Deconstruction and Construction & Demolition Waste Policy Creating Green Jobs in New York City
New York City generates 7 million tons of construction and demolition (C&D) waste annually- approximately 50% of the City’s waste! Currently, New York City does not require or incentivize recycling and reuse of C&D waste. To address this glaring environmental issue, Build It Green!NYC would like to propose policies recommendations based on successful C&D waste reuse and recycling policy at work in Chicago, Los Angeles, San Jose, and Portland, OR. (Attached are summaries of the various programs.)
Policies that foster recycling and reuse of Construction and Demolition waste (C&D) through deconstruction can spur much higher rates of waste diversion and job growth with minimal government spending. Deconstruction is the careful dismantling of buildings to maximize waste diversion through reuse and recycling. Deconstruction requires more labor than standard demolition but offsets the cost of additional labor with lower waste disposal costs. According to the EPA, recycling creates six times the number of jobs versus landfilling. Deconstruction and reuse have a even higher job creation ratio due to the labor required.
City government action is needed for deconstruction and building material reuse and recycling to become standard practice in NYC. Without action, millions of tons of materials will continue to be shipped hundreds of miles for burial in or on top of landfills. High “recycling“ rates currently claimed by waste transfer facilities are derived grinding waste used to cover landfills as Alternative Daily Cover. Alternative Daily Cover has the same environmental impact as landfilling materials and should not be counted towards recycling rates. The decomposition of materials in and top of landfills creates methane gas – a greenhouse gas over 25x more powerful than carbon dioxide and which accounts for 3% of the NYC climate change emissions.
Waste diversion policies and the resulting supply of separated recyclable and reusable materials will drive investment in local recycling infrastructure to process materials and create additional jobs. Recycling requirements in Massachusetts led to the construction of six state-of-the-art private recycling centers. NYC recycling policy helped establish Pratt Paper Mill on Staten Island: the mill has generated over 240 jobs and recycles 50% of NYC’s municipal paper waste. In 2011, BIG!NYC generated $1.2 million in revenue with 20 living wage jobs from the deconstruction and reuse of over 900 tons of material. With city support through policy and investment, Build It Green!NYC and other C&D waste recyclers and reuse centers could create more jobs while diverting millions of tons from the landfill.
We recommend the following policy initiatives to encourage deconstruction and greater recycling and reuse:
1) Require a Recycling and Reuse Plan for demolition and construction The NYC Green Codes Task Force Resource Conservation 1 (RC1) recommends that demolition and construction projects submit a Recycling and Reuse Plan to DOB detailing proposing recycling, reuse and disposal of waste for the project. We strongly support this recommendation. We also recommend the DOB maintain a construction and demolition waste ‘best practices’ manual and annually-updated list of recycling and reuse options on their website. Chicago, San Francisco, and Portland have similar requirements.
2) Create a deposit-based demolition permit Construction and demolitions sites should be encouraged to recycle and reuse through a deposit-based permit fee. In this system, all demolition and large construction permits would require a deposit based on square footage or job value. The contractor redeems a portion of the deposit based on the percentage of material reused or recycled. Material taken to a reuse center or single stream recycler would count as 100% recycled. Material taken to a mixed transfer station would receive the audited recycling rate of the transfer station. The City would keep deposits that were unclaimed due to low diversion rates or if materials were taken to an uncertified facility. San Jose has successfully implemented this incentive system.
3) Certify waste transfer stations receiving construction and demolition waste from NYC In order make a deposit system possible; the Department of Sanitation would certify, for a fee, waste transfer stations receiving construction and demolition waste from NYC including those in New Jersey. As part of the certification, DSNY would audit and assign recycling rates for each facility. Contractors would use the facility recycling rate to redeem the demolition deposit. For example, if a certified waste transfer station achieves a 65% recycling rate, all demolition loads taken to the facility would receive a 65% recycling rate. Currently, most waste transfer stations track their throughput for reporting to the state Department of Environmental Protection but the results are not publicized or audited. The DSNY certified recycler fee would pay for the auditing of transfer stations. This proposal gives DSNY the option to collect a per ton fee on unseparated construction and demolition waste to encourage onsite separation. Enforcement is integral to this policy as waste haulers and transfer stations in the NYC area do not have an unblemished history. Portland, Los Angeles, San Francisco and San Jose have similar certifications.
4) Require source separation and recycling for carpeting, ceiling tiles, lumber, new drywall, fluorescent light bulbs and appliances with refrigerants NYC Green Codes Task Force Resource Conservation 1 recommends that carpeting, large-dimension lumber, ceiling tiles, and new scrap drywall be sorted for reuse and recycling onsite. Fluorescent light bulbs and appliances containing refrigerants should also be required to be separated on site for careful recycling or disposal in order to reduce the release of toxic and damaging compounds. Once these materials are combined with other waste in single dumpster, they are nearly impossible to be recycled or reused. Source separation can actually lower waste disposal costs for lumber, ceiling tiles, and carpet. Massachusetts currently bans the landfilling and combustion of many reusable, recyclable, and compostable materials.
5) Prioritize reuse over recycling - mandatory salvage period for demolitions We recommend providing a mandatory salvage period at the beginning of every demolition permit in which only materials salvaged for reuse or donation can be removed. Reuse should be prioritized over recycling. Per ton, reuse leads to a greater reduction in landfilling and carbon emissions, creates more jobs, and maintains more of the materials’ value and embodied energy than recycling. We also recommend directing the NYC Economic Development Corporation, Brooklyn Navy Yard and other city controlled economic development zones to provide support and space for reuse centers.
