DSNY Proposed Rule Relating to Entities Engaging in Cleaning Services

Online comments: 70

• Dale Aucoin

  In a perfect world, this new law makes sense because it prevents bags of trash from sitting on street corners and next to garbage cans. Unfortunately this is going to make it much more difficult, if not impossible, for local neighborhood cleanup groups to keep the sidewalks, gutters, and storm drains of NYC clear of trash. Because the city doesn’t have the resources to keep our streets clean, this job falls on the shoulders of building owners/maintenance people, some of whom do decent jobs, but many do not. Community cleanup groups like the Litter Legion in Hell’s Kitchen are there to fill in the gaps. These small groups don’t have bins of their own and therefore need to leave bags of trash next to street bins. Essentially the city is going to kill these community groups by enacting this law, leading to more trash on the streets, and more rats on the streets.

  The city should be making laws that make it easier for people to keep the streets clean not harder. It’s much better to have trash in a bag next to a trash can, than blowing around the streets, and ending up in storm drains. That’s common sense IMHO.

  Comment added December 30, 2024 4:41pm

• Iris Lentjes

  I’ve been part of the volunteer driven organization Jackson Heights Beautification Group – TreeLC in Jackson Heights Queens for several years. We meet moat every Saturday mornings because we want to keep our neighborhood beautiful. While we want to mostly focus on tending to plants and trees, picking up trash from tree beds, the pavements, and the gutters in our neighborhood is a continously effort we unfortunately have to divulge much of our time on. I fully agree with the bin mandate and the war on rats. I do hope however a provisions can be made for our group within this proposed rule where we can leave black bags next to the street bins. We would put a sticker on our bag so the Sanitation department can recognize our bags. We can also report our garbage bags with 311, which we already do right now if we collect excessive amounts of trash. I hope you may reconsider and tweak this rule, because we unfortunately collect at least 3 full 60 gallon garbage bags each week filled with street trash, abandoned house hold garbage, lunches and food receptacles dumped out of cars from our gutters. This happens despite us having an ACE crew on 37th Avenue. Unfortunately, visitors and fellow neighbors do leave that much trash around. Please also note that we also collect trash from various rain gardens as part of the stewarding program DEP has in place. Should you need further data, please verify our entries on the NYC Tree Map. Our group is listed on that portal as the Jackson Heights Beautification Group. We log our cleaning and maintenance activities there most every week. So as stated, I hope you may make a provision for our group. Should you have any questions or concerns, please don’t hesitate to email me. Regards, Iris Lentjes

  Comment added December 31, 2024 8:19am

• Nicolas Marcotrigiano

  I am one of hundreds of New Yorkers who volunteers my time to clean streets and sidewalks in my community. Beyond just helping ease the constant burden of litter cleanup on local businesses and property owners, these groups provide a critical environmental and public health service that prevents litter from flowing into storm drains, causing flooding that threatens our neighbors health and well-being. What’s more, this activity is a vital source of connection and community building in a time when social isolation has caused untold harm across the city and country.

  It is unconscionable that DSNY would seek to criminalize this behavior, and I urge you in the strongest terms to change course.

  Comment added December 31, 2024 1:47pm

• Riley Wolf

  Hello,

  I am one of the many New Yorkers who participates in my neighborhood cleanup group, Community Cleanup PLG. Therefore, I am very concerned to hear this new proposal.

  While I understand the thought behind receptacles for the trash we collect, it is unrealistic for volunteer-run groups such as ours to be expected to do this, as we just do not have the access to the funds or adequate storage for these receptacles.

  Our group reports the locations of our trash bag drop-offs to 311 after each cleanup event, so DSNY can pick up and dispose of them. While it may take some time for the bags to be picked up, which leads to
  the concern of attracting rats and other pests, there would be a higher risk for pests throughout the community if this trash was left scattered everywhere.

  This may not have been the intention of the proposal, but to us, it seeks to penalize groups assisting the city in keeping itself clean, and therefore may snuff them out. These groups have purpose beyond just picking up litter; they keep storm drains free of clutter that therefore leads to less flooding, help to prevent the pollution of our water via chemicals from litter, and provide invaluable community. I would not have much of the community I have today if it were not for my neighborhood group.

  I urge you to reconsider and work with groups like ours to come up with a realistic solution. Thank you.

  Comment added January 1, 2025 2:11pm

• Teru Kuwayama

  The city should accommodate trash collection and drop off by individuals and civic groups. It’s understandable that we don’t want commercial or industrial actors to circumvent their responsibilities by using public trash receptacles, but extending a prohibition to “any entity” (which could include community groups or private citizens who take the initiative to clear trash from streets or parks etc) is counterproductive.

  Comment added January 2, 2025 9:47am

• Sarah Schuster

  Community groups that help keep our streets clean needs to place trash bags near public trash cans. Otherwise, we have no where else to dispose them. This is only hurting people who want to keep their communities clean by attempted to dispose trash that is otherwise on the floor.

  Alternatively: Add more/bigger public trashcans so we can properly dispose the trash in our neighborhood. The trash to trashcan ratio isn’t working if this is such a big problem. Thank you!

  Comment added January 2, 2025 7:12pm

• Kristin Eley

  I co-lead Community Cleanup PLG, and we love our weekly pickups. In addition to cleaning up the neighborhood’s never-ending trash, we have formed a meaningful neighborhood third place for folks. I don’t think the issue is folks picking up trash… I think the issue is not enough trash cans! Put one at every corner, and we’d be able to plop our bags into the bins. Thanks!

  Comment added January 3, 2025 3:59pm

• Tessaria

  Please talk more with community groups before signing something like this into law. You tell us what not to do, but you don’t provide a clear alternative. Community cleanup groups are part of the solution, work with us!

  Comment added January 3, 2025 5:59pm

• Shannon Donohue

  As one of the many local volunteers committed to keeping NYC neighborhoods clean, I understand the importance of reducing litter and its associated risks wherever possible. However, this proposal would likely exacerbate street litter by making it impossible for volunteer groups to operate. Many neighborhoods, including ours, rely on the community-led volunteer groups mentioned in these comments to address gaps in city resourcing and keep streets clean. The groups also foster a shared sense of pride and responsibility in the neighborhood. I urge the city to support community cleanliness by empowering residents to contribute to a more beautiful and sustainable city, rather than taking away their ability to contribute by enacting this proposal.

  Comment added January 4, 2025 5:41pm

• Amanda Melhuish

  This rule is sadly poorly considered, given the reliance of many neighborhoods on the work of local community clean-up groups to gather trash. Unless there is a plan to make their work unneeded with a huge investment in sanitation tidying litter themselves OR a plan to provide compliant receptacles to these groups, this will essentially criminalize and discourage community clean-up. No one likes leaving bags of trash on the street — perhaps table this rule until investing in citywide containerization plan that wisely repurposes public street space for this goal. Volunteer groups are doing their best to fill in the gaps created by policy failures and mismanagement of funding by city government. Work with them when developing these rules!

  Comment added January 7, 2025 6:23pm

• Amy Guo

  The language of the rule presented here would deprive many neighborhoods from the community cleanup they rely upon to keep their areas safe and clean. Criminalizing these groups would ultimately lead to more waste, bugs, and mice on the streets, not less; and eliminate a valuable point of social connection in a time of increasing isolation.

  Comment added January 18, 2025 6:31am

• Stephanie Joseph

  Trash is such a huge problem in our neighborhoods. Please don’t make it more difficult for citizens volunteering to clean our streets by implementing this new rule. It’s truly disheartening that so many people in our city don’t feel the responsibility to clean up after themselves. Our local cleanup groups are a ray of hope for cleaner community.

  Comment added January 18, 2025 8:59am

• Kathleen Nolan

  Why on earth are you discouraging neighborhoods from taking pride in keeping their neighborhoods clean and filling the gaps in the DSNY? This is a ridiculous idea. Community organizations in their various forms should not be threatened for helping government look successful. Instead of encouraging these groups to hire private garbage entities, DSNY should be encouraged that people are even picking up trash to begin with. Why can’t DSNY provide trash bins to organizations? Why can’t they just have more garbage bins in general? Why can’t they hire a community outreach person to coordinate extra trash pick ups with these groups? Carrot or stick. It’s ridiculous to go stick first for community organizations focused on IMPROVING the spaces around them.

  Comment added January 18, 2025 10:02am

• Maura FitzGerald

  In communities where DSNY refuses to put sufficient numbers of garbage bins for public use, we rely on public community cleanups to keep the neighborhood looking good. There needs to be an exception made for street litter cleanup, which is done in bags, and placed next to bins for pickup.

