Memorandum submitted by the Audit Commission
(Waste 19)
The Audit Commission is an independent body
responsible for ensuring that public money is spent economically,
efficiently and effectively, to achieve high-quality local services
for the public. Our remit covers around 11,000 bodies in England,
which between them spend more than £180 billion of public
money each year. Our work covers local government, health, housing,
community safety and fire and rescue services.
As an independent watchdog, we provide important
information on the quality of public services. As a driving force
for improvement in those services, we provide practical recommendations
and spread best practice. As an independent auditor, we ensure
that public services are good value for money and that public
money is properly spent.
SUMMARY
1. The Audit Commission welcomes the Committee's
consideration of the Waste Strategy for England 2007 and is pleased
to submit evidence to this inquiry.
2. This response primarily draws on emerging
findings from the Commission's ongoing research. There are limits
on our ability to draw firm conclusions from the evidence at this
stage.
3. The initial evidence shows that:
— Local authorities are making progress
in procuring waste management infrastructure, but some local authorities
and private sector contractors have expressed concerns.
— Regulatory stability, and early information
about any changes in regulation, is valuable in allowing local
authorities to plan and procure for the long term.
— As waste management arrangements
for household waste have become more complex, the need for effective
coordination of collection and disposal arrangements has increased.
However there are barriers to effective joint working, including
some deriving from the policy framework.
— There are strong arguments in favour
of the government's intention to consult on further restrictions
on sending biodegradable wastes and recyclable materials to landfill.
— A substantial strand of local authority
and local public opinion calls for more action by manufacturers
and retailers on packaging in order to reduce waste.
DETAILED RESPONSE
Introduction—the Commission's role in relation
to waste
4. The Commission audits and inspects a
wide range of public sector organisations, including all waste
collection authorities (WCAs) and waste disposal authorities (WDAs).
The Commission's aim is to be a driving force for improvement
in public services.
5. Subject to final parliamentary approval of
the Local Government and Public Involvement in Health Bill, from
April 2009 the performance framework for local public services
will change, with a new area based, risk focused and forward looking
assessment replacing the current Comprehensive Performance Assessment.
This new approach, called the Comprehensive Area Assessment (CAA),
is still being developed, but it is anticipated that one of the
components of CAA, the use of resources assessment, will have
an increased focus on sustainability in local areas. CAA will
also assess the prospects of improving the quality of life in
local areas, including the area's sustainability.
6. We are currently undertaking a national value
for money study into local authority waste management, focusing
particularly on the diversion of waste from landfill. We have
carried out fieldwork at 12 sites, covering 14 WDAs and 16 of
the associated WCAs. This response draws on emerging findings
from the first stage of the research, where these are relevant
to the topics highlighted by the Committee. The response also
draws on our experience of the audit and inspection of waste authorities.
Further work and analysis will be undertaken as part of the waste
management study, including an analysis of municipal waste management
strategies and a survey of local authority landfill diversion
plans. We cannot make firm judgements until this work has been
completed, but we would be happy to brief the Committee further
at a later stage.
7. This response concentrates on the role
of local authorities in relation to waste, including their relationship
with other organisations.
The Waste Strategy
8. We support the Waste Strategy's aim of
encouraging further movement up the waste hierarchy and we welcome
the statement that waste is a shared responsibility.
9. Working with their local populations, local
authorities have made significant progress in recent years with
respect to recycling and composting performance (from 7 per cent
of municipal waste in 1996-97 to 27 per cent of municipal waste
in 2005-06) (Ref 1). Key actions include introducing door step
collections of recyclable materials, often with support from DEFRA,
and making improvements in the facilities at household waste recycling
centres. The majority of collection authorities and disposal authorities
we have visited are also planning to develop their waste minimisation,
reduction or re-use activity further, for example through school-based
waste education and awareness programmes.
10. Our work in a range of local authorities
suggests that most WDAs, including all of our fieldwork sites,
are also taking steps towards landfill reduction through the procurement
of residual waste treatment and disposal infrastructure (see the
section on this topic below).
Waste minimisation and packaging
11. Many local authorities are seeking to
expand their waste minimisation and education programmes as part
of their strategy for reducing waste to landfill. However, the
purchasing choices of local people are made in a context set by
the policies of large-scale producers and retailers, often operating
at a national level. Officers and elected members in most of the
authorities we visited expressed the opinion that more should
be done by central government to encourage waste reduction by
manufacturers and retailers, particularly in relation to packaging.
