ALIGN Testimony

Council Member Shaun Abreu, Chair

New York City Committee on Sanitation and Waste Management

My name is Jenille Scott, and I am the Climate Director of ALIGN: The Alliance
for a Greater New York. We bring together labor, climate, and community for a
more just and sustainable New York, and I am writing as one of the leading
organizations of the Transform Don’t Trash Coalition fighting for a green
economy and better conditions for our state’s workers. Thank you to Sanitation
committee chair Council Member Shaun Abreu for the opportunity to submit
testimony today.

ALIGN strongly supports Intro 55 which requires the Department of Sanitation
to accept commercial solid waste at city-owned or operated marine transfer
(MTS) stations and city-owned or operated rail transfer stations. The use of
marine transfer stations is a more environmentally sound practice than the use
of long haul trucks and will reduce truck miles traveled and traffic which
creates safer streets for pedestrians and reduces noise issues caused by the
current truck based system. Additionally, it will reduce the emission of harmful
pollutants which are released in already overburdened communities. This will
undoubtedly improve the air quality of these communities and create healthier
environments for workers. Marine transfer stations are operated by the New
York City Department of Sanitation (DSNY) so there are more stringent
requirements for compliance with regulations and labor standards so there are
less concerns than with privately owned facilities.

Intro 55 also creates an accountability measure for DSNY in the form of an
annual report that should be submitted to the Mayor, Speaker and to be made
publicly available online around the acceptance and processing of commercial
waste at each transfer station. This further emphasizes the aforementioned
point of more stringent compliance requirements for DSNY which will ensure

proper functioning of the facilities and maintenance of cleaner and safer
streets for workers and the surrounding communities.
The timing of this bill is significant as progress, although delayed, is being
made on the implementation of 20 Commercial Waste Zones (required by Local
Law 199) later this year. These commercial waste zones were developed with
the intention of creating safer and healthier environments and Intro 55 helps to
further the purpose of LL199 . Additionally the 2006 Solid Waste Management
Plan (SWMP) is nearing expiration and the new 20-year SWMP is due in 2026 so
this is a prime opportunity to ensure we develop and implement the 2026
SWMP the right way.

We urge this committee and council to support the passage of Intro. 55 and
bring overdo reform to the solid waste management system in New York. Thank

Jenille Scott
Climate Director

NYC-EJA Testimony

Testimony on the City’s Infrastructure to Handle and Process Organic Waste Pursuant to

Int. No. 55- Committee on Sanitation and Solid Waste Management

New York City Council
February 27, 2024

Founded in 1991, the New York City Environmental Justice Alliance (NYC-EJA) is a non-profit,
501(c)3 citywide membership network linking grassroots organizations from low-income
neighborhoods and communities of color in their struggle for environmental justice. NYC-EJA
empowers its member organizations to advocate for improved environmental conditions and
against inequitable environmental burdens by the coordination of campaigns designed to inform
City and State policies. Through our efforts, member organizations coalesce around specific
common issues that threaten the ability of low-income communities of color to thrive. NYC-EJA
is led by the community-based organizations that it serves. NYC-EJA is also a founding member
of Transform Don’t Trash (TDT), a longstanding coalition of environmental justice, labor, and
climate organizations working to transform New York City’s sprawling solid waste management
systems to be far more equitable, efficient, sustainable, and safe for workers and the
communities most affected by solid waste infrastructure.
In New York City, over 24,000 tons of garbage are produced daily, generating massive
transportation and pollution impacts to and from privately owned and operated waste transfer
stations along the waterfront. The current solid waste system is an ongoing environmental
injustice, in which 75% of the City’s waste is still trucked in and out of a handful of low-income
communities and communities of color. The vast majority of this garbage generated by
businesses and buildings citywide passes through communities with some of the highest rates
of asthma such as North Brooklyn, the South Bronx, and Southeast Queens. Despite laws
intended to change this, these communities of color continue to deal with far more than their fair
share of heavy truck traffic, safety hazards, pollution, noise, and odor that other neighborhoods
are spared. For this reason, NYC-EJA is here to express our strong support of Intro 055 of
2024, which would require DSNY to begin using municipal marine transfer stations to accept
commercial waste. Passage of this legislation would hasten the long overdue transition of NYC’s
waste export system from a polluting truck-based one to a water barge-based system, where
one barge can replace the capacity of 48 eighteen wheel tractor trailer “long haul” trucks from
spewing pollutants into these communities.
While the total amount of waste handled at private transfer stations in NYC has decreased
approximately 17% since the implementation of Local Law 152 of 2018 (the “Waste Equity
Law”), newly released data from the Department of Sanitation shows that the system remains

