Afonydd Cymru
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5th January 2017
Landfill Disposal Tax (WALES) Bill: comments from Afonydd Cymru Cyfengedig
1.1 Afonydd Cymru is the umbrella body for the six Rivers Trusts of Wales1. These trusts are all registered charities who actively work to restore our rivers and catchments. Their work is essentially hands on restoration, using a variety of funding sources including EU, governmental grants and of relevance here, the Landfill Community Tax. In respect of the latter some of our trusts have successfully bid for and used Landfill project funding both sides of the border. These projects will have gone towards ensuring compliance with the Water Framework and Habitats Directives and restoring rivers and fisheries with wide ranging public benefit.
1.2 The trusts’ work brings them into daily contact with waste, litter, fly tipping and simply using our rivers as conduits for plastic sacks and anything that can be thrown down a bank or over a bridge.
1.3 The whole concept of taxing landfill and using the benefit for both common good and via the communities scheme is one that resonates with all the rivers trusts. The issues of having the correct legislation in place and ensuring landfill regulations are workable, ie neither too onerous nor costly are clearly important to us.
1.4 We have read the policy intent and the Terms of Reference of the Inquiry and the various downloadable documents. The area we are competent to comment on is the Landfill Communities Scheme (LDTCS). The other aspects of the scheme seem to our layman’s view, eminently satisfactory.
2 Landfill Communities Scheme (LDTCS)
2.1 We think the proposal to deliver funding as a grant scheme with a single distributive body is good, as are the general principles (p6)
2.2 Likewise the project themes seem better aligned with both need and the overall objectives of the tax than hitherto. Our next comments focus on the Biodiversity section (2.12 p7).
1 The Wye and Usk Foundation, Severn Rivers trust, The Dee trust, Conwy, Clwyd and Gwynedd trust, Southeast Wales Rivers trust, West Wales Rives trust
Ffon: 07812118065 ebost: stephen@afonyddcumru.org www.afonyddcymru.orgorg
Afonydd Cymru is a registered charity No 1145675 and company limited by guarantee, registered in England and Wales no: 6742270
Registered Office: 23 College Street, Lampeter, Ceredigion, SA48 7DY
2.3 Geographic coverage was always a difficulty with the ten mile radius and a reduction to five might seem to target those most affected by a landfill site. Incidentally, Entrust altered or reinterpreted the regulation in respect of work to restore rivers by allowing work on any river that ran through the 10 mile zone.
2.4 As the ‘whole catchment management’ concept becomes the norm for environmental management, might it be feasible to use the presence of a landfill in any given catchment as the proximal yardstick rather than the rather arbitrary 5 mile circle? Thus the presence of a landfill site in, say for example the Cynon catchment, would enable a project anywhere within that area? The problem for Biodiversity projects is that need is not a function of proximity to landfill sites
2.5 Currently one of our trusts is working on a project to restore the river Arrow which crosses the border near Kington with work taking place both sides while the project is funded from landfill on the welsh side. We recommend that the consideration of cross border issues is considered: the reverse situation holds in the forest of Dean for example.
2.6 There is another funding source akin to landfill in Wales. This is the Aggregate Levy fund http://www.mineralproducts.org/documents/Aggregate_Levy_Fund_Leaflet.pdf. We wonder if this could be combined with the Landfill tax communities scheme working under the same distributive body, simplifying procedures, directing more funding to the “sharp end”?
Dr Stephen Marsh-Smith OBE
CEO Afonydd Cymru
Advisory Director Wye and Usk Foundation