Testimony of Action Environmental Group, Inc.
Ronald Bergamini, CEO
New York City Council
Honorable Antonio Reynoso
June 27, 2019
My name is Ron Bergamini. I am the CEO of Action Environmental Group, the parent company of Action Carting, NYC’s largest hauler of commercial solid waste & recycling materials. We employ over 1,000 people with our entire labor force union members. There are a number of bills on your agenda today related to our industry; however, my testimony will focus on intro 1574, the Creation of Commercial Waste Zones.
Creating commercial waste zones is the most radical policy change in the history of New York City solid waste collection. We remained unconvinced that this is the only way to improve the system. However, if change is going to occur it needs to be done right. The proposal in the current legislation, to create competitively bid single hauler zones, gets it right. It will undoubtedly yield safer operations, lower VMTs, lower cost structure, and create a fairer environment for the employees.
The fundamental reasons for embarking on this effort are to: 1) improve safety for the public and private hauler employees, 2) reduce vehicle miles traveled for environmental benefits, and, 3) improve service to the customers. The reduction in vehicle miles traveled will reduce emissions and create operating efficiencies that can enhance customer relationships.
We have long advocated for stricter standards to receive and maintain a license. This is a difficult business and those who actually drive the trucks and pick up the waste and recyclable material work hard in stressful conditions usually in the middle of the night. We are constantly training our people in our Action University, we hold regular monthly safety meetings and our safety committees are made up of those doing the work.
We have maintained for a decade that many of the city’s policy goals can be achieved through improving operational standards and adding them to the existing licensing requirements. The notable exceptions are reduced vehicle miles traveled and transparent pricing. Here we enter the debate of the choice between single hauler and multiple hauler districts.
Of the two choices, Action strongly supports a single hauler system which produces the greatest reduction in VMT’s. Even the goals of safer operations, better wages, and increased sustainability would benefit. A single hauler system is easily integrated with other City services. It requires only one-call to the zone designated hauler to assist the police in emergencies; manage street uses like parades, street fairs, and street closings; respond to noise complaints; and adjust to traffic, construction and store deliveries. Just one fun example – no garbage trucks in the theater district on Wednesday matinees.
All of the successful commercial waste franchise markets in the US follow a single hauler model, with clearly defined service and safety standards, and are based on competitive, transparent and well-defined pricing.
To those worried about specific service levels being maintained in a single player zone, I would urge you to describe your concerns and have the council or city require potential awardees to answer such concerns in their submissions. Essentially require the hauler to explain how we have the resources and know-how to do so.
While the single hauler in a zone may be the most important aspect of the bill, there are other issues that we hope to work with the Council and the Department on in the coming weeks. They include:
Pricing. This legislation discusses continuing a “Rate cap” structure. Other single hauler policies throughout the country create a Pricing Menu (like a utility structure). We prefer the Pricing Menu. Any legislation must make clear that periodically rates will need to be adjusted to suit market conditions and policy goals. For example, today’s market conditions are the worst for recycling markets in decades. Such a fundamental change in one aspect of our business may not happen frequently but it does happen.
Industry Standards. The legislation calls for a set of standards to be set by the DSNY Commissioner. This point needs clarification. It seems to imply that anything may be considered. The Commissioner should seek input from industry stakeholders and the City Council to provide guidance for such standards.
Innovation. Action supports and advocates continued innovation in our industry. Safely collecting and disposing of waste throughout the city is a great responsibility. Those who do the hard work each and every night must be allowed to do so professionally, with fair wages and within an appropriate and supportive work environment. We are proud to be part of this discussion and remain committed to the city of New York sharing its stated goals of better service, sustainability and above all, safety.