MEMORANDUM BY EB NATIONWIDE LTD (DSW 31)
E B Nationwide Ltd is an enrolled environmental
body which distributes Landfill Tax donations to other environmental
bodies within our "family" and direct to projects. Given
E B Nationwide Ltd's role, I intend to restrict my comments to
the topic area:
"a reduction in the amount of waste sent
to landfillin this context, the sub-committee would welcome
views on the effects of landfill tax and its associated credit
scheme".
COMMENTS ON
LANDFILL TAX
It is good that the Government has made everyone
aware that the Landfill Tax will increase by £1 per tonne
per annum until 2004. Waste producers, local authorities and the
waste management industry all need to have a relatively certain
market in order to ensure that waste is dealt with in the most
effective way. The waste management industry does take some time
to make significant changes, given the fact that it can take many
years for planning permission to be forthcoming for new facilities.
If Government wished to make a significant impact on how people
dispose of their waste, consideration should be given to announcing
soon a significant increase in the landfill tax at some future
date, say April 2005. This would ensure that all the parties involved
know that the current system of sending the majority of waste
to landfill would have significant cost implications in 2005.
This lead time would enable some new facilities to be planned
and brought into operation in anticipation of the changed fiscal
arrangements and communities helped to adjust to and accept social,
behavioural changes required.
LANDFILL TAX
CREDIT SCHEME
We operate a "family" of environmental
bodies. The majority of the environmental bodies within our "family",
have an advisory group made up of local people living near to
the landfill operations. This advisory group makes recommendations
on all applications that are received by that environmental body
and, where appropriate, prioritise the projects for implementation.
Each advisory group has a different group of members. Some have
councillors (district, county, community, parish, borough), individuals
from organisations such as voluntary groups, wildlife trusts,
friends of the earth, etc. and local authority officers. The exact
make-up of the advisory group is dependent upon local circumstances.
It has been found that the local input is invaluable to the environmental
body in making decisions on which projects to support. It also
ensures that the local communities feel that there is local representation
in deciding which projects are being implemented.
The environmental bodies themselves are companies
limited by guarantee with the directors generally coming from
a business background. It was recognised that there needs to be
a tie-in with local authorities and in the majority of cases there
is a senior officer from the local authority on the environmental
body as a director. Again, it has been found to be very beneficial
in as much as it aids the smooth operation of the implementation
of some of the projects. All the directors are appointed on a
voluntary basis. They are able to claim out of pocket expenses
(but few do). I believe that they see it as giving something back
to the community.
E B Nationwide Ltd is slightly different in
as much that it looks at projects predominantly for category c
and ccwaste research and development, etc.therefore
it does not have an advisory group.
COMMENTS
Over the last three years the Landfill Tax Credit
scheme has:
delivered many local amenity projects;
been seen by people local to landfill
sites as some recompense for having the disbenefit of living near
to a landfill site;
has delivered a new private sector
funding source;
has developed new community partnerships
and, in many cases, improved environmental conditions;
RECOMMENDATIONS
1. The principle of the scheme should be
retained ie the landfill operator should make a voluntary donation
to environmental bodies and neither the landfill operator nor
the local authority should control the operation of the environmental
body.
2. In order to fund the implementation of
Waste Strategy, national environmental bodies should be established
to co-ordinate the implementation of the various UK waste strategies.
The finance for this should come from within the 80 per cent of
the Landfill Tax that is currently retained by Treasury or increase
the 20 per cent cap to 25 per cent to enable Landfill Operators
to donate more. There is a fear from a number of communities that
local amenity projects will be down-graded as a result of a greater
emphasis being placed on the implementation of The Waste Strategy
and Category c type projects.
3. A panel of experts from Government departments,
the waste industry and academia should be established to enable
environmental bodies with applications for research and development
projects to get advice on technical or complex issues and this
should be made public and accessible.
4. Groupings of environmental bodies, such
as funded distributive environmental bodies (FDEB) should be encouraged
to work together to develop best practice and, where appropriate,
commonality of procedures.
5. Bids for funds from our "family"
of environmental bodies are significantly oversubscribed. However,
the local input from the advisory groups is a way to be transparent
and fair in the allocation of funding. This should be encouraged.
6. Of a greater concern are the projects
that come forward under categories a, b and c, where there could
be commercial gain. The Regulator should ensure that the guidelines
for taking on these projects are firmly set so there are no opportunities
for money being lost outside the system.
7. There are significant numbers of environmental
bodies that have been enrolled by ENTRUST and had projects approved
who have yet to receive any donation from a landfill operator.
These unfunded environmental bodies should have the option of
resigning their environmental body status and subject to them
having complied with all requirements be able to have their enrolment
fee of £100 returned. This will enable ENTRUST to concentrate
its efforts on the environmental bodies that are funded.
8. Whilst the requirement that the value
of any assets purchased for a pilot project should be retained
within the Landfill Tax Credit scheme, there are instances whereby
it is in the public interest that such assets could be retained
for the benefit of the longevity of the project. For example E
B Nationwide Ltd is currently funding a pilot project to have
paper-free administration in schools. The contributing third party
is DfEE. The project involves the establishment of computer hardware
within a number of educational establishments so that communication
can be made in electronic form to minimise the amount of paper
that is transferred. At the end of the pilot project, the hardware
would have to be sold to the highest bidder in order to comply
with the current rules from ENTRUST. Depending on the value of
the items at the end of a say two or three year period the cost
of removal would give an additional burden to the establishments
that had taken part in the pilot project. It seems to me that
there should be some scope for allowing the pilot project to be
turned into a fully developed implemented project without the
need for the assets to be valued and the money given back to the
environmental body. It is accepted that the principle of value
being retained within the Landfill Tax Credit scheme should be
preserved. However, in individual cases where the public is benefiting
from the continuation of such a project it should be possible
to have a degree of pragmatism.
CONCLUSIONS
The scheme itself is extremely successful and
oversubscribed. How to fund the Waste Strategies is a challenge.
However, it should not result in environmental bodies having less
money to fund amenity projects. Whilst there have been isolated
instances of alleged corruption, the overall scheme has delivered
far greater than was originally envisaged.
Local Authorities play a valuable role but local,
specific communities are sometimes overlooked in the hurly burly
of local politics. We can listen to the advice of local politicians
but ensure decisions are independent and robust.
September 2000
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