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Contact Front of Pipe:
PO Box 140, Lewes, BN7 9DS, UK.
Email: enquiry
frontofpipe.net
Web: www.frontofpipe.net
Telephone: +44-1273 401 331
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Complaints to Cambridgeshire County Council - all awaiting reply 13th October 2005 - no investigation attempted. 13th October 2005 - no investigation attempted. Head of Waste Bernard Warr commented in 2006 that Mark thought he had answered it, though this supposed answer has never been disclosed to me. No known investigation. To: "Shelton Mark" <Mark.Shelton@cambridgeshire.gov.uk> Dear Mark A brief response to your letter follows in red, and my request for background information is below in blue. I have noted below in green the flaws with your consultation questionnaire. I do hope that this time the County will take corrective action. The consultation event chair Elaine argued against waste prevention on the grounds that the public do not already understand it. Your letter helpfully added that recycling should be promoted before reduction. Amidst all this I do wonder whatever happened to the first principle of waste management, the 3Rs heirarchy. Your letter did not get around to addressing the two main points of my complaint to the event organisers SWAP: this strategy consultation contained no questions on strategy; and only one option on residual waste was offered for consideration, which we learnt is due to the fact that the entire consultation process is being held after, rather than before, those decisions are made. I understand from a participant at a later meeting that these flaws were not corrected. Your letter kindly asks if I would like to be involved in the process of further public comment. Yes please Mark. >1. I have attached a copy of our consultation questionnaire that will be sent to 100,000 households Thanks. There are specific problems with this draft of the leaflet which seem to make it unsuitable for public consultation. If it was used it would mislead readers and serve as an serious obstacle to public involvement in decision-making. i) Non-recyclable and non-recycled waste are equated, when of course they are not at all the same. Any discussion of residual waste should make it clear that much residual waste can be recycled. In other words greater ambition and effort with recycling is a viable option for residual waste. One of my neighbours doesn't collect biodegradable waste for composting because he hasn't got around to clearing out his undersink cupboard. Do we really want to invest in expensive technologies to save him this effort? Table 2.2.5 of your waste strategy 2002 shows that five years ago 83% of waste was theoretically recyclable. Current County recycling rates are over 45% yet the handout at the consultation event showed you hope to increase this to only 50% by 2032, when the percentage of recyclable waste should be higher than 83%. ii) The list of technological options for residual waste would mislead the public into thinking that these options were actually available, when Bernard Warr and Chris Brown clearly explained at the consultation that discussions with contractors are focused solely on the single option of MBT. In effect the entire consultation process is unable to inform decisions which have already been taken. The chair's suggestion that the public can object later at the planning application stage is no substitute for genuine consultation. iii) The County's discussion of technological options for residual waste does not include other reasonable options, such as greater recycling/composting (see i) above and waste prevention. It would be interesting to contrast the costs, flexibility and environmental impacts of the technical and non-technical solutions. In just 20 minutes at the consultation meeting our group proposed a barrage of potential improvements to current participation in recycling and composting. The opportunities for improvement are endless: do we really want to invest in slow-to-build technologies when fast-to-implement solutions are readily available? Can the County afford to throw away money on fines when unpopular residual waste facilities are held up in planning? iv) The claim that waste reduction is being 'maximised' could only hold true in a non-throwaway society. In a County where I am aware of no waste prevention strategy, no waste prevention policy, no Best Value target for reducing waste generation, no prevention analysis of waste streams, no prevention targets for key streams, no hazardous-waste prevention policy or initiative, no public dialogue about waste prevention, no staff for coordinating waste prevention and no mechanism for improvement in waste prevention policy or initiatives it would be more accurate to say that waste reduction is being 'started'. v) Your leaflet withholds vital information from the public about your plans for residual waste. It does not explain why the County's predicted household waste generation at 2020 has been increased by 22% since 2002, from 530 000t to 650 000t. Does this demonstrate 22% more pessimism in waste prevention or 22% more enthusiasm for expensive technical solutions? The leaflet does not explain why the 2002 Strategy's least preferred technical options of MBT and burning have now become the only available option. In particular the leaflet does not reveal that your pfi approval from DEFRA 'assumes' production of refuse derived fuel for burning and that DEFRA have included the County's future production of RDF in their calculations for the 'significant business opportunity' of burning rubbish. The leaflet does not explain why the County strategy's stated preference for pyrolysis/gasification of residual waste is supposedly unfeasible despite the Juniper report showing it is feasible and despite more local authorities proposing pyrolysis/gasification in pfi bids, than MBT. vi) The assumption that waste information is day-to-day a one way flow towards the public neglects to consider opportunities for dialogue, which can build trust and bring valuable new thinking and feedback. There are numerous possible mechanisms such as; stakeholder steering groups,electronic discussion fora, feedback emails/boxes on your publications and leaflets, and named contacts on your waste web pages. I appreciate that public dialogue requires staff time, but the costs of fines or avoidable capital investments will soon swamp staff