Memorandum by ENCAMS
ENCAMS RESPONSE
ENCAMS is pleased to submit evidence to the
Communities and Local Government Committee inquiry into the provision
of public toilets. We welcome the opportunity that this provides
to demonstrate public toilets are an important service. They create
town and city centres where people want to spend their time. Unfortunately,
public toilets are also costly to maintain and bring up to standard.
They are also targets for anti-social behaviour. ENCAMS believes
that provision should be fair across all groups based on their
need, and while we appreciate that this is difficult to achieve
it should not be an excuse to close toilets down. Rather local
authorities can show leadership by preparing strategies and innovative
schemes such as charging, community toilet schemes, private sector
partnerships and audits.
ABOUT ENCAMS
ENCAMS is an independent, registered charity
that works with major land owners and private sector bodies to
bring about sustained improvements in the quality of local environments.
We also campaign directly to the public and are probably best
known for our Keep Britain Tidy campaign that has been running
for over 50 years and aims to get people to stop dropping litter.
Over the past seven years the remit of ENCAMS
has widened so that we are now much more than just an anti-litter
charity. We tackle a broader range of issues including graffiti,
fly-tipping, community safety, dog fouling, neighbour noise and
nuisance vehicles. In addition to our campaigns, we also run a
number of programmes and award schemes for those individuals and
agencies involved in managing land. These include the Cleaner
Safer Greener Network, Eco-Schools and Blue Flag. We are also
responsible for the single, most definitive survey of the state
of cleanliness in England: the Local Environmental Quality Survey
of England.
ENCAMS receives grant-in-aid from Defra, whilst
additional income is obtained through other government departments
and external funding sources.
1. The need for public toilets—access
to public spaces, the needs of older people, disabled people,
children and families?
— Public toilets are important. People
need to access toilets when away from home and their closure,
lack of availability or generally poor standards can be a cause
for concern among would be users. On the other hand, if well-planned,
designed, maintained, clearly signposted and available when people
want to use them, toilets can contribute to local economies by
creating town and city centres where people want to spend their
time and consequently their money.
— In a survey carried out by ENCAMS
to gauge opinion on public toilet services, 84% of respondents
wanted more provision. This percentage was even higher within
certain age groups with 88% of 16-24 year olds and 91% of 55-64
year olds stating there should be more provision.
— Not only do the public want more
toilets they want the facilities to be of a good standard. Research
carried out on behalf of the National Consumer Council indicated
that almost all of the 2,000 people surveyed wanted their local
council to make sure public toilets reached a high standardi.
— Planning for inclusive public places
with services that are accessible to everybody must include toilet
facilities. At the moment, toilets are normally managed by local
authority Street Service Teams and seldom considered as part of
urban design. Local authorities should produce a toilet provision
strategy that all departments including Planning, Maintenance
and Regeneration must follow.
— Toilets should be placed in key areas
such as town centres, parks and leisure areas, tourist spots,
along main routes into towns and cities and strategic spots in
suburban areas. Toilets should be located so that they fit in
with the way public places are used both economically and socially.
— As government tries to encourage
more people to use public transport or cycle, toilet provision
is declining, making sustainable travel difficultii. ENCAMS believes
that toilets must be available at transport interchanges and at
key points along main access routes so that people travelling
on public transport, cycling or walking have facilities available
to them.
— A survey carried out by ENCAMS found
that 38% of women will choose not to visit an area or spend less
time there if toilet provision is inadequateiii. This is because
of all groups women are most likely to be accompanied by young
children and elderly relatives who have a greater need for toilet
facilities.
— The same conclusion can also be made
in respect of disabled people who are even more restricted in
where they can spend their time depending on the facilities available.
There are over 10 million disabled people in Britain with over
one third of people over 50 registered as disablediv. This is
a large group with an annual spending power of around £80
billionv, making a considerable impact on the economy.
— Baby change units are almost always
found in female toilets and ENCAMS would like to see more in male
toilets or the provision of family rooms so that men with young
children have facilities available to them.
— Change facilities are often designed
for babies, older children and adults with disabilities may also
require them.
2. Why provision has declined—the role
of anti-social behaviour such as vandalism and drug taking, the
image of public toilets (including cleanliness), and the cost
of upkeep
— Over the past decade there has been
a steady decline in local authority provision of public toilets.
In some places they are totally missing. Free toilets at major
railway stations have largely disappeared.
— ENCAMS believes there are at least
two reasons for the closure of public toilets: (i) the cost of
bringing toilets up to standards set out in the Disability and
Discrimination Act 1995 and (ii) the nuisance and damage caused
by anti-social behaviour.
