MANHATTAN CITIZENS’ SOLID WASTE ADVISORY BOARD

 

Office of

Manhattan Borough President

C. Virginia Fields

One Centre Street, 19th floor

New York, NY 10007

 

 

TO:                  New SWMP Comments c/o Ecology and Environment Inc.

                        90 Broad Street, Suite 1906

                        New York, NY 10004

 

FROM:            Manhattan Citizens’ Solid Waste Advisory Board

 

RE:                  Comments on the Draft Scoping Document for the Draft Environmental Impact Statement for the NYC Comprehensive Solid Waste Management Plan

 

 

The Manhattan Citizens’ Solid Waste Advisory Board (MCSWAB) submits the following comments on the Draft Scope of the Draft Environmental Impact Statement (DEIS) for the NYC Comprehensive Solid Waste Management Plan:

 

Waste Prevention, Re-use and Recycling

 

The DEIS fails to adequately examine the impact of enhanced waste prevention, re-use and recycling efforts.  Intro #174 before the New York City Council would require the adoption of a Zero Waste Management Plan.  “Reaching for Zero”, a report by the NYC Zero Waste Campaign and the Consumer Policy Institute/Consumer Union, outlines central elements of reaching a zero-waste future.  Much of that report should be incorporated into the proposed SWMP. 

 

The DEIS needs to study alternative scenarios that go beyond export of our garbage and the 20-year contract for recycling.  Building a comprehensive waste prevention program entails the siting of re-use/recycling facilities.  Further, we should encourage industries that create jobs by recycling and re-using materials that have been recovered from our waste stream.

 

The DEIS should also look at a pilot program instituting quantity-based user fees, and evaluate the impacts of such a program on waste quantity and the recycling stream.

 

The MCSWAB views the DEIS as an opportunity to study the positive environmental impacts of waste prevention, re-use and recycling programs: avoided trucking and disposal, economic development and reduction of the amount of toxic materials in our waste stream as examples.  If we want to engage in comprehensive solid waste management planning we need to look at the environmental impacts of the above- mentioned programs and study their economics comparatively with the currently outlined scenarios.

 

Long-Term Export

 

The DEIS should include an evaluation of the impacts from the handling of DSNY-collected waste and recyclables at more than the three former Manhattan sites. Tonnages should be re-distributed among a greater number of locations and the impacts of lower-tonnage scenarios should be computed. 

 

The DEIS should also include an assessment of the impacts from the handling of some amount of commercial waste at more than three sites.  That assessment should take into account the traffic, air-quality and noise impacts associated with the change in routing for collection trucks for commercial waste, together with the environmental cost savings of no longer needing to transfer commercial waste into long-haul trucks.

 

The final scope also needs to detail the commercial waste export scenarios that will be evaluated in the DEIS.

 

Selection of new sites for evaluation should be made using the basic criteria that appear necessary for physical operation of a site, according to the Department’s Commercial Waste Study: a footprint of approximately 2.8 acres, location in a manufacturing zone, and access to truck routes.  Sites should not be eliminated from consideration at this stage because they are in M-1 zones, are within a certain proximity to parks, or have legislative restrictions.  The existing Manhattan MTS sites include locations in M-1 zones and are adjacent to parks, and we believe that all potential sites should be evaluated according to the same criteria.

 

For several years, the MCSWAB Export Committee has been performing outreach to local Manhattan communities and conducting its own site research.  While the results of this work are in no way definitive or comprehensive, it is clear to us that the conclusions of the Commercial Waste Study should not serve as the basis for rejecting any export site alternatives for evaluation in the DEIS.  The Commercial Waste Study examined only those sites previously rejected in the EIS for the 2000 SWMP Modification.  Nowhere in the Commercial Waste Study does the report say why other locations were not evaluated, much less rejected.

 

EBUF

 

We support evaluation of EBUF options, which could avoid the need for expensive reconstruction of the MTSs and expansions to their footprint.  However, we request that evaluation of possible EBUF sites not to be limited to sites located outside of NYC.  Suitable sites in NYC with the appropriate industrial waterfront zoning and barge/rail access should be evaluated.  The economic development consequences, including potential job creation of such facilities, should be included in that evaluation.

 

Recyclables export

 

We strongly support the evaluation of new and existing MTSs for additional recyclables export.  Since recyclables such as paper, metal, glass and plastic are not considered putrescible waste, the siting criteria for such facilities are not as stringent as for transfer stations handling solid waste, and a scenario of creating new MTS sites in Manhattan that would handle recyclables exclusively should be evaluated.

 

Evaluation of Impacts From the Proposed Action

 

The evaluation of impacts from the proposed long-term plan should include an assessment of PM2.5 particulates, NOX, VOCs and dioxins emitted from diesel trucks, tugs, material-handling equipment and the dioxins, furans NOx and mercury emissions from the Newark waste-to-energy facility, which would impact air quality in New York City because of prevailing westerly winds.

 

Facility Design

 

Through careful consideration of building infrastructure, landscaping, water habitat and natural resources, marine-based facilities can provide innovative methods of education can be a lasting example of how well-designed, functional systems can co-exist in an urban environment.  This can be done through: plants and natural growth along outside walls and on the roof area, public viewing areas for public education purposes, and consideration of rooftop uses for the public.