Analysis of 360 Regulations: Closing Loops City Program

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During the Town+Gown:NYC’s Urban Resource Recovery Working Group’s development and refinement of its initiative, called Closing Loops City Program Initiative or CLCPI, to leverage the City’s capital program to close construction and demolition waste (CDW) material loops, using New York State Department of Environmental Conservation’s (NYS DEC) beneficial use designation (BUD) regulations, it became clear to the Working Group that the BUD regulations were complex and part of a complex set of wider State regulations and it was necessary to have practicing-level knowledge of the regulatory system in addition to the BUD regulations.

A summer 2021 Brooklyn Law School (BLS) student team researched NYC DEC’s Part 360 regulations and analyzed what actions the City would need to take to recover and re-use the
CDW materials in different stages of re-use feasibility with weak re-use markets that the CLCPI intended to target. The student team researched the legislative history behind the State’s regulations as well as the regulations governing the rest of the participants in the CDW system. The student team also performed helpful market analyses related to their focus CDW materials.

The BLS team research was done contemporaneously with the Working Group’s refinement of the CLCPI and directly informed the CLCPI.

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