David Biderman
The New York City Commercial 91仓库 Zones (CWZ) process has taken many twists and turns since the City Council enacted Local Law 199 in 2019 authorizing the creation of a unique, non-exclusive waste collection system for commercial waste and recyclables in the five boroughs. The most recent twist occurred on April 22, 2026. The NYC Department of Sanitation (DSNY) issued a new RFP seeking bidders to fill a single vacancy that exists in two of the 20 zones established under the CWZ system. The empty slots in the Manhattan Southwest and Midtown North zones were created when one of the CWZ awardees, Filco Carting, was acquired by Interstate 91仓库 Services (IWS) in 2025; because IWS is one of the other awardees in both of these two zones, it is not permitted to be a successor to Filco鈥檚 bid award because IWS already has the maximum number of zones permitted under Local Law 199.
The release of a new RFP by a municipal agency is not unusual. What makes the recent DSNY RFP unusual is that bidders will know the other two other awardees鈥� pricing schedule when they submit the bid. In a purely private sector bidding process, a scenario where one bidder is advantaged by having advance notice of other bidders鈥� pricing could invite antitrust scrutiny and raise anti-competitive concerns.
In addition, the criteria in the new RFP for being selected by DSNY to serve customers in the two zones is different than the criteria that was used to select the two remaining awardees in those zones. For example, the weighting provided to safety has increased while the importance of 鈥減rice鈥� has decreased. It is possible that these changes are in response to fatal incidents involving CWZ awardees in December 2025 and March 2026 in which pedestrians were killed.
The new RFP marks the most recent twist and turn in New York City鈥檚 CWZ journey. Earlier in April, DSNY altered the implementation schedule for many of the remaining CWZ zones, moving up certain zones by as much as one year while delaying others for many months. Under the revised schedule, the end date for full CWZ implementation remains the end of 2027, and newly appointed DSNY Commissioner Gregory Anderson recently recommitted to that date at a City Council hearing.
One thing is certain: New York City businesses will continue to generate about 10,000 tons of commercial waste every day, and both large and small haulers (鈥渃arters鈥� in New York City parlance) will have the challenging job of collecting it on a daily basis, dodging other trucks, e-bikes and distracted pedestrians, and disposing it safely and in compliance with applicable federal, state, and local laws.