  Comment added January 18, 2025 10:26am

• Leticia Aliaga

  Hello DSNY!! This new proposed rule is an impediment and deterrent to citizens like myself that take it up to clean up our communities.
  We are a vital resource for the DSNY and for our neighborhoods (especially those marginalized and not properly funded). Daily clean ups by community groups lead the efforts in keeping Bushwick clean. Your proposal will make the clean up process more complicated.
  And let’s be honest…. You all ain’t gonna clean our neighborhood so please consider the implications of this rule.
  Thank you for taking the time to read my suggestion.

  Comment added January 18, 2025 11:21am

• Larry Weissman

  The DSNY has removed public trash bins throughout my neighborhood in Kensington, Brooklyn (and elsewhere across the city), causing an intolerable increase in litter and refuse throughout the area. The result has forced community groups to organize neighborhood clean ups, collecting trash from sidewalks and gutters, leaving the bags adjacent to the few remaining public trash bins for pickup by DSNY. Either they can take away the street trash that taxpayers have collected or add more public bins throughout the district; to do anything else is shirking their mandate and responsibility to the citizens of New York City

  Comment added January 18, 2025 1:32pm

• Annika Leybold

  Dear DSNY,
  I’m a resident of Brooklyn deeply disturbed by the implications of this rule change. As someone who cares about my community and enjoys participating in neighbor-led community cleanups, I’m appalled that the city is now targeting, to the point of criminalization, the neighborly actions of helping to clean up our streets and parks. Given DSNY’s valid, but ultimately under-resourced efforts to keep our city beautiful, it is often up to everyday people to clean up our own communities. With increased flooding due to climate change, and the serious issues of sewers being clogged by trash in rain gutters, flexible and fast community efforts become all the more important. In a sane system, this would be encouraged and supported by city structures. Instead, we are witnessing a backlash against civic behavior. It’s impossible not to see a pattern here that began with DSNY’s increased cruelty and frequency in destroying unhoused people’s camps that began a couple years ago. The copification of the department of sanitation, arresting and destroying the lives of marginalized people, in the name of “clean streets” should be seen by all as a step toward fascism. We will not stand for it. Please stop this rule change.
  Sincerely,
  Annika Leybold

  Comment added January 18, 2025 2:52pm

• Johanna Mosenthal

  I am writing to express my opposition to the proposed new rule regarding trash bags on the curb. This rule will negatively impact neighborhood and community clean up groups who help the city bridge the gap between what DSNY is able to provide in terms of cleaning parks and sidewalks and public spaces, and what community members want and can do themselves. I have volunteered many times cleaning up parts of my community, most often through the community group Clean Up Crown Heights, and received many thank yous from neighbors. Not being allowed to place the filled and tied bags of litter next to the trash cans on the curb makes it much more difficult for groups to organize clean ups and dispose of the litter. How is it better to have litter all over the street than to have it tied up in one bag on the corner? The law should be rewritten to clarify that it’s about not dumping household trash.

  Comment added January 18, 2025 3:13pm

• Jaelynn

  There are not enough trash cans and too many people who litter. Everyday Let us clean up our own communities.

  Comment added January 18, 2025 5:14pm

• Elisa Fox

  Wording needs to be changed so that local community clean ups are still able to put bagged trash out. There is an inordinate amount of trash in NYC and local community clean ups serve a vital purpose of helping clean streets. The Rule must allow them room to continue their work.

  Comment added January 19, 2025 12:03am

• Casey Levine-Beard

  I am a member of a community with significant trash and rodent issues, and one key way our neighbors organize and make a difference is in community cleanups. These are suggested and supported by local community nonprofits.
  We can make a difference in our parks and surrounding areas but need to dispose of the trash as we are moving it out of public spaces and off to sanitation. Having it bagged next to trash cans is much better than loose in the streets and sidewalks, parks and gutters.

  Comment added January 19, 2025 10:27am

• Liz slome

  Strongly oppose, as this is the only way certain areas ever get cleaned.

  Comment added January 21, 2025 9:56am

• Chrissy Rose

  I strongly opposed this rule. It will penalize community groups who engage in litter cleanup and need a place to leave the trash they collect so it can be properly disposed of. DSNY alone does not adequately clean up our communities – volunteers and community groups like litter legion do our community a huge service by taking on some of this work. Do not hamstring their ability to help by imposing this rule!

  Comment added January 21, 2025 5:28pm

• Charles Todd

  I’m worried that these new rules will be a problem for community clean ups. I have been volunteering with Litter Legion in Hell’s Kitchen with my family for almost 5 years.

  Comment added January 25, 2025 11:41am

• Grace Koehl

  I am a resident of the Upper West Side and Master of Public Health student at Columbia. I recently began cleaning the block of 80th St where I live because I hope to contribute to my community. I never noticed how much litter was accumulating on my block, but it became very apparent once I started my weekly cleanups how dirty the area was. I am very happy to have the opportunity to help keep my neighborhood clean, safe, and healthy by removing wrappers, cigarette butts, and other debris.

  The new policy proposed to ban placing bagged trash near public receptacles would make it impossible for me to continue my volunteering. I often have more trash than can fit in the top of a public trash can and need to place the sealed bags nearby on the ground. The language of the rule targeting cleanups with “the purpose of supporting local businesses or communities” is especially perplexing, as I’m not entirely sure why the city would want to hinder those working hard to beautify their local communities.

  Please reconsider banning space near trash cans for individual and group volunteers supporting the community. We depend on this to continue our vital work.

  Comment added January 27, 2025 1:45pm

• Megan Taylor

  I volunteer with the Jackson Heights Beautification Group and Sanitation Foundation regularly to keep my neighborhood safe, clean, and enjoyable.

  Although there is a wonderful ACE crew picking up litter on 37th and Roosevelt avenues, I am still picking up trash from sidewalks, tree beds, storm drains, rain gardens, etc. on a weekly basis. If the existing corner trash cans are full, we have typically been allowed to leave bags of trash alongside them.

  We already report huge amounts of trash to 311, but I would hope that some provision might be made by DSNY for the work we do in our neighborhood, because this proposed rule would prevent volunteers, BID employees and ACE workers from continuing to maintain these areas.

  I understand that bags are not impervious to rats and other critters, but if the city is not able to keep our neighborhoods clean, then it should at least not stand in the way of its citizens volunteering to do so.

  Comment added January 28, 2025 8:30pm

• Tom Harris

  My name is Tom Harris, President of the Times Square Alliance. On behalf of our board and stakeholders, I want to start by affirming our respect for DSNY’s hard work, strong values, and leadership. The men and women of the department do a thankless job and I want to publicly acknowledge them for their dedication to this city. I do want to comment specifically about these proposed rules, which attempt to operationalize a well-intentioned but heavy-handed policy that has been poorly communicated and executed. Business improvement districts are the city’s partners in keeping our neighborhoods and our city clean, and these rules fail to reflect that.

  I note that the Alliance voluntarily embraced containerization, piloting retail containerization on 8th Avenue. Building on this idea, we reimagined containerization for the city’s public garbage in Times Square that we volunteer to pick up. We chose to do this because given the volume of our garbage and our ability to remove it, containerization makes Times Square cleaner. That said, we CANNOT support a policy that issues a mandate that all business improvement districts who pick up the city’s public garbage must comply or risk monetary penalties.

  BIDs are uniquely effective because each district assesses its needs and dedicates resources accordingly. BIDs supplement the city’s responsibility to collect trash – we do not replace the city’s core responsibility. Any garbage we are collecting is public garbage that is statutorily the responsibility of the Department of Sanitation to collect. Any bags that are on the street are there because the Department of Sanitation’s services do not meet the city’s demands.

  These rules do two things that are highly problematic: first, they create an unfunded mandate for all BIDs to containerize; second, they impose monetary fines for failing to comply with a container program that reaches beyond our responsibility to provide supplemental services.

  These rules imply, intended or unintended, that you do not view us as equal partners who you work with to develop a shared vision for keeping our city clean. These rules also fail to acknowledge that each business improvement district is unique with different priorities and different resources.

  True partners who value a relationship work with each other – they do not dictate how those relationships work. True partners do not impose rules that financially penalize partners for helping them do their job. True partners compromise and work together to resolve conflicts – they do not exert power through punitive rules and mandates.

  What these rules fail to do is provide any financial support for this additional mandate.

  As one of the largest BIDs in the city, Times Square pioneered and was able to quickly adopt containerization because we had the need, desire, resources and capacity to do so. The vast majority of the 76 BIDs in the City do not have that same ability, often operating with minimal staff and with budgets under $1 million. They are already stretched in their efforts to keep the city clean, safe, and desirable.

  These rules will result in smaller bids abandoning sanitation services and require the Department of Sanitation to do more.

