The Real Estate Board of New York to The Committee on Sanitation of the New York City Council Regarding Intro 0693-2022

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Thank you to Chair Nurse and Members of the Sanitation Committee for the opportunity to testify on legislation today aimed to identify solutions to enhance streetscape cleanliness across New York City.

In recent years REBNY has been at the forefront on working with policy makers to establish proposals to promote better operations relative to trash pick-up, commercial waste hauling and numerous other proposals. With this said, there is more work to be done and we commend the Council’s continued focus on the issues around sanitation.

Apart from Intro 693, in which we have more specific comments below, REBNY broadly supports the legislation being discussed today and looks forward to working with the Council on this package moving forward.

BILL: Intro 693-2022

SUBJECT: This bill would require that someone who manages or controls a building with 100 units or more provide a dumpster for refuse.

SPONSORS: Public Advocate Jumaane Williams and Councilmembers Nurse, Louis, Restler, Hanif, Hudson, Brewer, Won and Gutierrez.

REBNY believes that identifying opportunities to ensure that all large residential buildings have access to a dumpster is a laudable goal. As it pertains to efforts to mitigate against rats and other pests and in the fight to keep streets clean and absent trash bags, additional access to containers for trash and other refuse will be an important part of any long-term plan to improve sanitation in New York City. However, implementing such a requirement is much more difficult and complex than it would first appear. Specifically, the legislation as drafted creates questions about how new requirements for a dumpster would be practical in buildings or on lots with limited space, whether the space be inside or out.

As the Council certainly understands, a good number of buildings in the City’s existing building stock do not have the adequate space to accommodate these requirements. While many residential buildings of 100 units or more include rooms for trash, this is not a universal truth and certain buildings simply will not have the floorplate to accommodate a dumpster indoors.

This lack of adequate space is often even more sparse outside. With today’s streetscapes needing to be utilized by a variety of uses, adding a dumpster may simply be out of the question, and if there is space, it may not be the best use or what residents would most like to utilize said space for. This also fails to consider that many larger residential buildings also utilize ground floor space, including outdoor space, for retail and other commercial uses – often whose rent is utilized to offset building expenses elsewhere. It is unclear on if all these scenarios have been taken into consideration by this legislation. Unfortunately, a blanket policy will not solve for these individualized situations.

Moving forward, and at a minimum, the Council should include a provision that would exempt existing buildings that have extenuating site constraints. In addition, another solution would be to require such a requirement in only new buildings moving forward.

Thank you for the consideration of these points.