grossly unfair and unequal. Just four community districts still handle 75% of all NYC’s private
waste. Additionally, private waste transfer stations are more likely to be sited in communities
with a higher percentage of people of color living below the poverty line and bring with them
truck traffic, noise, and health-harming emissions according to NYC Comptroller’s recently
released audit report on the City’s Fair Share compliance. While there are 24 waste facilities
crammed into these overburdened community districts, a total of 45 other districts have no
waste facilities at all.
Reducing emissions and pollutants from trash removal operations is necessary for the climate
and health of all New Yorkers. City government can lead the way in spearheading environmental
protection, by going deeper than providing surface-level programmatic design without thorough
implementation efforts. Mayor Adams and the City Council should take immediate steps to
relieve these communities of excessive truck traffic, pollution, and odors, while reducing the
miles that are driven by dangerous and polluting waste trucks e on New York City Streets. We
call on the Mayor and City Council to Pass Intro 055 of 2024, which would require the City to
begin accepting commercial waste at publicly-owned Marine Transfer Stations, thereby
significantly reducing the number of dirty, dangerous diesel garbage trucks spewing
co-pollutants into already overburdened neighborhoods. Environmental justice communities
have long advocated for this step, which is required by the Solid Waste Management Plan
passed by the City almost 20 years ago but has still not been implemented by DSNY.
The fight for waste equity, cleaner air, healthier and safer communities continues as we work to
ensure not only that the City handles its trash and siting of waste transfer stations more
equitably, but also reduces its greenhouse and co-pollutant emissions by transitioning to
greener, alternative modes of solid waste management. NYC-EJA alongside TDT looks forward
to continued engagement with the Committee on Sanitation, and Council Members representing
impacted communities to ensure that we continue to make rapid progress toward a more
sustainable and just future.

NYLPI Testimony

In Support of Intro 55 of 2024

Thank you, Council Member Abreu and members of the Sanitation Committee, for the
opportunity to submit testimony today.

New York Lawyers for the Public Interest (NYLPI) strongly supports Intro 55 of 2024 requiring
the Department of Sanitation (DSNY) to begin accepting commercial waste at the City’s marine
and rail waste transfer facilities. This would enact a long-delayed environmental justice priority
by reducing the number of trucks traveling in and out of communities overburdened by private,
truck-based transfer stations. Currently, private sanitation trucks must travel unnecessary miles
across boroughs and communities to reach private transfer stations where waste is then
exported using large, highly polluting long-haul trucks.

The City’s nearly expired 2006 Solid Waste Management Plan (SWMP) directed DSNY to report
on efforts to process commercial waste at marine transfer stations and to issue an RFP to
process commercial waste at least one Manhattan marine transfer station, but no further action
has been announced.

The timeline required by Intro 55 is appropriate, as it would precede the new 20-year Solid
Waste Management Plan due in 2026 and would coincide with the expected citywide
implementation of the new Commercial Waste Zones (CWZ) system required by Local Law 199
of 2019.

The CWZ program was designed to sharply reduce commercial waste truck mileage citywide
and incentivize the use of waste and recycling facilities with high safety and environmental
standards, including publicly owned marine and rail-based transfer stations.
In the absence of equitable and efficient options to utilize municipal facilities located near
commercial districts and commercial waste routes, DSNY’s most recent Waste Equity report
shows that almost 12,000 tons per day (75%) of the City’s commercial waste continues to be
trucked in and out of a handful of overburdened communities in the South Bronx, North
Brooklyn, and Southeast Queens.

Fundamental reforms to a notoriously inefficient, dangerous, and polluting commercial waste
system are long overdue. Intro 55 would implement a common-sense solution first written into
the City’s SWMP almost two decades ago. We urge this committee and the Council to pass it
into law as soon as possible.