  As for fines: the Alliance sweeps streets, empties garbage cans, containerizes that garbage and transports 100% of that public garbage to sanitation garages. Our goal is to have zero bags on the street, and 99% of the time we achieve that goal. That other one percent is often because there was either more garbage than normal, or because someone dumped garbage near our containers. It is ridiculous to even consider fining us for experiencing an unusually heavy garbage day, or for another entity dumping at our locations.

  We value our partnership with the Department of Sanitation. A clear acknowledgement of the DSNY valuing that partnership would be to rescind these mandates and work with each BID to come up with a shared vision for making each neighborhood cleaner and bag free.

  Thank you.

  Comment added January 29, 2025 8:59am

• Jayden

  If this ruling passes, BIDs would be required to ensure that no waste bags are placed on the street, despite the fact that a significant portion of the waste collected results from illegal dumping—public garbage that is the responsibility of the City. Given the lack of enforcement, what measures has the DSNY implemented to address illegal dumping across NYC?

  Furthermore, BIDs operate under formal agreements with the Mayor’s Office and the City of New York, which clearly define their role as providers of supplemental sanitation services. These agreements do not transfer the City’s core sanitation responsibilities onto BIDs. As a property owner paying taxes for DSNY services, why should I also be required to fund a BID assessment to cover DSNY’s failure to fulfill its obligations?

  Legal Concerns:
  Authority & Jurisdiction:
  DSNY lacks the unilateral authority to dictate BID operations. BIDs are independent 501(c)(3) nonprofit organizations governed by contracts with the City. These contracts define their responsibilities and cannot be altered without mutual agreement. Any attempt by DSNY to impose additional obligations on BIDs without due process violates contractual rights and oversteps legal boundaries.

  Municipal Overreach & Due Process:
  Any policy requiring BIDs to assume DSNY’s sanitation responsibilities constitutes an unauthorized expansion of BID duties without legal justification. If BIDs fail to comply, they face summonses—an arbitrary and punitive measure that disregards the principles of fairness, transparency, and contractual governance.

  Failure to Address Root Issues:
  Instead of addressing illegal dumping and improving enforcement, DSNY is shifting responsibility onto BIDs and property owners—who already contribute through taxes and assessments. This approach imposes an unfair financial and operational burden without addressing the systemic failures that led to this issue in the first place.

  If DSNY seeks to modify BID operations, it must do so through proper legal channels, ensuring compliance with contract law and principles of due process. Any unilateral action to impose new responsibilities on BIDs without consent is legally questionable and sets a dangerous precedent for municipal overreach.

  Comment added January 31, 2025 11:44am

• Joanna Tallantire

  Thank you. I have attached testimony for this meeting.

  Comment attachment
  Testimony-for-DSNY-BID-Mandate-February-2025.pdf

  Comment added February 3, 2025 12:39pm

• Rachael Cain

  My name is Rachael Cain and I work with the community cleanup group the Pick Up Pigeons. We meet weekly to clean neighborhoods all over NYC because we love our city!!!

  I was disturbed to hear about this proposed DSNY rule, criminalizing leaving bags of trash collected by community volunteer groups near existing public trash cans. 

  As you know, the rule uses the NY Admin. Code’s definition of “entity,” which includes volunteer and community groups. There has long been a symbiotic relationship between volunteer trash pickup groups and the DSNY whereby the volunteers perform sidewalk trash pickup that DSNY is unable to perform. This proposed rule criminalizes volunteers for removing loose trash from the city streets. 

  The existing rule criminalizing leaving household and commercial waste in public bins could instead be very easily amended to say “in or in the vicinity of” to prohibit household and commercial uses from leaving abandoned bags near the existing public bins. Alternately, the rule could have a clear exception stating that the term “entity” as used in that section excludes “volunteer community groups.”

  Further, I would support an easier and more usable system to report trash collected by community groups. The existing city cleanup application, with two-week lead time and set trash pickup locations, is unusable by many community trash pickup groups who will not know the amount of trash that will be picked up or have a location for the pickup two weeks in advance – or may not need an entire, fully staffed DSNY truck to visit a location for a small number of bags. A simpler system allowing us to directly contact local DSNY in real time – either a 311-type system or a directory of local DSNY sanitation emails that we could contact – would be hugely helpful in preventing bags being abandoned by volunteer cleanup groups.

  Finally, if this push is about containerization, well, this trash was blowing around the street letting rats frolic in it prior to us picking it up. We love our city and want to make it better – please don’t make it harder for us to do so. 

  Comment added February 3, 2025 7:17pm

• Ankita Suri

  Volunteers in New York City have a significant role in the cleanup of our city, filling the gaps that the city itself is not maintaining or enforcing private businesses to do. I understand why this was proposed – of course, ideally, there wouldn’t be any overflowing garbage. But this doesn’t recognize the reality that requires multiple solutions to address NYC’s trash problems.

  Volunteers and regular citizens are collecting trash and placing them in garbage bags besides the bin. They don’t have access to private spaces to put this trash. There is no funding for this. This will limit the ability of the volunteers to do this work and will ultimately lead to more litter on our streets. Add MORE garbage bins and encourage more cleaning up – not less. People want places to put trash and are not given that opportunity by the city when those trash bins are overflowing and blocks apart from each other. On top of that now you’re hoping to eliminate the convenience of those trying to help the situation. Please reconsider.

  Comment added February 4, 2025 11:59am

• Rhiannon Blouin

  The reality of this code does not take into account the lack of public trash cans in large areas of New York City. If anything, volunteers making sure to coordinate trash disposal located next to public trash cans in tied bags and containers is helping the DSNY keep our streets clean. This law would make more sense if it penalized disposing of trash in front of property without orchestrated trash pick up. Rigid bins make sense for commercial and residential waste- however- most of the groups disposing of trash from the streets and sidewalks do not contain food items that would attract rats. The majority of groups do their due diligence to schedule pickup of trash bags after community clean ups. It’s not realistic to propose volunteer run groups purchase rigid bins when the infrastructure for collection is already in place.

  Comment added February 4, 2025 12:26pm

• Lucy T.

  Please reconsider this rule proposal. It seems like the purpose of this rule is to generate revenue for the DSNY at the expense of the community and its members. Community engagement groups that help remove trash in the neighborhood can reduce municipal costs from property damage caused by street flooding due to clogged stormwater drains, potential fires in neglected areas and public health issues (rats and other pests). These groups help provide support to the DSNY as well as other city agencies that will have to provide emergency response when a street floods (DEP), trash fires break out (FDNY) or an epidemic occurs (DOHMH) because of windswept trash blown away from overfilled public trash cans that is generated by the dense communities that outpaces the DSNY collection. Other potential benefits of community engagement groups providing cleanup are the value increase of the neighborhood and business sales tax gains which will improve the city budget granting city agencies like the DSNY with better equipment and hiring opportunities.

  Comment added February 4, 2025 3:12pm

• Jesaca Lin

  Dear DSNY,

  The overwhelming number of public comments regarding the proposed rule underscores the need for a more nuanced approach to waste management. While I understand the desire to address legitimate concerns about illegal dumping, this broad rule will severely hinder invaluable local community cleanup efforts. As a member of Pickup Pigeon, I can attest to the significant positive impact these volunteer initiatives have on our city.

  Our Impact:

  For the past two years, rain or shine, our group has conducted weekly cleanups, dedicating several hours to each session. Our average attendance last year was 10 volunteers, and we collected an average of 113 pounds of rubbish per session. This amounts to nearly 5,650 pounds of garbage annually – litter that would otherwise pollute our waterways, clog storm drains, and contribute to local flooding. Perhaps equally important to the environmental impact is the psychological impact on residents of seeing their neighborhoods filled with trash! We expand our impact by cleaning various neighborhoods across the city. Imagine the consequences if groups like ours were no longer able to operate. 5,650 pounds of trash—just from our small group—would remain on the streets of NYC.

  Our Challenges:

  The proposed requirement for rigid receptacles presents a significant logistical and financial burden for volunteer groups like ours. Like most New Yorkers, we rely on public transport to reach cleanup sites, making easily transportable bags essential. The cost and storage of a sufficient number of rigid containers would be prohibitive.

  Community Support:

  Our efforts are recognized and deeply appreciated by local residents and businesses, who frequently express their gratitude and often provide us with supplies. This demonstrates the high value our community places on our work.

  A Possible Solution:

  We believe there are ways to achieve DSNY’s goals without crippling community initiatives. We propose exploring a system of easily printable identification tags for bags collected by registered community cleanup groups. This would allow DSNY to distinguish between properly collected community waste and illegally dumped trash. We would welcome the opportunity to discuss this and other potential solutions with DSNY representatives.

  This proposed rule, as it stands, effectively discourages community involvement in keeping our city clean and sends the message that trash left on our streets is an acceptable outcome. We urge you to reconsider this rule and work collaboratively with community groups to find a solution that supports both effective waste management and the invaluable contributions of volunteer cleanup efforts.

