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front of pipe homepage > Cambridgeshire County Council's PFI tricks (2007)

Could Cambridgeshire County Council's largest ever contract (around £800 million) emerge from public service accountability practices better suited to a tin-pot dictatorship? Here is a selection of tricks used by Cambridgeshire County Council to manipulate the PFI process. The Council's ethos of public service and value for money is at risk of being discarded along with future decades of preventable, reusable, recyclable and compostable resources.

Ignore sustainable options
Revise the Council's Waste Strategy without telling anyone
Block public involvement
Issue unreliable information
Adopt a bunker mentality
Evade normal democratic processes
 

Ignore sustainable options

Ignore the option for residual waste of rapidly increasing prevention, reuse, recycling and composting. For the past 15 years this has been Cambridgeshire County Council's preferred option; now it has been discarded without any known assessment of opportunities. When Head of Waste Bernard Warr met with James Greyson on 15th February 2006 he agreed that this was a valid option and proposed to look into it. However this was omitted from the Council's notes for the meeting and my repeated reminders to consider this option were ignored. Mr Warr did not carry out his written promise (15th Feb 2006) to arrange another meeting to further discuss the potential for recycling. When James Greyson then sent a report with 4 pages of opportunities for greater recycling Mr Warr wrote to say that he had not read it.

Ignore the fact that all possible sustainable solutions involve increased source separation. Plan only for residual waste technologies treating mixed wastes. Ignore the regional waste strategy which proposes the principle of separately considering the best option for each type of waste (Box 9.2 page 194 http://www.eera.gov.uk/Text.asp?cat=128&id=SX11AE-A77F8F87). Ignore local opportunities for greater source separation. Ignore opportunities demonstrated by other places using greater source separation. Fail to act upon an undertaking in the Waste Strategy (4.5) to source-separate biodegradable and non-biodegradable materials collected from commercial waste disposal customers.

Ignore the option for residual waste of source separated materials suitable for emerging technologies such as cellulosic ethanol (now in commercial production elsewhere) and "ready to be implemented" plasma gasification (see suppliers http://www.advancedplasmapower.com/, http://www.startech.net, and http://www.safewasteandpower.com/). The Council's Outline Business Case correctly noted that "treatments that are not considered technically feasible or viable today may become attractive in a year or so's time". Unfortunately they did not use this knowledge to consider the option of postponing this decades-long technology choice for a year or so. This contrasts with Peterborough City Council's decision to pull out of the PFI with Cambridgeshire as "it would be more prudent to consider alternatives than to sign up for the PFI at an early stage." (page 150 Cambridgeshire Council OBC Dec 2004)

Ignore the contribution of improved recycling and composting to meeting Landfill Directive targets. In the first quarter of 2006/07 County recycling rates rose above 50%, 4 years ahead of the 2010 target date anticipated in the County waste strategy and 9 years ahead of the PFI's hopelessly unambitious 2015 50%-recycling target date in the Council's OBC (page 154). Faster improvements in recycling mean that biodegradable wastes (paper, cardboard and compostables) have reduced faster than expected and government restrictions on biodegradables are less pressing. Unfortunately the Council have not taken this into account and continues without pausing for thought. Four years after the Strategy was written the Council were unable to advise a Cambridge primary school on safe composting methods or to recommend someone who could. There appears to be no sign of the waste strategy's proposal (at 4.5) to separately collect compostable wastes from commercial customers.

Pursue only PFI options based on disposal. The Council considered bids based on MBT and incineration, which produce no products of value (see below) besides a tiny fraction of lowest grade steel. This suggests that, in common with waste contractors, the Council have been unable to shift their mindset beyond dependence on waste dumping of all kinds. This leaves the County in a worse position than with no PFI contract, since the solutions and technologies of genuinely sustainable waste management must be paid for in addition to the PFI white elephant. Dependence on disposal is convenient for waste contractors but it is a disaster for the public and for the environment. The Council's Mark Shelton wrote in October 2005 that the decision to pursue only disposal-based technological solutions arose in an informal meeting between local authority officers and PFI advisors, and that "no formal report of their deliberations was produced." A request for any notes of this meeting was never answered. A similar undocumented meeting led to Council officers (who spoke of possible 90% recycling) accepting a maximum 60% rate at the suggestion of PFI advisors.

