DC set a floor for privately collected trash — and put the condo credit under review
DC set a floor for privately collected trash — and put the condo credit under review
2026-09-09 · District of Columbia · Compliance
A District of Columbia association that pays a private hauler now has a statutory service floor to hold it to: at least 32 gallons of solid waste container space per residential unit, and collection at least twice per week. The CLEAN Collections Amendment Act of 2024 took effect March 21, 2025.1
The Act also does something quieter that matters more in the long run. It puts the condominium and cooperative trash collection tax credit under formal review by the District's Chief Financial Officer.
The service floor
The requirement, added to the District's solid waste provisions at §§ 8-1031.01 and following, is stated in units a board can check: 32 gallons of container space per residential unit, and collection twice per week at minimum.
That is a standard against which an association can measure what it is actually receiving — and, where the service falls short, a basis for a conversation with the hauler that is not merely a complaint.
The credit under review
A new § 47-872(f) directs the Chief Financial Officer to report, in its Tax Expenditure Review, on “[t]he estimated percentage of the cost of waste collection services covered by the condominium and cooperative trash collection real property tax credit,” along with the median commercial trash cost reported by apartment buildings.
The credit exists because most District condominiums and cooperatives do not receive District trash collection. They pay a private hauler, while their owners pay the same property taxes as households that do receive it. The credit is the District's partial answer to that.
A formal CFO review is where a change to a credit originates.
What the service floor gives a board
Do the arithmetic, then read the contract. Multiply units by 32 gallons and compare against the container capacity actually on site. Compare the collection schedule against twice weekly. Both are five-minute checks, and both give a board a specific number to raise rather than a general dissatisfaction.
Understand what the floor does and does not do. It is a regulatory minimum, not a term of the association's contract. A hauler that is below it is not automatically in breach of an agreement the association signed; the remedy runs through District enforcement rather than through the contract, unless the contract incorporates the standard. Boards renewing a hauling contract should ask for the standard to be written into it — which converts a regulatory floor into a contractual right the association can enforce itself.
Capacity is a bulk-waste problem in disguise. The recurring District complaint in condominium buildings is not weekly household waste; it is move-in and move-out cycles, holiday volumes and furniture. A container allowance sized to 32 gallons per unit does not address those, and a board that solves its baseline capacity may still be paying for special pickups. Worth pricing separately at contract time.
Why the credit review deserves attention now
The credit is one of the few places District tax law recognises that a condominium or cooperative pays privately for a service its taxes nominally fund. Any movement in it lands directly in the operating budget of every affected association.
The CFO review is designed to produce two numbers: what share of the actual hauling cost the credit covers, and what the market rate is. Those numbers can support either conclusion — that the credit is inadequate and should rise, or that it is generous relative to cost and should not. Boards that want the first conclusion should be able to supply their own figures.
That is the practical suggestion here: an association that knows its per-unit annual hauling cost, and can state it, is in a position to contribute to a review that will otherwise be conducted on aggregate data.
The gap that has not been filled
One route to relief was tried and abandoned. A District bill would have made condominium buildings of eight or fewer units eligible for District residential solid waste collection outright, and required a study of the cost. It lapsed at the end of the previous Council Period, and no equivalent measure exists in the current one.
So the smallest District condominiums — three- and four-unit rowhouse conversions with no economies of scale — continue to pay a commercial hauler for a service their single-family neighbours receive from the District. That is the underlying inequity, and the credit review is where it will next be examined.
What to watch next
The CFO's Tax Expenditure Review, and whether the numbers it reports prompt a councilmember to move on the credit. Also whether anyone reintroduces the small-building collection eligibility measure in the next Council Period.
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