  Sincerely,

  Jesaca Lin

  Comment added February 4, 2025 3:22pm

• John Lindaman

  Criminalizing groups that undertake community cleanups makes no sense. The things they clean up and bag for collection do not create a health hazard because they were all things already laying on the ground prior to bagging, so there is no logical need to require them to also be placed in the newly required receptacles. Don’t penalize community groups keeping our city clean unless the city is willing to do this work (which the presence of the trash indicates it is not in the first place)–these groups work with DSNY, not against it! There is a clear difference between this kind of trash and commercial trash, which should absolutely be required to follow sanitation guidelines.

  Comment added February 4, 2025 4:46pm

• Tim Reed

  I volunteer with a community group that picks up and bags litter, focusing on a different neighborhood once or twice each week. This is an important effort to help clean up neighborhoods that are otherwise overlooked or underserved.
  I am against this rule change as written as it would criminalize community cleanup volunteer efforts. The rule should be rewritten to allow the use of city garbage bins by volunteer community groups.

  Comment added February 4, 2025 5:30pm

• Stan Cherian

  I am opposed to this as it criminalizes community cleanups.

  Comment added February 4, 2025 9:06pm

• Vincent Chau

  So this rule is to make things harder for people who help keep the neighborhood clean because the people who’s job (DSNY) to make the neighborhood clean isn’t doing a good enough job?

  Shouldn’t DSNY make it easier and for people and organizations who make their jobs and purpose (clean neighborhoods) easier?

  They literally pack everything and put it in one spot. I think this proposal would make NYC a dirtier place.

  Comment added February 5, 2025 10:33am

• Luke Raithel

  I have taken part in multiple community clean up events for a variety of organzations to help tidy up the neighborhoods of Bushwick, Ridgewood, and Glendale. These are always very positive events and have an undeniably good impact on the area. Street trash is an unfortunate reality in this city but making it harder/penalizing grassroots organizations that are looking to help clean and beautify areas of the city out of the goodness of their hearts is a mistake.

  Comment added February 5, 2025 12:38pm

• Yelena Makhnin

  attached

  Comment attachment
  Sanitation-testimony.docx

  Comment added February 5, 2025 3:21pm

• Albert Oeswadi

  The Department of Sanitation of New York’s efforts to prohibit the placement of refuse, while aimed at maintaining cleanliness and order, inadvertently criminalizes community cleanup initiatives. These initiatives are effective in keeping areas clean and making people feel proud of their neighborhoods. As part of a neighborhood cleanup crew, we always report our trash via 311 for a pick-up.

  Comment added February 5, 2025 4:13pm

• Lydia A DiLalla

  I’m against this rule change as it is an attack on community organizations that are tending to their neighborhood. The “Entities” are New Yorkers trying to better the streets. They are volunteers. Do-gooders. They just want to make the world a little better, God knows we need it. This would make things more difficult for such “Entities.” DSNY should be finding ways to work with these organizations rather than punish them.

  Comment added February 5, 2025 4:56pm

• Kimberly Steger

  My investment in trash clean-up started with my child’s Fort Greene public school. In collecting trash around her school yard, sidewalks, and the curb, I have the ease of dropping clutter that blows in from the neighboring park, commuters refuse, and pedestrian waste into the school dumpster. However, if I was engaged in extending the effort in other parts of Fort Greene, Clinton Hill, The Navy Yard, and Vinegar Hill, this rule change would significantly thwart the efforts to reduce the public health and public safety threats (mental health, rat mitigation, flood mitigation, crime reduction, etc.) from uncollected trash.

  Because the wording of the rule seems to be addressing organized entities, not individuals, there may be a gray area of where informal alliances initiate said community improvement efforts and reference public waste bins.

  Additionally, if there is a rule elsewhere that uplifts each of the organizations listed as “entities” to be mandated to have collection bins issued or approved by the Department that serve as rigid receptacles with tight-fitting lids.

  Comment added February 6, 2025 11:58am

• Elizabeth Lovejoy

  Testimony attached for this meeting.

  Comment attachment
  DSNY-Hearing-Testimony.pdf

  Comment added February 6, 2025 12:47pm

• James Ellis

  See attachment

  Comment attachment
  North-Flat-BID-DSNY-Rules-Hearing_02102025_final.pdf

  Comment added February 7, 2025 2:14pm

• Maria Fernandez

  I am a Astoria, Queens native and thankfully still live in my hometown. As many who have submitted comments on here – I have also spent a good portion of my life in helping clean the streets of New York City.

  In a city where millions of folks reside and work, the Department of Sanitation cannot do it alone. A good amount of people cannot stand seeing their neighborhood and streets filled with litter and waste.

  A lot of times volunteer groups clean remote areas that are overlooked and are simply not within reach of any trash bins.

  Unless millions of people change their habits for the greater good, volunteer street cleaning groups and individuals will exist to fill in the gap and clean up after others.

  Please do not punish, and criminalize those that are actually trying to do good for society.

  Thank you

  Comment added February 8, 2025 11:25am

• Mark Caserta

  I am Mark Caserta, Vice President of Small Business Support at the Brooklyn Chamber of Commerce. I am providing comments on the Department of Sanitation’s proposed containerization rules for organizations that provide supplemental cleaning services.
  The Brooklyn Chamber of Commerce supports the Department of Sanitation’s goal of eliminating garbage bags on street corners and, as a result, reducing the number of rats on our city streets. However, we agree with the New York City BID Association’s comments on the
  proposed rules, especially:
  Lack of funding: Small and medium business improvement districts (the vast majority of Brooklyn’s BIDs) were created through a city process through which a special assessment is collected by the City of New York and provided to the BIDs for services such as supplemental cleaning. In order to provide the best services possible at the lowest costs to landlords and
  merchants, BID budgets are tightly constructed and managed, without much wiggle room for additional expenses. The extra cost of installing secure, closed bins on public street corners on behalf of the City of New York or carting waste to Sanitation facilities without providing additional
  public funds is nothing more than an unfunded mandate. While BIDs do have the ability to raise assessments in order to account for additional costs, this process can be long and arduous and is not guaranteed. It requires sign-off from the City Council and the Mayor and could take more than a year, if successful.
  Timing: Even if the proposed rules pass, as is, most small to medium BIDs would be unable to come up with the funds to comply with the rules by the deadline of August 1 st . As noted, an assessment increase can take one year or more and is a legal process that is mandated by the City of New York. The only choice that our Brooklyn BIDs would have is to reduce or eliminate their services, which is not something that the City of New York should have as its ultimate goal.
  Again, BIDs were created through a City process and are encouraged. Why is another City agency creating a policy that could damage them? This make no sense.
  We respectfully urge the Department of Sanitation to work with our BIDs to find funding and to be flexible in timing in order to preserve critical BID services and keep our streets safe and clean
  Thank you.

  Comment attachment
  BKChambeofCommerce-DSNY-TESTIMONY-021025.docx

  Comment added February 8, 2025 6:58pm

• Coalition of Volunteer Community Groups

  As volunteer community groups engaged in cleaning our streets, sidewalks, curbs and gutters and public plazas, we are against this proposed rule which would put an undue burden on our groups who give their time to care for their communities. We have prepared a detailed letter with suggestions for moving forward.

  Comment attachment
  Volunteer-Groups-Letter-to-DSNY-Re_-Proposed-Rule-Relating-to-Entites-Engages-in-Cleaning-Services.pdf

  Comment added February 9, 2025 6:40pm

• Catie Savage, Litter Legion founder

  I have the utmost respect for the uniformed men and women of the Department of Sanitation who work hard to keep our city clean both of trash and snow. However, making such ill-advised changes to the Administrative Code without thoughtful engagement with the very organizations it would impact is a serious oversight. While the Department handles many functions to remove trash and recycling from our streets and sidewalks, regular manual cleaning of all our public spaces is not one of them.

  The very organizations impacted by this rule change are the ones who have worked with the Department to collect all the loose bits of trash so that all the sanitation workers need to do is collect the bagged material. To force such organizations to use rigid tightly lidded containers (more secure than public litter baskets) places an undue burden on these groups that are providing a valuable and appreciated public benefit for their communities. I request that the Department reconsider this rule and work with all of the stakeholders to find workable solutions.
  Sincerely,
  Catie Savage
  Founder, Litter Legion

  Comment added February 9, 2025 6:51pm

• Sunita Vatuk

  I work with Jackson Heights Beautification Group in Queens on Saturdays to care for street trees and take litter out of the tree beds. We work all over the neighborhood downshift on which blocks need the most care, and often decide that morning where to focus s our efforts. We can’t plan 2 weeks in advance, and never know in advance how much we will collect. Sometimes we need to prune tree branches (with permission from Parks). We are an all volunteer organization. All of which is to say that the new rules would put an undue burden on us and hamper our efforts. Please exempt volunteer groups from this proposed regulation.