Select their preferred option with explicit reference to the likely increased demand for cement in the area, discussions with the cement industry and "the Council's hopes that co-firing cement works with RDF will be a realistic prospect". The Council deny "doing a deal with RMC/Cemex" but this cannot be verified since a Freedom of Information request revealed that no record exists of this particular meeting, despite detailed minutes seemingly being kept of all other confidential meetings with this company. Cemex announced in March 2007 that they are trialing RDF burning at their local Barrington site and are offering a "secure outlet for solid fuel made from municipal waste". http://www.letsrecycle.com/info/waste_management/news.jsp?story=6681 The Council have provided no evidence of corruption in their PFI deal but it is clear that secrecy and a bias towards expensive unproductive solutions is precisely the circumstances underpinning the well-known waste-sector corruption in other places, such as Italy.

Revise the Council's Waste Strategy without telling anyone

Omit the Strategy's commitment to establish regular public waste and recycling forums, able "to define what members of the public think are appropriate ways of moving forward" (section 2.4 of the 2002 Cambridgeshire Municipal Waste Strategy). James Greyson met with Head of Waste Bernard Warr on 15th Feb 2006, when this commitment was repeated but again no action was taken. The Council have thus failed to establish this essential dialogue with members of the public. Had these forums been estblished, the public would have had an opportunity to comment on the PFI at an early stage and the Council would have been unable to unilaterally dismiss all sustainable options.

Omit a commitment for Council officers to examine alternatives to "end of pipe solutions" contained in the strategy (section 2.1.3). The failure to rethink strategy around front of pipe solutions is demonstrated by the Council's failure to consider any sustainable options for residual waste (as described above). Instead of considering front of pipe solutions the Council proposes, with this PFI, to commit the County to 3 decades of further dependence on end of pipe thinking and practice. This Front of Pipe website, a growing resource of practical opportunities, has been known to the Council since October 2004 but has yet to attract their interest.

Omit the Strategy's prioritisation of residual waste technologies. Anaerobic digestion and emerging thermal technologies such as gasification and pyrolysis were prioritised. MBT would be considered only if these others were not feasible and the residue would be landfilled. Incineration would be pursued only as a last resort (section 2.6). The Council could have waited for the emerging technologies to emerge (gasification is now being planned for Bristol). The Council have also broken their commitments about waste burning by considering an incineration PFI bid and allowing MBT to produce RDF for burning. The Council have not disclosed this major change of policy to the public or to DEFRA.

Omit the Strategy's restriction of a residual waste contract to 20 years (section 2.6 and 4.8). The contract duration has been extended to at least 28 years with no opportunity for public comment. The Council are burdening residents with up to 12 more years of payments for a project they have not endorsed. A longer timescale is used as a sweetener in PFI deals so that the public end up paying not only for the capital repayments but also for the associated services, with no opportunity for price competition. In this PFI the cost of the services is more than £700 million. The capital element is not known but is likely to be about what the government are contributing from taxpayers money (£35 million). The government could have given this money to the Council without locking local people into paying over £700m on a guess at what is needed over the next 28 years.

Apply the waste hierarchy upside-down. The 2002 Cambridgeshire Waste Strategy admits (2.1.3 on page 3) that it mostly provides "end of pipe" solutions in which resources are disposed to land or air rather than used again. In 1.1.2 the Strategy recognises its duty under Best Value to reverse the growth in waste; however there is no target or plans for greater waste minimisation (see section 3 on breaking PFI criteria). Five years later in 2007 there are still no known Council plans for greater waste minimisation and the Council assumes that waste will continue to grow over the coming 25-30 years (page 2 of waste 'fact' sheet). Planning for waste growth after 2010 is not permitted in the East of England (see Regional Waste Strategy page 52). The Council's waste 'fact' sheet (page 4) positions the waste hierarchy upside-down, showing least emphasis on prevention and most on disposal to air and land. The waste hierarchy is not about moving from least sustainable to next least sustainable.

Pursue a form of procurement not mentioned in the Strategy. PFI is a highly controversial form of public procurement, removing spending from balance sheets and commiting the public to decades of payments for contracts that are seen by the Commons Public Accounts Committee as a "giant waste of taxpayers' funds". The public had no say in the use of PFI for waste management in Cambridgeshire, despite footing the bill. HM Treasury advise shows that this PFI is being pursued in circumstances which are inappropriate and unlikely to offer value for money. An ethos of public service must not be replaced by a business ethos. Allowing the private sector to choose what to do with waste puts the fox in charge of the hens.

