This morning, we presented the following testimony at the New York City Department of Sanitation's public hearing on the draft environmental impact statement for the city's proposed Commercial Waste Zone plan:

As advocates for safer streets, we strongly urge adoption of the Exclusive Zone Alternative for the city’s Commercial Waste Zone Program.

As the analysis conducted for the Draft Generic Environmental Impact Statement makes clear, the Exclusive Zone Alternative will significantly reduce vehicle miles traveled as compared to the proposed action, reducing overall private-hauler VMT by 60% versus 50% for a non-exclusive zone program – a difference of nearly three million vehicle miles traveled annually.

Given the fact that drivers of commercial-waste vehicles have killed more than two-dozen people on city streets over the past five years, this is a significant, and potentially life-saving, difference.

The reduction in VMT will be even more pronounced in the densest parts of the city. An exclusive-zone plan would reduce VMT in the Midtown Manhattan central business district by 52% versus the proposed non-exclusive program.

The additional reduction in vehicle miles traveled from the Exclusive Zone Alternative will provide other important benefits besides improved safety. Reduced VMT will mean better air quality and lower greenhouse gas emissions, and the more streamlined routing of trucks will lead to reduced noise levels, as well. Importantly, worker safety will also be optimized under an exclusive-zone system.

Finally, exclusive zones will require fewer trucks and less fuel, leading to significant cost savings for the commercial haulers awarded exclusive-zone contracts. Some of these savings can be passed along to customers, offsetting concerns about increased costs due to reduced competition – which the city can also manage through better regulation.

The long-term stability created by an exclusive-zone system will best enable private haulers to amortize investments in newer, cleaner, and safer trucks and technology, thanks to the stable customer base, predictable revenue stream, and long-term, enforceable contract with New York City that such a plan would create.

We urge adoption of an exclusive-zone plan for New York City’s commercial waste.

–––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––––

If you would like to submit your own comments to the Department of Sanitation regarding the Commercial Waste Zone Draft EIS, they're holding a second public hearing later this week.

You can also submit testimony via email until 5 p.m. on Monday, March 25, to [email protected].