The GMA is aware of the growing concerns within the groundscare sector with regards to the upcoming change in red diesel legislation in April. Whilst we are yet to see the change in proposed legislation we have been advocating for, we are still in communication with Government and continue to seek clarity concerning the use of red diesel. The following update clarifies what the GMA has said previously in response to the consultation with Government and how recent communications with Government have gone.
How the GMA responded to the original consultation
The GMA was involved in the original consultation with Government on reforms to the tax treatment of red diesel and other rebated fuels and a summary of our response, in collaboration with BALI, stated that:
- Removing the entitlement of red diesel for groundscare and sport turf maintenance would lead to increased costs, reduced outputs, and impact the surfaces that end users rely on
- Maintenance schedules would be reduced at sports grounds at all levels, parks, and fields etc due to increasing costs
- It could reduce the safety and quality of sports surfaces as a result
- With lack of viable alternatives for some clubs and organisations, they would not be able to maintain certain areas
The GMA also confirmed that removing the entitlement would impact on the price of goods in the sector and cause prices to rise in the long-term supported by evidence to back the claims. Concern was stated about the lack of clarity provided by the consultation in relation to landscape, grounds, and sports turf maintenance, winter maintenance operations and amenity weed management.
A list of questions from the consultation, and our responses in full which cover the above in more detail, can be found at the bottom of the page.
What the GMA has done to address current legislation
As the current form of legislation does not cover a number of areas of our members’ work in the groundscare sector, we have sought clarification from Government and have been advocating for an exemption for the sector in the same way that golf is expempt.
The GMA has been in communication with a Cabinet MP who understands the issues that the current form of legislation creates and has raised our concerns with colleagues in the Treasury to seek a clarification on legislation. In his letter to the Treasury that was shared with the GMA, the MP states that:
The GMA “has raised concerns that the current guidance indicated that you can use red diesel on a tractor and mower to move on the verges alongside a road or highway, but not as part of grounds maintenance as it is deemed as HMRC does “not regard this as horticulture”.
In addition, the GMA “has explained that the current guidance states that golf clubs may use red diesel, but there is absolutely no distinction between a golf club and a sports pitch, such as those indicated above. Furthermore, there seems to be a conflict within the guidance as I understand community amateur sports clubs were apparently included in the guidance of 29th November 2021 but then there is another part of the same document that says red diesel cannot be used after all.”
“I would be most grateful if you would look into the concerns which my constituent has raised above and let me have your comments, so that I may respond to my constituent in greater detail. I would be particularly grateful if you could clarify the guidance as it is clear that grounds management should be considered horticulture. This is particularly important in the context that the Premier League, The FA, and the Government’s Football Foundation has set out the mission to improve over 7000 grass pitches by 2024 and 20,000 by 2030 to ensure the 12 million grassroots footballers have great places to play. However, without the acceptance that the maintenance and improvement of sports pitches is horticulture, this will obviously have a significant effect on the outcome of the new initiative.”
We understand the concern within the sector and, whilst the situation in Ukraine and subsequent fuel crisis will likely have increased pressure on the industry and delayed action by Government, our exchanges with Government have been positive, particularly as the MP has suggested that “it is clear that grounds management should be considered horticulture”. As golf courses have been given an exemption, our belief is that the same should also be applied to our sector and conversations have been encouraging. Whilst the events in Ukraine have likely taken precedence in recent weeks, we hope to receive a further update soon.
We have made positive progress over recent months in gaining the support of a Cabinet MP and having our argument for an exemption taken to the Treasury for review. Whilst we have shared examples with Government of why an exemption is needed for the groundscare sector, we want to encourage our community to share their own individual stories to help us in our upcoming conversations with Government.
The GMA is looking to gather more individual stories from those who will be affected by the change in legislation about how their work will be impacted and the negative implications this will have on both professional and community sport.
If the change in legislation will affect you, please get in touch with us at firstname.lastname@example.org and share your experiences on how the change in legislation will impact:
- Your current red diesel consumption and costs
- The operational and financial capacity of your ability to shift to alternatives to red diesel
- Your capacity to pass through costs down the supply chain
- Your ability to absorb extra costs
- Your ability to continue your work and what the negative effects of not being able to do so might be ie. to local sports pitches, clubs’ abilities to continue, etc.
The GMA will continue to share updates with our membership and the wider sector when further information is received.
Our response to Government consultation on reforms to the tax treatment of red diesel and other rebated fuels
Our complete responses, in collaboration with BALI, to the following questions were as follows:
1. Will removing the entitlement to use red diesel in your sector create perverse environmental outcomes? If so, please explain how, providing relevant evidence.
Removing the entitlement to use red diesel in the groundscare and sports turf maintenance sector will inevitably lead to reduced outputs and substandard and unkept areas of landscaping and playing surfaces. Sports such as football, rugby, cricket, horse racing, tennis etc. all rely upon good quality maintenance to provide the necessary surfaces for their respective sports, along with parks and areas of parkland that rely on being maintained for utilisation by the public.
Any increase in fuel cost will lead to a large reduction in maintenance works within these areas in order to fit future budgets.
Large sports fields and complexes require a significant level of management to ensure their continued success and contribution to the sport and environment. In order to maintain and upkeep these facilities it requires the significant use of diesel-powered equipment.
2. How will removing the entitlement to use red diesel in your sector impact your organisation? Please provide details on:
- (a ) Your organisation/sector’s current red diesel consumption and costs, including as a proportion of total costs, and broken down by different uses (i.e. what types of vehicles and machinery)
- (b) The operational and financial capacity of your organisation/sector to shift to alternatives to red diesel (specifying what these alternatives are)
- (c) The capacity of your organisation/sector to pass through costs down the supply chain
- (d) The capacity of your organisation/sector to absorb extra costs
a) The removal of the use of red diesel will affect the sports turf and groundscare industry directly if the intention is to include these areas where red diesel is withdrawn post April 2022.
Large contractors may spend more than circa £500,000+ per annum on diesel for mowers, tractors and machinery associated with all aspects of landscape construction and maintenance. An increase for these types of contractor could see an increase of circa £200,000 per year and many of these service Local Authorities!
b) The groundscare industry is 90% made up of grassroots sports and organisations who struggle to run, maintain, and provide with the current running costs. There are electric hand-held tools and passenger vehicles but are way out of the price range currently. The popular machinery is all powered by diesel and petrol engines and whilst there has been minimal change to battery/electric powered it is very much a slow burner and will not become the norm within the short/medium term.
C) We have all faced significant financial pressure due to Covid and this has exaggerated the pressure within the groundscare/sportsturf industry. Most clubs and organisations may not be able to resume a return to sport due to financial pressure and this has in turn put pressures in the local community and sport participation.
d)The extra burden of increased fuel costs would have a massive impact on the sportsturf/groundscare industry at a time it is already facing significant challenges.
3. What impact do you expect the removal of red diesel entitlements from most sectors will have on the environment and on air quality? Please provide any evidence you deem relevant.
The impact of removing red diesel from groundscare/sportsturf industry and organisations will have a small impact on the environment and air quality. Some manufacturers have made a move to electric powered machinery, but this is very limited and does not really cover the larger equipment/machines.
Minimum viable alternatives that are capable of performing the same tasks will lead to clubs/organisations/contractors etc. simply not being able to maintain areas.