NWRA Testifies at NYC Council Committee Hearing on Commercial Waste Zones

NWRA Testifies at NYC Council Committee Hearing on Commercial Waste Zones

Arlington, VA – Lew Dubuque, vice president of chapter management for the National Waste & Recycling Association (NWRA), testified before the New York City Council Committee on Sanitation and Solid Waste Management about the city’s proposal for commercial waste zones (CWZ).

“NWRA and our members share New York City’s goals of promoting a modern and effective industry that is not just focused on providing its core services but is refocused on sustainability, zero waste, emissions reductions and fair labor practices,” said Dubuque.

NWRA offered several recommendations to the committee including:

  • Moratorium on new licensees: It appears as if the Business Integrity Commission (BIC) is still issuing licenses to companies that have not been subject to the pre-qualification process and therefore will be ineligible for a franchise award.
  • Timeline: We urge a measured and extended implementation timeline to ensure that customer service and account transitions are executed in an orderly and efficient manner. Further, award winners will need appropriate time to communicate, procure equipment and ramp staffing to onboard new customers and amend service levels. Sequencing the transition of zones to “test” the process is worth consideration, even if such a strategy extends the implementation timeline.
  • Implementation: Engage effectively with industry on suggestions for an orderly transition to the new zoning structure. The current Q&A approach is inefficient and severely limiting in terms of the open and frank exchange of ideas, concerns and solutions. There is a wealth of experience and knowledge in the industry that will inform and benefit the process.
  • Pricing Model: The pricing model for containerized waste requested in the current request for proposals (RFP) is deficient as the “Max Rate” concept ignores the predominant pricing model of service charge for collection plus charge for actual container weights. We suggest that the RFP be amended to establish max rates for the service charge as well as the disposal charge, consistent with historical, transparent practices. Every effort should be made to minimize that possibility by a careful review of the proposed system.
  • Regulations: The City of New York Department of Sanitation (DSNY) must issue the remaining drafts and finalize all outstanding regulations that affect in any way CWZ obligations and implementation.
  • Data: Update all available data, including but not limited to the number of commercial businesses; waste generation of all types; fuel costs; disposal costs; recycling/organics processing costs; the number of industry companies remaining; and the number of industry employees and their wage scales.
  • Comprehensive Picture: When all regulations are completed, and market data updated, DSNY should develop a comprehensive picture of the intended CWZ scheme and its implementation, and present it to key stakeholders, including the business community.
  • Business Integrity Commission’s Role: Clarify/confirm whether/what BIC’s role will be post-implementation.
  • Quality Control: Subject the entire package to independent review for suggestions on final improvements.

NWRA will continue to engage with New York City on these issues and help implement the CWZ program.


The National Waste & Recycling Association (NWRA) represents the private sector waste and recycling services industry. Association members conduct business in all 50 states and include companies that manage waste, recycling and medical waste, equipment manufacturers and distributors, and a variety of other service providers. For more information about NWRA, please visit www.wasterecycling.org.

Brandon Wright
National Waste and Recycling Association