Land Use Policy 1995 12 (1) 29-36

Political conflict over waste-to-energy schemes

The case of incineration in New York

Matthew Gandy

The incineration of municipal waste has emerged as one of the fastest-growing non-fossil-fuel sources of energy in developed economies. This alternative source of energy has been actively promoted by a range of Interest groups, yet there remains a high level of political opposlUon to inclneratlon. This paper illustrates the diversity and complexity of political opposition to waste incineration, using the example of New York. It is concluded that the development of waste incineration involves increasing socioeconomic polarization at different spatial scales and is better conceived as a response to the problems of municipal waste management than an integral component of a sustainable energy policy.

developments in energy and waste management policy and trace some broader issues not specific to New York.

W a s t e i n c i n e r a t i o n as a r e n e w a b l e e n e r g y source
The contribution of waste incineration to the disposal of municipal solid waste in developed economies has been rising steadily over the last 10 years, and the promotion of waste incineration is now widely portrayed as the only realistic alternative to dwindling landfill opportunities. 5 Not only is incineration increasingly presented as the most cost-effective approach to waste disposal but it is also being put forward as a source of renewable energy integral to a sustainable energy policy. In the U K context, for example, some 58% of the renewable energy capacity supported by the Non-Fossil Fuel Obligation levy is derived from waste incineration plants. This dwarfs the contribution from all other sources of renewable energy combined (hydropower, landfill gas, sewage gas and wind power). 6 The environmental case for waste incineration can also be illustrated by the 1992 Waste Management Plan drawn up by the New York City Department of Sanitation, where incineration is clearly advocated as environmentally preferable to the landfill of waste: Landfilling waste produces 12 times more greenhouse gases than converting waste to energy that would otherwise be generated by burning coal (the major source of electricity in the U S ) . . . In New York City where the fuel displaced would more likely be oil, which produces about 83% as much carbon dioxide as coal, converting waste to energy would produce about 1/5 the greenhouse gases as iandfilling with 50% methane recovery.7

Much of the existing literature on incineration and energy from waste schemes has tended to focus on the technical and economic appraisal of different policy options, rather than on the place of these waste management developments within wider and often highly contested developments in public policy, such as the attempt to promote environmental sustainability in urban areas I or the impact of neoliberal fiscal austerity on urban governance. 2 Much of the literature which does examine the political aspects of the waste incineration debate comes from the mainstream environmentalist literature, with few linkages made to other research in the social sciences. 3 In this paper I have sought to highlight some of the political dimensions to the waste incineration debate through the example of public opposition to the proposed Brooklyn Navy Yard incineration plant in New York City. 4 Although the approach of this paper is primarily empirical, I will in the concluding sections outline some possible avenues for more theoretically inclined analysis of

The author is Lecturer in Geography, School of European Studies, University of Sussex, Falmer, Brighton, BN1 9QN, UK (Tel: 0273 606755; fax: 0273 623246).

0264-8377/95/010029-08 1995 Butterworth-Heinemann Ltd

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Political conflict over waste-to-energy schemes: M Gandy

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Development of incineration in New York

By the early 1980s New York City found itself increasingly reliant on just one landfill site, the enormous Fresh Kills site on Staten Island, for disposing of over 70% of its municipal waste stream, as shown as Figure 1. 8 This highly restricted pattern of waste disposal can be compared with a variety of past waste disposal options, which once included ocean dumping, a variety of comprehensive recycling initiatives, over 80 landfill sites {,in the early 1930s) and some 22 incineration plants/Three main developments account for this contraction in available waste disposal facilities over the post-war period. First, there have been the increasingly restrictive environmental regulations, marked by the ending of ocean dumping following court action against the city by the neighbouring state of New Jersey in the 1930s and in the 1970s, and increasingly stringent federal controls on the use of incineration and landfill, to tackle the chronic pollution of water courses and poor air quality in US cities. Second, there has been a progressive exhaustion of landfill capacity in and around the city, and there is limited potential for land reclamation in coastal and riparian areas because of environmental protection of wetland habitats for wildlife. The possibilities for the landfill of municipally collected wastes outside New York City are now severely restricted, forcing the city's Department of Sanitation to find waste disposal opportunities within the city boundaries. 1 Finally, there have been a set of interrelated

