Landfill Disposals Tax Consultation. May 2015

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1 Baltic House / Tŷ Baltic, Mount Stuart Square / Sgwâr Mount Stuart, Cardiff / Caerdydd, CF10 5FH : : enquiry@waleslink.org Landfill Disposals Tax Consultation May 2015 For the purposes of this response, we have restricted our comments to the Community Wellbeing section of the consultation. QUESTION 27: SHOULD WELSH GOVERNMENT ALLOCATE A PROPORTION OF LANDFILL DISPOSALS TAX REVENUE TO ENHANCE THE WELLBEING OF COMMUNITIES? The Landfill Communities Fund (LCF) has been a great success and has left its mark on community life and the natural environment. We strongly support the use of taxes raised from environmentally damaging activities to support wildlife and community projects as a form of environmental and social justice. WEL strongly supports the continuation and enhancement of the LCF. Under Object DA, the LCF is one of the few remaining funding streams that maintains a direct interest in outcomes for wildlife. Indeed, against the wider backgrounds of austerity and a funding community rarely focussed on nature conservation, this fund is increasingly essential to continue work to halt the continuing, and in some places, devastating, loss of wildlife in Wales. As is widely reported in the groundbreaking State of Nature Report 1, we are in a state of major and continuing decline in wildlife, with 60% of the species in the UK having declined over recent decades. We have quantitative assessments of the population or distribution trends of 3,148 species. Of these, 60% of species have declined over the last 50 years 31% have declined strongly more than one in ten of all the species in the UK are under threat of disappearing from our shores altogether The LCF has: allowed important habitats to be restored to help safeguard Wales s rich, but drastically declining, biodiversity provided healthy green spaces for people to enjoy and connect with nature supported volunteering and skills development opportunities for local communities 1 The State of Nature Report

2 LCF-funded wildlife projects also allow Wales to meet its key environmental objectives and legal obligations: halting and reversing the loss of wildlife/biodiversity by 2050 (with interim targets for 2020) ensuring all statutory designated sites (such as Sites of Special Scientific Interest (SSSIs) and Special Areas for Conservation (SACs)) are in favourable condition by 2026 (with interim targets for 2015) This fund helps the charities to contribute to these government obligations. For example: Wildlife Trust of South and West Wales s (WTSWW) Gwendraeth Grasslands Project restored and enhanced Carmel National Nature Reserve (NNR) SAC and SSSI; Plantlife has undertaken work to conserve nationally and internationally important lichen communities on the Gower peninsular through the control of invasive species; Buglife has carried out detailed invertebrate surveys and habitat management works on brownfield sites within Swansea and Neath Port Talbot to conserve and raise awareness of the importance of this habitat and the range of rare and endangered invertebrates that they support; Coed Cadw/The Woodland Trust has developed the woodland and visitor centre at Plas Power near Wrexham, reaching out to communities close to the site and ensuring that these woods are very much part of the local woodland culture now and for the future; and Butterfly Conservation s restoration of Median Farm, Carmarthenshire: fencing and installation of water supply has allowed this important Marsh Fritillary butterfly site to be grazed for the first time in years. The LCF helps Natural Resources Wales (NRW) to fulfil the Welsh Government s statutory duties to restore sites of national and international importance such as the Carmarthenshire Dunes SAC. The fund has also been used to deliver significant improvements under the Water Framework and Habitats Directives in respect of improvements to riverine habitat, water quality and biodiversity. Withdrawing this fund would mean that the Welsh Government will lose a much-needed mechanism to reach its biodiversity targets and will cause further loss of biodiversity in Wales. The fund helps to support the Well Being Goals in the Well Being of Future Generations Act especially in creating A Resilient Wales A nation which maintains and enhances a biodiverse natural environment with healthy functioning ecosystems that support social, economic and ecological resilience and the capacity to adapt to change (for example climate change). Finally, the LCF is one way that the Finance Ministry can discharge their statutory duties to conserve and enhance biodiversity under the Natural Environment and Rural Communities (NERC) Act 2006, especially in meeting the requirement to take account of biodiversity and more particularly to conserve species and habitats listed under section 42 of that Act. The LCF also contributes to a number of other Welsh Government duties and obligations, including poverty alleviation, improving health and wellbeing, creating jobs, developing and teaching skills, and adapting to climate change. 2

