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Memorandum of Analysis Regarding Requiring Reuse or Recycling of Discarded Carpeting in Commercial Buildings or Units (Intro No. 201)
January 31, 2017
BILL: Intro No. 201
SUBJECT: Requiring Reuse or Recycling of Discarded Carpeting in Commercial Buildings or Units
SPONSORS: Koo; Gibson; Rosenthal; Richards; Constantinides; Johnson; Rodriguez; Lancman; Van Bramer; Vacca; Koslowitz; Torres; Gentile; Espinal, Jr.; Cohen; Kallos; Vallone; Levin; Crowley; Menchaca; Williams; Rose; Levine; Reynoso; Chin; Eugene; Garodnick; Dromm; Ferreras-Copeland; Cabrera; Greenfield; Maisel; Lander; Treyger; Cornegy, Jr.; Salamanca, Jr.; Barron; Ulrich
The Real Estate Board of New York (REBNY) represents over 17,000 property owners, developers, managers, brokers, and other real estate professionals in New York City. We commend and generally support this bill’s intent to reduce the amount of carpeting that is entering our landfills, with exceptions as noted below.
This legislation proposes to ban the disposal of carpeting from commercial units or buildings as solid waste by mandating recycling or reuse. This bill would also impose steep fines upon building owners, developers and haulers to enforce the ban.
While REBNY supports the Council’s sustainability efforts, we believe this legislation overlooks significant barriers to implementation that may ultimately hinder diversion efforts. For example, this bill would require haulers to ensure that carpeting is kept separate from all other solid waste. This could pose additional financial burdens for smaller haulers that may not have access to a separate facility to store recycled carpeting. In addition, the large volume of carpeting this bill would introduce to a small pool of infrastructure-ready haulers might mean higher collection fees for building owners who could pass on additional costs to tenants.
Additionally, the bill’s lack of specificity detailing the different types of carpeting that can be recycled may be another cost-prohibitive barrier for haulers. Depending on the type and material, carpeting may or may not be broken down to a marketable product. For Instance, carpet tiles are more easily recycled but broadloom carpeting can be very difficult to recycle, and has little to no-post consumer value.[i] This bill should specify which types of carpet should be recycled, preferably, carpet that could have post-recycling value.
Lastly, this legislation should also include clearer language detailing the extent to which carpeting should be broken down as well as language addressing the disposal of carpeting materials when they cannot be broken down further. The current lack of clarity may unfairly subject haulers to fines of up to $20,000 per violation for improper disposal. Such a steep fine is likely to impact collection and transportation fees for owners, developers and tenants.
[i] Recycling 101. Carpet Cycle: Helping to Preserve the Environment for Future Generations. Web. January 30, 2017. <http://www.carpetcycle.com/recycling-101/>