Containerization Requirements for Buildings Containing 10 or More Dwelling Units

Online comments: 10

• Peter Nigrini

  The Empire Bin containerization program presents the opportunity to significantly improve the public realm. I encourage you to roll it out as quickly and efficiently as possible. I feel lucky to live in a district that is among the first to benefit.

  Comment added May 16, 2026 3:57am

• anonymous

  New York City Department of Sanitation
  Bureau of Legal Affairs
  125 Worth Street, Room 710
  New York, NY 10013

  Re: Proposed Rules Relating to Containerization Requirements

  I am submitting these comments regarding the Department of Sanitation’s proposed amendments relating to residential containerization requirements for buildings containing 10 or more dwelling units.

  Our properties are older mixed use Chinatown buildings containing 16 residential units above ground floor and basement restaurant uses. While we understand the City’s goals relating to rat mitigation and cleaner streets, the proposed rule does not adequately address the physical realities and limitations of many older Lower Manhattan buildings.

  The proposed rule gives DSNY discretion to determine that a building’s “circumstances warrant a different containerization method or alternative set out method.” We strongly urge DSNY to explicitly clarify within the final rule that the following conditions constitute valid grounds for alternative set out approval or exemption from standard rigid container requirements:

  • Lack of lawful interior storage space
  • Narrow hallways or means of egress that would be obstructed by required containers
  • FDNY fire safety concerns relating to blocked or narrowed exits
  • Lack of side yard, rear yard, loading dock, or curb cut
  • Mixed use buildings where commercial operations already occupy limited service and cellar areas
  • ADA or pedestrian clearance concerns
  • Prewar or tenement style building configurations that physically cannot accommodate multiple rigid bins safely

  Our buildings do not have dedicated trash rooms, loading docks, side yards, or rear access. Interior hallway areas are narrow and function as primary residential egress paths. Requiring large rigid bins to be stored within these common areas may create conflicts with FDNY safety requirements, emergency access, tenant movement, and sanitation handling.

  In many older Chinatown buildings, cellar access is already heavily utilized by restaurant infrastructure, utility systems, storage, and building operations. These buildings were constructed long before modern containerization mandates and were not designed to accommodate large wheeled bins internally.

  We respectfully request that DSNY create a formal hardship or alternative compliance pathway for older mixed use multifamily buildings where standard containerization is physically impractical or creates safety concerns. We further request that DSNY specifically recognize “lack of lawful storage space” and “egress obstruction concerns” as explicit qualifying conditions for alternative set out methods.

  We also encourage DSNY to work collaboratively with FDNY, DOB, and affected property owners before imposing requirements that may unintentionally create unsafe hallway conditions or conflicts with other building regulations.

  Thank you for the opportunity to comment on this proposed rule.

  Comment added May 21, 2026 4:24am

• Shawn

  I am in complete support of the containerization requirements and the permanent street containers for people to bring their trash to. My neighborhood in Clinton Hill CB2 is completely overrun with rats due to large buildings leaving piles of trash out for hours for rodents to feast on (and which invite non-building residents to dump their trash there too). It’s completely unsanitary and with hantavirus in the news we need to take this much more seriously. The faster this rolls out, the better.

  Comment added May 23, 2026 10:23am

• Anonymous

  I believe clarity and flexibility is needed in any final requirement for use of on-street containers. The arbitrary use of “more than 30 units” lumps in massive buildings that generate large amounts of trash with more modest buildings that can easily use sidewalk containerization. If a moderately sized building that is above 30 units can successfully use sidewalk containerization, they should not be required to use on-street containerization. I urge flexibility to allow this with extenuating circumstances where on-street containers:
  – do not fit the aesthetic of historic neighborhoods and should be limited to only absolute necessary deployment
  – cause narrow and unsafe travel routes on narrow streets. On days when opposite side parking is in effect, an on-street container and parked car opposite one another will constrict the street width – we often see this play out when cars park illegally, and fire trucks have great difficulty squeezing through the constricted street.

  I fully support containerization with use of approved NYC bins, but I urge a redefinition of “large” to be above 60 dwelling units, or an addition of another tier to distinguish between building sizes that provides more flexibility below 60 dwelling units, and accommodation for historic neighborhoods and streets that are defined as “narrow.”