3 QUESTION 28: IF THE WELSH GOVERNMENT ALLOCATES A PROPORTION OF LANDFILL DISPOSALS TAX REVENUE TO ENHANCE COMMUNITY WELLBEING, WHICH OF THE FOLLOWING ACTIVITIES SHOULD BENEFIT FROM FUNDING, AND WHY? WEL recommends that biodiversity conservation must be the priority area for any future funding from the LCF. The LCF is one of the few funding streams for pure biodiversity projects. It has supported, and should continue and expand, this delivery. If funding from the LCF is reduced or removed, the Welsh Government will not achieve its biodiversity obligations and targets as outlined at the top of page two of this response. Biodiversity as a whole is significantly underfunded. This is a key factor in Wales failing to hit the 2010 target to halt the loss of biodiversity 3. However, as the fund is likely to decrease in Wales as the number of landfill sites reduces, we would like to see the fund increase from the current 5.7% diversion rate to being ring-fenced at a minimum of 10%. However, given the social and environmental benefits that biodiversity conservation projects bring, perhaps significantly more of the tax should be diverted towards biodiversity conservation in order to meet the Welsh Government biodiversity objectives. WEL supports the Welsh Government s strategic wider environmental objectives (including climate change mitigation and resilience) as well as compliance, waste minimisation and tackling poverty. However, WEL believes that these objectives can and should be delivered through mainstream government policy and public spending. This will ensure that more funds within this scheme remain available to empower communities and deliver biodiversity projects. As mentioned above, biodiversity-centred projects still help tackle poverty and deprivation in communities, and have benefits for public health and climate change mitigation. QUESTION 29: DO YOU HAVE ANY THOUGHTS ON THE POSSIBLE ADMINISTRATIVE MODEL? Considering the number of landfill sites in Wales is reducing to 10, WEL recommends that there is one Distributive Environmental Body (DEB) in Wales this will help cut down administration and therefore more money should be directed at good causes. It is worth noting that all regulation builds in costs. However, DEBs and charities demonstrate correct procedure by being registered companies and/or charities and are thus subject to regular audits. Setting up a duplicate process would add complexity and administrative burden to charities, which would mean less money for good causes. Current regulation for project funding eligibility states that projects must be in the vicinity of a landfill site. In practice, however, this has often been interpreted as 10 miles as the crow flies. This inflexibility disadvantages projects that just fall outside this area and, in the long-term, could mean an exhaustion of good projects in the 10 mile radius. As the consultation itself acknowledges on page 44, there are relatively few sources of funding for biodiversity. If funding for species and habitat conservation and management relies on their proximity to a decreasing number of landfill sites (even if related operations were added) this means that many species and habitats will continue to decline. WEL recommends that sites within an approximate 20 mile radius of any new or disused landfill site (e.g. have a fuzzy boundary) should be eligible initially. However, we ask that 3 Environment And Sustainability Committee Inquiry into the Failure to Halt the Loss of Biodiversity by %20Sustainability%20Committee%20Inquiry%20into%20biodiversity%20in%20Wales /cr-ld8384-e-English.pdf

4 consideration also be given to removing the vicinity test in order to allow LCF funds to be spent where there is the greatest conservation need and therefore likelihood of success. We would also like to see the definition widened from landfill sites to landfill sites and related activities (such as depots and transfer stations). It must be recognised that funds committed through a contract are not easy to spend within short timescales (e.g. the Welsh Government s Nature Fund). Indeed, it is vital for the success of conservation projects to have funders who can commit to funding long term projects (3-5 years). Reducing the length of projects means increased administration costs for both applicants and the Distributive Environmental Body. Furthermore, most environmental projects need several seasons to be implemented and to carry out effective monitoring. It is also vital to recognise that there is a big difference between unspent funds and funds retained by a DEB that are already allocated for multiple-year projects, released on a yearly basis. Therefore, WEL recommends that the fund must continue to allow multi-year projects. It should also be recognised that this fund helps to unlock significant match funding (independent funding organisations and volunteer hours). It is therefore important that the fund continues to fund projects by 90% - this could be increased to 100% funding. We would encourage the Welsh Government to take the opportunity to look at other avenues for green taxation and how these might be used to fund the Welsh Government s statutory nature conservation obligations. WEL Recommendations Biodiversity conservation must be the priority area for any future funding from the LCF The LCF should be increased to 10% of the Landfill Disposal Tax There should be one Distributive Environmental Body (DEB) in Wales There should be no duplicate process set up that would add complexity and administrative burden to DEBs and charities, which would mean less money for good causes Because of the likely contraction of the number of landfill sites, WEL would ultimately like to see the removal of the location criteria. In the immediate future the eligibility criteria should be within 20 miles of a landfill site or related activities Biodiversity projects should be judged against their compatibility with meeting the Aichi targets, contribution to the Wales Biodiversity Action Plan and conservation of species and habitats that are listed under section 42 of the NERC Act 2006 The definition should be widened from landfill sites to landfill sites and related activities (such as depots and transfer stations) The LCF should continue to fund projects by 90% or increased to 100%. The LCF fund must continue to allow multi-year projects to reduce administrative burdens for applicants and the DEB, and to ensure that effective long-term projects can be implemented and monitored Welsh Government should take the opportunity to look at other avenues for green taxation and how these might be used to fund Welsh Government s statutory nature conservation obligations.

5 Wales Environment Link (WEL) is a network of environmental, countryside and heritage Non-Governmental Organisations in Wales, most of whom have an all-wales remit. WEL is officially designated the intermediary body between the government and the environmental NGO sector in Wales. Its vision is to increase the effectiveness of the environmental sector in its ability to protect and improve the environment through facilitating and articulating the voice of the sector. The following WEL members support this document: Afonydd Cymru Bat Conservation Trust Buglife Bumblebee Conservation Trust Butterfly Conservation Wales Coed Cadw / Woodland Trust Plantlife Cymru RSPB Cymru Vincent Wildlife Trust Wildlife Trusts Wales Youth Hostels Association Registered Charity Number / Rhif Elusen Gofrestredig: Chair / Cadeirydd : Bill Upham Director / Cyfarwyddwraig : Susan Evans