New York City's Commercial Waste System Overhaul: Five Key Takeaways

New York City recently announced contracts for commercial waste collection managed by 65 companies, a significant development in the city's waste management system. However, the real challenge lies in completing the system's construction by 2026.

The shift from an open market where licensed haulers could operate citywide to a zoned system where specific haulers operate only in designated areas is extremely complex. Many questions remain about how the system will be implemented and how the expected environmental and safety benefits will be achieved.

The New York City Department of Sanitation (DSNY) has declined interview requests and provided no further details. The City Council's Sanitation Committee is expected to discuss the issue at future budget and oversight hearings, but specific dates have not yet been set.

Against this backdrop, here are five key areas to watch as the process gets underway.

Initial reactions

Unlike other waste-related announcements, DSNY and Mayor Eric Adams have not held press conferences on this matter in recent years. Aside from a supportive statement from the New York League of Conservation Voters after the contracts were announced, environmental and business groups have largely remained silent.

Labor and environmental groups in the Transform Don't Waste NY coalition, which actively pushed for the 2019 legislation, have also largely stayed quiet since the contracts were announced. Teamsters Local 813, a coalition member, had seen this as an opportunity to expand its influence; Laborers Local 108, not a member, had expressed its own concerns about New York's system. Neither union responded to requests for comment.

Brooklyn Borough President Antonio Reynoso, the primary sponsor of the 2019 law, issued a statement welcoming the program's progress but did not directly comment on the specific winning bidders.

Some observers attribute this to DSNY not yet publishing the full list of subcontractors, as well as the ripple effects from a February 6 Crain's New York report about unresolved violations at one winning bidder.

New York City regulates waste collection mechanisms more strictly than many other markets, and violation tickets from the Business Integrity Commission (BIC) are not uncommon, but some observers find the large number of alleged violations at Cogent Waste Solutions particularly notable. The report also noted that other companies, including the two largest winning bidders in the system, had received violation notices in the past.

Cogent spokesperson David Vermillion said via email: "We are reviewing the materials to assess each allegation. Cogent takes this matter seriously. Our service to New Yorkers is critical, and we are actively communicating with BIC to discuss the details of their allegations. We are confident we will resolve this matter promptly."

New Sanitation Committee Chair, Council Member Shaun Abreu, said on X that he would discuss the matter at oversight hearings. He wrote on the day of the report: "Who we allow to manage our waste is a critical safety and consumer protection issue, and the public should know how these decisions are made." Abreu's office did not respond to requests for further comment or hearing dates.

Joshua Goodman, DSNY Deputy Commissioner for Public Affairs, said proposals from all vendors with valid BIC licenses were eligible for review.

He said via email: "Every selected hauler holds a BIC license, and if a hauler's BIC license is revoked, they immediately lose eligibility to operate in the commercial waste zone program. Additionally, DSNY has the authority to require any hauler to have an independent monitor whenever it deems necessary."

Fleet plans

Calculations based on updates to winning bidders' plans again confirm that the program will reduce commercial waste truck mileage by 50%. In Midtown Manhattan, where multiple companies' trucks currently travel each night, the reduction is expected to be even greater, reaching 70%.

These calculations are expected not to account for the possibility of haulers using DSNY marine or rail transfer stations, a long-discussed idea. Former Sanitation Committee Chair, Council Member Sandy Nurse, recently reintroduced legislation calling on the agency to make this possible.

Advocates have also previously been optimistic about the potential to move away from diesel vehicles. In a model contract, DSNY included provisions requiring fleets to have at least 50% "zero-emission vehicles" by 2030 and 100% by 2040. When these vehicles will hit the road remains to be seen. DSNY itself has ordered at least seven electric vehicles.

Interstate Waste Services Executive Chairman Brian D'Amico said its subsidiary, Action Environmental, has placed "significant new orders" for various equipment but has not yet received an electric truck it ordered long ago.

Cogent Vice President Nino Tristani said via email that the company is "actively working on implementing zero-emission vehicles," and that "timelines may vary due to factors such as availability, infrastructure readiness, and technological developments." Mr. T Carting said it cannot fully move forward until charging infrastructure is further developed and trucks can maintain standard shifts.

Waste Connections Northeast Region Government Affairs Manager Andy Moss wrote that the company "will pilot zero-emission vehicles and evaluate their performance before zone implementation." The company has piloted hybrid electric trucks in at least one market in the past.

Safety standards

Safety concerns were another focus in the debates leading to the system. A high-profile ProPublica investigation into the death of a worker at Sanitation Salvage highlighted the issue, which also led to the closure of that major company. Concerns about general worker safety protections and public safety were also an issue.

Although the local industry has implemented updated safety requirements in recent years, the implementation of zone contracts raises this to a new level. The system has multiple requirements for vehicle standards, safety technology, and worker training.

