Letter Report on the New York City Department of Information Technology and Telecommunications’ Compliance with Local Law 36
Letter Report on the New York City Department of Information Technology and Telecommunications’ Compliance with Local Law 36
June 30, 2014
LETTER REPORT IN BRIEF
This brief summarizes our audit findings regarding the compliance by the New York City Department of Information Technology and Telecommunications’ (“DoITT”) with Local Law 36, which governs waste prevention, reuse, and recycling by City agencies. The objective of this audit is to determine if DoITT is complying 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 DoITT 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 DoITT 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 DoITT generally complies with Local Law 36. However, we found that DoITT did not submit its waste prevention, reuse and recycling plan to DSNY until the fall of 2013, after this audit had commenced, notwithstanding Local Law 36’s requirement that such a plan be submitted to DSNY by no later than July 1, 2011. We further fund that DoITT did not submit its 2012 annual report to its Commissioner or to DSNY as required. While DoITT source-separates its recyclable materials, we noted a lack of receptacles for recycling mixed paper in one of the DoITT’s locations.
In addition to these findings, we observed that DoITT has made additional efforts to address waste prevention, reuse, and safe handling of hazardous waste. Specifically, DoITT has set its printers to double-sided by default and encourages its employees to double-side all copies by placing posters by the copiers. DoITT also participates in a City-wide contract for hazardous waste pickups by an independent contractor. These measures were taken in accordance with DSNY’s additional guidelines developed pursuant to Local Law 36.
The audit recommended that DoITT assess its plan each year and submit annual updates to its agency’s Commissioner and to DSNY. We also recommend that DoITT provide adequate bins for the collection of mixed paper and cardboard in addition to plain shredded papers bins.
Agency response
The agency stated that it “obtained compliance with our recycling obligations by arrangements with the management of the buildings in which we rent office space. Each building management operates a facility in which recyclable materials are separated. This operation was in place well before your predecessor commenced this audit; our initial omission to file the required documentation of that operation with the Department of Sanitation was purely a procedural oversight that did not impair our adherence to recycling requirements.”