MEMORANDUM BY THE ENVIRONMENTAL BODIES
COUNCIL (EBCO) (DSW 113)
1.1 The Landfill Tax Credit Scheme was introduced
as part of the Landfill Tax Regulations on 1 October 1996. This
enabling legislation required the appointment of a Regulator for
the scheme. ENTRUST, a not for profit regulatory body, was appointed
by HM Customs & Excise to be responsible for the regulation
and administration of the scheme. The Regulator was required by
HM Customs & Excise to facilitate the setting up and resourcing
of a representative user group. The purpose of this user group
(EBCO) was to provide the regulator with advice on the operation
of the credit scheme and feedback from Environmental Bodies (EBs)
enrolled within the scheme.
1.2 EBCO welcomes the Environment, Transport
& Regional Affairs Committee's intention, as highlighted in
press notice No. 50 of Session 1999/00 dated 27 July 2000, to
examine whether the policies set out in the 1998 report on sustainable
waste management are sufficient to deliver that objective. With
particular interest in whether sufficient measures and financial
resources are in place to support the implementation of those
policies. Therefore, EBCO wishes to contribute to this important
debate by providing relevant evidence from its experience of the
operation of the Landfill Tax Credit Scheme. The purpose of this
scheme and its preset objectives will be of particular relevance
to the following key areas of interest highlighted in press notice
More efficient use of resources and
a consequential reduction in the amount of material entering the
An increase in recycling of waste,
particularly by greater development of markets for recycled material
(including compost) and the use of producer responsibility measures.
A reduction in the amount of waste
sent to landfillin this context, the sub-committee would
welcome views on the effects of the landfill tax and its associated
Sufficient action to educate the
public about the importance of sustainable waste management.
2. EBCO WORK
2.1 EBCO was set up by ENTRUST to provide
feedback on the operation of the credit scheme. In order to interact
with the growing UK wide network of EBs (2200 on 14.09.00) and
to provide both feedback and advice, EBCO with support from ENTRUST,
has developed the following range of communication mechanisms:
2.1.1 Quarterly Newsletter
EBCO has produced a quarterly newsletter which
is circulated to all enrolled EBs by ENTRUST. EBCO has full editorial
control of the newsletter and uses the publication to inform EBs
and encourage dialogue.
EBCO has developed and manages a multi-access
website (www.EBCO.org.uk.) and direct line telephone number of
provide online access and support for EBs. This website includes
regularly updated information relevant to the scheme and a bulletin
board available to all EBs to enable "online" discussion
and debate on key issues affecting EBs.
2.1.3 Regional Meetings
EBCO has developed a programme of regional meetings
for EBs. These regional events are managed and provided by an
independent facilitator with the primary objective of initiating
debate and capturing qualitative feedback on the operation of
the scheme. This feedback is shared with the Regulator and used
to amend, adapt and develop the scheme's procedures and processes.
2.1.4 EB Workshops
EBCO has worked with the Regulator to create
a series of focused workshops, which bring together a variety
of EB organisations to test and advise the regulator in respect
of proposed scheme developments. These workshops have been formed
to comment on the appropriateness of changes to report forms and
the development of clear "user friendly" guidelines
for organisations wishing to enrol as EBs.
EBCO, in partnership with the Regulator has
been involved in the development of a series of regional fora
across the UK, which bring together EBs, landfill operators, local
authorities, academic institutions and other interested parties
to discuss in open forum issues affecting the scheme, its achievements
and future development.
2.2 The above comprehensive portfolio of
programmed activities has ensured that the Regulator is made aware
of key issues impacting on the effectiveness and efficiency of
the scheme. But additionally to ensure that EBs have a mechanism
to be both listened to and heard. This approach has provided EBCO
with a unique insight into the UK's largest co-ordinated network
of locally based agents for sustainable environmental improvement.