David Biderman, President of Biderman Consulting, citing a recent DSNY email to haulers, said: "Many winning bidders will be required to provide training beyond their previous levels, including requiring each driver and helper to receive at least 40 hours of safety training."

According to DSNY's model contract, this training must be completed within 180 days after the winning bidder finalizes its agreement with the city. At least 16 of the 40 hours must be classroom training. Other training requirements also apply to new employees. Biderman said he is working with "multiple winning bidders" on this.

Action's Vice President of New York City Operations, Josh Haraf, said the company has been strengthening its efforts in this area and is well prepared.

"We are ahead of the curve on every requirement the city has put forward, whether it's cross mirrors, backup cameras, or side guards... These are now standard for us." Action's trucks are equipped with five cameras, as well as an in-cab AI system that corrects behaviors like speeding, phone use, or not wearing seat belts.

Haraf said Action now has five dedicated safety professionals in New York City and has strengthened new employee training, which has brought a "significant change" in company culture, reducing its recordable injury rate by 50% in 2023.

Recycling and organics plans

When Los Angeles announced its commercial waste zone contract system in 2016, the city said haulers' plans would bring $200 million in recycling and organics infrastructure investment. As of last year, the city said progress on diversion rates continued, but the invested amount was $175 million.

New York has not yet released similar investment statistics for its own system.

Several of the largest winning bidders in New York's system told Waste Dive they are moving forward with plans to upgrade or expand recycling infrastructure. DSNY said it had no further information to share but noted that the system's pricing structure is a factor.

Goodman wrote: "Haulers must charge customers less for recycling and compost collection than for waste collection. This financial mechanism incentivizing businesses to properly divert landfill waste should both drive diversion rates up and create a market for more recycling infrastructure in the commercial waste sector."

Others say it is too early to tell.

Biderman said: "I would like to see investment in recycling infrastructure and increased recycling rates for New York City businesses, but it's too early to tell whether commercial waste zone awards will achieve this."

The advocacy group New York Lawyers for the Public Interest (a member of Transform Don't Waste NY) told the Queens Eagle it hopes to see more transparency in haulers' waste reduction and diversion plans.

At least one element of the program—allowing micro-haulers to participate in organics collection—may not initially scale as envisioned. BIC created a special license for this category of companies, but the first company to obtain it, Common Ground Compost, decided not to participate in the zone system. Only one other company, Peat, also obtained a micro-hauler license.

Common Ground Chief Operating Officer Candice Cotler said: "The information is just not sufficient." She cited program logistics issues and the difficulty of predicting the ability to serve across zones when its tricycles can only carry about 600 pounds of material per trip.

Common Ground also has a consulting business and will participate in the system as a subcontractor, providing education and curbside waste audit services. Cotler said they have already received inquiries from businesses.

She said: "I think CWZ provides a very unique opportunity," because many customers may have to switch haulers. Cotler encourages large properties to start implementing zero-waste programs and hire sustainability managers if they haven't already.

Implementation mechanisms

To date, DSNY has only announced an implementation timeline for one zone—central Queens, where customer transition will begin in September and be completed by January. The specific timelines for the remaining 19 zones are unknown, only that they will be completed "by 2026." This puts most of the work under scrutiny in 2025, when Adams and other city officials face re-election.

As the timeline becomes clearer, observers expect businesses may begin consolidating or swapping operations, adjusting strategies, or even selling companies.

Waste Connections CEO Ron Mittelstaedt said on a Wednesday earnings call that the system will replace a market with "decades of competitive uncertainty," creating "growth opportunities in both organic growth and acquisitions, whether within or adjacent to market areas."

Any acquisition would still require BIC approval as usual, and DSNY approval if it affects competition within a zone, but companies have other options to optimize their positioning. Current BIC regulations allow companies to request reassignment of customer contracts or subcontract work with at least 30 days' notice, which is already common in the current market.

Filco Carting CEO Domenic Monopoli said: "For us, the smart move is to see who won central Queens and then swap with them for our work in other zones. That makes sense for haulers, for the city, and for customers." He added that the company plans to "aggressively focus on our three Manhattan zones" before implementation begins to build route density.

D'Amico said Action will seek similar opportunities and position itself before more information is available.

He said: "We are planning as if we must be ready to grow organically and take on more customers at a moment's notice."

Meanwhile, elected officials are also focused on ensuring the rollout goes smoothly.

Reynoso's statement mentioned the possibility of "minor issues along the way" given the system's scale, and said DSNY should be prepared to adapt "so we can achieve the best version of this program." Nurse said she will watch how the city communicates this "massive overhaul" to the tens of thousands of affected businesses, especially at a time when certain budgets are affected.

Nurse said: "Given the cuts to DSNY's outreach and communications budget, this will require an all-hands-on-deck effort to spread the message. I hope that during implementation, it truly reflects the originally envisioned goal of a safer, healthier, and more efficient commercial waste collection system across the five boroughs."