Memorandum by the British Resorts and
Destinations Association
INTRODUCTION
1. The British Resorts and Destinations
Association (BRADA) represents the tourism interests of over 60
local authorities, all of which include one or more significant
resort town and/or rural destinations within their boundaries.
The common thread is that for better or worse, the visitor economy
is one of, if not the most important, social and economic drivers
in their geographic area of responsibility. We also have five
tourist board members and 11 commercial associate members. This
response has been written primarily from the local authority viewpoint.
BACKGROUND CONTEXT
2. What outwardly appears to be a simple
task; of providing public toilets is, in practice, fraught with
pragmatic, invariably locally contentious, problems; problems
that can have significant implications for the image, reputation
and, thus, arguable, impact directly upon the economy of the area
involved. Broadly, the more day and staying visitors, whether
local or from further afield, any area caters for, the greater
the demand for access to toilets is likely to be and, by implication,
the bigger the associated issues and problems of providing and
maintaining them.
3. These peaks of "visitor demand"
may be temporary, for example in the case of occasional shows,
markets or similar events. They may also be virtually permanent,
albeit with major seasonal and/or daily peaks and troughs. For
example, those associated with the ebbs and flows within popular
leisure or holiday destinations, or those seen in the popular
retail or leisure quarters of towns and cities. There are also
now invariably marked variations within even the same or adjacent
24-hour periods. For example, markedly differing demands between
that generated by the typical daytime and typical night-time economy,
or between demands of a weekday as opposed to that at a weekend.
What is more, these patterns of peaks and troughs will vary dramatically
between different towns and different destinations, including
within those towns that lie in the same administrative area. Occasional,
predicable peaks can, and probably should, be catered for using
temporary, portable facilities, funded from within any event budget.
Everything else has to be catered for by permanent public or private
provision or, as is often the case, by an ad hoc combination of
both.
4. We would contend that public provision
is contentious because it is a complex, relatively capital and
revenue intensive process, that is not a statutory duty and thus
is not formally allocated, ring fenced funding within Formula
Grant. All authorities (in England), of course, receive funding
for non-statutory services under the Other Service Block within
the Formula Grant; a catch all for everything from parks and gardens,
through leisure to tourism services, public toilet provision and
much else besides. On the whole, the Other Service Block grant
is viewed as being insufficient to cover the full range of "other
purposes". Indeed, some authorities claim that money from
this already inadequate block regularly ends up subsidising holes
in the statutory service grants.
5. Whatever the truth of these arguments,
the public seldom realises that the provision is technically "unfunded",
seeing it as the local authority's duty to provide the service
and their right to receive it. This perception has implications
for public expectation and for key sub issues, for example, the
public's attitude towards charging regimes; "don't we already
pay for this?"
6. When it starts to become apparent to
locals that provision is an additional draw on scarce local, discretionary
resources, this too can cause difficulties. Individuals, who expect
adequate provision when they visit other destinations, begin to
begrudge the cost of providing the same service "at home"
for the benefit of others. It is a not uncommon attitudinal problem
affecting many aspects of the tourism and visitor economies; we
are all welcome visitors wherever we go; they on the other hand
are still all unwelcome tourists when they visit us on our home
turf.
7. Because provision has long been discretionary,
it has tended to be routinely under funded. Indeed, many working
in the area point to decades of under investment as being the
root cause of the problems of poor quality or the inadequate nature
or scale of provision now. Certainly, in situations where radical
savings have had to be made at short notice, for example in response
to capping, the provision of public toilets has been one of those
services that has been dramatically curtailed, or sometimes even
abandoned. The question of whether to curtail or abandoning provision
routinely surfaces in authorities across the UK and in circumstance
of far lesser crisis than a capping order. If money is tight a
proportionately greater burden falls to discretionary services
and to services that are less directly ascribed to local users.
