STATE OF NEW YORK
THOMAS P. DiNAPOLI STEVEN J. HANCOX
OFFICE OF THE STATE COMPTROLLER DEPUTY COMPTROLLER
COMPTROLLER 110 STATE STREET DIVISION OF LOCAL GOVERNMENT
ALBANY, NEW YORK 12236 AND SCHOOL ACCOUNTABILITY
Tel: (518) 474-4037 Fax: (518) 486-6479
February 6, 2009
Honorable Matthew Ryan
City of Binghamton
38 Hawley Street, 4th Floor
Binghamton, NY 13901
Report Number: P4-8-08
Dear Mayor Ryan and Members of the Common Council:
A top priority of the Office of the State Comptroller is to help local government officials manage
government resources efficiently and effectively and, by so doing, provide accountability for tax
dollars spent to support government operations. The Comptroller oversees the fiscal affairs of
local governments statewide, as well as compliance with relevant statutes and observance of
good business practices. This fiscal oversight is accomplished, in part, through our audits, which
identify opportunities for improving operations and City governance. Audits also can identify
strategies to reduce costs and to strengthen controls intended to safeguard local government.
In accordance with these goals, we conducted an audit of paper purchases of six municipalities
and school districts in Broome County (County). The objective of our audit was to determine if
local municipalities and school districts could have a positive impact on the environment by
using 100 percent post-consumer recycled paper.1 We included the City of Binghamton (City) in
our audit. Within the scope of this audit, we examined the City’s copy paper purchases from
January 1, 2007 through August 7, 2008.
The results of our audit and our recommendations have been discussed with City officials and
their comments have been considered in preparing this report. City officials were given an
opportunity to respond to our findings and recommendations within thirty days of the exit
conference but they did not respond in writing. They did, however, inform us that they would be
submitting a corrective action plan after the issuance of this report. At the completion of our
audit of the six municipalities and school districts, we prepared a global report that summarized
the significant issues we identified in all of the units audited.
Post-consumer recycled paper means that the paper is made from recovered paper that has been recycled by a
consumer. Pre-consumer materials are generated by manufacturers and processors, and may consist of scrap,
trimmings and other by-products that were never used in the consumer market; using post-consumer materials has a
greater environmental impact than using pre-consumer materials.
Summary of Findings
During our scope period, all City departments purchased non-recycled paper. If all City
departments had purchased 100 percent recycled paper, they would have helped the environment
in several ways. The City could have saved from 330 to 465 trees, conserved energy that would
have heated three houses, reduced green house gases equivalent to the average annual operation
of four cars, saved 169,859 gallons of water and eliminated 21,800 pounds of solid waste.
Background and Methodology
According to New York State Department of Environmental Conservation,2 paper constitutes the
largest single component of the municipal waste stream — over one-third by weight. Recycling
one ton of paper (40 cases) can save between 17 and 24 trees, 460 gallons of oil, eight cubic feet
of landfill space, and prevent 5,690 pounds of carbon dioxide (CO2) emissions. The City of San
Francisco, California recently became the latest member of a Green Cities California coalition to
direct all city departments to purchase only 100 percent post-consumer recycled paper. The
Green Cities California coalition contends that converting its purchases of an aggregate of a half
billion sheets of paper to 100 percent post-consumer recycled paper can save 19.6 million
gallons of water, 11.5 million kilowatt hours of electricity, 67,000 trees,3 and prevent 8.6 million
pounds of carbon dioxide (CO2) emissions. The Federal government also requires its agencies to
purchase at least 30 percent post-consumer recycled paper. Further, the New York State
government requires its agencies to purchase 100 percent post-consumer recycled paper.
Purchasing recycled paper also helps create markets for recycled paper; thus increasing the value
of used paper as a commodity, as an added incentive to recycle paper.
According to our survey results, municipalities and school districts within Broome County
purchase 150 million sheets of paper (this equates to 750 tons) annually.4 These municipalities
and school districts generally purchased non-recycled paper of differing sizes; the most prevalent
size was 8.5 by 11 inches. If all the municipalities that responded to our survey convert their
purchases of paper to 100 percent recycled paper they can save an estimated 12,741 to 17,988
trees, 11,992 million British Thermal Units (BTUs),5 6,558,125 gallons of water, 841,688
pounds of solid waste, and prevent 1,579,946 pounds of CO2 emissions.