They claim the support of local people on this point, based on,
for example, unprompted responses to municipal waste management
strategy consultations[22].
12. We welcome the work within the voluntary
Courtauld Commitment to explore biodegradable packaging and particularly
to improve the labelling of packaging as to whether or not its
materials can be recycled or composted. This should help reduce
the quantity of packaging in residual municipal waste. However,
to be useful rather than confusing for members of the public,
labelling should take into account the fact that the materials
accepted for recycling and composting vary across authorities.
The proposals for financial incentives to increase
household waste prevention and recycling
13. The Commission has no objection to the
general principle of local authorities being able to use financial
incentives to influence how citizens dispose of waste, subject
to certain conditions. Any scheme should:
— be fair and equitable across communities.
14. Further detail is given in the Commission's
response to the DEFRA consultation on the financial incentives
proposals (see the Appendix to this memorandum).
Infrastructure for municipal waste treatment and
disposal
15. Recycling targets and the Landfill Allowance
Trading Scheme (LATS) have stimulated councils to divert waste
from landfill and move up the waste hierarchy by commissioning
new waste management infrastructure. However, the scale and speed
of infrastructure delivery, and its likely contribution to meeting
the national targets for diverting biodegradable municipal waste
from landfill, is uncertain.
16. The Commission is conducting research (in
cooperation with DEFRA and the Regional Centres of Excellence)
to understand current and planned infrastructure capacity across
England, set against local authorities' landfill diversion plans
up to 2020. This survey will also collect the projected costs
of changing collection and disposal methods, as authorities move
up the waste hierarchy. This research should provide a clear picture
of progress in diversion of waste, the associated costs and any
potential risks at both a national and local level. The results
of this work will be published as part of our waste management
study in spring 2008, although we will make the information available
to DEFRA well in advance of that for use in their national waste
modelling.
17. Emerging findings from our fieldwork
in relation to the procurement of new infrastructure are positive:
— Many local authorities felt that
central government has improved its support and guidance to authorities
engaged in waste procurement, through the creation of the Waste
Infrastructure Delivery Programme (WIDP).
— Local authorities and their partners
are aware of the planning risks for procurement timescales and
have been seeking to mitigate these.
— There is some evidence of waste disposal
capacity being built by the private sector without requiring contracts
to be in place with users in advance.
— The Office of Fair Trading expressed
concern in 2006 about the implications of local authority dependency
on a limited number of suppliers (Ref 3). However the local authority
waste disposal market now appears to be seeing a wider range of
competitors. This includes UK firms from other sectors of the
economy and new technology providers from abroad, often operating
as sub-contractors or as part of consortia. Smaller UK waste management
companies provided a real challenge to the larger waste management
operators in two recent procurements in our fieldwork areas.
— Authorities engaged in negotiating
long term waste disposal contracts have devoted significant resources
to detailed modelling in order to understand and manage the risks
involved in a large number of future scenarios.
18. However, during fieldwork private sector
waste contractors expressed concern about the demands placed on
bidders for local authority waste procurements (which are often
through the Private Finance Initiative), including the process
of competitive dialogue[23].
These demands limit their capacity to bid for contracts, constraining
market capacity and competition.
19. Private sector contractors also observed
that the attractiveness of local authorities as customers varies.
In deciding where to deploy their bidding capacity, waste companies
consider factors such as evidence of political support for the
procurement, a professional client side team and effective deployment
of external consultants in the process. Potential bidders wish
to avoid investing time and money in procurements that are unduly
lengthy, involve substantially changing requirements or fall through
due to lack of political support. There is therefore a risk that
some councils will have difficulty getting good value from a competitive
bidding process.
20. Most recent waste disposal contracts
are for long periods (25 years or more). Some local authorities,
while recognising that long contract durations may be necessary
where major capital investment is involved, expressed concerns
about the appropriateness of long contracts given the uncertainties
around the future size and composition of the waste stream and
the effectiveness or future acceptability of disposal technologies.
21. Building flexibility into long term
contracts can be difficult and expensive even if done from the
outset. Moreover, the experience of some authorities engaged in
negotiating variations to existing long term disposal contracts
indicates that such negotiations can also be lengthy and difficult,
and the variations may be expensive. Those authorities committed
to long term contracts placed great value on consistency in the
political and regulatory environment.
