Public comments for: Source Separation and Handling Requirements for Commercial Organic Waste

Comments

Comment:
The New York City Department of Environmental Protection (DEP) submits these comments in response to DSNY’s proposed Commercial Organics Waste Rule, which was published in the City Record on August 27, 2015. DEP appreciates the opportunity to provide comments on these draft rules. We look forward to working with DSNY on the successful implementation of this important program.
Agency: DSNY
Comment:
The DSNY has not publicly discussed the technology that will help businesses and individuals responsibly compost organic waste, without causing unintentional impacts on the environment. Majority of the waste companies that accept organic waste in the city use a system called windrow composting. Even if they are implementing forced aeration, windrow has issues with leachate and sometimes odor problems. It is clear that the best way to control the fermentation process is in an enclosed space, which is called in-vessel. My company FOOD to PLANT is one of the leading compost technology providers in Manhattan, but no other NYC compost company has technology like we have developed. This is concerning to me and the industry we are trying to develop. For example: FTP has selected 16 different strains of micro-organisms, which are patent pending, that help speed up composting rates. We also developed an advanced filtration device using nano-zeolite, UV lights, and a metal ion catalytic converter that removes 99.99% of VOC's. Also, no one is utilizing pressure swing absorption technology to concentrate oxygen from the air to boost fermentation speeds. We do all of this, and it should be a standard for all in-vessel composting. My concern is that hotels and other businesses will end up causing more harm than good, by utilizing simple "compost" technology. FTP has designed a compost system utilizing all of this technology into a small in-vessel system that can fit into a kitchen. Why put the burden on larger companies when everyone can be composting at home safely with zero odor? I agree 100% with this law, but I want to ensure that NYC is using the most advanced technology available, that minimizes the environmental impact in a cost effective way.
Agency: DSNY
Comment:
The New York State Department of Environmental Conservation has the following comments: Under the definition of “Organic waste” it includes food that is sold to farmers and meat by-products that are sold to a rendering company. It has been department staffs' experience that farmers typically do not pay for food scraps and the rendering companies sometimes pay restaurants but it is not always the case. The definitions do not address the use of waste vegetable oils as an ingredient in biodiesel. On-site systems: under 1-11(b)(1)(iii), the proposed rules allow on-site systems if any residuals generated by the unit are taken to an organic waste processing facility. The Department is concerned about on-site systems that simply grind and/or liquefy the organic waste and discharge the waste to the sanitary sewer system. Although 1-11(b)(iii) requires any on-site system to be operated in accordance with sewer discharge rules, it is not clear that the discharge of liquefied waste would be banned if it was only a limited amount compared to the overall flow in the sewer system. If this material was allowed to be discharged to the sewer system, it could be argued that it eventually could be partially converted to energy through anaerobic digestion at one of the wastewater treatment plants. However, NYCDEP does not currently beneficially use the biosolids so the organics from the food scraps would not be recycled. This would be contrary to the intent of the food scrap recycling law. 1-11(b)(3)(iii) – the wording is hard to follow. 1-11(c) and (d) – the terms “disposal”, “discarded” and “disposing” do not seem appropriate for food scraps that will be recycled.
Agency: DSNY