Misperceptions exist relating to complications in the actual use of recycled paper in printers and
copiers. We investigated and researched concerns that were raised and the most common myths
regarding the use of recycled paper. We concluded that these misperceptions were unfounded;
we provided detailed conclusions about these concerns in Appendix A. We also conducted
interviews with employees regarding their concerns with using 100 percent recycled paper.
We conducted this performance audit in accordance with generally accepted government
auditing standards (GAGAS). Those standards require that we plan and perform our audit to
We surveyed all municipalities and school districts in Broome County and received responses from 32.
A British Thermal Unit (BTU) is a measurement of the amount of heat required to raise the temperature of one
pound of water one degree Fahrenheit.
obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objective. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit objective.
Consumers have the option to purchase paper that contains anywhere from 0 to 100 percent pre-
consumer or post-consumer recycled paper. Municipalities can help conserve natural resources
and reduce unnecessary waste by utilizing 100 percent post-consumer recycled paper. According
to the estimates provided by the Environmental Defense Fund,6 to produce one ton (40 cases) of
non-recycled paper it takes three tons of wood, 38 million BTUs of energy, 5,690 pounds of
CO2, 19,075 gallons of water, and produces 2,278 pounds of solid waste. To produce one ton of
100 percent recycled paper it takes 22 million BTUs of energy, 3582 pounds of CO2, 10,325
gallons of water, and produces 1,155 pounds of solid waste.7 Therefore, for every ton of recycled
paper produced, instead of non-recycled paper, there is a savings of three tons of wood, 16
million BTUs, 2,108 pounds of CO2, 8,750 gallons of water and 1,123 pounds of solid waste.
The City can have a positive impact on the environment by using 100 percent post-consumer
recycled paper. We found that the City did not purchase recycled copy paper but instead
purchased 772 cases (19.4 tons) of non-recycled copy paper during the audit period.
The City’s purchasing agent stated that the City purchases paper off the County bid or the New
York State Office of General Services (NYS OGS) contract. Recycled paper is not included on
the County bid and was not available on the NYS OGS contract in less than truck-load quantities
until September 1, 2008, therefore City officials did not purchase recycled paper during the audit
period. City officials also had concerns over the cost of the recycled paper. The City’s
purchasing agent stated that City officials would be willing to try recycled paper if it was
included on the County bid and if the additional cost is minimal.
If the City had purchased 100 percent recycled paper instead of non-recycled paper during the
audit period, they would have conserved the following resources:
330 to 465 trees or 58 tons of wood
310 million BTUs that would heat three houses
40,921 pounds of green house gases that would be equivalent to the annual emissions
produced by four cars
169,859 gallons of waste water
21,800 pounds of solid waste.
Nonetheless, we determined that the cost of recycled paper is slightly higher than non-recycled
paper. NYS OGS awards commodity contracts for use by local governments and school districts
at competitive prices and has contracts for purchase of both non-recycled and recycled paper.
The Environmental Defense Fund is a national nonprofit organization dedicated to create cost effective solutions to
environmental issues. http://www.edf.org/home.cfm
Environmental estimates were made using the environmental defense fund paper calculator.
Based on those contracts there is a 7 to 11 percent premium for recycled paper. NYS OGS
contracts are based on large quantity purchases and usually offer very competitive prices.
However, the City currently pays less than the NYS OGS contract price for non-recycled paper
which demonstrates good procurement practices for this commodity. As a result the City would
experience a cost increase by switching to the NYS OGS contract and at the same time switching
to recycled paper. However, if the City continued to follow its current procurement practices
and received the same percentage cost differential by bidding recycled paper, we estimate that
the additional cost to the City would be approximately $1,000 per year bringing the annual cost
of paper from approximately $12,000 to $13,000. By doing so, they would save approximately
226 trees per year, equating to approximately $4 for each tree saved.8
1. The City should explore the usage of recycled paper. City Officials should monitor the
cost of recycled paper and determine if the benefits of purchasing recycled paper out
weigh the additional cost.
