The Real Estate Board of New York to The New York City Council Committee on Sanitation and Solid Waste Management re: Intro 353

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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 submit testimony regarding Intro. 353-2026, which would establish a Commercial Waste
Zones Working Group to study the implementation of New York City's Commercial Waste Zones (CWZ)
program and make recommendations concerning its operation and future policy direction.

REBNY supports the creation of a structured forum for stakeholders to evaluate the implementation of the
CWZ program. The CWZ system is a significant change to the City's commercial waste collection framework,
with implications for businesses, property owners, waste haulers, workers, and communities throughout the
five boroughs. Given the scale and complexity of this transition, ongoing stakeholder engagement and
feedback are critical to ensuring that the program achieves its objectives while minimizing unintended
consequences.

We appreciate that the legislation recognizes that representatives from carters, labor organizations,
environmental experts, and micro-hauling organizations should participate in the working group. However,
the legislation does not provide for representation of the commercial property owners and businesses that
are ultimately responsible for procuring waste collection services and implementing many of the operational
changes associated with the CWZ program.

Commercial property owners are among the stakeholders most directly affected by the CWZ program, as
they are responsible for coordinating waste storage, collection schedules, loading dock operations, tenant
communications, and compliance with new requirements. These responsibilities are particularly significant
in office buildings, mixed-use properties, retail centers, industrial facilities, and other multi-tenant commercial properties. Commercial owners possess firsthand operational experience that would provide
valuable insight into how CWZ properties function in practice and help the working group develop practical,
effective recommendations.

Accordingly, REBNY recommends that Intro 353 be amended to reserve at least two seats on the working
group for representatives of commercial property owners and managers. Including commercial property
owners alongside labor, environmental advocates, and waste industry representatives will strengthen the
working group's recommendations and improve the program's long-term implementation.

REBNY appreciates the Council's efforts to establish a transparent process for evaluating the
implementation of CWZs and looks forward to working with the Council to ensure commercial property
owners are represented in this important conversation.
Thank you for your consideration.

CONTACT:
Zach Steinberg
Executive Vice President
Real Estate Board of New York
[email protected]