socioeconomic changes associated with the rise of mass consumption (and the rapid growth of the municipal waste stream), escalating labour costs in waste management, declining markets for recycled materials and a severe fiscal crisis facing New York City in the 1970s, forcing a re-evaluation of urban policy towards greater fiscal austerity and closer partnership between the private and public sectors, li The problem facing New York is that the Fresh Kills landfill site is approaching full capacity, with estimates of its closure date varying from 2003 to as late as 2011, depending on whether there are restrictions imposed on the out-of-state haulage of commercial waste from the city by private waste haulers. 12 Since the mid-1980s there has been greater usage of the Fresh Kills site for the disposal of commercial wastes in response to increasing tipping fees for these kinds of waste in New Jersey and Long Island.13 It is the imminent exhaustion of the Fresh Kills landfill site which has refocused attention on the expansion of waste incineration, currently restricted to three small outmoded plants and numerous apartment house incinerators. Recent efforts to expand incineration date from the early 1970s Lindsay administration's proposed 'super incinerator' to be based at the Brooklyn Navy Yard site, but this project was abandoned in the face of the city's 1975 fiscal crisis along with a range of other capital construction projects. 14 The earliest example of incineration with the production of electricity in the city can be traced to 1905, with the construction of a plant which provided the lighting for the East River Bridge and other local highways. 15 In the 1930s the newly organized Department of Sanitation began building new incinerator plants in order to meet the shortfall in waste disposal capacity from the exhaustion of landfill sites and the growing political restrictions on ocean dumping. By the late 1930s the LaGuardia administration had built two incinerators equipped with turbine generators for the production of electricity, but the New York Edison Company refused to buy it, making incineration economically unattractive in comparison with cheaper waste disposal by landfill. 16 However, the OPEC oil price rises of the 1970s and the perceived threat of energy shortages to US economic prosperity brought about an important shift in the legislative framework for energy policy. In the late 1970s President Carter introduced measures to subsidize non-fossil fuel sources of energy and developed legislation requiring for the first time that utilities must purchase energy produced from alternative sources. 17 This shift in energy policy received strong backing from packaging manufacturers, retailers, investment bankers and power plant construction firms. These interest groups were nervous about materials recycling and waste reduction emerging as the main alternative to landfill as a

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Political conflict over waste-to-energy schemes: M Gandy

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waste management such as sewage sludge and medical wastes. Public participation also involved funds for the employment of independent consultants for the Bronx and Manhattan SWABs (the Queens College Centre for the Biology of Natural Systems and Resource Recycling Systems Inc of Ann Arbor, Michigan). The new plant will have four separate furnaces and a 500-ft high stack making it the largest incinerator in New York State, handling 3000 tonnes of waste a day, equivalent to some 15% of the wastes collected by the city. w

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Political conflict over the proposed Brooklyn plant