  Comment added June 8, 2026 1:22pm

• Anonymous

  I fully support containerization, and hope that the project continues and is codified moving forward. Overall, I find the containerization to be a great success. I find the bins to be a much better use of the street than free & subsidized parking for the small percentage of NY’rs that own cars. There is a noticeable downturn of rats on the block. As a pilot block we initially had flap top dumpsters, and that was the best option. By lowering the barrier of entry into the idea & making disposal as simple as possible, the block was the cleanest it had ever been with no additional measures taken. They also held the largest amount of trash. While I understand that the empire bins are what has been decided on, what has been created is a multistep process that could be improved. The bins are only opened by building supervisors, so tenants must first place trash else where to then be collected in the bins. This often still leaves trash out. Additionally the bins seem to have several mechanisms that break, including the tops and push bar. They also don’t have the capacity the original containers had, often causing trash to be placed back on the street when the bins are full. I fully support large scale containerization, in any form we can get but I do see room for improvement and hope if we’re going to do it, we can do it right the first time.

  Comment added June 15, 2026 9:08pm

• Raphael

  To the Department of Sanitation,

  I am writing in support of the city’s containerization effort, and specifically to comment on the proposed extension of the Manhattan Community District 9 pilot through October 2027 and its expansion into Brooklyn Community District 2.

  I live in M9, and my block has been part of both the original 10-block shared containerization pilot and the current M9 pilot. I want to be clear: I believe containerization works. When shared bins were first introduced on our block, rat sightings dropped significantly. The improvement was real.

  I am writing because I want the broader rollout to succeed, and our experience has shown that the program needs stronger consistency, clearer rules, and better enforcement before it expands.

  Over the past year, rat sightings on our block have increased again. From what I have observed, the problem is not containerization itself. The problem is that the rollout left gaps: some buildings were covered, others were not; some rules were clear, others were not; and enforcement has not been consistent enough to keep buildings compliant.

  My block includes townhomes, small apartment buildings, mid-sized buildings, and larger buildings, so it offers a useful example of the challenges the city will face as this program expands.

  The townhomes have mostly adapted well. Large buildings with Empire Bins are generally in better shape when those bins are actually used. But mid-sized buildings and some large buildings have fallen through the cracks.

  I urge DSNY to address the following before expanding the program further:

  First, please do not leave mid-sized buildings in limbo. Buildings with roughly 10 to 30 units need a clear containerization solution. Relying on owners to opt in has created confusion, especially because owners are often not the people handling the trash day to day. Supers are. Larger buildings should receive Empire Bins directly, and mid-sized buildings should be allowed to share Empire Bins where appropriate.

  Second, please address large buildings that front an avenue but set out trash on the side street. Several larger buildings near us appear to have been missed because their main address is on an avenue, even though their trash is placed on 149th Street. Without containers, these buildings have gone back to setting out bags, and the rats have returned. This is exactly the kind of gap that undermines the program.

  Third, please clarify the actual bin requirement and timeline. Residents have been told to use official DSNY bins, but in practice many different bins are still being used, and the new truck system does not appear to be fully in place. The city needs to make the rules and implementation schedule much clearer.

  Fourth, please enforce against bad trash storage. On some properties, trash is still left in chewed-through plastic bins or piled beside overflowing bins. Even when an Empire Bin exists nearby, it is not always being used consistently. If trash is still accessible to rats, the program cannot achieve its purpose.

  Fifth, please bring back the kind of consistent enforcement that made the original pilot work. During the first 10-block pilot, conditions were documented regularly, including with photos, and that accountability mattered. Buildings that allow garbage to pile up should be ticketed. Without enforcement, the responsible buildings carry the burden while the problem buildings continue to attract rats.

  Finally, I strongly urge DSNY to restore daily pickup for shared containers. In the original pilot, daily collection was one of the biggest reasons the program worked. Trash did not sit long enough to become a food source. Daily pickup, combined with shared Empire Bins for mid-sized buildings, would solve many of the capacity and coverage problems we are seeing now.

  The issue is not whether containerization works. It does. The issue is whether the city can implement it consistently. Where bins are available, used properly, collected regularly, and backed by enforcement, the streets are cleaner and rat activity goes down. Where the rollout is optional, unclear, or unenforced, the conditions regress.

  I urge DSNY to fix these problems in M9 before expanding the program to Brooklyn CD2 and beyond. The city has a real opportunity here, but the success of the rollout depends on closing the gaps we have already seen firsthand.

  Thank you for your work on this program and for the opportunity to comment.