3. EBCO PERSPECTIVE
3.1 EBCO from its inception in 1997 has
endeavoured diligently to maintain within its structure, a breadth
of representation, which covers both the geographic spread and
diverse type of EB. The popularity of this scheme, the significant
resources available and the breadth of permitted applications
have resulted in a considerable diversity of EB type. Fundamentally,
there are two generic types, ie those, which distribute funding
on behalf of landfill operators and those, which receive funds
to carryout projects.
3.2 However, the nature of those receiving
and some of those distributing have become quite specialised.
For example, some EBs are single issue focused and may be universities,
local community networks or existing voluntary organisations,
with a focus on particular issues, such as local environmental
improvement, waste minimisation, tree planting, historic building
restoration or public amenity development. This has led to the
development of a very diverse range of active organisations. The
popularity of the programme and the enthusiasm with which it is
approached, can be confirmed by the large number of enrolled bodies
(2200) currently registered in the scheme. Funded EBs are currently
participating in 4000 approved projects across the UK.
3.3 The most recent available statistics
indicate that around 20 per cent of funded EBs are working exclusively
on Objective C & CC (sustainable waste management & market
development) projects. However, further analysis of the statistics
indicate that almost 45 per cent of all funded EBs have elements
of their programmes with projects within object C and CC categories.
EBCO believes that this important network is rapidly becoming
an infrastructure, with the capability of making a significant
difference in terms of a greater opportunity to recycle, a reduction
of landfill volume and promoting the behavioural changes required
to underpin future sustainable waste management initiatives. Additionally,
EBCO is aware that the EB network has recently launched two linked
steering bodies to encourage the development of object C &
CC projects and to provide co-ordination of the scheme's activities
with other research. The two organisations are, the Information
and Access Steering Group (IASG) and the Value Enhancement Steering
Group (VSEG). Both groups should contribute significantly to enhancing
the effectiveness and value of the credit scheme as it develops
further sustainable waste management initiatives.
3.4 EBCO notes the sub-committee's interest
in the impact of the credit scheme on the reduction of landfill
volume. Undoubtedly the sub-committee will already know that the
encouragement of more sustainable waste management activities
is one of a series of approved objects for the credit scheme.
It is therefore worth noting that in addition to the network described
above, approximately 29 per cent of deployed credits to date are
being used on projects which fall within this objective (categories
C & CC). This reflects a financial expenditure of almost £40
million distributed across 866 independent projects.
3.5 EBCO acknowledges that this is a significant
impact and that the credit scheme has the potential for even greater
impact, although some changes in the enabling legislation may
be required if the intention is to focus more directly on waste
minimisation outcomes for the scheme. Equally importantly, EBCO
would like to stress the real value of the UK wide network, which
has developed within the credit scheme. This network properly
informed, resourced and deployed provides a significant potential
to address and achieve progress on many of the issues highlighted
in press notice No. 50.
4.1 EBCO's interaction with the EB network
highlights considerable support for the scheme. EBs are concerned
Ensure a greater provision of information
about the scheme.
Create greater degrees of consistency
in respect of distribution mechanisms.
Simplify the administration.
Increase communication between the
Encourage a review into the barrier
created by the scheme's requirement for a 10 per cent contribution
from the landfill operator, or as is frequently the case (estimated
as 75 per cent of cases) a third party, to release the tax credits.
4.2 EBCO wholly endorses the landfill tax
credit scheme as an imaginative response to releasing resources
to achieve sustainable environmental improvement and, in particular
sustainable waste management.
4.3 EBCO would further encourage the sub-committee
to consider recommending a greater percentage of the tax recovered
(currently up to a maximum of 20 per cent) to be made available
for resourcing the growing network of EBs.
4.4 It may be worth the sub-committee considering
that any increase in the percentage currently available could
be dedicated, or ring-fenced for waste minimisation objectives.
This would have the effect of underpinning the existing breadth
of environmental projects while encouraging the network to increase
activity in respect of sustainable waste management initiatives
at a local level.