Rule status: Proposed
Comment by date: May 4, 2021
Rule Full Text
BIC is proposing changes to promulgate rules for micro-haulers, a sub-class of licensees who solely collect under a prescribed annual tonnage of organic waste by bicycle or zero emissions vehicles. The proposed changes to also affect recordkeeping requirements for licensees.
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May 4, 2021
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Tok Michelle Oyewole
NYC-EJA’s Testimony on BIC’s Proposed Rules Governing Microhaulers with Certifications
May 4, 2021
My name is Dr. Tok Oyewole, and I am testifying on behalf of the New York City Environmental Justice Alliance (NYC-EJA).
Founded in 1991, NYC-EJA is a non-profit citywide membership network linking grassroots organizations from low-income neighborhoods and communities of color in their fight for environmental and climate justice.
For decades, NYC-EJA has led efforts for comprehensive policy reforms to address the disproportionate burden of New York’s solid waste system on a handful of environmental justice communities. The impacts of the solid waste system are greatest in a few low-income and communities of color where truck-dependent transfer stations are clustered, causing higher proportions of health consequences such as asthma, heart disease, and various cancers.
We are here today to advocate for adjustments in the proposed BIC rules pertaining to microhaulers that we think would improve equity and working conditions for small, largely up-and-coming businesses whose diversion of organic waste using zero- and low- emissions vehicles benefits environmental justice communities that bear the brunt of traditionally mismanaged waste, and whose work benefits frontline communities by reducing greenhouse gas emissions exacerbated by waste management.
BIC’s Rules should seek to make entryway into microhauling more accessible:
This can include implementing programs and pilots that support starting microhaulers, including technical, legal, and financial assistance, and streamlined aid in citing locations.
Additionally, new microhaulers should have a one year exemption before they are required to have Business Automobile Liability Insurance, and should have a lower rate (but would still be required to have auto insurance)
Investigation fees should also be waived for Not-For-Profit Corporations and Worker-Owned Cooperatives § 6. Subdivision (a) of section 3-01 of Title 17.
Lastly, while we recognize BIC’s important mission in creating a just landscape for commercial waste regulation and addressing malpractice, we share concern about some of the regulations that apply to microhaulers. The requirements for criminal background checks for employees in leadership and employees are troubling, in part because some Microhaulers and Processors Trade Association (MPTA) member organizations prioritize hiring people with barriers to entry to work, including people who have been formerly incarcerated.
Thank you for the opportunity to raise these comments regarding the proposed rules pertaining to microhaulers with certifications.