Given an environment where few local authorities do not struggle
to make budgets balance, the provision of public toilets and other
non-essential services, will always be under a degree of financial
threat. It is, therefore, hardly surprising that such a capital
and revenue intense service sometimes becomes subject to a, "mend
and make do for now", attitude.
8. Cost and access to adequate sustained
funding is undoubtedly the central issue in the provision of public
toilets, but it is no longer, just a simple cash equation. Because
public toilet provision is not a statutory duty the nature, style
and type of provision in place now varies greatly from authority
to authority and even in some instances within authorities, where,
through boundary changes, markedly different historic infrastructure
and approaches have had to be cobbled together. What is provided
now, how it is run, age of structures, historic levels of maintenance
and so on all influences, both the current provision, and what
could and should be realistically done with more adequate resources,
ie a simple injection of much needed cash will help but it would
not now bring provision up to a uniformly high standard across
England, or the UK, overnight. Unless of course it was an unrealistically
generous injection, something we have largely ruled out.
9. In internal debates about the provision
of public toilets that we have had, one area seems to be routinely
ignored (politely avoided?) and that is other human factor. We
appear willing to discuss wilful misuse, including vandalism,
drug usage, other criminal activity and even a wide range of sexual
activities in public toilets. The inference is that these are
the acts of a minority, largely outside the understanding and
control of us the majority. This somehow makes these acceptable
topics for debate. However, there is a marked reluctance to acknowledge
the fact that when a toilet is dirty it is not simply because
someone, or, more particularly, the anonymous "system",
has failed to clean it over a prolonged period. Often, in reality,
one person has made it dirty by accident or by design and then
has done little or nothing to correct it. Having now studied the
issues, it becomes clear that a sizeable proportion of the public
have fairly poor toilet habits and/or little or no respect for
others that might follow them.
10. Unless we acknowledge that many individuals
do not use public (and presumably private) toilets "properly",
then we will routinely underestimate the true nature, scale, means
needed and, thus. the cost of maintaining public toilets in a
good clean state, for the use of the rest of us that do. Then
add to this the cost of wilful damage and routine wear and tear,
often in old outdated facilities, and you have a significant maintenance
bill (physical maintenance as opposed to cleaning). New state
of the art facilities can deal with some of the routine maintenance
and normal cleaning costs, but it still cannot easily address
the human factor. For clarity, if for example someone wishes to
urinate up the wall, or all over the pan, smear faeces on the
wall or leave used sanitary products and rubbish of all types
sitting on the cubical floor or on the fittings and fixtures,
then they will, and they regularly do. No amount of technology
or innovation can tackle this, just plain old fashioned, constantly
active, labour intensive supervision and cleaning.
11. New state of the art facilities can
tackle some of problems of the maintenance associated with older
facilities (multitudes of different fittings and spares, exposed
pipes, vast areas of breakable tiling, etc.). They are calculated
to design out opportunities for vandalism, yet the cost of any
residual maintenance needed, can still be prohibitive. For example,
the replacement of a damaged modern automated electric lock can
cost in the order of £1,000, as compared to perhaps a few
tens of pounds for an old-fashioned door bolt or door handle.
Trained technicians now service modern state of the art loos,
not the toilet cleaner or some jobbing local maintenance men.
Thus, while volume of work might decrease, the cost of that undertaken
may rise out of all reasonable proportion.
THE NEED
FOR PUBLIC
TOILETS
12. There is undoubtedly a need to provide
access to toilets in those places where people routinely find
themselves outside their home or work environment for any length
of time. If I am at home, or in my place of work, or at someone
else's home or place of work I can usually accesses a toilet.
If I am in many types of leisure facility (restaurant, bar, cinema)
or in certain retail shops (department stores), I can also usually
access a toilet. However, if I am out and about on the streets
for some time there may be an issue, particularly if the place
is unfamiliar and I do not necessarily know which shop, bar or
other venue can facilitate me. In broad terms the issue of access
to toilets is more of an issue for much younger and older people
who perhaps, for obvious reasons, cannot wait or cannot easily
walk as far or as quickly to find facilities as others might.