costs. Vii) The section on reducing rubbish contains the wrong list. If the leaflet is about waste services then the relevant list is not what householders can do, but what the County can do to help themselves and the public to reduce waste. A good starting point would be a vision or ambition for the future that extends beyond reusing plastic bags. 2. > The group of officers were senior officers from the County and District Councils, supported by our Please may I see instead the informal paperwork which recorded this meeting? The info I was after previously was actually the written record of the outcome from your waste strategy 2002: "2.1.3 Whilst most of the waste strategy will provide “end of pipe ” solutions there is a very definite need to target the generation of waste at source and, therefore, encourage waste minimisation. A small group of officers is currently examining this area." Please may I now see this? 3. > The pyrolysis report (by Juniper) is held by Cambridge City Council. I will ask them if they are Thanks very much. 4. and 5. > The business case and tender documents are considered to be commercially confidential I don't follow this. Since the tender documents are available to anyone wanting to tender, restricting them from the public serves no commercial purpose, but actually obstructs democratic accountability and public participation. Is it really in the interests of the public and the county for waste decision-making to operate as a black box marked "information unavailable - please cross your fingers"? I note that your own website states "We intend to publish copies of all our Invitation to Tenders." http://www.cambridgeshire.gov.uk/business/selling/opportunities/ccc_ads.htm 22nd March 2006 - no investigation attempted. The Council's Head of Waste Bernard Warr on 3rd April 2006 commented, "I have no suggestions to make at this stage". To date (June 2007) the Council have made no attempt to investigate or to respond. To: ian.stewart@cambridgeshire.gov.uk Dear Mr Stewart Cambs Council refer to 3 consultations for this project: 1. 2001 for the waste strategy, which did not mention pfi. MBT and waste burning were end of list, last resort, least preferred options (section 2.6). The length of contract was given as 20 years(section 4.8) which has now grown to a probably 33 years or more, with no public knowledge or support. A promise to establish "regular public waste and recycling forums" has been broken. 2. 2005 workshops, held after all key decisions had been made, which did not mention Cambs preferred option of making RDF for burning, nor their "encouraging" discussions with the cement industry. The unadvertised workshop I attended had 10 people representing the whole of Cambridge, including council staff in role as public stakeholders. My complaints to Cambs and to DEFRA (who funded the event) received no satisfactory response and no improvements were made to the subsequent 6 workshops. 3. 2005 leaflets, which did not mention the recycling-based option. The leaflets claimed to be maximising waste reduction, despite the absence of credible policies or plans for this. My detailed critique of the leaflets a month before they were distributed was not even replied to. The only known publicity for the leaflets was a press article the day before the deadline directing readers to the recap website, on which the leaflet was nowhere to be found. None of these 'consultations' provide any meaningful or valid form of public engagement in the pfi process. This not only invalidates any possible funding from DEFRA but is also legally questionable under UK implementation of the Aarhus Convention for public participation in environmental decision-making. Furthermore the conduct and use of these 'consultations' appears to be incompatible with any interpretation of County policy on public consultation and involvement. As was explained to me by a Council officer, there is a risk that considering other options besides those offered by the pfi bidders would risk upsetting the bidders. However it seems the time has come when the County must choose between working on behalf of its population and working on behalf of waste disposal companies. My study of the waste pfi project is attached. It was sent to the waste management team a week ago with an offer to send corrections or suggestions. None have been received. 27th March 2006 - faulty investigation, no response to my reply of 11th May 2007 (available if needed for any investigation). Further follow-up with Chief Executive on 8th June 2007. March 27th 2006 Dear Mr Stewart My recollection of the discussion referred to does not include any correction of any points made in my pdf report. (I believe you have this report, Cambs PFI 2.pdf , though I can send it again when needed.) At the time I did happily acknowledge Mrs Barrett's repeated insistence that the County really did intend to consult effectively with the community. This statement does not however constitute any imaginable correction of any points in my report. In fact I recall challenging a series of 7 questionable statements by Mrs Barrett and being able to produce County Council documents to substantiate my remarks. By way of example I offer just 2 of the apparently incorrect statements of Mrs Barrett. 1. "The 2005 consultation workshops discussed all the available options for residual waste." I produced the handout from the event confirming that just one sole option was offered for discussion. I recall Mrs Barrett explaining that other options, such as the prevention/recycling option, were "taken for granted" thus not needing to be explicit. 