City Council Committee on Sanitation and Solid Waste Management Hearing on Commercial Waste Zone and Organics Legislation

Good morning Chair Sanchez and thank you for holding this hearing today. My name is Erin Wright, and I’m here representing Brooklyn Borough President Antonio Reynoso. He appreciates your ongoing attention to the rollout of Commercial Waste Zones (CWZ), a program he created during his time in your position.

When fully implemented, this program will address myriad issues with the private carting industry by:

• limiting vehicle miles traveled;
• increasing enforcement of dangerous driving;
• incentivizing the replacement of out-of-date fleets;
• requiring more attention to worker safety; and
• increasing diversion of waste from landfills.

Despite unfortunate delays and our continued calls for DSNY to speed up the program’s rollout, BP Reynoso has been pleased with its implementation so far. Initial information indicates that increased enforcement in the active zones is leading to improved safety outcomes, that more workers now have union protection, and that the program has not caused costs to rise dramatically, as some had predicted.

I am here to provide comments on the three bills being heard today related to CWZ, as well as Intro 369 on expanding traditional organics processing in the five boroughs.

Intro 353 would create a CWZ Working Group. The Council has been considering this bill for many years, and it’s time to finally pass it. Having experts at the table from both within and outside the industry can only help guide the process and ensure its continued success.

Intro 367 would require DSNY to establish a plan for accepting commercial waste at the Marine Transfer Stations (MTSs). BP Reynoso originally introduced this bill when he was still in the City Council, and unfortunately DSNY continues to slow roll this necessary measure, which would remove dangerous and polluting waste trucks from our streets. Thanks to advocacy by the environmental justice community, the MTSs remove waste by barge and rail rather than long-haul truck. This bill will push DSNY to create a clear plan that will support our EJ communities, and we urge the Council to pass it quickly.

Intro 911-A would increase the number of carters allowed to participate in CWZ in Staten Island. BP Reynoso has concerns about this proposal and the precedent it could set for other zones citywide. The decision to allow three carters per zone was based on balancing the need to provide oversight to a chaotic system with the need to maintain competition within the market. Adding more carters to any zone has the potential to undermine the program’s goals as designed. Carters who DSNY did not select are not shut out of the process entirely – each awardee can subcontract with up to three businesses, leaving opportunities open. This bill is at best unnecessary and at most actively harmful to the program, and should not pass.

Unrelated to CWZ but also of high priority to BP Reynoso is Intro 369, which would require the City to establish traditional composting facilities in each borough. Right now, much of the organic waste collected curbside is sent to the Newtown Creek Wastewater Treatment Facility to be codigested with wastewater. While any diversion from landfill is better than none, traditional composting is preferable to codigestion. 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 1,600 tuck loads, of biosolids per day at its wastewater treatment plants, and much of it ends up in landfills. There are also major concerns that these biosolids are contaminated with PFAS, also known as “forever chemicals.”

Traditional composting, meanwhile, creates soil amendment the City can reuse in its parks and street trees, and these facilities create jobs and support community engagement. Intro 369 would also ensure that these facilities are sited equitably around the city, rather than the current situation, which concentrates truck traffic in North Brooklyn, counter to the goals of previous legislation supporting waste equity. I am attaching our report Expanding Composting in New York City: The Case for Passing and Implementing Intro-0369-2026, which goes into more detail about the need for this bill and creates a methodology for identifying siting opportunities citywide.

Thank you again for holding this hearing today. We look forward to continuing our work with you to monitor the rollout of CWZ and to support efforts to keep organic waste out of landfills.