  Comment added February 9, 2025 10:38pm

• Bonnie Astor

  I agree with most of the previous writers and fellow JHBG volunteers. What is it going to take to have our well thought out and logical viewpoints heard? Volunteerism in the US is at an all time low due to post COVID concerns .other health scares, aging population areas and people struggling with family finances. Seems like NYC should be grateful and nourishing our efforts.

  Comment added February 9, 2025 11:52pm

• Bill Bruno

  Dear Acting Commissioner Lojan:

  I volunteer with the Jackson Heights Beautification group to help care for street trees and public gardens. I am deeply concerned about the language of a recently proposed rule and potential impacts of amending Section 16-120(e)(2) of the New York City Administrative Code. The rule is written in a way that specifically targets organizations like the one for which I volunteer.

  I totally understand the value and importance of containerization when applied to residential and commercial waste. However, applying such rules to organizations who perform manual cleaning such the cleaning of tree beds can create problematic consequences.

  To require that volunteer groups purchase, store and maintain rigid receptacles with tight-fighting lids in order to have their bags of litter collected, under threat of fines, is unworkable and would severely compromise our mission to clean and care for street trees and public gardens in our neighborhood. There is no way for our group to know in advance how much litter we will collect and where, exactly, the litter will be concentrated, so how could we possibly plan to have enough bins and the means to secure them from theft when put out for collection? The litter we collect can come from anywhere in 16-block stretch of one or two avenues, it is not practical to simply lug a bin around and no reason not to use the litter baskets already out there.

  Furthermore, the current process for volunteer community groups to liaise with DSNY requires a two week advance notice that includes indicating the area to be cleaned and where filled bags will be left for collection. It is often impossible to know what area will be the most dirty, and therefore benefit the most from our work, this far in advance or where the most convenient bag locations will be.

  Despite assurances from leaders within the Department that this rule would not be applied to organizations like ours, the language very clearly includes us since the rule, as written, would bar us from depositing the litter we collect in public baskets or leaving bags or branches (we often prune street trees). We would argue that, since we are not a store with a fixed location and a limited area of responsibility for litter collection, but a group which operates over a broader area, that using the public litter baskets is not an abuse of their purpose.

  I suggest the following that the language be updated to specifically exclude “volunteer community groups” and that a revised system be created to allow volunteer groups to interface with DSNY in real time to alert of cleanup activities resulting in bags or branches (as we often prune street trees) being left at public litter baskets for collection rather than the current system of filling out documents at least two weeks in advance with information we may not have available at that time.

  We want to continue to work with the Department to keep our community clean and help reinforce the message that caring for our shared public spaces is the responsibility of all New Yorkers. We hope you will recognize our requests and continue to partner with us in this effort.

  Comment added February 10, 2025 12:48am

• Nina Leonard ( Flatbush Development Corporation)

  Dear Members of the NYC City Council,

  Flatbush Development Corporation urges reconsideration of the proposed rule, as it will significantly hinder cleaning efforts in our commercial corridors. By restricting where refuse from community cleanups can be placed, this rule creates additional burdens on local businesses, making it more difficult and costly for them to maintain clean storefronts. Without a designated place to dispose of collected waste, litter will accumulate, attracting rodents and worsening sanitation conditions. Merchant associations and community organizations, which play a vital role in keeping our neighborhoods clean, do not have storefronts or private collection sites to store trash from cleanup efforts. This rule will discourage much-needed volunteer and merchant-led cleanups, leaving more waste on our streets. We urge the Council to consider alternative solutions that support, rather than hinder, our collective efforts to maintain a clean and thriving business district.

  Sincerely,
  Flatbush Development Corporation

  Comment added February 10, 2025 7:50am

• Adrian Kondratowicz

  I have been working on organizing community clean ups since 2008. In the last 5 years my project has organized over 200 clean ups in NYC, ranging from local street and park clean ups to whole remediation efforts of abandoned public spaces. I am not a non-profit nor do I get paid for my services rendered to the city. I promote urban beautification and environmental awareness to my local community using art as a catalyst for change in the form of the TRASH project. We place our trash in pink polka dotted bags as a sign that volunteers did this work. Anyone who has seen us work, especially the folks who live in the areas we clean up, always graciously thank us and appreciate seeing the pink bags on their streets.
  We understand the rule proposed and are left scratching our heads. Why would the city include our groups and discourage a wave of civic engagement that is growing, saving the city money and doing an essential service for all? This new rule will deter anyone who is interested in volunteering and getting involved in any civic sanitation activity. For communities that are always last on the list of trash collection, this means more trash, more rats, and less health and safety. Since 2020 there has been a boom in civic engagement and this rule will kill the momentum all the clean up groups have been building to keep their communities clean.
  Lastly, over the years I have seen too many poor or ill-considered solutions that seem to overcharge or misuse the funds from the city rather than maximize the natural order of things. We are strongly in opposition to this rule and have proposed a list of solutions to make this rule work for the city and volunteer groups. We hope the city sees our value and will not include community clean up groups in a rule that is limiting and prohibitive to all communities/volunteers who want to lead a clean good life.

  TRASH project

  Comment added February 10, 2025 9:57am

• Meredith Faltin

  Why would you make this a rule? Why would you make it harder for community organizations and volunteers to do good?? I don’t understand you people…

  Comment added February 10, 2025 11:35am

• Erin Piscopink

  Please see attached

  Comment attachment
  Testimony_DSNY-Rulemaking_Containerization_SoHo-Broadway-Initiative.pdf

  Comment added February 10, 2025 11:49am

• Dr. Camelia Tepelus

  My name is Camelia Tepelus, I am the Executive Director of the Morris Park BID in the Bronx, a BID with a $390,000 in assessment revenue, 1 full time staff member, paying 2 full time supplementary sanitation staff from our vendor Streetplus $153,000/year, to clean up sidewalks along 21 blocks of commercial corridor on Morris Park Ave in the Bronx.

  We cleaned Morris Park Avenue for the past 6 years, 7 hrs/day, 7 days/week, 365 days/year. The proposed rule simply states that what we can NOT do, which is place neatly collected bags of public “within the vicinity of any public litter basket”, but does not tell us what to do instead, other than requiring that “such materials be placed out for collection by the Department in rigid receptacles with tight-fitting lids.”

  The rule does not indicate HOW to comply with it. It does not tell us WHERE would it be acceptable to DSNY for us place the excess PUBLIC trash we sweep. Former Commissioner Tish seemed to think that small BIDs with budgets of under $.5 Mill mostly in outer boroughs can do the exact same thing that large BIDs do with $25 Mill budgets, which is transport their own trash. Newsflash, being poor is not the same as being wealthy. And it is us, smaller BIDs that are a majority of all BIDs serving commercial corridors. And no, we can not afford to hire trucks to transport the additional trash to DSNY’s garages – which is the DSNY’s taxpayer-funded mandate to do.

  This rule – in its current formulation – asks us to either stop cleaning sidewalks of our commercial corridors, or dispose of excessive trash, somehow by magic.

  Nothing happens by magic. Cleaning the City takes careful planning, coordination, analysis, and finally execution that costs money. It is critical to remember that even though we/BIDs are privately funded by commercial property owners, at the end of the day, and just like DSNY we provide a public service: a service ensuring that commercial corridors create a positive pedestrian shopping experience, and bring taxpayers money to the budget. We are now paralized knowing that we will not afford to transport the trash ourselves – which is 1) the mandate of DSNY; and 2) would be both unaffordable and causing us to cut other critical programs – beautification, community events, holiday lights, etc.

  At the moment we are basically stuffing our existing DSNY cans as much as possible, and hope this will be sufficient due to the low foot traffic associated to the cold weather. But came summer, we will need a procedure and a process of disposing of excess trash agreed with both DSNY and DOT.

  Instead of this over-simplifying, trash-disappearance-by-magic rule, there are smarter and more collaborative ways for DSNY and BIDs to address this issue, including actual data collection and the ability to customize implementation – either through increased frequency of trash cans emptying, or through new mechanisms such as the “Empire Bin”, which, if installed on sidewalks, would need DOT approval for the site placement (see photos).

  We – BIDs servicing long commercial corridor are somehow expected by the former Commissioner Tish to do the same as individual businesses. But we collect much more public trash. If anything, we should be compared with larger apartment buildings, or schools, for which DSNY is already exploring better mechanisms to collect the garbage – such as the Empire Bins or the large containers that can be lifted by the sanitation trucks with side-forks.

  Finally, there was a poor, non-collaborative process leading up to this regulation, which shows a significant and troublesome discrepancy between the DSNY executives and policy makers that were testifying in front of you at the November, and the DSNY operational staff on the ground that is in contact with us, such as Chief Frank Lettera, or in our case Bronx East 11 District Superintendent Vincent Allard, clearly much better informed, practical and conscious of the realities on the ground. We appreciate them and we thank them.

