The Real Estate Board of New York to The Department of Sanitation on the Draft Environmental Impact Statement for Citywide Containerization Program

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The Real Estate Board of New York (REBNY) is the City's leading real estate trade association representing commercial, residential, and institutional property owners, builders, managers, investors, brokers, salespeople, and other organizations and individuals active in New York City real estate. REBNY appreciates the opportunity to provide comments on the Citywide Containerization Program Draft Environmental Impact Statement (DEIS).

REBNY appreciates DSNY's efforts to modernize New York City's waste management system and supports the City's goal of cleaner streets, improved public health, and safer working conditions through containerization. We have been supportive of the City's ongoing efforts to implement containerization. As the City advances implementation of this program, coordination across agencies and continued operational flexibility will be essential to ensuring the program's long-term success.

The DEIS concludes that the proposed program would not result in significant adverse impacts. However, REBNY encourages DSNY to continue evaluating operational issues identified through stakeholder engagement. Large residential and mixed-use buildings often have unique loading, servicing, and curb management needs that may not be fully captured through citywide analysis. Continued engagement with owners and managers as implementation progresses will help ensure container siting and collection operations remain compatible with day-to-day building operations.

REBNY also encourages DSNY to coordinate implementation of the Citywide Containerization Program with the phased rollout of Commercial Waste Zones (CWZ). Property owners and managers are simultaneously adapting to new contracting requirements, new service providers, and new waste collection practices. Coordinated implementation, clear guidance, and ongoing communication will help minimize operational disruptions and ensure that buildings can effectively integrate both programs into their existing waste management operations.

For larger commercial and mixed-use buildings in particular, maintaining flexibility to accommodate varying pickup schedules, loading configurations, and tenant-specific operational needs will be critical to the success of both initiatives.

Lastly, interagency coordination is imperative. We encourage DSNY to continue coordinating closely with the Office of Emergency Management (OEM), the Mayor's Office of Climate & Environmental Justice (MOCEJ), the department of City Planning (DCP), and the Department of Buildings (DOB) as implementation moves forward.

For instance, in flood-prone areas, coordination with OEM and MOCEJ will be important to ensure that container placement, operations, and emergency response protocols remain compatible with flood preparedness and post-storm operations.

Similarly, coordination with DCP and DOB will be necessary to identify any zoning or building code provisions that may inadvertently limit implementation or create operational conflicts for buildings transitioning to the new waste collection system. Where regulatory updates are warranted, REBNY encourages the City to pursue them in parallel with implementation measures for containerization, not after.

REBNY appreciates the department's efforts on this program and looks forward to continued discussions and working with the agency on its implementation.

CONTACTS:
Maddie DeCerbo
Senior Director of Urban Planning
Real Estate Board of New York
[email protected]