22. For some authorities these concerns
about uncertainty were heightened by the scale of their potential
contracts, which were large even in relation to other local authority
capital expenditure.
New technologies
23. Our fieldwork suggests that private
finance for new technologies is difficult to secure before a full
scale plant processing UK municipal waste is running successfully.
Mechanical-biological treatment and anaerobic digestion facilities
for municipal waste have opened in the last few years. Their proven
track record has improved the "bankability"[24]
of projects depending on these processes and encouraged the development
of markets for their products, although some issues remain (see
next section).
24. Advanced thermal treatments for municipal
waste remain less familiar within the UK. However gasification,
pyrolysis and mechanical heat treatment plants part-funded by
DEFRA's New Technologies Demonstrator Programme will start operating
within the next two years. We would expect these technologies
to become more bankable, dependent on the outcome of these projects.
However the development of waste treatment technologies will continue,
and we would encourage the government to monitor any need for
further public development funding as newer technologies offering
significant potential benefits arise.
The classification of outputs from waste treatment
25. Local authorities need as much information
as possible about the regulations that will govern outputs from
waste treatment processes before making investment decisions.
We therefore welcome the Environment Agency's work on a protocol
for anaerobic digestate from segregated waste and on a number
of other protocols for other major waste streams.
26. As one means of diverting biodegradable waste
from landfill, many councils have chosen to procure facilities
for various forms of biological treatment of mixed waste. The
classification of outputs from these treatments is important because
it determines how these outputs can be used or disposed of. This
will influence the LATS benefits and overall costs of the treatment
processes. In our fieldwork we found that some authorities who
made plans in the expectation of the favourable regulation of
the outputs of mixed waste processes have been obliged to change
their plans and projections when it became apparent that the regulation
would be less favourable than anticipated. We would encourage
the Environment Agency to be as clear as it can in advance about
the likely regulatory treatment of outputs from mixed waste treatment
processes.
Regulation of landfilling
27. We welcome the government's intention,
subject to continued analysis, to consult on further restrictions
on sending biodegradable wastes and recyclable materials to landfill.
As the Waste Strategy notes, a variety of bans have been used
successfully in other EU member states. A projected shortage of
accessible landfill was a powerful stimulus for three of our fieldwork
authorities, which are among the authorities that have been engaged
for longest in moving up the waste hierarchy.
28. The government has emphasised the importance
of greater certainty and stability in policy frameworks, for effective
long-term planning. Annual LATS allocations were announced for
the years from 2005-06 through to 2019-20. Authorities told us
that this scheme has been successful in moving waste management
up the agenda of local authorities. Early announcement of controls
on landfilling waste beyond 2020 would promote sustainable waste
management across all waste generating sectors. This would generate
future demand for the treatment of waste by the private sector
and the public sector, which could further stimulate the market
for waste treatment infrastructure. Any such controls would give
long term certainty to local authorities in planning procurements
beyond the lifetime of LATS and also would allow councils greater
freedom to be involved in the collection of commercial waste.
RELATIONSHIPS BETWEEN
AUTHORITIES
Co-ordination between collection and disposal
authorities
29. Coordinating with waste collection authorities
is becoming more important as disposal authorities, including
joint waste disposal authorities (JWDAs), seek to divert sufficient
biodegradable waste from landfill to meet their landfill allowances.
Formal (sometimes legally binding) agreements are becoming increasingly
common as waste disposal authorities sign significant contracts
for waste treatment facilities, with guarantees concerning the
provision of waste from collection authorities. Deciding on the
most effective waste management arrangements involves complex
modelling of both collection and disposal services, for example,
to maximise materials recovery.
30. Each authority has to achieve best value
individually for a waste management service that is increasingly
becoming a joint effort between collection and disposal. A common
dilemma is that for disposal authorities to achieve their landfill
allowances, avoid substantial penalty charges and obtain best
value in their waste treatment contracts, they may need collection
authorities to invest in new and more expensive collection arrangements.
But collection authorities, with restricted budgets and no financial
penalties like those imposed on disposal authorities under LATS,
have little incentive to invest. The only significant pressure
on them is the risk of missing a statutory recycling target, which
does not attract a financial penalty. We visited two JWDAs (of
the six that exist) and reaching agreement appears to be more
straightforward in such areas, where collection authorities ultimately
bear the cost of disposal through a levy.