  We are here to support cleanliness in the City, and to work alongside DSNY in smart, data-driven ways to make this a reality in NYC’s commercial corridors. We are optimistic that together we devise a strategy that is optimally applicable to each commercial corridor’s needs.

  We are here to work together and to partner with DSNY in keeping our city clean in creating a thriving environment for small businesses and neighborhoods.

  Please allow at least 1 more year until August 2026, to improve this rule and to give us sufficient time to articulate along with DSNY mechanisms for implementation to its desired aim – clean commercial corridors in NYC.

  Thank you for your consideration to our testimony on this matter.

  Dr. Camelia Tepelus
  Executive Director
  Morris Park Business Improvement District

  Comment attachment
  Testimony-MPBID-DSNY-Feb-10-2025-.pdf

  Comment added February 10, 2025 12:17pm

• Ulrike Nischan

  I am a planning member of the Clean Bushwick Initiative, a community group that organizes regular street cleanups, a Super Steward with NYC Parks, and a Rain Garden steward with the NYC Department of Environmental Protection, though opinions here are my own. In my volunteer capacity in all these roles, I have filled the gap for the DSNY by removing litter and illegally dumped debris off the streets. I strongly oppose the proposed rule change outlined in Section 16-120(e)(2). I, along with numerous other volunteers, work tirelessly to keep our NYC neighborhoods clean by collecting litter and placing it in bags near public trash bins for pickup. This proposed rule creates unnecessary obstacles that will make it significantly more difficult for us to continue our efforts.
  First and foremost, requiring individual volunteers and community groups to use rigid receptacles with tight-fitting lids presents a logistical challenge. Unlike businesses or residents who have designated trash collection systems, individual volunteers and community cleanup groups operate on a volunteer basis, often working on an ad-hoc schedule. Carrying large, rigid containers to various cleanup sites is impractical, especially for volunteers who clean in areas far from their homes and rely on public transportation. Trash bags have been the most efficient way to collect and dispose of litter without burdening volunteers with cumbersome equipment.
  Additionally, prohibiting the placement of bagged litter near public trash bins forces the clean-up community to choose between discontinuing clean-ups or risking fines. Public trash bins are natural collection points that ensure litter is properly disposed of instead of being left scattered on sidewalks or streets. If our volunteers are not allowed to leave collected litter in a reasonable location for city pickup, the only option will be to transport it ourselves—a task that is simply not feasible given our limited resources. Without a viable alternative, this rule risks discouraging volunteer cleanups altogether, leading to dirtier streets, more rats, and other environmental hazards.
  Furthermore, imposing penalties on community groups for simply trying to help maintain public spaces punishes volunteers for helping our communities. Volunteer-driven initiatives should be encouraged, not penalized, especially at a time when sanitation services are already strained. Rather than enforcing rigid and impractical disposal requirements, the Department of Sanitation should work collaboratively with community organizations to find solutions that support, rather than hinder, grassroots cleanup efforts.
  I urge the Department to delay issuing new rules on this issue for at least a year to allow time to develop policies that facilitate community engagement in keeping our neighborhoods clean. Possible alternatives include designated drop-off points for community cleanup efforts or allowing exceptions for DSNY issued bags to be used for voluntary litter collection.
  Volunteers give their time and effort freely to improve the city. Do not make it harder for us to do so.

  Comment attachment
  Testimony-proposed-rule-amending-Section-16-120e2-UN.docx

  Comment added February 10, 2025 12:50pm

• David Estrada

  2/10/2025
  Re:
  RULE TITLE: Amendment of Rules Relating to Placement of Refuse and Recycling for Collection
  REFERENCE NUMBER: 2024 RG 108
  RULEMAKING AGENCY: Department of Sanitation

  Public Testimony by David Estrada, Executive Director, Sunset Park Business Improvement District

  Good morning, my name is David Estrada, and I am the Executive Director of the Sunset Park Business Improvement District. I greatly appreciate the opportunity to submit testimony regarding the proposed new DSNY rule.
  In short, we believe this rule is unnecessary and unlikely to contribute effectively to our shared goals of rat mitigation and public trash containerization. Our organization urges DSNY to pause this rule—and any similar initiatives—until there has been comprehensive planning and support for a smooth transition to citywide containerization. As written, the proposed rule is vague, overbroad, and, in some places, oddly specific, which makes it incompatible with the real work that BIDs and community groups are doing to keep our neighborhoods clean.

  Additionally, this rule contradicts DSNY’s own claims that BIDs are “trusted partners.” Instead, it risks becoming a punitive measure that undermines our longstanding, collaborative relationship with the city. Furthermore, the issue of illegal dumping and improper use of corner baskets is already addressed by existing DSNY laws and regulations.

  The suggestion that this rule is merely a “clarification” is misleading, to say the least.

  Since 1995, our small, independent, locally-run nonprofit has proudly served Brooklyn’s Fifth Avenue, from 38th to 64th Streets. Our district covers 1.3 miles, a dense, mixed-use commercial corridor with 26 blocks, 52 block faces, 400 buildings, and over 600 businesses. We also maintain 96 designated DSNY corner waste basket locations.

  While our community is bustling, it is also an underserved, lower-income, immigrant neighborhood, home to small “mom-and-pop” businesses with residential units above. It’s crucial to understand the scale of our operations in a district that is both large and high-need. Our annual assessment totals $300,000, with one-third allocated to sanitation and related services, such as tree pit care, graffiti removal, and volunteer cleanups. However, the majority of our budget supports a supplemental sanitation worker who works seven days a week. This worker collects trash blown by the wind, overflowing from baskets, and discarded in tree pits. We collect about 25,000 bags of trash annually.

  Despite our modest size—we have only two employees—we play a central role in the community as a social service and economic development anchor. We are part of the solution, and we want to continue supporting DSNY. That’s why we’re here today.

  We value our local DSNY sanitation garage (BK07) and consider the Superintendent and Cleaning Supervisors to be partners in this effort. We acknowledge that containerization is the ideal solution, and we are committed to collaborating with urgency to achieve it. However, replacing entrenched practices with rules that penalize partners will not lead to success.

  Consider this: if our BID didn’t sweep, bag, and deposit trash at corner baskets, that waste would remain on the sidewalks, clogging gutters and overflowing from baskets. BIDs don’t create waste—we make DSNY’s job easier by managing the daily volume of public trash that DSNY alone cannot handle.

  About a year ago, DSNY ordered BIDs to take on the responsibility of containerizing public trash at our own expense. The demands were not only impractical, but they also lacked a clear plan, support, or funding. While there has been some progress in dialogue, we are still far from a true partnership on containerization.

  For 30 years, we’ve been eager to help, but we need a clear path forward. While we support containerization—especially for rat mitigation—we recognize that implementing it quickly within our district presents significant challenges.

  If DSNY is concerned about bags accumulating at corner baskets, why not simply increase the frequency of service? Too often, we find baskets already overflowing, which means much of the trash we consolidate into bags comes from baskets that have been neglected too long. If DSNY is struggling to keep up with street trash, how can we expect them to suddenly manage corner baskets and bins more effectively?

  Our board of directors will be forced to reevaluate our sanitation servcies in light of this new rule. Should DSNY begin issuing tickets in response to our efforts to maintain cleanliness, we will be forced to suspend our corner basket service.

  It’s also worth noting that about a third of our 96 corner waste baskets are missing at any given time. This has been a long-standing issue. While we respect our local DSNY garage and workers, the agency has not done enough to maintain the fixtures that already exist on our streets, yet now they want us to add more.

  We also urge you to consider that residential overcrowding, street vendors, construction crews, and storefronts that avoid commercial waste hauling contracts contribute to significant improper dumping—primarily in bags, and typically at corners whether or not a basket is present. This waste is outside our BIDs control and clearly not within DSNY’s ability to stop.

  If DSNY is serious about containerization, they must fund and establish a program that BIDs can reasonably participate in. This funding must cover the startup costs, ongoing maintenance, labor, permits, and insurance. DSNY must actively partner with our community stakeholders, not just offload siting, permitting, and public relations to BIDs.

  Let’s work together to create a concrete plan with clear logistical support, reliable funding, and service-level agreements that involve both BIDs and DSNY. Let’s plan for the future with realistic goals and a step-by-step approach, knowing that we all want a cleaner, safer neighborhood.

  The bottom line is this: Business Improvement Districts want to help. We are ready to collaborate and take action, but we need DSNY to bring the necessary resources and cooperation to make sustainable success a reality.

