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Citizens Union


Recycling Before Exporting: Turning Garbage into Dollars

Amidst all of the turmoil accompanying the City's long overdue closure of its Fresh Kills Landfill, one bit of good news has been overshadowed: in late 1999, the City's diversion rate of recyclables - the most commonly accepted measure of recycling success - surpassed 21% of the City's residential waste. In three boroughs, over 25% of all garbage is now being recycled.

Local Law 19, requiring mandatory recycling, has come a long way since its passage ten years ago. Still a 21% diversion rate is but prelude to two significant challenges still facing the City. First, we must boost diversion rates even higher, so that the existing infrastructure for collecting and processing recyclables is being fully utilized. Second, the City should take maximum advantage of the economic value of what is collected and marketed - by attracting and developing local businesses that create jobs and economic activity.

It's worth noting that the City is exporting not only enormous quantities of residential and commercial trash - more than six million tons each year - but an increasingly large amount of cash, to national waste management and transportation companies, as well as communities that host landfills. Similarly, the bulk of the city's recyclables are also exported - to factories and mills located elsewhere in North America and in the world. These materials then create products that the City's businesses and residents turn around, import and buy.

So what can be done to boost recycling? Several things. First, improve collection of currently targeted materials. Much like the Police Department used ComStat as a tool to identify and target pockets of crime, the Department of Sanitation (DOS) has the data, but not the commitment or resources, to target poor-performing community districts. Returning to weekly collection has helped - nine districts now divert over 30% of their waste. But four districts still languish at 10% or below.

Second, expand the materials targeted for recycling. Look around the country. Other cities are targeting additional "discards" for which economic markets exist, or are developing. From residences, those materials include textiles (used clothing) and electronics; Seattle just added additional plastic containers, such as butter tubs and yogurt cups. Notwithstanding the City's failure to enforce existing commercial recycling rules, used commercial carpeting is on the cusp of being economically viable as a recyclable and should be so designated.

Third, expand recycling collection to public spaces - the last frontier. Currently, New York City Transit flaunts state and local law by refusing to collect recyclables throughout the subway system, and recycling containers should be included in the City's much-delayed plans for new street furniture.

Fourth, although more of a waste prevention initiative, food waste can now easily be eliminated from the City's residential garbage - through an aggressive program to install food waste disposers, i.e., garbage grinders, in residences. Although legal for over two years, disposers have not yet caught on in New York - in part because new housing construction is at historic lows. Yet, food waste is approximately 15% of the city's collected garbage - twice the national average. Reducing food waste also makes sense because it is largely water-based and generates vermin, odor, and methane gas problems at every stop along the way.

As to the economic development potential of recyclables, the City does have one flagship project: the development of the Visy Paper corrugated cardboard mill on Staten Island, which now consumes a good portion of our wastepaper. Unfortunately, the Visy mill is the exception that proves the rule. While New York is the "Saudi Arabia" of recyclables, it has failed to be creative and aggressive in capturing their value.

In fact, New York's enormous volume of wastepaper could supply several more urban-sized mills (for which at least one project is on the drawing board). Other cities are spurring and supporting businesses based on the recycling of tires, computers, carpets, wood, and other materials. Why isn't New York?

The problem isn't lack of studies; previous Sanitation and economic development czars have researched and advocated seizing this opportunity. We also don't lack models for programs; dozens of state and city-supported models exist elsewhere. Perhaps it's a matter of scale: when compared to Wall Street and Silicon Alley, recycling-related opportunities seem small. But for the City's dwindling manufacturing sector, and its residents who rely on those job opportunities, creating recycling-related jobs makes enormous good sense. After all, the raw materials already are here, as are the markets for the new products they can make!

As the debate sharpens over the City's management of solid waste for the coming decades, the opportunities for expanding and benefiting from recycling deserve serious consideration. In the face of estimates of $300 million or more annually in increased waste handling costs once Fresh Kills is closed, it makes no sense to continue unnecessary exports of trash - and hard-earned cash - to economies outside of our border, when they could much more beneficially be recycled and reused here.

Steve Hammer is Co-Chairperson, Citywide Recycling Advisory Board

Transfer Station Siting and Community Quality of Life: The Red Hook Story

In less than two years, Staten Island's Fresh Kills landfill, the last in New York City, will close. Creating an alternative system that will manage the post-Fresh Kills disposal of the 13,000 tons of residential garbage the City generates each day presents a tremendous opportunity to rationalize its solid waste management and create opportunity where now there are only problems.

