Public comments for: Proposed Rules Relating to the Registration of Recycling Processing Facilities

Comments

Comment:
Testimony submitted by ISRI (Institute of Scrap Recycling Industries) New York Chapter is attached.
Supporting Document:
Agency: DSNY
Comment:
see attachment
Supporting Document:
Agency: DSNY
Comment:
On behalf of the New York Chapter of the Institute of Scrap Recycling Industries (ISRI, www.isri.org ) please accept our appreciation for your interest in our concerns re: the regulation proposed last week by the Dept. of Sanitation. I am sending this email and the attachment as a preliminary comment. By way of introduction, ISRI is a Wash. DC based trade association for the recycling and scrap processing industry. The ISRI New York Chapter has more than 75 member companies which process, broker and consume scrap material commodities. Please note that the scrap processing industry has a significant economic footprint In the City. The attached econometric report provides empirical statistical data. Moreover, the scrap processing industry not only provides needed recycling infrastructure, but also provides good-paying "blue-collar" employment opportunities. ISRI members and I fully expected that a forthcoming proposed regulation would be limited to a simple registration requirement whereby scrap processors (which have historically been required to be licensed with the Department of Consumer Affairs) would (1) also be required to register with DSNY and (2) be required to report to the DSNY aggregate tonnages of processed scrap material. The regulation proposed last week goes far beyond that anticipated scope. 1 - The proposed regulation would require detailed reports consisting not just of aggregate throughput data but would also the require the filing of trade-secret proprietary information concerning the customers and consuming manufacturers to which processed scrap material is sold. 2 - The proposed regulation would restrict a scrap processor from purchasing scrap material only from an individual or business licensed by the Business Integrity Commission. Note: the BIC does not license scrap material transporters. BIC has neither the interest nor the resources to administer a licensing process for every itinerant scrap "peddler", many of whom but for the opportunity to earn an honest living from scrap may otherwise not be employable due to immigration status and / or personal histories. In short, ISRI finds the proposed regulation to be over-broad, over-reaching and contrary to the best interests of the scrap processing industry and contrary to the public interest. ISRI looks forward to engaging with the Mayor's Office and the Department of Sanitation to craft a reasonable registration / reporting rule. Moreover, state legislation supported by ISRI New York and Empire Chapters (S. 4882 / A. 8051) which has recently passed the State Senate and is pending in the State Assembly, as well as comprehensive revisions to the NYS DEC Solid Waste Management regulations now undergoing public comment, will likely address the purported interests of the City without imposing a duplicative and unnecessary regulatory burden.
Supporting Document:
Agency: DSNY
Comment:
Why doesn't DOS stick to their job of cleaning the garbage and not monitoring and controlling scrap metal business. DOS, you are you wasting time, wasting tax money and going out of bound from this ridiculous rule? For example, you want to control how we, the scrap metal processor, have to be "effectively processed" recyclable materials. Are you kidding me? What if we can't "effectively processed" the recyclable material, are you gonna give us the capital to buy better tools so we can process it? This rule, was it created because of metal theft? If that's true, get Consumer Affair to crack down on scrap yard who doesn't have the license. Moreover, it's them who's doesn't follow the law.
Agency: DSNY