StreetsPAC's Testimony to DSNY on Draft Scope of Work for a Draft Environmental Impact Statement for the Commercial Waste Zone Program

Earlier today, we presented the following testimony at the New York City Department of Sanitation's public forum on the draft scope of work for the draft environmental impact statement on the city's proposed Commercial Waste Zone plan:

StreetsPAC strongly supports New York City’s proposed Commercial Waste Zone plan. As advocates for safer streets, we’re deeply concerned by the frequency with which commercial waste haulers injure and kill pedestrians and cyclists – private carters have killed nearly three-dozen people since 2010. The current system leads commercial drivers to make dangerous choices behind the wheel; running red lights, reversing through intersections, driving in the wrong direction and speeding are endemic, and epidemic. The current free for all also leads to dangerous fatigue, with many drivers and crewmembers working long overnight shifts of up to 18 hours.

While we support the proposed plan, however, we think it can go further. We urge the city to study an exclusive single-hauler zone option in the Environmental Impact Study. While the proposed non-exclusive plan is estimated to reduce nightly vehicle miles traveled from 79,000 to 29,000, an exclusive-zone option might be able to reduce that number even more, which could further improve pedestrian and worker safety, and would likely yield additional benefits in reduced emissions, improved routing efficiency and shorter distances between collection points. Given the potential reduction in crashes that an exclusive-zone system could deliver, it should be included in the EIS.

In addition, we believe any new zoned plan should also require private haulers to make safety upgrades to all commercial-fleet vehicles. The requirement for installation of life-saving side guards should be accelerated, and it should be mandatory for all vehicles to be equipped with state-of-the-art safety technology, including road-safety analytic systems such as those offered by ZenDrive, 360-degree cameras, and GPS tracking. Drivers should undergo extensive Vision Zero safety training, and rear-riding steps should be removed to increase crew safety.

The long-term stability created by an exclusive-zone system will best enable private haulers to amortize these 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. Again, we support the proposed semi-exclusive system, but strongly urge consideration of an exclusive, single-hauler option as the best possible alternative.

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StreetsPAC
StreetsPAC supports candidates for public office who will champion Safe, Complete and Livable Streets.