Unfortunately, the Giuliani Administration has not taken advantage of the opportunities this transition offers. There has been no attempt to reduce the waste stream through aggressive recycling, nor to minimize the creation of neighborhood-disrupting new garbage facilities by converting to new uses the existing Marine Transfer Stations that will no longer have a purpose once Fresh Kills closes. Nor has there been any serious exploration of new waste management technologies which might, for instance, convert garbage to pollution reducing ethanol. Instead, the City has allowed a siting process to go forward that does not minimize community impacts, but rather shifts the burden of garbage management from Staten Island residents to poorer, minority neighborhoods in Brooklyn and the South Bronx.

For years, the City has ignored the law and refused to obey siting regulations designed to prevent this conflict producing opportunism. Even after losing in State courts on two occasions, there is still no genuine City compliance with either the specifics or intent of the law. As a result, garbage transfer stations, with their foul odors, noise and vermin, continue to be located next to parks, residences and churches in poor communities. In addition, the number of such facilities that can operate in a given area remains unrestricted.

I live in one of these communities, Red Hook, Brooklyn, which is now targeted for one of the largest waste facilities on the East Coast.

Red Hook is an old waterfront community with a rich, working class history. First settled by the Dutch in 1636, Red Hook was home to tide mills (mills which depended on the ebb and flow of the tide to turn the mill wheels) and later to ships and their support industries. By the Civil War, Red Hook was a thriving community of industrial and residential uses with a population of approximately 23,000. The factories and homes of the mid-19th century, are the housing stock and commercial/industrial spaces that exist today, which make Red Hook attractive for both residential and industrial uses.

Today, Red Hook is a one square mile peninsula, cut off from the rest of the City by the physical barrier of the Gowanus Elevated Expressway and the Brooklyn Battery tunnel, and isolated by the lack of subway service. Its current population is 12,000, with a median income of $10,500. Its residents are ninety percent African-American and Hispanic. Low income housing is 87% of the total housing stock. Red Hook already has five waste transfer stations, including a City municipal marine transfer station (MTS) with a capacity of 4800 tons of garbage per day. It is also the location for waste industry support facilities and other noxious uses such as an oil depot, chemical plants, impound lots, and bus depots (many of which are unpaved) The air shaft for the Brooklyn Battery Tunnel, through which 70,000 vehicles travel each day, vents into the neighborhood. A number of brownfields are a further burden on neighborhood quality of life. Industrial zoning that was foisted upon the community in 1961 has decimated neighborhoods and produced large tracts of vacant land that make the community a prime candidate when a site for a noxious use is needed.

In recent years, the Red Hook community has struggled to revitalize itself by getting rid of such noxious uses and by gaining access to its own waterfront, a hitherto undiscovered treasure and the one place from which the Statue of Liberty can be viewed face-on. A pier was recently renovated for public access and several waterfront esplanades have been opened. Red Hook also boasts New York's only working trolleys. Red Hook is a diamond in the rough. It has some of the most stunning waterfront in the region with its commanding views not only of Lady Liberty, but also of the Manhattan Skyline and New York Bay. It is home to the Civil War Era waterfront warehouses and it is less than 1000 feet from Governor's Island.

At a time of growing national consensus about the need to control sprawl, it is critical that communities such as Red Hook are redeveloped to their fullest potential. They can offer a quality of urban life that can compete with the lure of the suburbs. Not to recognize and foster this potential would be a profound failure of civic imagination, one that would present major issues of environmental justice as well.

Working in concert with other communities through The Organization of Waterfront Neighborhoods (OWN), major environmental groups and elected officials, the Red Hook Civic Association and the Red Hook community intends to see that this opportunity is not missed and the interests of the community, which are the interests of the City, shall prevail.

John McGutrick is a member of the Red Hook Civic Association

Solid Waste


Until the mid-1980s, New York City disposed of virtually all of its garbage locally: burying it in landfills or burning it in incinerators. Since then, with time running out local landfills and new incinerators rejected as environmentally unacceptable, New York has been transitioning to a system of exporting its garbage to distant, rural landfills. Virtually all of the City's commercial garbage, which is collected by private carters, is now exported. And a steadily increasing percentage (now over 50%) of the residential garbage collected by the Department of Sanitation is now being exported as well. By the end of 2001, when the City's last landfill, Staten Island's infamous Fresh Kills, closes, NYC will export 100% of its residential garbage.

