INTRODUCTION
The New York State Climate Action Council in its Nation-leading Climate plan and resulting law set the goals of a 40-percent reduction in statewide greenhouse gas emissions from 1990 levels by 2030 and an 85-percent reduction from 1990 levels by 2050. The Plan states, “GHG emissions from the waste sector represent about 12% of statewide emissions, including landfills (78%), waste combustion (7%), and wastewater treatment (15%). Most of these emissions represent the long-term decay of organic materials buried in a landfill, which will continue to emit methane at a significant rate for more than 30 years.”
Waste as part of the requirements to achieve these goals the CAC recommends comprehensive action to reduce the state’s generation of solid waste and the implementation of circular economy approach to materials management is understood and employed.citing its role in the generation of greenhouse gasses
We have structured these comments and amendments as a plan to achieve a sufficient number of specific objectives and complete deliverables by specific dates in order to approach zero waste by the early 2030s. This is necessary to achieve climate change reductions in a timely manner according to the CLCPA. We should not be relying on incremental changes that are not date-specific without deliverables that will achieve far less in the planning time horizon. To do fewer action items than we have recommended will not ensure the State reaching or approaching DEC’s Zero by 2030 goal.
We recognize that there are a lot of action items proposed here and we are committed to work to assist you in advocating for DEC to get sufficient funding and staffing to accomplish all the action items here.
We have drawn from a number of documents that we have written as well as included references to the work of others in structuring our recommendations. These documents include our collective, alternative zero waste plans written in 1991 Recycle First, 2004 Reaching For Zero and Roadmap 2022 - New Zero by 2030 Plan’ as well as legislative recommendations (e.g. 2022 MSWAB proposed zero waste bill for NYC, Revision and Update of the 1988 Solid Waste Management Act, and Proposals for legislation by MSWAB waste prevention committee) and numerous other fact sheets, position papers, and outside references.
Three additional sections were added at the end as they were not addressed in the draft SWMP: (1) Sustainable Disaster Debris Prevention and Recovery, (2) Environmental Justice, and (3) Update and revision of the NYS Solid Waste Management Act of 1988.
We suggest that the DEC tailor the draft plan to always follow the Zero Waste Hierarchy (www.zwia.org/zwh), which means the discussion of reduction should come before reuse/repair in this and the following sections that have it reversed.These comments, amendments and deletions were debated in over 20 meetings lasting 2 - 6 hours each, among many people from many organizations over more than two months. We look forward to your response.]