A written corrective action plan (CAP) that addresses the findings and recommendations in this
report should be prepared and filed within 90 days, pursuant to Section 35 of the General
Municipal Law. For more information on preparing and filing your CAP, please refer to our
brochure, Responding to an OSC Audit Report, which you received with the draft audit report. If
you submitted a written audit response to this report and have indicated that it is also intended to
serve as your CAP, you do not need to submit another CAP. Our office is available to assist you
upon request. If you have any further questions, please contact the Binghamton Regional Office
at (607) 721-8306.
Steven J. Hancox
Office of the State Comptroller
Division of Local Government
and School Accountability
Price increase is based on an average of 8.23 percent increase and the paper cost for 2007 which totaled $12,016.
The trees saved annually are based on the 2007 purchases copy paper which totaled 443 cases (11.07 tons) of paper.
Misperceptions About Recycled Paper9
All paper is recycled now, there is no need to ask for it and all paper companies are making
recycled paper, so all paper must be recycled.
More than 90 percent of the printing and writing paper made in this country today is still non-
recycled paper.10 One office supply vendor’s website on August 4, 2008 listed 48 types of copy
paper, 12 of which were made with recycled paper. According to the website conserveatree.org,
even at the height of its success, recycled paper had approximately 10 percent of the printing and
writing paper market. Now distributors, printers and paper mills say that demand is dropping
because buyers believe they no longer have to ask for recycled paper.
Recycled paper jams copiers.
According to the website conserveatree.org, Stanford University and Humboldt State University
in California, there is no problem with using recycled paper in copiers. All that is required is
good quality paper. It does not matter whether that paper is non-recycled or recycled. In fact,
some of the most popular copiers are made to engineering specifications that require the
machines to perform satisfactorily with recycled paper. Today’s recycled copier paper is high
quality and technically perfected for use in copiers. From the units we audited, we found no
verbiage in the copier leases or warranty agreements stating that recycled paper was bad for their
copy machines. While auditing one unit, we spoke with the copier repair person who informed us
that he has not seen problems with the copiers that used recycled paper. The New York State
Office of General Services contract for recycled paper requires the vendor to guarantee that: “All
copy paper furnished must be unconditionally guaranteed to provide trouble-free operation when
used on xerographic type copiers - regular speed and high speed machines, laser and ink-jet
printers, plain paper faxes, and offset duplicators. If requested, bidder must submit a letter from
the paper mill manufacturing the paper bid on, unconditionally guaranteeing that the recycled
paper furnished will operate trouble free.”
The little fibers in recycled paper create too much dust in copier machines.
Both Stanford University and conserveatree.org agree that excessive dust is not created by the
little fibers in recycled paper, but from inadequate production processes or incomplete
vacuuming of cut paper sides. According to a major printing company, recent technological
advances in de-inking have significantly improved the quality of recycled paper. Recycled
papers, just like non-recycled papers, vary from high to low quality in terms of print quality and
Misperceptions found at http://www.conservatree.org/paper/PaperTypes/RecyMyths.shtml,
tm and at http://www.ibuydifferent.com/takeaction/paper_myths.asp
Conserveatree.org, a nonprofit organization dedicated to converting paper markets to environmental markets
It is better to burn paper for energy than to recycle it.
According to the EPA and the University of Michigan website, paper can be recycled up to eight
times, thereby saving resources such as water and energy, and reducing pollution. The impact
and value of these repeated savings are much greater than the minimal amount of energy
produced when the paper is burned. According to Harvard University, burning the paper still
produces emissions into the air including air pollutants and greenhouse gases. While it is true
that some incinerators also produce electricity, it is not without impact. Recycling the material,
or reusing or reducing its use, will save electricity and is a much more efficient way of handling
the material. Further, information available on the Harvard University website states that
recycling saves 3.6 times the amount of energy generated by incineration and 11 times the
amount generated by methane recovery at a landfill.
Making recycled paper is environmentally damaging.