— The Disability Discrimination Act
was intended to improve access for disabled people. However, some
local authorities are using it as an excuse to close down existing
public toilets that do not meet the standards set out in the Act.
— ENCAMS believes that this attitude
goes against the spirit of the law and compounds the problem for
those with disabilities, allowing even fewer choices about how
they spend their time in the community. The Act was intended to
give disabled people the same access to services that people without
a disability enjoy and take for granted. It was not intended to
reduce the level of service for everybody.
— ENCAMS would like to see guidance
produced to stop local authorities from closing facilities because
they do not meet requirements for the Disability Discrimination
Act. There should be an obligation on local authorities to upgrade
facilities to the standards set out in the Disability Discrimination
Act and not close facilities because of it.
— Public toilets are often the target
of vandalism and anti-social behaviour and because of this are
seen as a problem by local authorities rather than a benefit to
the community.
— There are several forms of anti-social
behaviour which particularly affect public toilets such as graffiti
and vandalism, drug use, homelessness and importuning. In an attempt
to solve these issues local authorities will close down or restrict
opening times.
3. Who pays: should local authorities provide
free toilets, should the public pay; should local business contribute?
— Toilets that are clean and well-kept
are popular and heavily used despite charges being made for them.
However, local authorities should consider that some people are
unhappy paying for toilets. In a survey conducted by ENCAMS, 36%
of respondents said they would not pay to use a public toilet.
Of the remaining respondents, most said they would not pay more
than 20 pencevi.
— ENCAMS recognises that charging a
fee for toilets may be the only way to ensure that there is a
decent standard of provision but would like to see a proportion
of public toilets in key areas that are available free of charge.
— ENCAMS supports the repealing of
the statutory prohibition on charging for the use of urinals contained
in the Sex Discrimination Act (Amendment) Regulations, which come
into force in 2008. Local authorities should be able to charge
for toilet provision but the fee must apply to all who use the
facilities. This will create new scope for incentives for better
provision.
— Working in partnership with local
businesses and transport operators could significantly improve
the number of available facilities.
— Local authorities should also open
up toilet facilities in public buildings such as libraries, museums
and town halls.
— Local authorities may also be able
to leverage funding from planning notice 107 to fund the build
and maintenance of public toilets.
— Private investment could be used
to fund toilets or, more radically, toilet provision could be
made a condition of planning permission for new developments.
4. Opening hours and other accessibility
issues
— Local authorities should assess provision
by carrying out audits. These audits should be aimed primarily
at improving facilities and not to justify closure.
— If there are toilets beyond repair
or no longer used, there should be a public consultation before
they are closed or demolished. Public toilets should only be closed
if there is a clear case that the facility is no longer viable
and that the community is in favour of closure.
5. Security—should toilets be staffed,
un-staffed, automated?
— As outlined above, ENCAMS believes
that local authorities should use audits to assess what level
of service they provide in order to improve services. Whether
a toilet should be staffed, un-staffed or automated is likely
to depend on its own unique location and usage, and therefore
the decision is best made at the local level.
6. The gender balance—are men and women
being unfairly served by current provision?
— Research shows that more women than
men are out and about shopping and spending time in the community.
A survey carried out to support the revision of the British Standard
for public toilet provision highlights that at any one time women
outnumber men 70:30 in shopping centres and this ratio can go
as high as 90:10 in some placesvii. Yet male toilets often outnumber
female toilets by 2:1.
— ENCAMS would like to see a fairer
ratio. The British Toilet Association suggests there should twice
as many facilities for women as for men, one cubicle per 550 females
and one cubicle or urinal per 1,100 malesviii.
— Where urinals have been installed
specifically to target late night street fouling it should not
divert resources away from general toilet provision that would
benefit both men and women.
— Not all biases are in favour of men
though. Baby change units are almost always found in female toilets
and ENCAMS would like to see more of these in male toilets or
the provision of family rooms so that men with young children
have facilities available to them.
7. Provision beyond the local authority—innovative
schemes to encourage shops, cafes, pubs and other businesses to
provide toilets to more than paying customers
— While the number of local authority
public toilets are declining, they are being replaced to some
degree by commercial provision in town and city centres. Department
stores such as John Lewis, Debenhams and larger Marks & Spencer
have free toilet access. As they usually have lifts there is wheelchair
access too. Fast food outlets such as McDonalds and Burger King
are also plentiful and have toilets, although they frown upon
non-patrons using them. Generally speaking, the privately provided
toilets are cleaner and safer than the old local authority toilets
used to be.