31. Some councils are proactive in local business
networks, promoting waste awareness and waste reduction with small
and medium-sized businesses and making links where possible with
other companies that reuse or recycle waste. Expanded council
commercial waste collection services can also be useful to local
small businesses, and such greater engagement may be desirable
if it either encourages more recycling or enables economies of
scale across waste streams. However, extending council collections
of commercial waste may be an issue for disposal authorities if
it increases the overall biodegradable waste they must deal with
under LATS. We have seen some disposal authorities actively encouraging
collection authorities to introduce trade waste recycling schemes,
to achieve an optimal solution for both parties. We are not at
present persuaded that this will always resolve the issue given
the possible difficulties and expense of introducing new trade
waste recycling schemes.
32. The proposed creation of nine new unitary
authorities would bring collection and disposal together in a
number of areas. Also, subject to final parliamentary approval,
the power contained in the Local Government and Public Involvement
in Health Bill will allow authorities to form Joint Waste Authorities
voluntarily. But at present, if authorities in two tier areas
cannot reach agreement on the way forward then the last resort
available to disposal authorities is the use of powers of direction.
However, disposal authorities are reluctant to use these powers
(and none of our fieldwork authorities had used them) because
this would have a disruptive effect on their relationship with
the collection authorities, and may not be appropriate in the
context of developing new working arrangements intended to be
of mutual benefit.
33. There may be scope for central government
to review how, in practice, local LATS obligations (which bear
on disposal authorities) and statutory recycling targets (which
bear on all waste authorities) fit together in the light of the
chosen strategy for an area. Tensions between authorities could
be reduced by, for example, creating better incentives for collection
authorities to emphasise waste minimisation and removing biodegradable
material from the waste stream, as part of a more integrated system
of performance assessment.
34. Our fieldwork found examples of waste
partnerships that had generated and maintained a commitment to
significant, long term changes, despite political differences.
However, developing sufficiently strong partnerships between authorities
requires a substantial investment of both officer and member time
over a significant period. We found examples of delays and difficulties,
even within the most successful partnerships. This is not surprising
given our previous findings about the challenges of partnership
working (Ref 5).
Joint procurement
35. Another potential driver for effective
partnership working between authorities is the need to achieve
economies of scale. This is heightened by the tension between
rising collection and disposal costs, and the need to demonstrate
best value and the pressure for efficiencies, most recently the
requirements of the Comprehensive Spending Review 2007. Fieldwork
for the waste management study suggests that there may be potential
for greater economies of scale through more joint procurement
of disposal facilities and (separately) more joint procurement
of collection services, although we are not able to quantify this
potential at the current stage in the research. Moreover, the
potential benefits need to be balanced against the risk of weakening
competition in the medium term if the amalgamation of contracts
in a geographical area gives significant advantages to an incumbent
supplier. The optimal lengths of disposal and collection contracts
are likely to be different, so joint contracts for collection
and disposal would require particularly compelling benefits to
justify them.
36. Barriers to more joint procurement, particularly
for collection, often appear to relate to the political desire
to retain local control of waste services, rather than strictly
operational issues. Arguably, local control enables waste management
arrangements to meet local wishes, based on knowledge of local
circumstances. But this needs to be balanced against the potential
financial benefits of shared services and community preferences.
Several fieldwork authorities argued that in fact many users would
prefer more unified rather than locally tailored services (for
example having the same colour boxes and bins, and the same materials
collected for recycling, across authority boundaries).
37. With respect to disposal, some authorities
are procuring joint residual waste facilities in order to make
efficiencies, although we have also encountered examples where
plans for partnership working have fallen through, for a variety
of reasons, and others where joint procurement has been deemed
to be inappropriate or impractical.
Future work
38. We hope to publish our report on local
authority waste management in May 2008. The report will identify
good practice, and provide information to local authorities so
that they are better equipped to make sound, evidence-based decisions.
We would be happy to discuss the emerging findings of the waste
management study in more detail with the Committee or its officials
if that would be helpful.
REFERENCES
Reference 1
DEFRA municipal waste management statistics.
Available at:
http://www.defra.gov.uk/environment/statistics/wastats/index.htm.