Block public involvement

Provide no opportunity for a consultation at which the public could ask Council waste staff about the waste PFI. The 2001 public consultation did not mention a waste PFI scheme. The 2004 review of the Waste Strategy never happened (see below). The 2005 'consultation' events were not open to the general public and not advertised publicly. The 2006 scrutiny committee meeting did not allow the public to ask Council staff anything. DEFRA's most basic guidance "information sheet 1" on involving communities and stakeholders has been ignored. The Council have flaunted UK law implementing the EU Directive Providing for Public Participation in Development of Plans and Programmes which requires meaningful and ‘continuous’ community engagement. Formal complaints about consultation remain uninvestigated by the Council after more than 18 months.

Ignore Cambridgeshire residents' clearly expressed opposition to waste burning. The scheme ignores the fact that in 2001 only 2.5% of the public supported waste burning to deal with rubbish (page 23 of Council consultation report). The Council's Ouline Business Case page 146 claims to DEFRA that "It was considered essential to capture the views of the local community before the design of any strategy was embarked upon." It does not explain why those views would then be ignored in accepting bids solely for technologies involving waste burning.

Fudge the only consultation during the PFI process. From September to December 2005 the Council ran 'consultation' events and distributed 'consultation' leaflets. Both the leaflets and the events were seriously flawed and mismanaged. James Greyson took part in the first of the events and received unsatisfactory answers when pointing out that only one option had been offered for residual waste. The numerous flaws in this event are described in 3.13 and 3.14 of this report, and summarised here). The 200 word consultation 'findings' bear no relation to the discussion that took place, reflecting only the seriously flawed information in the Council's 'consultation' leaflet distributed to some households at the time. Despite receiving complaints about both the leaflet (7 specific serious flaws identified to the Council before it was published) and the event (immediately afterward and despite promising an investigation (on 23rd March 2006), there has been no known investigation and the Council continue to promote the 2005 'consultation' as valid. (See also DEFRA's cover-up of the Council's failings.)

Run 'consultations' without publicity. The Council claimed to have consulted the public in November 2005 on a consultation about recycling plans and the waste PFI. However there was no press release issued to advertise the opportunity and no Councillor or member of the public is known to have taken part. The document being consulted upon was seen on the Council's RECAP site in March 2005 entitled "JOINT MUNICIPAL WASTE MANAGEMENT STRAGEY 2005" with the spelling error uncorrected 4 months after the supposed 'consultation' ended. There was no publicity for the 2005 'public waste strategy consultation events'. There was one press article the day before the deadline for the 2005 leaflets consultation, with a link to the RECAP website on which the leaflet was not available.

Postpone a review of the Waste Strategy, so avoiding greater public knowledge and discussion of the PFI. The Council's Outline Business Case tells DEFRA that the 2002 Cambridgeshire Municipal Waste Strategy was due for review in March 2004 (page 147). This would have provided an opportunity for public input into the basis for any waste PFI scheme but that review never took place. The Council now say the Strategy will be reviewed in 2007, after the PFI deal is planned to be signed.

Issue unreliable information

Pretend the PFI is about recycling when the effect is to kill progress with recycling. The Council's press release following Council approval of the PFI contract in May 2007 refers to recycling 12 times but does not mention that it is set to end Cambridgeshire's recent increases in recycling rate. The PFI will require recycling in Cambridgeshire to increase from the 2006 level of 51% to a target of 60% in 2025. However Cambridgeshire's recycling is expected to reach 60% before the PFI machinery starts working in 2009/10, leaving the PFI with nothing to do to meet its long-term targets. The PFI has no plans for preventing, reusing, composting or recycling the remaining 40% of household waste. If this PFI goes ahead the County's national leadership will be lost and Cambridgeshire will be known instead for the way it wasted its waste. (Notes: Recycling in Cambridgeshire has increased by 6% per year between 2001 and 2006. If it then increases at only 3% per year, recycling will rise from 51% in 2006 to 60% in 2009, leaving the PFI with nothing to do to meet its long-term target. See 2001 to 2005 rates. See 2006 rate.)