Some indication of the degree of opposition to the proposed incineration plant at the Brooklyn Navy Yard site can be illustrated by the range of groups who lodged objections to the city's waste management proposals during the period of public consultation in 1992. The diversity of opinion is reflected in the opposition of groups such as the Clinton HillFort Greene Coalition for Clean Air, the Consumer Policy Institute, the Environmental Action Coalition, the Lower East Side Coalition for a Healthy Environment (with backing from the United Jewish Council and the Physicians for Social Responsibility), the League of Women Voters and many others. 2 These groups represent the interests of the scientific and medical establishment, various residents' and tenants' associations, women's groups, environmentalists and grassroots political activists, and reveal a similarity to other anti-incineration campaigns elsewhere in the USA and Western Europe where waste management issues have been extensively politicized. 21 An examination of the objections to the Brooklyn plant reveals a range of specific concerns around which this broad coalition of different interest groups has been mobilized, focused principally on the interrelated issues of public health and environmental protection. The most vociferous opposition has come from organizations representing people living in close proximity to the proposed plant. There is local opposition in New York to the presence of any waste management facilities, even garages and depots, because of the likely impact on property prices, and this has tended to reinforce the trend for the location of unwanted facilities in sparsely populated industrial or blighted areas, often in low-income parts of the city such as East Harlem or the Bronx. 2 2 This pattern of the poorer areas of New York being disproportionately affected by locally unwanted land uses will be perpetuated through the proposed incineration plant, since some 69% of people living within 4 km of the Brooklyn Navy Yard site are classified as belonging to minority groups in the 1990 census. 23 An important issue for mobilizing public concern

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Figure 2. New York City's municipal incinerators (existing and proposed), Sources: Natural Resources Defense Council and City of New York Department of Sanitation,

result of the politicization of waste issues in the 1970s and the passing of mandatory recycling and returnable container legislation in a number of US states, notably in Oregon and Vermont. Support for the construction of new incineration plants now includes many firms formerly involved in the nuclear industry, who now find themselves with excess turbine manufacturing capacity because no new nuclear energy plants have been ordered in the USA since the Three Mile Island accident in 1979.18 In 1978 Mayor Ed Koch proposed the construction of the first of a new generation of incineration plants at the Brooklyn Navy Yard site shown in Figure 2. By 1985 an Environmental Impact Statement had been completed and although the plant is due to begin construction in 1996, uncertainty remains through the protracted planning and public consultation process. In particular, the issuing of a permit by the State Department of Environmental Conservation to allow construction to proceed has been delayed by a protracted legal challenge by private citizens coordinated by the anti-incineration environmental group NYPIRG (New York Public Interest Research Group). The city's 1992 waste management plan, with the Brooklyn plant as its key proposal, was drawn up after extensive public debate, involving formal consultation over the Environmental Impact Statement with the Citizens' Solid Waste Advisory Boards (SWABs) in each of the five boroughs and the City-wide Recycling Advisory Board (CRAB), along with a variety of other committees concerned with further aspects of

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Table 1. Projected air pollution emissions from the proposed Brooklyn Navy Yard incineration plant. Pollutant Nitrogen dioxide Sulphur dioxide Hydrogen chloride Carbon monoxide Particulates Sulphuric acid Non-methane hydrocarbons Zinc Formaldehyde Lead Mercury Tons per year 2 972 1 189 537 368 161 92 66 28 27 15 5

Other pollutants: cadmium; chromium; copper; nickel; arsenic; selenium; beryllium; flouride; polyaromatic hydrocarbons; polychlorinated biphenyls; polychlorinated dibenzo-p-dioxins; polychlorinated dibenzo furans; tetrachlorinated dibenzo-p-dioxin; and 2,3,7,8-TCDD.
Sources: Natural Resources Defense Council and City of New York

Department of Sanitation.