6) Require city projects to obtain 75% recycling and reuse rates New York City government projects should lead the way for construction and demolition recycling and reuse. All City and City funded projects should achieve a 75% recycling or reuse rate. Buildings seeking LEED certification must submit a Waste Management Plan and be encouraged to achieve a 50-75% recycling rate.
Additionally, all city road projects should be required to use recycled content for roadbed and asphalt. This will create a market for asphalt shingles, concrete rubble and other C&D waste.
7) Clearly define recycling – do not allow ADC or incineration to count as recycling Do not allow the use of Alternative Daily Cover or incineration/combustion to count towards recycling rates. Grinding dry waste for use as landfill cover does not provide any environmental benefit and promotes the abuse of recycling regulations. Incineration contributes substantially to climate change and local air pollution.
Prepared by Justin Green, Program Director, Build It Green!NYC
Addendum: Policy links
Urban Green Council - Green Codes Taskforce Resource Conservation www.urbangreencouncil.org/greencodes/full-proposal/
NYC DDC Construction & Demolition Waste Manual - www.nyc.gov/html/ddc/downloads/pdf/waste.pdf
California - Summary of various policies by city and model ordinance.
CalRecycle Construction and Demolition Waste Home - http://www.calrecycle.ca.gov/
Chicago - Chicago requires contractors track the amount of C&D debris generated on project sites. Contractors must then recycle at least 50% of the recyclable debris. Contractors must submit a Recycling Compliance Form to the Department of Environment at the end of each project, along with an affidavit from the waste hauler or recycler documenting the recycling.
Portland, OR - Portland certifies and licenses waste handlers receiving waste from the city. All construction and demolition materials generated are required to go through these handlers. Portland collects a licensing fee from waste handlers and per ton fee from waste haulers disposing of materials. Wood, metal, yard debris, corrugated cardboard and rubble (concrete, asphalt, brick, dirt, etc.) must be recycled or reused.
Los Angeles - All C&D projects with a value in excess of $100,000, all demolitions of a structure or structures, and all projects which consist only of grading must submit a recycling and reuse plan (RRP) demonstrating how they will divert at least 50% of all soil, rock, and gravel, and at least 50% of all C&D debris, excluding inert material. Inert material cannot comprise more than 2/3 of the project’s C&D debris for the purpose of meeting the 50% requirement unless it is determined the project will not generate enough other C&D debris to meet the requirement. No permits for covered projects are issued until the project has an approved RRP. Project applicants submit an initial progress report within 90 days of issuance of the permit. Annual progress reports must be submitted thereafter until the completion of the project. Within 45 days of project completion, the permit applicant must submit a final compliance report and proper documentation documenting the amount of debris generated and diverted. Failure of the permit applicant to submit the interim or final report or proper documentation may result in administrative penalties and the county may withhold approval of any or all future RRPs submitted by the responsible person for any projects until the administrative penalty has been paid.
San Jose - The City of San Jose's Construction & Demolition Diversion Deposit Program (CDDD) is an incentive program to encourage the recovery of debris from construction and demolition projects. San Jose’s C&D ordinance applies to all most new construction, demolitions and renovations. Applicants for covered projects must submit a security deposit based on project size. Material from projects can be taken to a certified C&D recycling facility or contractors and residents can document how the material was otherwise diverted. Within 180 days of project completion, the applicant must submit documentation showing the material was taken to a certified C&D recycling facility or diverted some other way to meet the 50 percent diversion goal. The documentation must be submitted with a request for reimbursement in order to get the security deposit returned
San Francisco - In 2006, San Francisco adopted Ordinance No. 27-06 mandating the recycling of C&D debris. This ordinance affects all construction projects such as new construction, remodels and partial demolitions, and requires that all C&D materials removed from the project be properly recycled. C&D materials source-separated at the construction site for reuse or recycling must be taken to a facility that reuses or recycles those materials. All mixed C&D debris must be transported off-site by a registered transporter and taken to a registered facility that can process mixed C&D debris and divert a minimum of 65% of the material from landfill. Full demolition of an existing structure requires that a Demolition Debris Recovery Plan (DDRP) be submitted to and approved by the Department of the Environment before the Department of Building Inspection will issue a Full Demolition Permit. The DDRP must demonstrate how a minimum of 65% of the material from the demolition will be diverted from landfill.
Massachusetts - Massachusetts completely banned the landfilling or combustion of asphalt pavement; brick and concrete; cathode ray tubes, clean gypsum wallboard (effective July 1, 2011); ferrous and non-ferrous metals; glass and metal containers; leaves and yard wastes; recyclable paper; cardboard and paperboard; treated wood, untreated wood and wood waste; and white goods (large appliances).
Recycling Construction and Demolition Wastes - http://www.mass.gov/eea/agencies/massdep/recycle/reduce/managing-construction-demolition-wastes.html
Madison, Wisconsin - Madison requires the recycling of debris from construction, roofing, and remodeling projects. New construction projects that use concrete and steel support must recycle 70% or their construction debris by weight. New construction projects that use wood framing and remodeling project with a value in excess of $20,000 must recycle the following materials: clean wood, clean drywall, shingles, corrugated cardboard, and metal. Persons seeking a demolition permit must file a reuse and recycling plan with the Recycling Coordinator. The City of Madison has certified firms that can recycle mixed loads of debris as well as firms that recycle specific materials. The easiest way to meet the recycling requirements is to take debris to these City Certified Recycling Firms.