Mislead the public. The Council repeatedly claimed their planned facilites will "convert waste into a valuable resource". In fact it will produce no net material or commercial value and large losses of resources as waste to land and to air. The contaminated 'grey compost' produced by MBT has no market value, cannot be sold as compost, and will become even less usable in future as other local authorities produce more genuine compost. The higher-quality source-separated compost in production in Cambridgeshire is given away free of charge by Donarbon. The RDF produced by MBT becomes toxic pollution and greenhouse gases, contributing to ill health and climate change. Each tonne of RDF burnt causes a net production of 1.91 tonnes of waste, the opposite process from creating valuable resources (see page 19 http://www.biffa.co.uk/files/pdfs/MassBalance_Thermowaste.pdf). The RDF also has no market value, it will incur, at best, a similar gate fee as landfilled rubbish to send for burning (Council Outline Business Case Dec 2004 page 50). At worst, RDF disposal will cost around as much as landfill (due to future oversupply and restrictions on burning outlets).

Mislead the Environment Scrutiny Committee. This Committee, responsible for oversight of all Council environmental decision were kept in the dark about the waste PFI for 2 years (from commencing the OBC in January 2004 to January 2006), "we did not know about the PFI decision making process until recently" (by email from the Committee chair 13th March 2006). This meant no oversight of the botched option selection phase of the PFI. A substantial report by the Council's PFI procurement board to the Scrutiny Committee contained such extensive errors and omissions that no effective scrutiny of the PFI process was possible. See analysis.

Mislead DEFRA. The Council's Outline Business Case commits them to review the County waste strategy in March 2004 (Strategy summary on page 147). In practice the Council found it more convenient to publisha revised strategy after the PFI procurement in 2007, blocking any meaningful opportunity for public comment or involvement in the PFI options. Appendix 10 of the Council's Outline Business Case to DEFRA (pages 169 to 171) is a table outlining the Council's supposed compliance with DEFRA PFI guidelines. Much of this information is blatantly unreliable; see detailed comment.

Agree to be misled by DEFRA's consultants. Senior Council waste management staff publicly stated that they believe in up to 90% recyclability of municipal waste. James Greyson was told by the Council that they attempted to include a 75% recycling target in their waste PFI Outline Business Case (bidding for public money issued by DEFRA to subsidise PFI). However they were warned by DEFRA's consultants 4Ps to restrict themselves to a long-term recycling target of 50-60%. This absolutely critical piece of advice was given and accepted with no supporting analysis and no written record or correspondence (according to a Freedom Of Information request to the Council). The Council's Waste Strategy shows that around 83% of municipal waste was recyclable, which suggests that a 75% target would be an achievable stepping-stone towards full resource recovery.

Use scare tactics. The Council have consistently (eg press release and waste 'facts') cited the risk of being fined £150 for each tonne of waste above government limits, without mentioning that this would not happen in practice since if needed the Council could purchase allowances through the Landfill Allowance Trading Scheme (LATS) at a current price of only £20/tonne. The Council does not make it clear that allowances and fines apply only to biodegradable municipal waste and not to all waste. The Council's Outline Business Case (not disclosed publicly) admits that LATS allowances could be purchased but assumes a price of £100 per tonne, 5 times their actual price. Waste prevention, neighbourhood re-use schemes, home composting and community composting can also reduce waste and avoid fines at very low prices. This assumption gives an illusion of urgency to adopting the Council's proposed PFI. Despite being 9 years ahead of their own recycling targets the Council have made no assessment of the long-term potential for meeting LATS targets using continuous improvement of prevention, reuse, composting and recycling.

Use spin in place of clarity. The Council's report to the Environment and Community Services Scrutiny Committee of 26th Sept 2006 argues at 4.4 iv that the proposed MBT solution is flexible; "Depending on how environmental legislation changes over time, the stabilised organic output of the process may be recyclable for forestry and land reclamation uses." which translates as "the process makes contaminated compost which may not legally be used on land and will most likely have to be landfilled." At 4.4v the Council asserts that their proposed MBT scheme is "a sustainable solution" despite its 2 main products being destined for disposal to land and air. MBT compost is not good enough to be specified even for use on contaminated land - see article. The Council's proposals will perpetuate waste management based upon disposal, the precise opposite of a sustainable solution.

Quote unsupportive research as if it was supportive. The Council's report to the Environment and Community Services Scrutiny Committee of 26th Sept 2006 quotes a Friends of the Earth study at 4.4v, “the best option from a climate change point of view is an MBT process that extracts both the metals and plastics with the stabilised residual going to landfill." In fact the quoted option is for recycling the extracted plastics not burning them, as is clear on page 5. Ironically the study is entitled "Dirty Truths - incineration and climate change".

