Monday, December 05, 2005

Food Waste Disposers, the DEP and DSNY: Bad Faith and Bad Policy

Given the depth of the solid waste crisis in NYC, it is mystifying that the two lead agencies whose mandate is to address the issue have taken such an unyielding position to the use of food waste disposers as one crucial methodology that can be usefully employed to mitigate a whole range of garbage disposal problems. The failure of the Department of Sanitation (DSNY) is most egregious since that agency has historically supported disposer use with enthusiasm (In fact current DEP Commissioner Emily Lloyd was one of the device's cheerleaders when she was Sanitation Commissioner in the early 90s).

The DSNY turn around posture is so extreme that it cannot be understood without the strong suspicion that it is coerced. This is underscored, as we have pointed out elsewhere, by the Department's failure to include any analysis of the efficacy of food waste disposers in its City Council mandated study of commercial waste.

It should be pointed out that this so-called study was worthless from any perspective and was properly excoriated by the Organization of Waterfront Neighborhoods. All of which is dramatized by the obvious inadequacies, pointed out strikingly by Councilmember David Yassky, of the city's SWMP in dealing with the problems of commercial waste.

The SWMP, and the mayor's clever fair share siting plan, only deals half-heartedly with the issues of truck traffic and the overburdening of certain low-income communities with noxious waste transfer stations. And as we have said before, there is absolutely nothing in the plan that will lead to any significant waste reduction. What this all means is that the city has the worst of both worlds: it has an overly expensive solid waste plan that maintains the environmental burdens on certain less-empowered neighborhoods.

The Alliance's Richard Lipsky outlined all of this in a 2003 memo to EDC Executive Vice president Kate Ascher. The memo clearly laid out the inadequacies of the city's solid waste policy and reminded Ascher that it was the mayor himself who, commenting on the dangers of garbage truck traffic when the city's original plan had collapsed, said that, "We are not going to continue to give our kids lung disease, no matter what the cost is...That's the bottom line."

Well Mr. Mayor, the bottom line is that without significant waste reduction, at both the residential and commercial end, the communities that are now saturated by garbage truck traffic will continue to suffer. At the same time the costs and uncertainties of garbage export will continue to threaten the city's fiscal health.

Food Waste Fanaticism

Which brings us to the issue of obstruction and bad faith. Our Ascher memo clearly lays out the following benefits accrued from the use of food waste disposers:

1) Cleaned up neighborhood stores and the associated public health benefits

2) Reduced truck traffic as number of pick-ups is concomitantly reduced

3) Reduced export dependency, a process whose costs are escalating

4) Reduced transfer station activity and the elimination of putrescibles that make the activity so noxious.

No one argues that this will be accomplished without any attendant costs to the city's waste water infrastructure. What is missing, however, is any cost-benefit analysis, something we encouraged Ascher to do since we believe strongly that the two lead agencies have a "trained incapacity" to do the necessary evaluation. In addition, given the fact that existing data compiled by the DEP in its 1995 pilot study indicate that the agency's alarmist attitude might be suspect, the whole issue cries out for a fair and impartial analysis.

All of this is given greater credence by the fact that the city of Philadelphia, a municipality with a similar sewer infrastructure, reports none of the doom and gloom that DEP spews forth whenever the disposer issue is brought up.

Wisconsin Study Should be Replicated

Aside from the DEP's own pilot evaluation of disposers, we also are fortunate to have a study done by the University of Wisconsin. This study, which was commissioned by a manufacturer of disposers but was conducted under rigorous scientific guidelines and done by leading environmental engineers, found that "the disposer is the most convenient and most likely to be used method to achieve source separation of the putrescible waste from the solid waste stream."

In addition, in comparing the use of disposers to other systems such as composting and landfilling, the study determined that, "A food waste disposer processing food waste through a publicly owned treatment works (POTW) has the lowest cost to the municipality; the least air emissions, especially greenhouse gases!; converts the food WASTE to a RESOURCE which may be recycled; and as a result overall is the most environmentally friendly and sustainable option for recycling non-edible food RESOURCES" (emphases added).

Of particular interest is the study's comparison of disposer use to the vaunted compost option. As the study points out, "Hauling food waste that is 70% water represents over 59% of the life-cycle costs of the compost operation." The problems of retrieval in a complex urban environment only exacerbate the costliness of this option (not to mention the logistics and expense of compliance).

It is also important to emphasize that a compost facility requires a great deal of space that is unavailable near a city like New York. Long-haul trucking is required and it should also be emphasized that a so-called compost facility is nothing more that a rather smelly landfill in terms of its impact on localities.

Even more significant is the comparable value of the end-products: "Composting also results in the loss of most of the nutrients in the food to the extent the resulting product is of very low value and is typically not worth the cost of hauling and spreading it into the soil. In some communities the compost is of such low value that it is used as landfill cover. Food waste can be processed through the POTW at a much lower cost to the municipality, retain the nutrients for recycling and reduce the atmospheric emissions" (emphasis added).

What this all should mean is that the potential benefits of both residential and commercial food waste disposers need to be carefully studied by an independent team of evaluators. The Wisconsin study may be viewed as biased (although opponents imbued with a blind righteousness have never bothered to try to replicate it) but when coupled with the DEP's own evaluation there is enough evidence to suggest that the benefits of the use of disposers far outweighs any of the costs.

This is why Intro 742 is vitally needed to not only cut through all of the agency obscurantism, but to also afford policy makers a clear unbiased view of what are the best methods for the city to dispose of its waste in an environmentally sound and economically efficient manner. To continue to refuse is to shortchange New York's citizens and is the ultimate manifestation of bad faith.