Exporting garbage requires a new infrastructure facility: the transfer station, where collected garbage is consolidated and transferred to long distance trucks. There are now roughly 100 such facilities for commercial garbage citywide, and they are generally loathed by the residents of the industrially zoned neighborhoods like Greenpoint where they are concentrated. The closing of Fresh Kills will require an additional system of transfer stations for residential garbage.

In many ways, New York's solid waste management has had a very successful decade. Recycling is up, the cost of commercial waste disposal is down, incineration has been abandoned, Fresh Kills is on the way to being closed, and out of City landfills are accepting the City's garbage with a minimum of difficulty. The City has transitioned to an export system of garbage without the disposal crisis many predicted.

But the transfer station system works badly and faces ongoing attack. Unlike other integral components of the City's infrastructure, which at some fundamental level are accepted and accommodated, even after a decade transfer stations continue to be regarded as illegitimate temporary expedients. The problem is that New York has been unable to make its newest infrastructure system work except by allowing transfer stations to externalize their very high social, environmental and financial costs - costs that are disproportionately paid by working class and lower income communities.


Transfer stations handling commercial waste have brought to their local communities major odor, noise and traffic problems. They are frequently a major obstacle to community renewal efforts, while their concentration in lower income neighborhoods, often ones with large populations of people of color, is raising growing issues of environmental justice and fair share.

City and state solid waste planning and permitting processes have done little more than mitigate the worst transfer station impacts. Oversight agencies have been hobbled by their recognition that transfer stations have become an essential component of the City's infrastructure and by their resulting fears that aggressive regulatory enforcement would disrupt the outward flow of garbage. The governmental memory of New York's two garbage strikes and streets filled with rotting garbage remains vivid and frightening.


13,000 tons of commercial garbage now move through transfer stations each day. 15,000 tons more of residential garbage will have to go through transfer stations once Fresh Kills is closed in 2001.

To create this capacity while avoiding the perils of siting the new transfer facilities itself, New York City has issued a series of Requests for Proposals (RFPs) for private waste entities to ship specified amounts of garbage out of the City, with the understanding being that the private entity would either establish a new transfer station or expand an existing one.

Unfortunately, the problems associated with transfer stations, and the lack of confidence in government oversight of them, has spawned bitter local opposition to many of these private sector efforts. Two battles in particularly are currently energizing opposition to the transfer station system - one in Red Hook and the other at Hunts Point in the South Bronx.

These and other battles have divided neighborhoods and pitted borough against borough and New York against New Jersey. The resulting stalemates have forced the City into a series of short term contracts to directly truck waste across the river to New Jersey disposal sites and transfer stations, which has greatly increased the cost of solid waste disposal and garbage-related truck traffic.


The transfer station system evolved through individual ad hoc decisions, as private garbage collectors went into industrially zoned areas and set up on the cheapest, most immediately convenient sites. These operations were often undercapitalized and environmental concerns like odor control came last. Since this unpromising beginning in the late 80s, regulators have been playing catch-up, with marginal success.

Government's failures to solve the transfer station problem are rooted in two major fears. The first is the fear of regulators that aggressive enforcement could cause too many transfer stations to close, with unwelcome consequences for the smooth flow of garbage out of the City. And second, government has also feared that overly active enforcement role would leave it with the dread responsibility for siting transfer stations. Even having the unequivocal ability to prevent transfer station siting has been seen as something for government to avoid, for community opposition would almost certainly embroil sanitation and environmental agencies in an endless series of siting conflicts that governments perceive would be lose-lose choices that could similarly threaten smooth garbage export.

If government policy toward transfer stations is problematic, so too are community and civic efforts to reform transfer station management. First, many of these efforts have pursued essentially process strategies: better solid waste planning and regulatory enforcement, and genuine consideration of issues such as environmental justice and fair share. But after a decade of such efforts, the continuing persistence of transfer station problems demonstrates that process strategies alone cannot overcome the inherent governmental fears.

Second, advocacy efforts have generally had limited or single target goals: block a particular facility, improve recycling, address fair share, etc. But from a citywide perspective, even when such efforts succeed, they simply push the impacts elsewhere.

Third, advocates and critics of transfer station management have never developed a real systematic alternative to the existing system. Advocates also have political realities that dictate caution. They are wary of accepting involvement in site selection, or of being seen as an ambassador for ideas like consolidating residential and commercial garbage that could raise local fears that their neighborhood will wind up getting more garbage. And often, they lack the resources to do anything more than focus on the immediate crisis.

