With upwards of 10,000 tons of commercial waste being generated, collected, and processed each day, waste companies will continue to compete, and CWZ will continue to attract capital and investment as awardees seek to solidify their New York City trade waste business.
David Biderman
On April 23, the New York City Council鈥檚 Sanitation and Solid Waste Committee held one of its most important oversight hearings in years. The purpose of the hearing was for the City Council to provide legislative oversight over the Department of Sanitation鈥檚 (DSNY) Commercial Waste Zone (CWZ) program, as well as review several pieces of legislation.
At the hearing, Acting DSNY Commissioner Javier Lujan announced a revised for CWZ, under which several zones will transition into the program on a periodic basis starting in late 2025 and through December 2027. In October 2025, both of the two zones in the Bronx will commence transition, and beginning December 1, 2025, only the three CWZ awardees in each zone will be permitted to collect trade waste from commercial customers. This follows the initial implementation of CWZ in the Queens Central zone, which took place in late 2024.
Why the Delay?
was established as a result of the passage of Local Law 199 in Fall 2019. This bill was enacted against a backdrop of allegations that the private sector solid waste industry in New York City was unsafe, provided low wages to its employees, and did not recycle enough of the discarded material placed on the curb by 120,000 business. One of the principal motivators for the legislation was a City-funded that determined 聽the total number of vehicle miles traveled (VMT) by the private sector collection vehicles in New York City could be reduced by more than 50 percent. The reduction in VMTs, it was thought, would reduce traffic, air pollution, and greenhouse gas emissions, make collection more efficient, and reduce the number of collisions and injuries involving collection vehicles.
As a result of Local Law 199, New York City has been divided into 20 separate zones, but implementation of this new approach to solid waste collection was delayed by the COVID-19 pandemic and other factors. Following an RFP issued in 2021, three companies that will be permitted to collect all 鈥渢rade waste鈥� (regular trash, recyclables, and food/organic waste) from commercial customers in each of the 20 zones (DSNY collects residential and institutional waste). In addition to the zones, DSNY selected five companies that are authorized to collect containerized waste throughout the city.
Two companies鈥擨nterstate Waste Services and Waste Connections鈥攚ere initially awarded 14 and 12 zones respectively.聽 Waste Connections subsequently purchased another CWZ awardee (Royal Carting) in late 2024. Because this transaction put Waste Connections over Local Law 199鈥檚 limit of 15 zone awards per company, and both Waste Connections and Royal were awardees in the same zone, Waste Connections reportedly has given up at least one of its zone awards, and DSNY is expected to select an awardee to fill that slot later in 2025.
Several other companies, including Cogent Waste Solutions, Boro-Wide/Mr. T Carting, Filco Carting, and Recycle Track Systems, were awarded multiple zones. There were also nine companies that were each awarded a single zone. In all, 18 companies in response to DSNY鈥檚 RFP.
Impact of the Hearing
DSNY鈥檚 representatives , noting there have not been any complaints from customers. However, DSNY acknowledged there were several unexpected hiccups along the way, including that the majority of businesses in Queens Central did not select any of the three awardees during the four-month transition period, forcing DSNY 聽to assign each of them to one of the awardees. One of the three Queens Central awardees accepted the vast majority of the 鈥渁warded鈥� customers and has nearly two-thirds of the 8,000 customers in this zone. DSNY also testified 聽hundreds of violations have been issued in Queens Central to the awardees.
Committee Chair Shaun Abreu expressed frustration at the slow pace of CWZ implementation at the hearing, as did a representative from Brooklyn Borough President Antonio Reynoso鈥檚 office. Reynoso was the Chair of the Council鈥檚 Sanitation and Solid Waste Committee in the late 2010s when CWZ was considered and enacted, and is widely considered to be one of the driving forces behind the creation of this unique, non-exclusive franchising program. Several of the community groups that advocated for Local Law 199 also urged a faster implementation. Chair Abreu noted that the release of the full schedule is a helpful step as it provides useful information to stakeholders about the impending changes in the marketplace.
The companies that operate in New York City have not been necessarily waiting for DSNY to issue a CWZ implementation schedule. In 2019, there were approximately 60 licensed companies actively collecting trade waste from commercial customers in New York City. Not all of these companies submitted proposals in response to DSNY鈥檚 RFP, and several dozen CWZ applicants, including many multi-generational, small family-owned carters, did not receive any awards. Many of these companies have sold some or all of their business or are planning to do so in the near future. This industry consolidation will likely occur faster than the final implementation of CWZ, and there are rumors of numerous deals or route swaps percolating through the New York City solid waste industry. Awardees are eager to purchase companies with customers in zones that they were awarded, and many carters want to monetize their companies before CWZ is implemented.
A handful of collection companies that did not get CWZ awards continue to operate and are evaluating various options. Several companies have diversified geographically into New Jersey or Long Island. Some companies are likely to focus on construction and demolition (C&D) material, which is not subject to CWZ. A few companies may seek to acquire an awardee or replace an existing awardee if it is purchased, and the transaction puts the acquiring company over the 15-zone limit.
What鈥檚 Next?
DSNY stated at the hearing that it would provide at least six months鈥� notice to awardees before starting the transition in any zone. The April 23 schedule identifying the Bronx zones as 鈥淧hase 2鈥� beginning in October 2025 provided a little more than five months鈥� notice. Several hearing attendees believe that DSNY intends to start Phase 3 in January 2026 and then transition two zones in every quarter until late 2027, when three zones in Brooklyn and Manhattan would transition simultaneously. If that is correct, DSNY will need to provide notice to the Phase 3 awardees by July 2025.
Although 2025 is an election year in New York City and a new Mayor is expected to be elected, CWZ has sufficient momentum and political support that it is highly unlikely 聽a new Mayor will substantially modify the program. It is possible that a new Mayor and a new DSNY Commissioner may have different views concerning the pace of CWZ implementation or other waste-related issues that intersect with CWZ, such as the legislative proposal (Intro. 1228) to expand commercial organics waste diversion requirements (which was discussed at the April 23 hearing).
One thing is for sure: with upwards of 10,000 tons of commercial waste being generated, collected, and processed each day (more than 3 million tons per year), waste companies will continue to compete, and CWZ will continue to attract capital and investment as companies seek to obtain a piece of the lucrative New York City trade waste business.
David Biderman is the President of Biderman Consulting, LLC. David serves on the Department of Sanitation鈥檚 Commercial Waste Zone Safety Task Force and was the National Waste & Recycling Association鈥檚 (NWRA) registered lobbyist in New York City for more than 10 years. He served on the NYC Business Integrity Commission鈥檚 Trade Waste Advisory Board while he was SWANA鈥檚 Executive Director (2015-2023) and NWRA鈥檚 NYC program manager (2001-2015), and provides safety training to numerous companies in the New York City metropolitan area. David can be reached at [email protected].