Citywide Comptroller / SBS · Small Business Forward Initiative · High
Comptroller's audit finds Small Business Forward cut $2.4M in fines but failed to deliver structural reform
Comptroller Mark Levine's audit of the Small Business Forward Initiative, released in early April and the subject of agency follow-up responses throughout May, found that the program reduced fines by $2.4 million across 35 regulations at five agencies, but did not produce the deeper structural compliance-cost reductions it was launched to deliver. Mayor Mamdani signed Executive Order 11 on January 14 extending the program into a third round.
The audit examined the 116 regulations reviewed for reform under the 2022 Adams-era Executive Order 2, of which 35 ultimately had fine schedules amended. Agency-by-agency, the largest percentage cuts came at DSNY (59 percent reduction in fine amounts) and DCWP (58 percent). DOHMH had the smallest percentage reduction at 18 percent but accounted for the largest absolute dollar impact, roughly $1.98 million in fine reductions across 18,710 summonses. FDNY produced a 4 percent reduction; DEP reported no summonses under the amended regulations during the review period.
The Comptroller's central finding is that the program never defined "small business" and never required agencies to report on whether the actual beneficiaries of the fine cuts were small businesses or larger entities subject to the same rules. The review recommends that the city designate a lead agency to coordinate progress, issue regular public reporting on small-business impact, and establish a formal protocol for monitoring outcomes. Most agencies indicated they would seek guidance from the Mayor's Office on the recommendations. FDNY disagreed and argued centralized responsibility should not fall on any single regulatory agency.
EO11, signed by Mamdani on January 14, extends the initiative for a third round and signals that fine-cutting will remain a central plank of the administration's small-business approach. The program's existing fine schedules at DSNY, DCWP, and DOHMH remain in force; whether the administration adopts the Comptroller's structural recommendations will shape the next round.
What it means for small businesses
The headline number ($2.4M cut) sounds substantial but represents roughly 12 percent of fines collected on the affected regulations. If you have a recent DSNY or DCWP citation, the post-reform fine schedule may apply and your actual exposure may be lower than the standard reference. Before paying any summons, look up the current fine schedule for that specific violation code. The reform applies only to the 35 amended regulations, so check whether yours is on the list.
Manhattan DSNY · Local Law 199 of 2019 · Critical
Lower Manhattan CWZ window: 21 days left as the final stretch begins
The Commercial Waste Zone enrollment window for Lower Manhattan, which opened April 1, is down to 21 days as of week's end. The window closes Sunday, May 31. Businesses without a signed contract by that date will be auto-assigned to one of the three zone-authorized carters at the maximum allowable rate published by DSNY. Based on the Queens Central experience, sign-ups concentrate in the final two weeks of any enrollment window.
DSNY Press Secretary Vincent Gragnani has cited the Phase 1 experience as the basis for the two-month transition design: in Queens Central, the majority of sign-ups occurred in the final two months of a four-month window. With Lower Manhattan compressed to two months total, that pattern projects sign-up volume to concentrate sharply between now and May 31. The three zone-authorized carters serving Lower Manhattan need to staff, route, and contract that volume in a compressed window.
Lower Manhattan CWZ covers Financial District, Civic Center, Battery Park City, Tribeca, Seaport, Governors Island, and Liberty Island. Per DSNY's published rate cap calculator, the maximum allowable monthly refuse rates run from approximately $35 to $90 per cubic yard depending on container type and pickup frequency. The negotiated rate spread against the cap typically runs 20 to 40 percent for businesses that solicit competitive quotes from all three authorized carters before signing.
Once a business is auto-assigned, the contract is binding for its full term and rate renegotiation generally does not reopen until term end. For a typical Lower Manhattan restaurant or retailer generating 8 to 15 yards per week, the difference between a negotiated rate and an auto-assigned maximum runs $200 to $600 per month. Over a three-year contract, that compounds to between $7,000 and $22,000.
Action this week
If you operate in any Lower Manhattan CWZ ZIP code (10002-10007, 10009, 10012-10014, 10038, 10280, 10282) and have not yet signed a contract, this is the week to get quotes from all three authorized carters. Use DSNY's Maximum Price Calculator at nyc.gov/dsny to benchmark the quotes you receive. Separated organics and recycling rates are required by law to be lower than refuse; a properly separated waste stream lowers your monthly bill below what a mixed stream would.