2. "MBT provides valuable products such as compost and RDF." I noted that the so called 'soil conditioner' which MBT creates may not legally be labelled 'compost' and that since the source separated compost already produced by Donarbon is being freely given away in bulk, there is no realistic chance of a contaminated product with highly restricted uses having a positive market value. I showed Mrs Barrett where the Cambs Outline Business Case assumes disposal of RDF at a significant cost, which will inevitably escalate with future national oversupply of RDF. My draft pdf report was given to the waste management team and DEFRA (prior to the discussion with Mrs Barrett on 15th March 2006) with a written invitation to contact me with any suggestions for corrections. None have been received. I question whether it is acceptable for public servants to engage in spreading rumours instead of direct and open dialogue. This is not an isolated incident. I have been shown another email from a senior Councillor listing his "suspicions" of me. These "suspicions" were again not addressed to me. In this case the rumours were not circulated to other PFI procurement board members, so far as I know, so I plan to invite the honourable Councillor to contact me directly with any concerns he may still harbour. I have attempted since last September to commence a positive and constructive dialogue with Cambs waste management department. This has yet to start, with the result that time is wasted all around and a series of opportunities for vital improvements have been lost. The most promising moment was a meeting with 2 members of the team in which it appeared that an agreement was reached to collaborate on shaping a "plan B" (their term) as an addition to the options offered by the PFI. Unfortunately my offer of help with a Plan B was omitted from the notes of the meeting and repeated written offers of assistance since then have been ignored. It may be a common organisational response to treat dissent with suspicion rather than with dialogue. However unless everything in my pdf report is wrong, I may yet prove to be one of the best friends the County has ever had. In the current context of an advanced procurement for a contract worth around £800 million there are 2 conflicting views on the role of open discussion. The first, eloquently expressed by Mrs Barrett is that open discussion of other options "might upset the bidders" and thus undermine delivery of the PFI. The second is that open discussion ensures genuine competitiveness in a procurement process by allowing options other than those preferred by bidders to be considered. In this second view, the spreading of rumours to a procurement board as an alternative to direct open dialogue is anti-competitive and prejudicial to sound decision-making. If one of the keenest members of the public is excluded from open dialogue then what hope is there for the remaining population of Cambridgeshire? As explained in my pdf report, there has yet to be any opportunity whatsoever for open discussion by the public of the options for residual waste and the possible role of a PFI. The relevant EU directive, UK law, DEFRA criteria and County Policy exist with good reason. Active and meaningful public participation would ensure that Cambridgeshire gets waste management that works in the public interest. Without it we may get waste management which simply won't work. I would be grateful for an investigation into whether the PFI procurement board have been given information which unfairly undermines the legitimacy of views and options which have not been offered by bidders. I request that this investigation includes the role of public participation in the waste PFI and looks back to find why a promise in the Cambs waste strategy 2002 for regular public waste forums was never implemented. Had this initiative been implemented here, as it has across the country, public funds in the order of £625 000 may have been saved and the PFI fiasco avoided. I request that any necessary information and guidance be provided to staff, Councillors and PFI Board members regarding: I request that the report of this investigation is completed before any further public funds are spent or decisions made in pursuit of the Cambs waste PFI. The current situation of unreliable information makes sounds decisions on allocation of public funds impossible. If you are able to indicate that you have seen this message before it enters the County complaints procedure I would be most grateful. Many thanks. 13th May 2007 - no investigation attempted. Head of Waste Bernard Warr wrote on 21st May 2007 to ask for the names of the officers involved before commencing any investigation. This is a ploy to avoid taking action since any request for information should be made within an investigation not instead of one. I replied to say that all senior staff with responsibility for waste and environment were involved (copy available for any investigation). To: ian.stewart@cambridgeshire.gov.uk Dear Mr Stewart If I may, I would take this opportunity to make a further complaint, that the waste PFI appears to have operated a number of 'tricks' which are against the public interest, and that the waste PFI has misled the Council's Scrutiny process which otherwise could have provided democratic safeguards. Evidence for the claims is offered on two pages on the site http://www.frontofpipe.net (click on the links in the right hand green column for 'tricks' or 'scrutiny'). In contrast to the Council's persistently faulty waste PFI information, the Council has so far been unable to inform me of any error in my report into the waste PFI which I sent you last year (as an attachment to the email included below). However if the Council offer evidence of any current error on the front-of-pipe site I shall be glad to review it. Without the 'tricks' and evasion of Scrutiny the waste PFI would not exist in its current form, so any altered reputation and credibility of the Council due to publicity or inquiries is not something for which I would feel responsible. 8th June 2007 - new complaint about misinformation to Councillors. Dear Mr Stewart May I further complain that Brian Smith misrepresented my views in his circular to Councillors on the eve of their vote on the PFI contract, in an apparent ploy to obstruct members' consideration of alternate views. This is explained at http://www.sdinnovation.co.uk/lastditchmisinfo.html Should he have wished to do so, Mr Smith had every opportunity over a year and a half to familiarise himself with my views, which I have not kept secret. My phone number has been on all my correspondence and web-pages but has not once been used by the Council. My follow-up response to Councillors arrived too late to inform their vote and consequently this crucial meeting, like that of the PFI Board in March 2007 was misled with a manipulation of the facts by your staff. In both cases the misinformation was circulated without being copied to me, which displays an aversion to open and honest dialogue. Don't you think that if the waste PFI was as well justified as is claimed, that it could have proceeded without the aid of repeated falsification of alternate views?
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