Public comments for: Recycling Requirements for Entities that Receive Private Carter Collection

Comments

Comment:
Please see uploaded document for comments.
Agency: DSNY
Comment:
Please see the attached comment by SEIU 32BJ regarding the Proposed Rules.
Agency: DSNY
Comment:
See the attached.
Agency: DSNY
Comment:
STATEMENT OF THE BROADWAY LEAGUE The Broadway community has always done everything within our purview to reduce the environmental impact of our facilities. For example, many theatres have been retrofitted with thermal performance windows, reducing heat loss in the winter and cool air loss in the summer. Many have installed water filtration systems for backstage use to reduce plastic waste and the gasoline consumption of the delivery trucks. Our paper hand-towels are green seal approved and made from recycled paper. With assistance from Con-Edison, we have re-lamped our theatres with energy efficient light bulbs and the overall consumption of natural resources are constantly monitored to see how we can conserve even more energy, water and fuel. All theatres have reprocessing programs. After collection, most waste is separated at our carting company’s plant for recycling. For back stage areas, recycling bins for paper, and bottles and separate bins for other waste, aid in this process. For the public areas, used Playbills are collected and recycled. We have found that these measures not only help the environment, but often lead to significant cost savings. We continue to strive for new ways to conserve, reuse and recycle in all areas of our operations. We applaud this agency for its efforts to standardize the method that private industries undertake to fulfill with the City’s mandate on recycling, our venues may simply be incapable of compliance with some of the proposed rules. In many instances, theatre owners would be required to station a second set of large collection bins behind each venue. At present, there is scarcely sufficient room for one set. As Fire Code restrictions mandate routes for emergency egress, in many instances there is simply insufficient space to accommodate additional collection bins while simultaneously enabling compliance with safety regulations. Further, the proposed Recycling Rules will require venue staff to separate recyclables from other trash in-house, however our theatres do not have the personnel or capacity to do so. Please note that all Broadway Theaters have landmark status. Owners are therefore prohibited from making alterations that would be necessary to accommodate more bins. Accordingly, we respectfully request that the Rules, while effectively streamlining the recycling process and increasing efficiencies wherever possible, are amended to take into consideration the spatial and practical limitations of our facilities. On behalf of the Broadway theatre community, the League supports any effort by the City to improve the environment. We would therefore be delighted to collaborate with DSNY to create Rules that advance its goals while accounting for the real-world affects they will have on building owners.
Agency: DSNY
Comment:
Attached
Agency: DSNY