Yet the current folklore that transfer stations are an intrinsic evil needs a major reality check. Like it or not, transfer stations perform a critical environmental and infrastructure function. They are important sources of blue collar employment and light industrial activity, and are critical for preserving public health. The question therefore is not how to get rid of them, but where should they be sited, how should they be run, and what changes in current laws and practices are needed to bring civic peace and resolution to the issue.


So what will it take to create a viable transfer station system? The answer would probably include the following: 1) Obtain agreement on a policy goal of siting transfer stations where they will minimize both local and interstate truck traffic and maximize garbage movement by barge and rail; 2) Combine the currently separate commercial and residential garbage streams to minimize the need for transfer stations; 3) Understand the implications of those concerns for current siting controversies such as Red Hook and AMR in the South Bronx ; 4) Make transfer stations operate in an urban friendly manner; 5) Shut down existing substandard stations as new ones come on line; 6) Determine the role of recycling and waste reduction, and the role of marine transfer stations once they are no longer needed; 8) Lower the rapidly escalating costs of garbage handling; 9) Determine the right division of labor between public and private sectors and assess the current administration's privatization program. These questions should all be answered, and then of course, there remains the task of putting them all together and making the right solution work politically.


In recent months, some critical local stakeholders have realized that they must go beyond opposing proposed local transfer stations and work as well for an overall solution. Thus, spurred by the Red Hook Civic Association, the Organization of Waterfront Neighborhoods has proposed that the City consider conversion of its eight marine transfer stations (which are currently used to load garbage into barges for shipment to Fresh Kills) to waste transfer stations once Fresh Kills is closed.

This proposal is appealing because it avoids the complications and community costs of siting new facilities. It is far from a complete solution. Yet the willingness of community interests to recognize the need for an alternative presents a major opportunity to engage community interests in a process of a viable solution. But so far, government interests are responding to this opening in a vague and desultory manner.

Under State law, the City has to modify its solid waste plan to include its program for managing residential garbage post Fresh Kills. The long delayed Draft Environmental Impact Statement for such a plan is supposedly going to be issued by the New York City Department of Sanitation "soon." Since the plan modification must be approved by the City Council, advocates are looking towards using the plan amendment process to raise community concerns over transfer stations, citywide garbage truck traffic increases, and the rising costs of solid waste management. Many advocates see these hearings, if and when they occur, as a first step towards making transfer stations an issue in the 2001 mayoral election.

Third, though citywide civic groups have long been involved with solid waste, most of that involvement has been at the policy planning level or in promoting recycling. Issues of siting have largely been left to local community groups. Now two of the citywide civics, EDF and RPA are actively reaching out to community and environmental justice interests, seeking to forge a local-regional coalition that can put forth a credible alternative program to the existing jerrybuilt transfer station system.


Only two things seem certain at this time. The first is that the Fresh Kills landfill will close on schedule and the City will be exporting 100% of its solid waste by the end of 2001. Everything else - how it will be done, at what price and with what external impacts - seems up for grabs.

The second certainty is that the issue of solid waste and transfer stations will wind up in the 2001 mayoral race. If the advocates follow the course of the past, then the Mayoral campaign will hear a primal scream of "help us" and the candidates will respond with various pledges to feel your pain and make solid waste planning and regulation work better. There will be improvement at the margins but all the basic problems will remain. But if civic stakeholders can come up with a specific strategy, one that they can make a touchstone of solid waste concern that candidates can safely respond to, then the prospects for finally resolving the transfer station problem and replacing today's motley set of ad hoc facilities with modern, community friendly transfer stations will be greatly improved.


John McGutrick of the Red Hook Civic Association, is a major opponent of Waste Management Inc.'s proposed Red Hook transfer station and a strong force in the Organization of Waterfront Neighborhoods. Steve Hammer, Co-chair of the Citywide Recycling Advisory Board, writes about the role that recycling should play in lowering the pressures to create transfer stations.


New York City Department of Sanitation - Admired for their operational skill in doing an unattractive job, but without the kinds of planning and community relations skills needed to address the transfer station problem. Also responsible for enforcing transfer station compliance with local solid waste regulation.

New York State Department of Environmental Conservation - Oversees the state required solid waste plan development process municipalities are supposed to go through. DEC also grants permits for transfer stations and other solid waste facilities, and enforce state solid waste regulations. Given that the solid waste planning process is designed to insure garbage is disposed of without the external costs of New York's current transfer station system, most regard that as prima facie evidence of DEC failure to properly administer the solid waste planning process.