Brooklyn / Manhattan DSNY · CWZ Implementation Rule · Standard
DSNY files Brooklyn North and Upper Manhattan implementation rule, hearing scheduled May 8
The Department of Sanitation filed the formal proposed rule for the implementation schedule of the Brooklyn North and Upper Manhattan Commercial Waste Zones this week, with the public comment hearing scheduled for Friday, May 8. The two zones are now slated for a sign-up period beginning October 1, 2026, with full implementation by November 30, 2026. The announcement materially moves up Upper Manhattan from its earlier scheduled position later in the rollout.
Upper Manhattan was previously scheduled near the back of the 20-zone rollout. Moving it up to coincide with Brooklyn North accelerates the citywide implementation timeline. The shift was first reported in DSNY's mid-April scheduling adjustment, which also moved Queens West later (originally scheduled to launch April 1 alongside Lower Manhattan, Queens West was delayed for unspecified reasons but is now formally part of the same May 31 enrollment window as Lower Manhattan).
The May 8 public hearing is the formal comment period for the Brooklyn North / Upper Manhattan implementation dates. After the comment period closes, DSNY publishes the final adopted rule typically within 30 days. Businesses in those zones should begin tracking which carters have been awarded those contracts and what the published maximum rates will look like.
Brooklyn North covers Williamsburg, Greenpoint, Bushwick, Bedford-Stuyvesant, Fort Greene, Clinton Hill, Prospect Heights, and adjacent neighborhoods. Upper Manhattan covers Harlem, East Harlem, Washington Heights, and Inwood. Combined, the two zones contain roughly 8,000 to 10,000 commercial establishments that will transition to the CWZ system in Q4 2026.
Plan ahead
Businesses in Brooklyn North or Upper Manhattan have approximately five months before the October 1 sign-up window opens. The right preparation now: review your current waste contract for early-termination clauses, run a baseline of your weekly volume by stream (refuse, recycling, organics), and identify which of the three carters awarded to your zone aligns with your service hours and pickup needs. The carter list will be published in the final adopted rule.
Statewide NYS Senate · Packaging EPR (PRRIA) · High
PRRIA amendments now in Senate Environmental Conservation Committee, six weeks to passage
The Packaging Reduction and Recycling Infrastructure Act (S1464A / A1749), reintroduced April 30 by Senator Pete Harckham and Assembly Member Deborah Glick with roughly 150 amendments, has been formally referred to the Senate Environmental Conservation Committee. The Albany session adjourns June 17. The bill has approximately six weeks to clear committee in both houses, pass the floor in both, and reconcile any cross-house differences before sine die.
The amended bill retains the core structural framework: producers selling packaging in NYS with more than $5 million in annual net revenue and more than two tons of annual packaging waste would register with a Producer Responsibility Organization, pay fees calibrated to packaging type and weight, and the PRO would reimburse municipalities for recycling infrastructure. The reduction schedule scales with producer tenure: 10 percent reduction in three years, 30 percent in twelve. Plastic recycling rate targets reach 25 percent by 2030 and 75 percent by 2055.
Industry response remains split. The Flexible Packaging Association and the American Chemistry Council oppose the amended version, citing restrictions on chemical recycling and provisions on flexible packaging. A competing bill from Senator Monica Martinez (the Affordable Waste Reduction Act, S5062) has industry backing but remains in committee. Assembly Speaker Carl Heastie has signaled that PRRIA will receive a floor vote before session adjourns; the floor vote is the key procedural hurdle the bill has not cleared in either of the prior two sessions.
If enacted, New York would become the eighth state with a packaging EPR law, joining Maine, Oregon, Colorado, California, Minnesota, Maryland, and Washington. A Siena College poll cited by the bill's sponsors shows 73 percent of New York voters supporting the legislation. Beyond Plastics, the bill's primary advocacy organization, projects $1.3 billion in taxpayer savings over a decade if the bill passes.
For NYC businesses
Most NYC small businesses are not direct producers and would experience PRRIA indirectly through cost-of-goods inflation if producer fees flow through to wholesale pricing. The exposure category to watch: any business with private-label packaging (own-brand drinks, custom takeout containers, branded retail bags) above the two-ton threshold. If you sell anything packaged under your own brand at meaningful volume, monitor the threshold language and the definition of "producer" in the final bill text before assuming you are exempt.