The furor over the Mayor’s transfer station siting plan has temporarily abated but will undoubtedly heat up in the fall once the state sets a date for the implementation of the city’s Solid Waste Management Plan (SWMP). When it does, the Mayor’s temporary victory over the Speaker on transfer station siting will be quickly forgotten as a contentious battle over the inadequacies of the SWMP, glossed over in the land use site fight, begins in earnest.
In particular, many of the mayor’s temporary allies on the Council will begin to blast away at the most egregious flaw in the City’s plan: the total failure to come to grips with the collection and disposal of commercial waste. Much of this fight traces back to the commercial waste study commissioned pursuant to Local Law 74.
This study had two basic mandates. The first was to examine the environmental and public health impacts of the clustering of privately-owned waste transfer stations in certain communities. This aspect of the study was effectively blistered by the Organization of Waterfront Neighborhoods (OWN) and the Lawyers for the Public Interest.
Without going into too much detail, the critique tore apart the Department of Sanitation (DSNY)-sponsored report and clearly underscored its failure to even minimally follow the guidelines mandated for such studies under CEQR. The commercial waste study, according to this analysis, totally whitewashed the environmental and public health impacts of transfer stations.
Since the study was supposed to help inform the new DSNY transfer station siting regulations and “provide a foundation for the Department’s efforts to develop a new Comprehensive Solid Waste Management Plan (SWMP) for the next 20 years,” its clear that the glaring inadequacies outlined by OWN raise serious questions about the legitimacy of the Mayor’s draft SWMP.
Managing Commercial Waste
The second objective of the commercial waste study under Local Law 74 was to “assist the city in managing the commercial waste stream in the most efficient and environmentally sound manner.” As we have outlined more fully in our memo to the City Council, the City’s study never did what it was mandated to do and, because of the Department’s bias, left out even analyzing significant waste reduction-recycling methodologies that would have begun to address private sector disposal issues.
The most salient gap, of course, was its refusal to analyze commercial waste disposers. As we have remarked, one could possible disagree about the efficacy of this methodology but to leave it out of its scope of work makes the entire study worthless. But efficacious it is. It's clear that commercial waste disposers do help city businesses to manage their garbage “in the most efficient and environmentally sound manner.” (Local Law 74).
Transfer Station Siting: Inextricably Connected
On top of the efficacy of commercial waste disposers, particularly for the city’s food businesses that generate the heaviest and most noxious putrescible waste, it is also true that the extensive use of the technology will inevitably (and dramatically) reduce the amount of garbage that is trucked to transfer stations and eventually sent to out-of-state landfills. Therefore, the commercial transfer station siting issue, as well as the aggregate number of such facilities that are needed, is inextricably linked to the implementation of an effective waste reduction methodology in the private sector.
Fair Share is an important concept but it need not be based on the faulty assumption, built on the malfeasance of the DSNY, that being fair is insuring everyone suffers equally. Instead of pitting communities against each other, policy makers need to find ways to reduce the necessity and number of noxious transfer stations in the first place. In the fall, the failure of the city to do this will keynote the policy debate and hopefully link communities in a common effort to craft a sensible, and waste reducing, SWMP.