New York City Council - Must approve the solid waste plan and future amendments to it. The Council has been a strong and effective defender of recycling, but otherwise has yet to carve out for itself a substantial role in formulating solid waste policy.

Staten Island Borough President Guy Molinari - Has taken advantage of a Republican Governor and Mayor, and of the critical role he played in getting both elected, to insure Fresh Kills is closed on time and keep new waste facilities on Staten Island to a minimum.

Bronx Borough President Fernando Ferrer - A major actor in the Hunts Point AMR facility controversy and has been working to develop integrated areawide and citywide solutions to transfer station issues. A voice of reason on the need to recognize that transfer stations are needed and must be properly managed.

Neighbors Against Garbage (NAG) - Greenpoint, Williamsburg based group concerned with the clustering of transfer stations for commercial garbage in the northeastern Brooklyn.

New York Environmental Justice Alliance - Focuses on transfer stations, their siting and their concentration in neighborhoods of low income and color.

New York Lawyers for the Public Interest - Active in providing legal muscle on a number of transfer station issues, including the two leading current controversies, the Red Hook and Hunt's Point facilities.

The Point Community Development Corporation - The community organization in Hunts Point that has led the community opposition in Hunts Point to the AMR facility.

Environmental Defense Fund - Long time environmental force on New York issues thanks to its stalwart Counsel Jim Tripp, is now working actively with local communities on waste transfer issues. A major focus of the EDF effort is exploring combining management of the two main waste streams, commercial and residential garbage, to rationalize facility siting and minimize the number of stations needed.

The Regional Plan Association - Also involved in the issue, driven by waterfront and community renewal concerns. One RPA focus, reflecting its transportation interests, is using the rail system for solid waste export, to minimize truck traffic and help fund the proposed trans-Hudson rail tunnel. RPA is also working on minimizing transfer stations on the waterfront and replacing the current sprawling network of 100 plus transfer stations with a handful of modern facilities modeled on successful overseas best practices that could serve as nodes of local, light industrial redevelopment.

Inform - An environmental organization with a distinguished record in environmental education and analysis, is reportedly preparing a new planning analysis of the potential for local waste reduction.

Organization of Waterfront Neighborhoods - A citywide coalition of communities bordering the waterfront that are concerned with conditions of current transfer stations and threats to bring new ones into their communities.

Uprose - A Sunset Park based community organization that is not currently fighting any transfer specific new transfer station proposal but sees the Sunset Park waterfront as a prime target for future garbage management and is determined to head it off.

The Solid Waste Advisory Boards are a borough by borough system of citizen advisory oversight set up by the New York City Department of Sanitation.

The Citywide Recycling Advisory Board is a similar entity focusing on recycling. Currently preparing a Snuff Mill Manifesto on new opportunities for waste reduction and recycling.


In The News: Waterfront Primer

The City's waterways are a maritime crossroads for a varied group of users and uses. These can generally be divided into six categories: organizational, economic and commercial, historic, environmental, communal, recreational.

Organizational -- Though the City's political process is sure-footed on land, offshore, it is chaotic. Overlapping jurisdictions and uncertain responsibilities make waterfront politics murky at best. More than twenty different federal, regional, state and city agencies share responsibility for the harbor. Labor unions, and civic, recreational, environmental organizations and business also enter the mix. No one entity is in charge, because everyone is.

Economic and commercial Commerce was the harbor's raison d'Ætre, and NYC's pre-eminence owes greatly to maritime activity. New Amsterdam was established for its fine harbor and abundant supply of export furs. Industrial innovation included Fulton's steamship, the Erie Canal, the Brooklyn Bridge, and containerization established New York among the world's great port cities.

Since containerization and a move toward integrated water and land shipping, cargo ports have moved to the New Jersey side of the harbor where space and geography facilitate road and rail links. Today, New York's remaining shipping terminals -- Howland Hook in Staten Island and Red Hook and South Brooklyn Marine in Brooklyn -- vie with ferry terminals and tourist attractions for harbor related income.

Congressman Nadler's rail tunnel proposal is rooted in the Empire State's tradition of large industrial innovations. His plan would connect terminals throughout the harbor, and would link East of Hudson rail lines to rail networks nationwide. His vision is a modern variation of a 1927 Port Authority plan.

