perspectives, February 2014. Available at: http://ehp.niehs.nih.gov/1307272/ 50 Inform, Inc. “New York City’s Commercial Waste Hauling Fleets: An Opportunity for New York City to Ensure Cleaner, Quieter Waste Collection Operations.” Feb 2006. Available at: http://www.informinc.org/reportpdfs/st/INFORM%20NYC%20Commercial%20Waste%20Haulers%20Report%28final%29.pdf 51 Washtenaw County, “Washtenaw County Recycles: Residential Solid Waste Profile & Assessment Report,” May 2005. p12. Available at: http://www.ewashtenaw.org/government/departments/environmental_health/recycling_home_toxics/solid-waste/profile_and_assessment_report/sw_report.pdf. 52 Williamsburg/Greenpoint OUTRAGE, “Truck Traffic and Air Quality Project,” 2009. Available at: http://outragenbk.org/wpcontent/uploads/pdf/OUTRAGE_Truck_Traffic_and_Air_Quality_Full_Report.pdf 53 The 14 South Bronx transfer stations include facilities processing Construction and Demolition and Fill material. Additionally, there are several recycling facilities in the South Bronx. All of these sites contribute to negative local health and safety impacts by concentrating diesel truck traffic in the South Bronx. 54 New York State Comptroller’s Office, “The Prevalence and Cost of Asthma in New York State,” 2014. Available at: http://www.osc.state.ny.us/reports/economic/asthma_2014.pdf 55 Spira-Cohen, et al, “Personal Exposures to traffic-related air pollution and acute respiratory health among Bronx schoolchildren with asthma.” Environmental Health Perspectives, 20111; 119(4) 559-565. Available at: http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3080941/ DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 28 56 Natural Resources Defense Council, “Truck Drivers Face Elevated Health Risks from Diesel Pollution,” December, 2007. Available at: http://www.nrdc.org/health/effects/driving/driving.pdf. 57 Jacquelyn Smith, “The Ten Deadliest Jobs in America,” Business Insider, December 5, 2014. Available at: http://www.businessinsider.com/most-dangerous-jobs-inamerica-2014-12# 58 Seattle Public Utilities, “2014 Organics Report.” Available at: http://www.seattle.gov/Util/cs/groups/public/@spu/@garbage/documents/webcontent/01_030055.pdf 59 Seattle Public Utilities, “2014 Recycling Report.” Available at: http://www.seattle.gov/Util/cs/groups/public/@spu/@garbage/documents/webcontent/01_030056.pdf 60 City of Seattle, “Solid Waste Collection and Transfer Contract Between City of Seattle and Cleanscapes, Inc.,” Sections 800 and 845. Available at: http://www.seattle.gov/util/cs/groups/public/@spu/@garbage/documents/webcontent/spu01_005944.pdf 61 TDTNYC analysis of Seattle Public Utilities Recycling and Organics Reports for 2006-2014. 62 Sources: Quarterly recycling reports and direct communication with San Jose Environmental Services Department (2014 data were unaudited by the city as of publication.) 63 Nora Goldstein, “Creating Infrastructure for Commercial Waste Diversion,” BioCycle, August 2011. Avilable at: http://www.greenwaste.com/sites/default/files/pdfs/ZWED_BioCycle_Organics%20Processing_Part%20II_August%202011.pdf; US Environmental Protection Agency,” EPA, San Jose, Recycler celebrate food waste to energy conversion,” November 2014. Available at: http://yosemite.epa.gov/opa/admpress.nsf/0/4AA0D04C1225418785257D9B0060224B 64 The Organic Stream, “Lessons Learned From San Jose, CA,” October 20, 2014. Available at: http://www.organicstream.org/2014/10/20/lessons-learned-from-sanjose-ca-building-anaerobic-digestion-facilities-for-municipal-organics/ 65 Los Angeles Bureau of Sanitation, “RFP: City-Wide Exclusive Franchise System for Municipal Solid Waste Collection and Handling,” June 11, 2014, Appendix 1.4. 66 Partnership for Working Families and New York Lawyers for the Public Interest, conversations with various anaerobic digestion facility developers, January 2015. 67 Los Angeles Bureau of Sanitation, “Draft Environmental Impact Statement, City-Wide Exclusive Franchise System For Municipal Solid Waste Collection and Handling,” November 21, 2013. Table 3.1.4-4, p. 3-68. 68 GHG figures and equivalences in this section were calculated using EPA’s WARM Model with inputs from Halcrow Study memo 1c, Table 5 “Materials Currently Diverted Mass Flow Analysis” and Table 15 “Tonnages Currently Disposed Suitable for Diversion Efforts.” The EPA WARM calculator is available at: http://epa.gov/epawaste/conserve/tools/warm/Warm_Form.html 69 The EPA’s WARM model only estimates the comparative GHG impacts of composting, landfilling, and incinerating food waste. Few life-cycle analyses of anaerobic digestion and composting have been completed; some facilities such as the ZWED plant in San Jose use both processes. 70 US Environmental Protection Agency, “Paper Recycling,” Available at: http://www.epa.gov/osw/conserve/materials/paper/basics/ DIRTY, WASTEFUL & UNSUSTAINABLE: THE URGENT NEED TO REFORM NEW YORK CITY’S COMMERCIAL WASTE SYSTEM • TRANSFORM DON’T TRASH NYC 29