According to conserveatree.org, Stanford University and the EPA, recycled paper production
saves trees, energy and water and produces less pollution. It also solves a community disposal
problem. The only area in which recycled paper creates more disposal materials is that it creates
a greater amount of sludge11 than non-recycled papermaking. The materials that make up the
paper sludge would otherwise have been scattered throughout landfills or concentrated in
incinerator emissions or ash. Recycling mill sludge becomes an environmentally preferable way
of handling potentially toxic materials such as inks and additives. The sludge of many recycling
mills tests non-toxic. Sludge that tests hazardous can be disposed of by an environmentally
According to the Environmental Protection Agency (EPA) there are many economic and
environmental benefits of paper recycling. Recycling reduces greenhouse gas emissions that
could lead to damaging climate change; saves money, because recycling fiber is cheaper than
harvesting and processing non-recycled fiber; saves considerable landfill space, because paper
products constitute the largest portion of municipal solid waste—accounting for nearly 40
percent of all waste generated, according to EPA; and reduces the volume of waste burned in
waste combustors, thus reducing air emissions. Recycling and buying recycled paper products
reduces energy consumption, decreases combustion and landfill emissions, and decreases the
amount of carbon dioxide in the atmosphere. When you reduce or recycle paper products, trees
that would otherwise be harvested are left standing. These living trees absorb carbon dioxide, a
greenhouse gas. On the other hand, when trees are harvested for papermaking, carbon is released,
generally in the form of carbon dioxide. When the rate of carbon absorption exceeds the rate of
release, carbon is said to be “sequestered.” This carbon sequestration reduces greenhouse gas
concentrations by removing carbon dioxide from the atmosphere.
Recycling does not “save trees” because we are growing at least as many trees as we cut
specifically to make paper.
According to information available from the Harvard University website:
Paper sludge is the waste product resulting from the production of the recycled paper.
Ninety-four percent of the natural resources America uses are non-renewable (up from 59
percent in 1900 and 88 percent in 1945).
Recycling saves these non-renewable resources. With recycling, 20 percent more wood will
need to be harvested by 2010 to keep up with demand. Without recycling, 80 percent more
wood would need to be harvested.
Ninety-five percent of our nation’s forests have been cut down and less than 20 percent of
paper manufactured in the U.S. comes from tree farms.
Tree farms and reclaimed mines are not ecologically equivalent to natural forests and
ecosystems. Recycling prevents habitat destruction, loss of biodiversity, and soil erosion
associated with logging and mining.
According to the Environmental Defense Fund, more trees are being planted than cut, but there is
a severe and continuing loss of natural forests that has accompanied this tree planting. In the
Southern United States, for example, where most of the trees used to make paper are grown, pine
plantations are replacing natural pine forests at an alarming rate. While pine plantations are
excellent at growing wood, they are far less suited than natural forests to provide animal habitat
and preserve biodiversity. Since 1950, the portion of Southern pine forest in plantations has
grown from 2.5 percent to more than 40 percent in 1990, with an associated loss in natural pine
forest. During this decade the acreage of pine plantations will overtake the area of natural pine
forests across the South, and is projected to approach 70 percent of all pine forest in the next few
decades. By extending the overall fiber supply, paper recycling can help to reduce the pressure to
convert remaining natural forests to tree farms. Both domestically and globally, we face
enormous pressure on forest resources to provide wood products, not to mention other important
“goods” such as wildlife and fisheries, watershed protection, animal habitat, etc.
Recycled paper is flecked with plant parts, so it is hard to write on.
According to the World Wildlife Fund’s website,12 recycled paper is almost identical to the paper
made without recycled content, except that it is better for the environment. The only way to
really tell the difference is to look at the label on the package for the recycled content. Paper
with flecks is made that way to look “natural” but all recycled paper does not contain flecks.
According to the Stanford Recycling Program, in the 1980s recycled paper was often of uneven
quality, sometimes appearing tan, gray or spotted. However, today recycled paper is available in
all colors, including the brightest whites, and meets the highest technical standards, sometimes
even exceeding comparable non-recycled papers. Recycled paper is no harder to write on than
World Wildlife Fund is an international, non-governmental organization for the conservation, research and
restoration of the environment. http://www.worldwildlife.org