Adopt a bunker mentality

Ignore alternative ideas. In June 2004 James Greyson offered to lead a study for the Council to explore waste prevention and recycling ideas, following Council participation in a zero waste workshop. The Council declined, citing a lack of interest from key staff. In October 2004 the Front of Pipe website offered a range of unexplored opportunities for recycling and waste prevention in Cambridgeshire. The offer to explore these was declined by the Council, "We've probably over-exhausted this dialog." (email from recycling officer 19 Oct 2004). At the supposed 'public waste strategy consultation event' in Sept 2005 James Greyson offered at least 20 practical suggestions for reducing waste and increasing recycling. The Council's report on this event included a grand total of 3 vague suggestions from all 85 participants. James repeated and expanded his suggestions in a 4 page outline of "unexplored opportunities in Cambridgeshire"; the Council's Head of Waste Bernard Warr wrote back to say he had not to read the report.

Accuse the public of "talking rubbish". See http://www.cambridgeshire.gov.uk/environment/waste/about/future/myths/ for a selection of misleading views intended to block legitimate public concern. For example "We have not changed our policy on recycling", claiming that the Council is "..continuing to work hard .. to increase what we recycle". This neglects to mention that the waste PFI marks the sudden death of ambition for recycling in Cambridgeshire. In 2006 Cambridgeshire already surpassed its 2015 PFI recycling rate target of 50% with 51% recycling in the 1st quarter of 2006, leaving only a further 9% to be met over the 19 years to 2025 (Council Outline Business Case Dec 2004 page 86). This may be compared to the 29% increase in recycling rate over the 5 years up to 2006. If Cambridgeshire residents continue improving their recycling at just half the speed of recent years (6% annual increases up to 2006) then the recycling target for the entire PFI contract duration will have been easily achieved before the PFI plant is even built and the PFI may then contribute nothing at all to recycling.

Adopt a defeatist and cynical attitude. At the 15th March 2006 public scrutiny meeting neither councillors nor staff made any challenge to any of the ludicrous statements from their invited speakers such as "the UK is not ready for the challenge of zero waste" and "the public will oppose anything you provide for waste". Despite claiming to believe that up to 90% of waste is recyclable, senior waste staff are planning for long term recycling of no more than 60%. The PFI is intended to deal with waste which cannot or is not recycled, which assumes that over the next 30 years there will be no move to manage residual waste more sustainably.

Offer DEFRA unsound financial assumptions. The Council's Outline Business Case assumption (on page 50) that the disposal cost of the RDF produced by MBT will be based on the current gate fee for landfill, "is supportive of the work DEFRA are undertaking to develop markets for RDF". Whilst this assumption may serve DEFRA's policy of increasing waste-burning it ignores how incineration capacity (restricted by public opposition) will lag behind RDF supply with the result that the true costs of RDF disposal will be on a par with the full cost of landfill disposal, including the landfill tax. As landfill space becomes scarce the RDF disposal cost will escalate. This means the likely short-term cost of RDF disposal will be 2 or 3 times the Council estimate and the long-term costs will be even worse. If mixed waste incineration is phased out due to its well-documented climate or health effects there may be no market at all for RDF.

Circulate unfounded allegations. James Greyson wrote and distributed his report on the Cambridgeshire PFI before the Scrutiny meeting of 15th March 2006. After the meeting a small number of residents discussed the PFI with a senior Council officer. Following the meeting this officer circulated an email to the waste PFI procurement board alleging that my report contained "incorrect statements" that she had clarified during our discussion. Consequently the PFI board were misled into disregarding the important information in the report. Deputy Chief Executive Brian Smith similarly circulated false information about James Greyson's views in advance of the final vote by Councillors on the PFI. On both occasions the misinformation was circulated without being copied to James. A formal complaint has yet to be resolved the Council.

Evade normal democratic processes

Set up the Waste PFI Procurement Board "to provide a vehicle for rapid political steer outside the County Council's formal decision making process." (Outline Business Case December 2004 page 67). The Decision-making process (Schedule 2 of the Outline Business Case) is marked "intentionally excluded from the OBC". The Board's existence and membership was unknown to the public for its first year. No public minutes of meeting exist. No member of the Board has replied to any email from James Greyson. The two most senior Council officers responsible for environment have each circulated the PFI Board with erroneous allegations (regarding information supplied by James Greyson) in advance of key procurement decisions. The first time this happened, a complaint about the failure to copy the circular to James Greyson was upheld and an apology given by the Council. Subsequently the Council officer who had upheld the complaint himself circulated further false information to the PFI Board and Councillors without including James Greyson among the recipients.

