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Public Testimony

Josh Raff (Action Environmental) supports CWZ working group, opposes Intro 911A

New York City Council · Jul 1, 2026 · starts 0:43:31 · 1 min 55 sec

Josh Raff of Action Environmental Services supports Intros 75, 356, 367, and 369, strongly supports Intro 353's working group as a productive stakeholder forum, and staunchly opposes Intro 911A, saying it undermines Local Law 199 and would set a harmful precedent by disrupting the Staten Island zone before launch.

Member of the Public - Josh Raff

Thank you.

Member of the Public - Josh Raff

Good morning, Chair.

Member of the Public - Josh Raff

My name is Josh Hariff, and I serve as the Marcus Vice President for New York City Action Environmental Services, a subsidiary of Interstate Waste.

Member of the Public - Josh Raff

Thank you for the opportunity to deliver testimony regarding the bills considered during today's hearing.

Member of the Public - Josh Raff

With respect to bills 75, 356, 367, and 369, Action Carding supports reasonable legislation that encourages street cleanliness, expands access to composting, and promotes economically feasible disposal options.

Member of the Public - Josh Raff

Action is poised to support commercial businesses with relevant compliance education in alignment with the progression of these bills.

Member of the Public - Josh Raff

Furthermore, Action Carding staunchly supports Bill 353 introduced by Councilwoman Nurse.

Member of the Public - Josh Raff

The creation of a commercial waste zones working group would structure a healthy dialogue amongst critical stakeholders who are responsible for the successful realization of local law 199's key objectives.

Member of the Public - Josh Raff

Awarded carters engage with the DSNY to successfully onboard zones.

Member of the Public - Josh Raff

However, there are limited opportunities to provide or absorb more holistic feedback amongst industry colleagues.

Member of the Public - Josh Raff

This working group would be a productive forum.

Member of the Public - Josh Raff

To discuss customers' experiences transitioning to CWZ service agreements, operational best practices and technologies that prioritize safety, and opportunities for efficiency improvements within an evolving regulatory landscape.

Member of the Public - Josh Raff

In contrast, Action Carding staunchly opposes the adoption of Bill 911A, which would unnecessarily alter the operating framework and timely implementation of the CWZ program.

Member of the Public - Josh Raff

This bill undermines Local Law 199's intended goals by diluting the required caliber for CWZ awardees and neglecting the DSNY's ability to course-correct underperforming zones.

Member of the Public - Josh Raff

Staten Island's residents and businesses deserve to benefit from reduced truck traffic, vigilant safety standards, and transparency in the same regard as other boroughs.

Member of the Public - Josh Raff

Therefore, Action Carding encourages this committee to avoid establishing a harmful precedent by disrupting the program's potential before the zone even launches.

Member of the Public - Josh Raff

Thank you for your time.

Justin E. Sanchez

Thank you, Josh.