Friday, December 02, 2005

DEP Nitrogen Bombs

We have pointed out that despite previous statements to the contrary, the current incarnation of the Department of Environmental Protection (DEP) is wholeheartedly opposed to the concept of commerical garbage disposals, even a pilot program that would test their impacts on the sewer system. Their biggest concern, we have been told, is that disposers will increase the amount of nitrogen in the waste stream which is costly to remove. And because New York is under strict federal guidelines via-a-vis nitrogen adding substantial amounts of organic matter will cost the city, the DEP says, upwards of $120 million. Certainly, with such high costs commercial disposers make little sense, right?

Well it depends on whether the DEP’s doomsday predictions are accurate. According to ex-Commissioner Ward’s testimony at a hearing on legalizing commercial disposers, his agency arrived at the $120 million figure – not a firm number, he admits – by consulting unnamed previous studies and by estimating the number of restaurants that would use grinders. The problem with the Commissioner’s apocalyptic forecast is that he expects us to unquestionably believe him despite the following:

1) As the agency’s opposition to grinders has increased so have their cost estimates. No new data or studies have emerged but for some reason these figures balloon at each subsequent hearing.

2) The Commissioner assumes that every restaurant in New York City will use grinders. This is hardly a proper estimate for determining impacts.

3) According to the DEP’s residential study, in terms of nitrogen impacts: The results show that in the decade after city-wide introduction of FWDs [Food Waste Disposers], increases in costs would be relatively small; approximately $4.1 million in 2005 (based on Queens and Manhattan data) for the most expensive nitrogen control measure. Measured against the estimated 1.525 billion dollar cost of maintaining the City’s water and sewer infrastructure, this represents a de minimis impact.

4) During discussions with 3 knowledgeable government officials from the city of Philadelphia, we were repeatedly told that after mandating commercial grinders there was no discernible increase in nitrogen or ammonia (which is nitrogen-based) attributable to the devices.

This last two items are especially relevant. According to real world data from the City of Philadelphia and the DEP’s own study, grinders do not add a significant amount of nitrogen to the waste stream. Instead of accepting these cold, hard facts – or at least testing them in a commercial pilot program – the DEP spurts out unsubstantiated blather and says it isn’t worth it to even have a test. The agency is so purposely blind to reality that not only has it failed to talk with Philadelphia about its positive experience but, according to a source, didn’t even know until informed today that the city mandates commercial grinders. What intellectual bankruptcy!

Another interesting point was brought out in a follow up conversation we had yesterday with a Philadelphia Water Department official. In his opinion, putting organic waste into the sewer is much more preferable than trucking it to a transfer station/landfill. First, he said, the odor of rotting organic waste is worse when being trucked than when it’s processed at a water treatment facility. Second, he said that combined waste water systems in cities like Philadelphia and New York function better when more organics are in the system. Because the waste water treatment plants are biologically-based, the more organic “food” (as opposed chemicals or plain water) that comes in the better the system’s efficiency and the better the quality of the biosolid (the end result).

Yet the New York City DEP stubbornly stands by its conjecture. Hopefully the City Council and the Mayor will realize that the agency’s claims are exactly that and the best thing to do is to test these concerns in an objective pilot program.