is the fear that large-scale incineration in New York City will worsen an already serious air quality problem, as suggested by data on projected emissions shown in Table 1. For example, the emission of chlorine-containing compounds such as dioxins is at the centre of epidemiological disputes about the possible effects on pregnant women, z4 Other pollutants include heavy metals and especially the projected release of some 15 tons of lead a year. Existing lead levels in New York are already a cause for concern: some 29% of 4974 children screened in the summer of 1991 had blood lead levels exceeding the official 1978 standard of no more than 30 ixg/dL in children. 25 Furthermore, there has been controversy over the City Law Department's attempt to block the construction of an incinerator in neighbouring New Jersey on the ground that emissions pose a health threat to New York, contradicting incinerator safety claims made for the Brooklyn Navy Yard project by the city's Department of Sanitation. 26 An important reason for the delay in construction of the plant is uncertainty over the disposal of residual ash from the incineration process, constituting as much as 15% of the volume of the original wastes delivered to the plant. The lack of any satisfactory arrangements for the disposal of over 900 tons a day of residual ash from the proposed plant led to the refusal of a construction permit for the Navy Yard plant by New York State's Commissioner from the Department of Environmental Conservation in November 1988. 27 A 1987 survey by the Department of Environmental Conservation found that levels of lead and cadmium in ash from six existing incinerators exceeded federal guidelines and rendered the ash hazardous waste. 28 There is also continuing uncertainty surrounding the cost of a major expansion of incineration. Studies commissioned by environmentalist groups have suggested that the operation of the plant may be more expen-

sive than anticipated because of debt servicing, technical difficulties, fluctuations in the revenue gained from power generation, and the cost implications of disposing of incinerator ash as hazardous waste. 29 The city's Office of the Comptroller has also taken up the environmentalist view that emissions from the proposed plant have the potential to contribute to acid precipitation and global warming through the release of carbon dioxide, nitrogen dioxide, sulphur dioxide and other pollutants, despite any reduction in methane emissions from the use of landfill sites. New York City is particularly vulnerable to global warming through the disruption of drinking water supplies by algal blooms in upstate reservoirs and salt water incursion of the River Hudson, in addition to the potential impact of higher sea levels and greater storm intensity on low-lying parts of the city. 3 Environmentalist groups have also opposed the expansion of incineration on the grounds that this will undermine the impetus for recycling and waste reduction in the city. 3~ This is significant because under the Solid Waste Management Act passed by the state legislature in 1988 there is a state-wide recycling target of between 40% and 42% for municipal waste. By September 1993 all 59 of New York's Community Districts were integrated into a comprehensive mandatory recycling programme reaching a recycling rate of around 14%, which compares favourably with the extent of recycling in other large metropolitan areas in developed economies. 32 The expansion of incineration will also have implications for the generation of low-skill employment within the city. Incineration is capital intensive whereas comprehensive recycling and waste reduction schemes are labour intensive and have the potential to help redress the serious imbalance between the city's labour market and available employment opportunities Between 1963 and 1992 employment in New York City's industrial sector declined by around 900 000 jobs, with most of these losses concentrated in manufacturing, while the three fastest-growing sectors of the New York economy have been consumer services, FIRE (finance, insurance and real estate) and government. 33 This has led to what is described as a 'dual city' split between an increasingly specialized high-skill economy and an army of poorly qualified and casually employed people drawn mainly from ethnic minorities and other disadvantaged groups. 34 Despite these wide-ranging objections, the proposed Brooklyn Navy Yard plan has not been without supporters in the city. The New York Chamber of Commerce and Industry has supported the shift to incineration on the premise that cheaper waste disposal and energy costs are vital for business. 35 Opponents of the Brooklyn plant have indicated that the city will itself bear the costs of capital construc

