Letter Report on the New York City Civilian Complaint Review Board’s Compliance with Local Law 36
Letter Report on the New York City Civilian Complaint Review Board’s Compliance with Local Law 36
LETTER REPORT IN BRIEF
This brief summarizes our audit findings regarding the compliance by the New York City Civilian Complaint Review Board (“CCRB”) with Local Law 36, which governs waste prevention, reuse and recycling by City agencies. The objective of this audit is to determine if CCRB complied with the local law, which is intended to make City agencies, and ultimately the City as a whole, more sustainable through efforts that promote a clean environment, conserve natural resources, and manage waste in a cost-effective manner. In addition, in the course of the audit, we noted efforts made by CCRB to follow additional recycling rules established by the Department of Sanitation for the City of New York (“DSNY”) pursuant to Local Law 36. Our audit of CCRB is one in a series of audits we are conducting of compliance with the local law.
In 1989, New York City established Local Law 19, codified as Administrative Code §§ 16-301, et seq., to establish an over arching “policy of the city to promote the recovery of materials from the New York City solid waste stream for the purpose of recycling such materials and returning them to the economy.” The law mandates recycling in New York City by residents, agencies, institutions, and businesses, and includes a series of rules to guide implementation. Local Law 19 requires the City to establish environmental policies to conserve natural resources and manage waste in a sustainable and cost-effective manner.
In 2010, the City enacted Local Law 36 by which it amended the recycling provisions of Local Law 19 (Administrative Code § 16-307) to require each City agency to develop a waste prevention, reuse, and recycling plan and submit the plan to DSNY for approval by July 1, 2011, and each year after. Local Law 36 also requires each agency to designate a lead recycling or sustainability coordinator for the agency and, where the agency occupies more than one building, to designate an assistant coordinator for each building the agency occupies. By July 1, 2012, and in each year thereafter, the lead recycling coordinator for each agency is required to submit a report to the head of its agency and to DSNY “summarizing actions taken to implement the waste prevention, reuse, and recycling plan for the previous twelve-month reporting period, proposed actions to be taken to implement such plan, and updates or changes to any information included in such plan.”
In addition, Local Law 36 requires the commissioner of DSNY to adopt, amend, and implement regulations governing recycling by City mayoral and non-mayoral agencies. DSNY is also responsible for consolidating the information contained in agency reports and including this information in the department’s annual recycling report.
Results
Our audit found that CCRB generally did not comply with Local Law 36. We found that CCRB did not establish a waste prevention, reuse and recycling plan and did not submit the required annual reports to its executive director or to DSNY as required by Local Law 36. Although CCRB recycles its office papers, such as copier papers and computer printouts, CCRB does not source separate other recyclables as designated by DSNY. These recyclables include metal, glass, plastics and beverage cartons.
In addition to these findings, we observed that CCRB has made additional efforts to address waste prevention, reuse and safe handling of hazardous waste beyond the requirements of the local law. Specifically, CCRB has set the office printers to duplex printing to reduce its paper usage. CCRB also follows city guidelines for the relinquishment and disposal of its unwanted computer monitors and other computer equipment. These measures were taken in accordance with DSNY’s additional guidelines enacted pursuant to Local Law 36.
The audit recommended that CCRB prepare its waste prevention, reuse and recycling plan as soon as practical and submit the required annual reports to its executive director and DSNY by July 1st of each year as required by Local Law 36. The audit also recommended that CCRB set up additional receptacles in its office to collect different streams of recycled materials as required.
Agency response
CCRB generally agreed with the recommendations and is in the process of developing a written recycling plan. It stated that “Our written recycling plan will detail much of the recycling efforts we have…” and “will be completed by the end of October 2014 and submitted to the Executive Director of the agency and to DSNY.”