— ENCAMS believes that if local authorities
worked in partnership with private businesses and transport operators
it could significantly improve the number of available facilities.
There are already innovative schemes in place in some areas such
as the community toilet scheme in Richmondix. Local authorities
could also consider private provision of modular toilets. Opening
up toilet facilities in public buildings such as libraries, museums,
town halls could also increase the number of facilities available.
— Some businesses see good toilet facilities
as an asset. If they bring people off the street into their store
simply to use the toilet they are more likely to buy from their
shop. Others may need to be convinced as they will only see the
overhead costs associated with running the facilities.
— If local authorities viewed public
toilets as an asset to their town or district far fewer toilets
would be closed down and there would be a much higher standard
of provision. Rather than seeing them as a nuisance, public toilets
should be viewed as a valuable addition to an area that will attract
more people for longer periods and improve the local economy and
appeal of an area.
8. Tourism—does public toilet provision
play a part in the attractiveness of our towns and cities?
— Toilet provision can play a part
in the attractiveness of towns and cities and other popular tourist
destinations too. Research carried out by ENCAMS found that over
60% of visitors considered the availability of public toilets
as an important factor when deciding on a beach to visitx. Toilets
were given the highest rating of all the facilities and were felt
to be an important factor regardless of the length of stay. Toilet
provision was so important for some (14%) that they researched
beaches first to see what provision there wasxi.
— The experience of ENCAMS team of
surveyors is that principal seaside resorts such as Blackpool,
Bournemouth, Bridlington, Brighton, Scarborough and Torbay are
well-provisioned when it comes to public toilets. In fact, the
Blue Flag award scheme that ENCAMS administers in England on behalf
of FEE (Foundation for Environmental Education) requires adequate
toilet provision and we survey toilets as part of the assessment
for this award. Blue Flag is an international award scheme that
recognises beaches that have achieved the highest quality in beach
management, water quality, safety and environmental education.
In 2007, England celebrated 20 years of Blue Flag with 85 awards.
The number of awarded has risen steadily since 2000, when there
were just 24 awards. The 2008 awards are scheduled to be announced
towards the end of May 2008.
9. Environmental impact of toilets
— ENCAMS would like the Committee to
consider as part of this inquiry the environmental impact of public
toilets. Specifically, newly purchased toilets should not flush
more than 6 litres per flush or if older toilets are in use they
must be fitted with water saving devices where possible. Dripping
taps and leaky toilets must not be allowed and an action plan
must be in place for checking visible leaks. Finally, public toilets
must have a waste bin.
REFERENCES
i Press release from National Consumer Council—2005—http://www.ncc.org.uk/.
ii Public toilets—the need for compulsory
provision—Dr Clara Greed.
iii To find out whether people are discouraged
from visiting places that do not have adequate provision, ENCAMS
conducted an omnibus questionnaire in June 2006. 32% of respondents
said they would adjust the time they spend away from home according
to what toilet provisions there were and women are more likely
to adjust the time spent away from home than men (38% compared
to 26%). Toilet Knowledge bank—ENCAMS www.encams.org.
iv Department for Work and Pensions—http://www.dwp.gov.uk/news/archive/english/2004/03
_12 _04.asp.
v Information obtained from disability Rights
Commission—http://www.drc-gb.org/newsroom/key _drc _facts
_and _glossary/number _of _disabled _people _in.aspx
vi A telephone omnibus questionnaire polled 527
people. When asked how much they'd be willing to pay to use a
public toilet, almost a third of people (30%) said they would
not pay. More men would be unwilling to pay (34%) than women (26%).
A quarter of people (25%) would only be willing to pay up to 10p
to use a public toilet. Almost a third of people would pay between
11-20p to use a toilet and 10% would pay between 21-50p. Only
6% of people would be willing to pay over 50p to use a public
toilet. Toilet Knowledge bank—ENCAMS www.encams.org.
vii Public toilets—the need for compulsory
provision—Dr Clara Greed
viii Figures released by The British Toilet Association—http://www.britloos.co.uk/
ix The community toilet scheme in Richmond Surrey
has 20 local businesses signed up to the scheme which involves
them opening up their toilet provision to the general public.
The scheme has been running for over a year and has proved very
successful. There are more businesses joining up all the time.
http://www.richmond.gov.uk/press _office/business _pride/community
_toilet _scheme.htm.
x Beach and Surrounding Area Segmentation 2005
www.encams.org.
xi Beach Users Survey 2002—www.encams.org.
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