Reference 2
P Downing and J Ballantyne, Tipping Point or Turning
Point? Social Marketing and Climate Change, Ipsos MORI Social
Research Institute, 2007. Available at:
http://www.ipsos-mori.com/publications/srireports/climatechange.shtml.
Reference 3
Office of Fair Trading, More Competition, Less
Waste: Public procurement and competition in the municipal waste
management sector, Office of Fair Trading, 2006. Available
at:
http://www.oft.gov.uk/advice_and_resources/publications/reports/competition-policy/oft841.
Reference 4
Confederation of British Industry, Building on
Success: the way forward for PFI, Confederation of British
Industry, 2007. Available at: http://www.cbi.org.uk/pdf/healthreport0607.pdf
Reference 5
Audit Commission, Governing Partnerships: Bridging
the Accountability Gap, Audit Commission, 2005. Available
at: http://www.audit-commission.gov.uk/nationalstudies/publishedstudies-crosscutting.asp.
Audit Commission
October 2007
Appendix
The Audit Commission's consultation response
on household incentives for recycling, August 2007
SUMMARY
The Audit Commission has no objection to the
general principle of local authorities being able to use the mechanism
of charging as a means to influence how citizens dispose of waste.
However, based on the evidence of fieldwork in connection
with our audit, inspection and studies functions, we also sound
a note of caution. Any scheme of charging should fit within a
waste strategy that results in the best overall management of
waste and value for money for an area and shouldn't create perverse
incentives/disincentives for the councils involved. Similarly
any scheme should be fair and equitable across communities.
DETAILED RESPONSE
We have answered the questions set out in the
consultation document where we have something pertinent to say.
QUESTION 1:
Do you agree that local authorities should have
the power to introduce financial incentives for promoting recycling
and reducing household waste? Why?
Response—We have no objection to the principle.
We have observed that well designed and fairly implemented charging
schemes can be used to successfully influence behaviour.
QUESTION 2:
(a) Do you agree that a power to introduce
financial incentives would help local authorities to meet their
recycling targets and their obligations under the Landfill Allowances
Trading Scheme?
Response—We have already noted that charging
mechanisms may influence behaviour. However, it doesn't necessarily
follow that such behaviour change means that recycling targets
or LATS obligations are met. For example; a particular charging
scheme might encourage much greater volumes of biodegradable materials
such as green waste to be composted by householders at home and
thus never enter the municipal waste stream. It is feasible in
this example that while the objective of the LATS might be met
(that is, less biodegradable landfill) the recycling target might
be missed (because proportionately there is less material to be
reclaimed from the waste stream).
In this case, while this would be a good outcome,
the system of applying statutory recycling targets would need
to change. It would be perverse if the risk of missing recycling
targets was a constraint on introducing better waste management
behaviours. The general lesson is that a scheme of charging would
have to form part of a whole system approach to the management
of waste designed to give the best outcomes, not just to meet
existing statutory targets.
(b) Are there other barriers that Government
could address to help authorities boost recycling and meet their
obligations under the Landfill Allowances Trading Scheme?
Response—There can be barriers in areas where
collection and disposal functions are separate because the pressures
of the recycling targets and LATS obligations do not bear on collection
and disposal authorities equally.
The pressure on the collection authority is the risk
of missing its statutory recycling target, which doesn't carry
any real sanction and no financial penalty. Whereas, missing the
LATS obligation can be very expensive for the disposal authority.
The disposal authorities we have visited were
trying to resolve these issues through working with the districts.
If they did not reach agreement they would only have their powers
of direction, which they see as an instrument of last resort.
There may be scope to review how, in practice,
local LATS obligations and recycling targets fit together in the
light of the chosen waste strategy for the area. There is a need
to minimise the risk of perverse outcomes perhaps by creating
better incentives for collection authorities both to minimise
the amount of municipal waste arising and to put a greater priority
on removing biodegradable material from the waste stream (for
LATS), as part of a more integrated system of performance assessment.
QUESTION 4:
(c) Do you agree that local authorities
should be free to determine the level of charges under a financial
incentive scheme?
Response—Yes. We would argue that councils
would need the greatest flexibility to implement a scheme that
achieves the desired result of reducing the amount of biodegradable
waste sent to landfill. At the same time it should be applied
fairly and not increase activities such as fly-tipping.