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tion, but unlike similar projects in the 1970s and earlier the plant will be the first major solid waste management facility in the city to be financed by the private sector. The civil engineering group Wheelabrator will design, construct, own and operate the plant under a service agreement with the city, and will finance the project through industrial development bonds and corporate equity. Under the service agreement Wheelabrator will provide several guarantees to the city including credit support, a project completion agreement and a cash deficiency agreement, so that the development of the project requires minimal financial risk to the city, which will also share in the revenue from the energy sales with Wheelabrator and the main purchaser of the energy, the city's electricity utility Con Edison. Other sources of support for the Brooklyn incineration plant have included the retail sector represented by the Grocery Industry Committee on Solid Waste, who fear that any expansion in recycling would involve handling increased quantities of returnable containers through an extension in the scope of New York State's Returnable Container Law, in force since 1983. The city's Department of Sanitation has also tried to respond to criticisms of incineration by putting the health and environmental risks in a wider perspective. For example, a survey of environmental pollution in the New York-New Jersey region by the US Environmental Protection Agency found that municipal waste incinerators rank as a very low risk in comparison with the medium risk posed by landfill sites and the very high risk from motor vehicle exhaust fumes. 36 The projected lead emissions from the proposed Brooklyn Navy Yard plant of some 15 tons a year have been singled out as a threat to children's health, yet on one calculation the energy generated by the plant will displace 1 million barrels of oil a year used by Con Edison, which would emit some seven times more lead for an equivalent generation of energy. 37 The projected emissions shown in Table 1 also represent a 'worst-case scenario' as set out in the 1985 Final Environmental Impact Statement, and in the 1992 Waste Management Plan the city has provided more recent emissions data from similar plants in operation elsewhere in the USA to allay public fears. In 1992 the Dinkins administration confirmed that it would proceed with the major new incineration plant at the Brooklyn Navy Yard site, despite having been elected on a pro-recycling environmental ticket with support from the Sierra Club and Brooklynbased community groups. 38 The Department of Sanitation argues that new incineration technologies are safe, that incineration reduces the volume of waste thereby significantly extending the life span of the Fresh Kills landfill site, and that burning waste is cheaper than a complete reliance on recycling and waste reduction.

The politics of waste incineration

The example of political conflict over incineration in New York suggests that there are a number of substantive issues being contested by a wide range of different interest groups: the protection of public health; the threat to property prices; the preservation of local environmental amenity; concern over the long-term cost of incineration in relation to other waste management options; the employment implications of capital-intensive waste management; the potential contribution of incineration emissions and ash disposal to regional and global environmental problems; and finally, the characterization of incineration as an 'end-of-pipe' technological fix for the problem of waste disposal which effectively undermines the impetus for higher levels of recycling and waste reduction. In terms of classifying the different interest groups, we can distinguish between those groups operating primarily in Brooklyn, opposed to the local impact of an incineration plant, and those sources of opposition of a more strategic city-wide level, introducing the arguments over employment generation and the broader environmental implications. We can also identify a greater emphasis by environmentalist groups on the conservation of resources through recycling activity than on the contribution of energy-from-waste schemes to different sources of electricity generation in the city. Given the variety of different arguments and interest groups, it might seem logical to apply a pluralist analytical framework highlighting the competing conceptions of waste management policy. 39 Indeed on first examination there does appear to be an absence of any underlying conflicts amenable to more structuralist or neo-Marxist informed interpretations, identifying class-based interests or underlying economic forces, for example. 4 However, the role of waste incinceration in enhancing socioeconomic polarization can be detected at three spatial scales: the local level in terms of the disproportionate environmental impact on women and on disadvantaged and minority groups resident in areas in proximity to incineration plants; the regional or city-wide level in terms of the loss of potential low-skill employment in the secondary materials and waste reduction sectors of the economy, well suited to rebuilding the manufacturing base of the urban economy; and finally, at a global level in terms of the implicit endorsement of current patterns of production and consumption and all that this implies in terms of the perpetuation of inequitable patterns of usage for energy and resources. A further issue for consideration is how the local state has been able to promote recycling and waste reduction strategies that are not conducive to the interests of the private sector packaging, retail and incineration sectors, perhaps illustrating some degree of state autonomy from the exigencies of the