Historic -- Historic sites are scattered throughout the harbor. They include popular sites like Ellis Island and the Statue of Liberty and less well known sites like Castle Clinton at the Battery, Floyd Bennett Field in Brooklyn, Fort Schuyler at Throgs Neck, and New Jersey's Sandy Hook Lighthouse. At Fort Schuyler, hidden within the SUNY Maritime College campus, is a well-preserved example of early nineteenth century military architecture with an extraordinary view. And the 1764 Sandy Hook lighthouse was already old when its much better known cousin, the Little Red Lighthouse under the George Washington Bridge was built in 1920 on the Hudson River. Few buildings or landmarks in NYC or in the nation have seen as much history drift past.

Environmental -- These days, less bad stuff floats in the waters of New York harbor. The 1972 Clean Water Act eventually forced NYC to process and treat all of its solid waste. Other local area governments also complied. While wastewater treatment does not always happen satisfactorily, particularly after significant storm events, water quality improvements have been widely noted.

Law, in concert with the acts of individuals and advocacy groups, has pushed government agencies to improve area waters and shores. Successes include the restoration of salt marshes, increases in harbor heron and striped bass populations, and safer water at bathing beaches.

The struggle for environmental improvement in this heavily used metropolis continues. A recent decline in the western Long Island Sound lobster population is attributed to water quality. Combined sewer overflows still release untreated sewage during heavy rains. Piers are crumbling due to marine borer infestation, a condition caused by cleaner waters. Each wave of ecological progress unveils the need for further action.

Communal -- Throughout the harbor, communities, individuals and organizations fight for access to the water, seeking improvements to the quality of their shores and esplanades, opening boat clubs, and promoting environmental awareness. In the South Bronx, where half a million people currently have no access to their encircling shoreline; residents protest further municipal encroachment. These Hunts Point residents want a waterfront that includes greenways, and boating - not garbage transfer.

Community efforts lead to conflict as well as to access. A ban on spoils dumping restricts dredging options, which in turn threatens port-related jobs. Using the Bronx coast to move garbage facilitates the City's efforts to shut the sprawling dump at Fresh Kills. What Staten Island gains, Hunts Point loses. The political process uses the waters to transfer political pain along with garbage and sludge.

Recreational -- As recreational uses emerge, human-powered craft are returning to harbor waters. In 1999, Tribeca's Downtown Boathouse sponsored thousands of free Hudson River kayak trips. On the East River, local youth row specially designed Whitehall gigs built in NYC. Intercollegiate crew brings pomp and regalia to the waters of Pelham Bay.

Currently, Mayor Giuliani is seeking to bring minor league baseball to Staten Island's north shore and to Brooklyn's Coney Island, incorporating the waterfront as a key element of design and transport. The Mayor's mostly-dormant proposal to move the Yankees to Manhattan's west side assumed that ferries would be a major means of transport for fans. The proposed $200M sports center on Randalls' Island and the plans for 2012 Olympics in NYC both include water transport as an integral component.

Finally, NYC has dozens of waterside parks where people push strollers, jog, fish, and seek sunsets. Open space at the waterfront is a source of inspiration and freedom in a crowded city. The air is better and there is elbowroom. At water's edge, there are places to relax, explore and escape.

Peter Sounds Off:

Only in NYC could 578 miles of waterfront be both heavily underutilized and insufficient for all users. Despite this skewing of supply and demand, today's harbor has tremendous latent possibility. While the waterfront is not likely to regain its status as the main focus for jobs and economic activity, it could become the nexus for recreation, open space and improved quality of life.

A few points are essential:

1) The environmental improvement of recent years must be nurtured and extended. Investments in water quality must continue in all watersheds that drain to the harbor from the upper Hudson River to the open ocean.

2) Pioneering efforts that increase access should receive bureaucratic and financial support. Zoning should facilitate recreational access in manufacturing zones. Piers should be stabilized and opened to the public. Bulkheads should be made safe or repaired.

3) The City's youth should be educated about the waterfront and taught to swim. The swimming pool on a barge concept should be realized.

4) The waterways are now being shared by more and more users; each user must respect the rights of the others.

5) Ferry service should be expanded for tourism, recreational access and commutation. Ferries and other vessels should be subject to appropriate air pollution and wake guidelines.

Peter B. Fleischer, currently writing a book on the New York City waterfront, was formerly a transportation and environment policy advisor to New York City Mayors David Dinkins and Rudy Giuliani.

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