Hobble the Environment Scrutiny Committee. After the 15th March 2006 public scrutiny meeting I asked a senior member of staff why the meeting had considered only the options which were on offer from PFI bidders. She replied that to consider the actual options available for residual waste "would have upset the bidders". By restricting the meeting to choose between two unsustainable technological options (both dependent on waste burning and neither producing any significant value) the possibility of engaging public interest in attending the meeting was lost.

Pursue a PFI in circumstances that HM Treasury policy states are inappropriate. HM Treasury policy on PFI of March 26th 2006 explains on page 32 that a PFI is unlikely to deliver value for money where the precondition of public service accountability cannot be met or where the technology is susceptible to fast-paced change. This page of Council 'tricks', the analysis of the PFI misleading Scrutiny, and DEFRA's cover-up of PFI criteria non-compliance offer evidence that public service accountability is completely ineffective with waste PFIs. Page 147 of the Council's Outline Business Case correctly states that "the rate of change in the waste industry is accelerating and treatments that are not considered technically feasible or viable today may become attractive in a year or so's time." Waste treatments are in extreme flux, with incineration now intolerable to the public, gasification and plasma gasification ready to be implemented on a large scale and climate-critical technologies such as cellulosic ethanol in commercial production elsewhere. Waste management is at a historical turning point with reduction, reuse, recycling and composting exceeding 50% in areas of the UK and able to strategically replace all forms of waste dumping. Powerful economic instruments are now available for achieving zero waste globally, leaving concepts of 'waste' and 'disposal' with a diminishing role. The Treasury report cites information technology as a fast-changing sector unsuitable for PFI but the waste sector is experiencing vastly greater flux than IT. Waste management is unsuitable for PFI.

Claim to have provided information to Councillors which no Councillor says they received. On 25th April 2005 I wrote to all Cambridgeshire County Councillors asking if anyone had seen the May 2005 waste PFI newsletter (http://www.cambridgeshire.gov.uk/NR/rdonlyres/F426F65B-E19B-4800-9122-9C712BACD80A/0/May05Newsletter.pdf) which was supposed to have been circulated. No Councillor replied that it had been received. This newsletter was also not available at the September 2005 "public waste strategy consultation event" which I attended, despite these events being the only moment during the entire PFI process at which selected residents could ask Council staff about the PFI.

Omit all democratic processes from the Council's waste PFI timetable. This timetable includes only steps taken by the PFI procurement board. All possibilities for democratic participation, such as strategy revisions, consultations, council decisions and scrutiny efforts have been omitted. The Waste Strategy revision originally planned for 2004 (see OBC page 147) would have involved a consultation able to inform the PFI's crucial botched options assessment stage. Instead the fudged 'consultation' events in 2005 were able to offer participants a choice of only one option (MBT) to consider.

Obstruct legitimate requests for information. The Council's Outline Business Case (their application for public funds via DEFRA) was written in December 2004 and unknown to the public until September 2005 when it was first requested by James Greyson. Further requests continued until the document was released in February 2006. Despite this document being the only known explanation of what the Council was planning on behalf of the public, and despite containing no evident commercially sensitive information, it has still not been placed on the Council's website.

Use a PFI Communication Strategy which omits the public as stakeholders. To ensure that the public were fully engaged as stakeholders the Council's waste site planning process used a Statement of Community Involvement which was itself consulted upon. The Council Policy Framework Statement of 29th March 2005 describes on page 35 a waste PFI "communications strategy to ensure that stakeholders are engaged and public information is managed so as to maximise success of the project." However unlike waste site planning, there appears to have been no intention for the public to be stakeholders and no waste PFI 'communications strategy' has been disclosed to the public. On 29th March 2006 the Council took 5 pages of advertising in the local Weekly News including one full page about the Council's RECAP waste education. The main subject of the pages was "a guide to how Cambridgeshire County Council is working for you: how we did, what we are doing, reporting back and key targets for the year ahead". Among all this information there is not a single word about the largest contract that the Council have ever procured. £750 million of residents' money is to be spent on a waste PFI with no meaningful opportunity for public involvement.

Mishandle legitimate complaints. Of five complaints to the Council since October 2005 the Council have started to investigate only one.