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Political conflict over waste-to-energy schemes: M Gandy

market in the field of environmental policy. The degree of relative autonomy for the state from the needs of capital is relevant to the analysis of the diversity of policy developments under ostensibly similar capitalist economies. The theory of state autonomy is developed by Eric Nordlinger, who identifies a specific kind of autonomy where the state adopts a particular set of policies which diverge from those favoured in civil society. 41 In the case of the Brooklyn Navy Yard plant the failure by the state to proceed with the construction of new incineration capacity could arguably have only two outcomes: first, a breakdown in the city's waste management system after the exhaustion of the Fresh Kills landfill, with frightening consequences for the maintenance of public health and efficient service delivery as illustrated by the impact of the 1979 tugboat strike on waste management operations; and second, a need for a fundamental challenge to the processes leading the growth of the municipal waste stream over the post-war period, such as the proliferation of packaging and the nature of economic production under late capitalism. The difficulty with applying Nordlinger's distinction between the state and civil society in the study of waste and energy policy is that the influences on the decision-making process within the state itself are n o t clearly incorporated into his analytical framework, suggesting that in the analysis of environmental policy we need to develop a more subtle appreciation of the linkages between the state and society and also a clearer recognition of the diverse nature of the state itself through its multifarious functions. In the case of New York we can identify conflicts of interest between specific interest groups within the state, exemplified by the reports issued by the City of New York Office of the Comptroller which question the rationale for the expansion of incineration favoured by the Department of Sanitation. In other words, the role of the state is not necessarily as a unitary actor in the field of environmental policy. 42 Conversely, one might argue that recycling activity is a legitimation strategy in order to allow the state to proceed with other unpopular waste management strategies such as incineration under the guise of an integrated approach to environmental policy, thereby reintroducing the notion of unitary state activity at a more distant level than internal conflicts between different departments in the City of New York. 43 A useful area for further study would be the analysis of the evolving relationship between the waste management industry and urban government, to determine how fiscal austerity has contributed towards the diminished autonomy of the state in the field of waste management and also towards the setting of the policy agenda through the effective exclusion of more radical policies aimed at waste

reduction through changes in the production process. Equally, while there is a good literature on how municipal government increased its role in waste management since the 19th century, the opposite process of 'demunicipalization' in this area of local government services is much less widely analysed despite the important implications for environmental policy making.

Conclusion
The promotion of waste-to-energy schemes as a form of renewable energy should be treated with scepticism if the goal of energy and waste management policy is to address both environmental degradation and also social inequalities as part of any wider programme to operationalize that elusive concept of sustainable development. Although waste incineration is widely portrayed as a renewable source of energy by its proponents, it is more useful to conceive of incineration as the main alternative to landfill for the disposal of municipal waste. It is against a background of increasing expense and scarcity of suitable landfill sites in proximity to urban centres that the contribution of incineration towards municipal waste management has been growing. The politicization of waste management issues, as illustrated in the case of New York, can be seen as widening public recognition of the conflict between different social, environmental and economic objectives, in an area of public policy where decision making has been traditionally relegated to the narrowly technical public health needs of waste disposal by municipal government.

Acknowledgements
Firstly, I am grateful to the Nuffield Foundation for funding my research in the summer of 1993. I would also like to acknowledge the helpful comments by Gordon Walker on an earlier version of this paper given to the Institute of British Geographers annual conference held at the University of Nottingham in 1994. The data collection would not have been possible without the assistance of staff in the City of New York Department of Sanitation, the Environmental Action Coalition and the New York City municipal archives. Finally, thanks to Susan Rowland at the University of Sussex for assistance with the preparation of the illustrations.

References
1A variety of studies and reports have begun to appear, which
seek to address policy making for the urban environment as an

integrated whole. Examples include Elkin, T, and McLaren, D Reviving the City: Towards Sustainable Urban Development Policy Studies Institute/Friends of the Earth, London (1991); and Girardet, H The Gaia Atlas of Cities: New Directions for Sustainable Urban Living Gala Books, London (1993).