  To that end, we recommend:
  • Deferring any new rule until proper planning and funding are in place.
  • Addressing this issue after the Commercial Waste Zones are fully established.
  • Clarifying DSNY enforcement practices for mixed-use small retail and residential zones, as current enforcement times and the distinction between household and commercial trash are problematic.
  • Acknowledging that containerization cannot be imposed overnight and that in some areas a reasonable multi-year timeline is essential.
  • Developing reasonable standards for the number and placement of bins, and streamlining the DSNY/DOT permitting process.
  • Providing provisions for DSNY to support BIDs in maintaining and periodically replacing bins.
  • Issuing an RFP for group purchasing of bins at discounted rates for BIDs.
  • Clarifying the need for insurance on street fixtures and whether bins are considered capital or programming expenses.
  • Collaborating with large sanitation service providers like ACE, StreetsPlus, and Block by Block, whose field knowledge is invaluable.
  • Requiring DSNY to provide written terms of engagement for BIDs serving commercial zones where multiple entities are involved in waste management.
  • Setting a realistic, achievable goal for transitioning to containerization that aligns with BID funding, budget cycles, and governance processes.
  Thank you for your consideration.

  Sincerely,

  David Estrada
  Executive Director

  Comment attachment
  DSNYruleTestimony.pdf

  Comment added February 10, 2025 1:48pm

• Angel Hart

  Thank you, see testimony attached for the Long Island City BID.

  Comment attachment
  02.10.2025-DSNY-Containerization-Rules-Hearing-1.pdf

  Comment added February 10, 2025 2:28pm

• Ryan Pukos

  Please see attached for the full written testimony of the Grand Central Partnership regarding the DSNY Proposed Rule Relating to Entities Engaging in Cleaning Services.

  Comment attachment
  Trash-containerization-testimony_DSNY_02-10-2025.pdf

  Comment added February 10, 2025 3:50pm

• Zach Owens, West Village BID

  This proposed rule unfairly codifies a flawed sanitation policy, making a burdensome and ineffective system permanent without fully considering its real-world consequences. By targeting BIDs and civic organizations, groups that voluntarily supplement city services, it penalizes those actively working to keep neighborhoods clean while failing to address the real issue of illegal dumping. Locking this rule into law would create lasting financial and operational hardships for nonprofits, forcing them to divert critical resources from other community initiatives. Additionally, the optics of punishing civic groups for stepping up where city services fall short undermines public trust and discourages future cooperation. Instead of imposing rigid mandates, DSNY should collaborate with stakeholders on practical and adaptable solutions that improve sanitation without harming the very organizations striving to enhance New York’s public spaces. Attached is my testimony

  Comment attachment
  Testimony-Owens-West-Village-BID.pdf

  Comment added February 10, 2025 4:06pm

• Nathaniel Reynolds

  Testimonial Letter to the New York City Department of Sanitation (DSNY) on Proposed Rule Relating to Entities Engaging in Cleaning Services

  Thank you for this opportunity to provide testimony on the proposed rule relating to entities engaging in cleaning services. We are writing to ask you to withdraw the proposed rule, delay its implementation, and work with community organizations to reach a mutually beneficial solution such as a carve-out for community groups.

  We represent the Clean Bushwick Initiative (CBI). CBI is a community organization based in Bushwick, Brooklyn, that works to improve the cleanliness and sustainability of our neighborhood. In 2024, we hosted 15 cleanups throughout Bushwick, engaging over 250 volunteers and taking over 3,600 lbs of trash off the street. Cleanups involve keeping our streets and green spaces free of debris. We also educate volunteers about sustainability issues.

  We are concerned that the proposed rule amending Section 16-120(e)(2) would negatively impact organizations like ours. The rule prohibits placing refuse near public litter baskets and in other public locations but provides no practical alternatives for disposing of trash collected during community cleanups. This proposed rule does nothing to reduce street litter—it just outlaws cleaning it up.

  The Proposed Rule Does Not Prevent Litter, it Outlaws Cleanups

  Currently, Section 16-120(e) of the New York City Administrative Code prohibits the placement of household or commercial refuse in or around a public litter basket or in the streets or other public places. In effect, it is a rule against littering. Ostensibly, the proposed change seeks to clarify that community cleanup organizations, such as CBI, also may not place refuse within the vicinity of any public litter basket, or in the streets and other public locations. The actual effect of the proposed rule would be to make it illegal for community organizations to perform cleanups and remove trash from the streets and other green infrastructure, like rain gardens, because we would have nowhere to dispose of the trash we collect.

  The notion that Section 16-120(e) needs clarity is misguided and appears to rely on a fundamental misunderstanding of what cleanup organizations like CBI do: they do not create trash, they remove it. The current rule does not contain a hidden exception allowing community cleanup organizations to litter or dispose of household and commercial refuse in public litter baskets. It would already be in violation of the current rule for an organization to bring personal or commercial refuse to public receptacles or into the public streets, but this is not what community cleanup organizations do. Community cleanups, like those organized by CBI, collect litter already in the streets, often caused by illegal dumping. By placing this waste near public receptacles, cleanup groups make it easier for DSNY to collect and dispose of it. Without the efforts of thousands of volunteers with multiple cleanup organizations across the city, the litter already in the streets would remain there, contributing to health and pest problems, blocking drains, clogging rain gardens, and potentially ending up in our waterways.

  If the goal of Section 16-120 is to prevent litter and reduce trash in the streets, this proposed rule must be rejected. Cleanups work to clear streets of trash, not to leave more behind. This rule would discourage these efforts, leaving more litter on the streets and making it harder for volunteers to keep our neighborhoods clean.

  Broader Impact and Equity Issues

  Bushwick has been designated a disadvantaged community by the New York State Climate Justice Working Group and large parts of the neighborhood are included in a rat mitigation zone. The neighborhood already lacks adequate trash bins, enforcement, and resources for waste management. This rule would hurt underserved communities like ours the most, where residents rely on local efforts to keep streets clean. DSNY cannot manage all the waste on its own, so community groups fill an important gap. If groups like ours can’t operate, trash will pile up, and street cleanliness will decline. Beyond CBI, this rule will make it harder for schools, scout troops, park stewards, business improvement districts, and other groups to clean their neighborhoods.

  The impact would go beyond just street cleanliness and beautification. CBI maintains a number of rain gardens in Bushwick in partnership with the NYC Department of Environmental Protection that are necessary to absorb stormwater, reduce flooding, and filter pollutants. Our cleanups regularly focus on clearing trash and debris from the rain gardens and surrounding streets to ensure that the gardens are able to function properly. Without a way to dispose of this waste, maintaining rain gardens becomes much harder, which could lead to more flooding and pollution.

  Recommendations and Conclusion

  Rather than outlawing community cleanup efforts, we would urge the DSNY to 1) provide practical disposal options for community cleanups, like designated drop-off points; 2) install more trash bins in neighborhoods like Bushwick, especially larger, more secure bins; 3) provide more education and resources to local businesses and property owners to ensure they are aware of their obligation to keep the sidewalks in front of their property clean, as well as 18 inches into the street; and 4) create a carve out in the proposed rule for non-profit community organizations.

  Clean Bushwick Initiative is committed to improving our neighborhood and supporting DSNY’s mission to maintain cleaner streets. However, this proposed rule would make it harder for us and others to continue this vital work. Rejecting this rule and supporting community-led cleanups is essential to keeping New York City clean, safe, and healthy.

  Sincerely,
  Clean Bushwick Initiative

  Comment attachment
  CBI_Comment-on-Proposed-DSNY-Rule.docx

  Comment added February 10, 2025 4:19pm

• Clare Miflin

  Comments attached as pdf and pasted in below:
  The Center for Zero Waste Design is a nonprofit that develops research, advocacy campaigns, and policy tools for buildings and cities to achieve zero waste. We work with community organizations, nonprofits, and municipalities to provide thought leadership to ensure policies and systems are aligned for circularity. We thank the Department of Sanitation (DSNY) for this opportunity to comment on their proposed rule relating to Entities Engaging in Cleaning Services.

  We fully support DSNY’s goals to get rid of bags of trash piled up on sidewalks and instead move to a system where waste is collected from bins and containers by mechanized trucks. But we have strong concerns about the way DSNY is moving forward with waste containerization, without any outside stakeholder input, and moving forward in a way that goes against the City’s goals of improving pedestrian mobility and the quality of the public realm. We recently released a report On Containerization, which outlines alternatives to DSNY’s plans which would allow waste containerization to improve streetscapes and labor, at lower cost, and would help the City reach waste reduction and climate goals.

  Our concerns include:

  Lack of stakeholder or public engagement:
  There has been very little outreach and discussion with the groups doing the hard work, much of it volunteer labor, helping keep the city clean who are affected by this rule. As many of the BIDs testifying stated, this is a huge additional cost to them, cannot be made by August of this year, and their concerns have been ignored.