QUESTION 6:
The Government's view is that it would be essential
for local authorities to have good recycling services, fly-tipping
prevention and enforcement strategies and measures to help disadvantaged
groups in place before introducing financial incentive schemes.
Good communication with local communities before the implementation
of any scheme will also be critical.
(a) If the Government were to allow
financial incentives, what requirement should the Government place
on local authorities as regards:
(i) Existing recycling services—do
you agree with the proposal to require authorities to offer a
recycling/composting service for at least five waste streams to
any household covered by a financial incentives scheme?
Response—It is vital that good recycling
facilities are available to local residents so that the charging
scheme is an incentive to take part. However, requiring councils
to offer a specific (five stream) system across the country may
impact on their ability to deliver value for money.
Placing such a requirement on councils alone may
discourage useful voluntary sector participation in, bottle, clothing
or shoe banks and at civic amenity sites. Similarly, offering
advice on reducing waste, and alternatives which reduce the amount
of material entering the municipal waste stream in the first place
(such as home composting, wormeries, etc) may offer better value
for money rather than stipulating a minimum number of different
types of waste that must be collected for recycling.
(iii) disadvantaged groups?
Response—Charging needs to be carefully considered
in the light of the ability of councils to offer recycling facilities
and the ability of residents to participate. It should be recognised
that a number of local factors could apply that would effectively
exclude some groups from possible financial benefit through reducing
and recycling their waste.
Some particular examples include:
— Those without room to store waste
prior to collection. This applies to kerb-side recycling (for
example, no room to store several bins for "routine"
rubbish) and also to large occasional items such as furniture.
— Housing areas with communal bin stores—which
would effectively be excluded from any personal incentive scheme.
— Transient or newly arrived populations—most
of the examples cited seem to require householders to live at
a location for a year (examples are given over a year). This will
impact on students and migrant workers in particular.
(b) How far should these issues be
determined by the Government, and how far at local level?
Response—The arrangements should be determined
at local level within broad principles.
QUESTION 7:
(a) Do you agree that waste disposal
authorities should have the power to implement financial incentive
schemes at civic amenity sites?
Response—The inclusion of civic amenity
sites in a charging scheme is vital to ensure that waste is not
simply re-directed to them instead of being put out for collection.
There are several possible difficulties.
— A lesser or no charge at civic amenity
sites might encourage additional travel by residents (and a bigger
carbon footprint) taking their waste to sites when it would be
more efficiently collected at the kerbside. — Conversely,
people without access to a car or living far away from a civic
amenity site would be disadvantaged.
— The issue would be further complicated
at the boundaries between different charging schemes, for example
by people using a site in other authority areas because it is
nearer or cheaper.
(b) If so, how could financial incentives
be administered at civic amenity sites?
Response—Others will be better placed
to consider this, but it should accommodate all the factors required
for collection (not encourage fly-tipping, be fair and equitable
to all and encourage minimisation and recycling). How it would
be administered would depend on how the basic kerbside collection
charging scheme is set up, which would be a matter for councils
to determine.
QUESTION 8:
Are there other issues that Government needs to
consider concerning financial incentive schemes?
Response—Councils will need to consider
the value for money of the potential gains from introducing such
schemes against the likely impact and the costs of setting up
and administering the scheme over its whole life. In particular
administrative costs are likely to be affected by the degree of
central control and reporting that is required. In designing any
scheme government should carefully consider the likely burdens
of any new approval or reporting mechanisms.
As with all important new measures, the introduction
of local waste charging schemes would need to be sensitively handled
in terms of local consultation and national messages. At a national
level there would need to be clear leadership on the key issues
that can be reflected at local level.
Audit Commission
October 2007
22 There is also some support from national survey
evidence. When asked "Which of the following statements comes
closest to your views of how retailers are addressing social and
environmental issues?", 5 per cent of respondents agreed
that "Retailers are trying to do as much as they can, as
fast as they can", while 38 per cent agreed that "Retailers
are making some positive steps, but still have some way to go",
41 per cent agreed that "Retailers are only making slight
changes and still have a long way to go" and 11 per cent
felt that "Retailers are not really making any changes and
need to do much more" (Ref 2). Back
23
The CBI has expressed general concerns about PFI procurement delays
and expense (Ref 4). Back
24
That is, acceptability to the funders of privately financed projects. Back
| 