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2See, for example, Cochrane, A Whatever Happened to Local Government? Open University Press, London (1993); and Harvey, D 'From managerialism to entrepreneurialism: the transformation of urban governance in late capitalism' Geografiska Annaler 1989 71 3-17. 3See Institut fur 6kologisches Recycling Okologische Abfallwirtschaft: Umweltvorsage durch Abfallvermeidung If6R, Berlin (1989); Spill, E and Wingert, E (ed) Brennpunkt MOll Sternbuch, Hamburg (1990); and Newsday Rush to Burn: Solving America's Garbage Crisis Island Press, Washington, DC (1989). 4The material presented in this paper involved the analysis of a variety of official documents and archival material complemented by interviews with staff in the City of New York Department of Sanitation and the Environmental Action Coalition, New York. 5See UK Royal Commission on Environmental Pollution Incineration of Waste HMSO, London (1993). 6UK Department of Trade and Industry Renewable Energy Bulletin No 5 (October 1993) 7City of New York Department of Sanitation A Comprehensive Solid Waste Management Plan for New York City and Final Generic Environmental Impact Statement (August 1992). The data sources quoted in the waste management plan are Taylor, F and Hunter, P E 'Comparison of potential greenhouse gas emissions from disposal of municipal solid waste in sanitary landfills vs waste-to-energy facilities' Paper delivered to US Environmental Protection Agency/AWMA Second Annual InternationahSpeciality Conference 15-19 April 1991; Martin, G and Pippin, A 'United States emissions of carbon dioxide to the Earth's atmosphere by economic activity' Energy Systems and Policy 14 319-336. 8Goldstein, E A and Izeman, M A The New York Environment Book Natural Resources Defense Council, Island Press, Washington, DC (1990). A recent study commissioned by the Department of Sanitation estimates that the city produces 24 100 tons per day of municipal solid waste, including household, commercial and institutional wastes, but excluding medical wastes, construction wastes and sewage sludge: Tellus Institute A Statistical Profile of New York City of Solid Waste Management Planning (1991 ). 9City of New York Department of Sanitation The Waste Disposal Problem in New York City: A Proposal for Action New York (1984) 1De Kadt, M and Lilienthal, N Solid Waste Management: The Garbage Challenge for New York City Inform, New York (1989) l~Gandy, M Recycling and the Politics of Urban Waste St Martin's Press, New York, and Earthscan, London (1994) 12Goldstein, E A and Izeman, M A The New York Environment Book Natural Resources Defense Council, Island Press, Washington, DC (1990) ~3Davis, R and Meier, B 'Will it go up in smoke? The New York experience' in Newsday Rush to Bum: Solving America's Garbage Crisis Island Press, Washington, DC (1989) 140-150 ~4See, for example, Shelter, M Political Crisis~Fiscal Crisis Basic Books, New York (1985); Bailey, R W The Crisis Regime - the New York City Financial Crisis State University of New York Press, Albany, NY (1984); and Fitch, R The Assassination of New York Verso, London (1994). 15Soper, George A Modern Methods of Street Cleaning Constable, London (1909) 161-162 ~SGoodrich, Ernest P 'The opportunities for refuse salvage in New York City' American City February 1935, 58 17The key piece of federal legislation is the Public Utilities Regulatory Policy Act introduced by the Carter administration in 1978. 18'Norman Steisel and the art of the done deal' Village Voice 26 November 1991, 37; 'World nuclear industry' Financial Times survey, 17 November 1993 19Gotdstein and Izeman op cit Ref 12; telephone interview with Jennifer Stevens, policy analyst in the City of New York Office of the Comptroller (19 June 1994) 2City of New York Department of Sanitation Public Comments on a Comprehensive Solid Waste Management Plan for New York City and Draft Generic Environmental Impact Statement