  Most containerization solutions currently available to these groups are enclosures for bins, which are expensive, take up a lot of sidewalk or curbside space, and are not suited for BIDs with substantial volumes of waste.
  The rule requires waste be set out for collection “in rigid receptacles with tight fitting lids that do not exceed fifty-five gallons in size, unless an alternative receptacle is approved by the Department.” I believe the alternative is tilt trucks or hampers within an enclosure, as DSNY will be lifting the material by hand into the back of the truck. These solutions are not space or cost efficient, and do not improve labor for DSNY collection staff.
  Also, DSNY is rolling out alternative containerization solutions, like the Empire Bins being piloted in CB9, so why not wait and evaluate solutions like this before making entities invest substantial dollars in short term solutions?

  Negative impact on streetscapes and pedestrian mobility
  Placing 55 gallon bins on sidewalks will be the cheapest and only option available for many groups to be able to continue supplemental cleaning services. This will just add to the many permanently located bins we already see on sidewalks. We will have more bins chained to street trees and DOT poles alongside litter bins, to prevent theft. These bins will block pedestrian traffic along sidewalks. Given that almost half of NYC has sidewalk widths below 9 feet wide, per Open Street data – and the growing crowdedness of NYC sidewalks in general, the reduction in walkability and accessibility is unacceptable. The aim is to improve sidewalks and public space, not make them more cluttered.

  Alternative Solutions Include:

  We believe there are many alternate solutions that DSNY should consider piloting with BIDs or neighborhood entities:

  Adjusting collection times to reduce volume of waste to be stored.
  Adjusting collection times to collect waste more frequently, especially at times of high generation rates, could reduce the amount of time waste needs to be bagged alongside the litter basket. Many BIDs state that DSNY collection times are not consistent, which makes it difficult to know how much waste volume to plan for. Working with BIDs to locate the bags in better locations for DSNY’s collection routes could also make it more efficient for DSNY.

  Consider large stationary containers aka “Empire Bins” for neighborhoods with large volumes of litter bin waste.
  “Empire Bins” (the 4 cubic yard containers used in Barcelona and many other European and South American cities) would be a much more space efficient for waste to be stored, would cost much less, and be better for DSNY labor. I do realize DSNY do not yet have enough trucks to roll this out citywide, but they could pilot and evaluate it in CB9 or on a route which could easily be serviced by a truck working on that upcoming 2025 pilot.

  Collect waste from alternate off-sidewalk locations – eg loading docks, trucks.
  Some BIDs have access to loading docks in their district, through agreement with the building owner, and could stage waste temporarily there. Other BIDs have trucks for supplemental service – if they fill a box truck with bags of litter bin waste, DSNY could collect directly from the truck. These innovative approaches don’t require any new permanent infrastructure.

  Collect from larger 4-wheeled bins
  There are other products available which are not full enclosures, but instead allow 4-wheeled bins, with a capacity of 283 gallons, to be docked in place. If DSNY added simple lift mechanisms to their existing rear load trucks, they could pick up both 2-wheeled and 4-wheeled bins mechanically. This would allow them to collect larger capacity bins from both on-street and from large multifamily buildings – where the 4 wheeled bin can be directly hooked up to the trash chute and offer greater compaction. This option is cheaper and more space efficient, taking up less curb length which is needed for so many other reasons – passenger pick up, deliveries, bike lanes, bus lanes and parking.

  We believe that DSNY should work with BIDs and other entities to pilot and evaluate a range of solutions before offering a suite of options citywide. It is thoughtless to expect entities to figure out and invest in a short term solution, when there may well be much better options available.

  We would welcome the opportunity to discuss our suggestions with DSNY and help improve the outcomes of waste containerization citywide.

  Clare Miflin
  Executive Director
  Center for Zero Waste Design

  Comment attachment
  250210-DSNY-Proposed-Rule-BIDs-and-other-entitites-in-Cleaning-Services-.pdf

  Comment added February 10, 2025 4:21pm

• Brooke Schooley

  This proposed rule would be a disaster for heavily trafficked areas like the West Village. Overflowing trashcans are the responsibility of the city, and our BID is doing the city a favor by actively bagging overflowing trash. Our BID does not have the resources to invest in hard containers, nor do our streets have room for them. If the city doesn’t want bagged trash by the bins, they should increase the number of times they pick up the trash, or remove trash cans altogether so that there is no public trash service. Preventing bagging is simply going to result in litter falling everywhere around the bins and blowing down the street.

  Comment added February 10, 2025 4:49pm

• Vanessa Warren

  This is an insane rule. Can you imagine if BIDs which are a non-profit stopped picking up the public’s litter? As a resident and the block president of Wash Pl Block Assoc which is very near west 4th st and wsp the Village Alliance BID is doing God’s work! The funds required for this with 144 receptacles currently in this BID district would be completely out of budget and they have already warned that because of this they would stop this service all together. If the BIDs and other neighborhood dont provide the service of picking up after the public and tourists, who will? Is the city going to step up and make sure the sidewalks are clean every single day?
  Please change course before we are all living in filth… or make an exception for street litter cleanup, which is done in bags, and placed next to bins for pickup.

  Comment added February 10, 2025 5:09pm

• Jonah Birch

  The Office of New York City Council Member Tiffany Cabán is writing to express our concern over the proposed rule change by the Department of Sanitation, which would force trusted community partners like ACE Contract Services to either purchase permanent trash containers or use private trucks for waste removal. This would cost organizations like ACE an estimated $4-5 million a year, which would potentially force it to shut down essential services it provides to residents of District 22. Organizations like ACE serve a crucial function in cleaning communities like ours in Astoria, Queens, where they removed 12,000 pounds of trash in December 2024 alone. In addition, this rule change would threaten the employment of 165 individuals who rely on ACE for their livelihood and path to a better life. For these reasons, our office feels that this rule would be detrimental to public health, safety, and the well-being of our community. We ask you to reconsider.

  Comment added February 10, 2025 5:18pm

• Mary Ellen Sullivan

  Hello DSNY,

  I have participated in many community clean-ups, sometimes separating out recyclables and sometimes putting all trash and recyclables into black garbage bags. As community groups are doing these clean-ups, people passing by always say “thank you!” They mention that they have noticed the trash for a long time, but nothing has been done about it. If community groups are not allowed to perform this useful service, our city will be dirtier, uglier, and provide food and haven for rats. It will not be an improvement.

  I recognize DSNY is working to improve processes. I think containerization without exception for community clean-ups is a bad idea. Did DSNY talk with the BIDs? Did you talk with City Council Members who regularly organize clean-ups? Did DSNY speak with community leaders who have done their neighbors and the city a service by spearheading clean-up activities? Has the DSNY solicited ideas about how this challenge can be solved?

  I would urge the DSNY to partner with community groups and BIDs to come up with a workable solution. I would also urge DSNY to encourage everyone doing community clean-up efforts to also include recycling and organics in their efforts. Let’s focus on the goals of helping our city get clean and stay clean, AND divert recyclables, organics and yard waste to their proper and useful place. The community is DSNY’s partner. Help us help you.

  Comment added February 10, 2025 5:26pm

• David

  Communities depend on bids to help keep the city clean you are fixing something that isn’t broken why you don’t allow him to Bunch the garbage bags that they fill next to the public pickup wire baskets is beyond belief if you’re concerned that the plastic bags can be attacked by rodents then specify a much heavier gauge plastic bag to be used rodents can’t go through everything the city is not cleaning the streets in the same way a local bid can really sweep the neighborhood stop trying to prevent this from happening

  Comment added February 10, 2025 5:28pm

• 31st Avenue Open Street Collective

  As facilitators of the 31st Avenue Open Street in Astoria, Queens, we request that the DSNY reconsider the proposed rule change. We rely on our limited public litter baskets to maintain and beautify our Open Street. On weekends from April to December, our Open Street welcomes well over 200 visitors each day we’re in operation. As they support local businesses and enjoy free programming, our two city-issued litter bins fill quickly. With partner organizations, we bag overflowing waste, re-line bins multiple times daily, and clear debris to keep the street clean. This rule will severely hinder our commitment to maintaining a clean and safe public outdoor space for local families, businesses, and the community at large.

  We understand the immense challenges the DSNY faces in combating New York City’s waste and applaud their efforts. However, this well-intended rule change has far-reaching consequences and would impose a burden on small, non-profit organizations like ours to maintain and store compliant receptacles, effectively exacerbating the city’s litter problem.

  In lieu of this proposal, we request that the DSNY engage in conversations with community organizations like ours to find a better solution that avoids penalizing volunteer efforts. We all share the goal of creating a cleaner New York, and together we can make that happen.

  Sincerely,
  31st Avenue Open Street Collective

  Comment added February 10, 2025 8:06pm