  Sincerely,
  Raphael Sbarge

  Comment added June 15, 2026 10:02pm

• Michael Jameson

  The container program must be expanded to buildings with less than 10 units. I live in a townhouse with three units. My neighbors in comparable 3- and 4- unit buildings say they would eagerly participate. An earlier iteration of the pilot allowed this because the containers were not locked. Currently, we are forced to use and manage individual cans on rollers that must be moved up and down stoops on collection days and are subject to theft—an extremely cumbersome and inefficient, privatized scheme. Let all of us opt in to use the containers! They have most definitely reduced the visible rat population.

  Comment added June 15, 2026 11:24pm

• Emory

  First the required trash can are not good, the rats have eaten through the ones I’ve purchased. The street bens , people just leave garbage out and around them anytime oof day and it makes it hard to police them. We are being ticked for that. Getting new cards is hard to do and where do we get them from? Not sure if the city is still waiting for rats in our neighborhood. But the getting of new cards is a problem we now have only 1 card 562 W 149 St district 9.

  Comment added June 16, 2026 10:17am

• Clare Miflin, Center for Zero Waste Design

  The Center for Zero Waste Design is a nonprofit organization that has researched best practices for waste containerization around the world, and advocated for NYC to containerize its waste for a decade.

  We are glad that DSNY has chosen to next pilot waste containerization in Brooklyn CB 2, a neighborhood with a very different urban form from CB 9 in Manhattan, and believe it is a great opportunity to pilot alternate methods of waste containerization which would also help reach zero waste goals, improve public space and reduce building operating costs which ultimately are passed onto New Yorkers through rent or maintenance charges. Downtown Brooklyn was upzoned in 2004, and since then has experienced huge growth, with 22,000 new apartments mostly in high rises, and a redesign of the public realm which prioritizes pedestrians, along with many bike lanes and bus lanes. This means that many large new buildings do not have enough curbside space available for the many Empire Bins they would require.

  We are glad to see that this rule allows DSNY to determine that certain buildings should use a different set-out method. Buildings need to register by July 31st, DSNY needs to inform them if there is an alternate method of containerization by August 15th, 2026, with implementation by October 15th 2026. This timeline is extremely tight, especially given the coordination with DOT and building owners that would be required to plan and install the 4-wheeled bin pilot that we believe is the best alternative containerization method for this neighborhood. Compared to Empire Bins this solution would take up less space, improve labor, and save costs up to 80%. Curbside space used to stage the 4-wheeled bins could also be used for deliveries later, in a neighborhood with a huge demand for curbside access.

  We recommend that the determination and implementation dates for alternate methods should be extended, and DSNY should start planning alternate method pilots for both small and large buildings. See our website for more on our recommended pilots and our report the Hidden Costs of Trash, which showed that the average cost for managing waste in buildings is almost $1000 per apartment per year – costs which could be greatly reduced or eliminated with our recommended pilots. This report was also covered in a Vital City op-ed.

  We are very glad that as stated in the rule, DSNY intends to collect more data to be able to evaluate the Empire Bin pilot before rolling out citywide. We urge DSNY to evaluate the pilot, including the alternate methods used, in terms of criteria including:
  – Diversion of recycling and compostable waste,
  – Number of permanent bins obstructing sidewalks
  – Amount of curb lane permanently and temporarily used for waste staging
  – Impacts to both building and DSNY labor.
  Sharing key performance indicators that will be measured, and the results of the evaluation will help advocacy organizations and New Yorkers support this huge change to the way NYC is collecting waste.

  We strongly believe that NYC should plan to containerize waste that doesn’t require building staff to lift tons of garbage bags 4’ high into Empire Bins every week. Such work is not permissible by health and safety regulations in many countries, and I strongly encourage NYC to design waste systems to phase out the requirement of such backbreaking labor for both DSNY and building staff workers.

  The Center for Zero Waste Design is ready and willing to help DSNY ensure that this waste containerization in NYC is as successful and impactful as it can be.

  See attached testimony, and more on our website: https://centerforzerowastedesign.org/all/advocacy/containerization-pilot-proposals/

  Comment attachment
  260617-Empire-Bin-BK-2-testimony-written.pdf

  Comment added June 17, 2026 4:23pm

• Rebecca Poole

  Please see attached comments.

  Comment attachment
  Containerization-Pilot-Rules.pdf

  Comment added June 17, 2026 7:50pm