(June 1992) 21The example of Hamburg is discussed in Gandy op cit Ref 11. 22Interview with Patricia Grayson of the Bureau of Waste Prevention, Reuse and Recycling in the New York City Department of Sanitation (26 August 1993) 23The minority category includes those not describing themselves as 'white, non-Hispanic' in the 1990 Census. The calculation of the percentage minority population living within 4 km of the proposed site is taken from City of New York Office of the Comptroller Smokescreen: How the Department of Sanitation's Solid Waste Plan and Environmental Impact Statement Cover Up the Poisonous Health Effects of Burning Garbage (1992). 24See, for example, Women's Environmental Network Dioxin: A Briefing Women's Environmental Network, London (1989). Public concern over dioxins has also been stimulated by scientific papers such as Beychok, M 'A data base of dioxin and furan emissions from municipal refuse incinerators' Atmospheric Environment 1987 21 29-36. 25City of New York Office of the Comptroller Bum, Baby, Bum: How to Dispose of Garbage by Polluting Land, Sea and Air at Enormous Cost (January 1992); City of New York Office of the Comptroller op cit Ref 23 26City of New York Office of the Comptroller A Tale of Two Incerators: How New York City Opposes Incineration in New Jersey While Supporting It at Home (May 1992) 27Davis and Meier op cit Ref 13 28New York State Department of Environmental Conservation, Division of Solid and Hazardous Waste Ash Residue Characterization Report (July 1987) 29City of New York Office of the Comptroller op cit Ref 25; Environmental Defense Fund To Bum or Not to Burn: The Economic Advantages of Recycling over Garbage Incineration for New York City EDF, New York (1985); New York Public Interest Research Group A Fiscal Analysis of the City of New York's Solio Waste Management Programs and the Proposed Brooklyn Navy Yard Incinerator NYPIRG, New York (1992) 3City of New York Office of the Comptroller Fire and Ice: How Garbage Incineration Contributes to Global Warming (March 1993) 31See, for example, the statement of Eric A Goldstein on behalf of the Natural Resources Defense Council before the New York City Council Environmental Protection Committee concerning New York City's Solid Waste Management Plan (25 August 1992). 32For a fuller account of recycling activities in New York, see Chapter 4 in Gandy op cit Ref 11. 33City of New York Office of the Comptroller The Trash is Always Greener on the Other Side: A Plan to Keep Recycling Jobs on the New York City Side of the Hudson (August 1993) 34Sassen, Saskia The Global City: New York, London, Tokyo Princeton University Press, Princeton (1991) 3sCity of New York Department of Sanitation op cit Ref 20 36US Environment Protection Agency Risk Ranking Work Group, Region II Overview Report: Comparative Risk Ranking of the Health, Ecological and Welfare Effects of Twenty-Seven Environmental Problem Areas in Region II EPA, Washington, DC (1991) 37City of New York Department of Sanitation op cit Ref 20 38See, for example, 'Dinkins burning for incinerator' New York Newsday 26 August 1992; and 'Full steam ahead for garbage plan' New York Newsday 27 August 1992. 39The pluralist approach to policy analysis is typified by writers such as Robert Dahl, Daniel Bell and Nelson Poulsby. The idea of policy as the outcome of various competing interest groups retains a strong influence in sections of the environmental movement and is also associated with teleological conceptions of a shift to a post-industrial society. For further details of these debates, see Frankel, B The Post-Industrial Utopians Polity Press, Cambridge, UK (1987); and Weston, J Red and Green Pluto Press, London (1986). 4A good example of environmental research tracing the analytical limits to pluralist approaches through the introduction of structural economic factors is Andrew Blowers' study of the Bedfordshire brick-making industry: Blowers, A Something in the

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Air: Corporate Power and the Environment Harper & Row, London (1984). "lNordlinger, E A On the Autonomy of the Democratic State Harvard University Press, Cambridge, MA (1981) "2For an overview of the role of the state in public policy see Ham, C and Hill, M The Policy Process in the Modern Capitalist State

Harvester Wheatsheaf, Hemel Hempstead, UK (1993). 43The theory of legitimation is especially associated with the work of J0rgen Habermas and Claus Offe. However, the idea has not been widely applied to the analysis of environmental problems, though an exception is Sandbach, F Environment, Ideology and Policy Basil Blackwell, Oxford UK (1980).

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