Traditionally the solution has been to provide and clearly signpost,
strategically placed public conveniences.
13. In terms of tourism and the visitor
economy, the provision has been particularly important for two
major reasons. Firstly, as indicated above, genuine visitors are
less likely to know what the non-public provision is and where
to access it. Secondly, to be a visitor to anywhere involves travel
and, for many, by nature, a journey of any reasonable length both
starts and ends with a visit to the toilet. Only trains and the
occasional coach have built-in toilet facilities. As a consequence,
transport nodes, including stations and car parks, very often
have strategically placed public facilities. In rural areas the
failure to provide facilities in popular official and unofficial
parking areas can lead to public health issues, as the absence
of facilities does not necessarily act to counter the natural
demand. If you are in the travel business, or are reliant on it
to provide potential customers, then by default you are also in
the business of trying to ensure that your customers can access
publicly available toilets.
14. In terms of popular UK destinations
both the young family and the older (35 plus) markets are key
segments. Road transport and, in particular, the car, acts as
the delivery, a national average of 80% plus, (often actually
nearer 95% plus in many destinations), of all domestic day and
staying visitors. Therefore, in most traditional destinations,
the failure to provide adequate toilet facilities, particularly
at key strategic points and parking areas, would be to ignore
a basic requirement of their core customer base. Notwithstanding
the logical economic argument, several authorities, both resort
based and otherwise, still struggle to find the resources needed
to properly meet known demand at every location where it is seemingly
justified.
DECLINING PROVISION
15. The historic provision of public toilets
grew out of public health issues and was, for a considerable period
of time, the provision of public toilets, along with things like
bathhouses, sewers and drinking water, was a major social function
of local government. Times have changed, as have the pressures
and duties on local authorities. What was an essential service
is now a desirable, non-statutory function that competes for finite
resources. How local authorities function and the cost of directly
employed and/or contract services has also changed significantly.
Labour is no longer a cheap asset. The base and on-costs of employing
a low skilled toilet attendant are prohibitive, as are other labour
costs. For example, the cost of fitting a toilet seat now significantly
outweighs the cost of the seat itself. Add to this the increasing
cost of utilities, other general revenue costs and the capital
cost of refurbishing or building new facilities and you get a
sense that, whilst still a major public undertaking, it is not
one which the wider public sector policy agenda has properly addressed.
16. In many towns the provision has been
scaled down. Some of that scaling down may be sensible readjustment,
some of it may not as there are difficult balances to be achieved.
In one typical example six Victorian facilities, some with upwards
of a dozen cubicles in each of the ladies and gentlemen's sections,
have been replaced by just two sets of three unisex cubicles on
two sites. ie six down to two sites and 60-80 cubicles down to
12 unisex facilities, an apparently significant reduction in both
volume and coverage (other mid 50's and 60's blocks also remain
and have been refurbished). However, the chronically neglected
Victorian toilets belonged to a different age and were created
and catered for different volumes of usage in a very different
society.
17. Each new unit of three cubicles at around
£120,000 represents a significant investment. These manually
serviced, automated units compared with an estimated capital cost
of £120,000 for just one totally self-servicing cubicle.
Given budget constraints, it was not deemed practical or publicly
acceptable to replace 80 cubicles on six sites with just four
cubicles spread over two to four sites. These indicative costs
(costs can be much higher depending on a combination of factors)
may go some way to explaining the many difficult choices local
authorities have to make when deciding what future route to take.
18. The variation in costs are so significant
and there are so many other inherent issues involved that it is
not simply a case of trying to purchase the best that money can
apparently buy. In the case cited above, even if they had been
able to afford sufficient self-cleaning (a misconception since
there is still a significant degree of cleaning/maintenance) cubicles,
other toilets in the resort, all outlying facilities and those
in other towns in the borough would still have needed traditional
servicing. There was no prospect of replacing the borough's entire
stock with very expensive fully automated cubicles and, thus,
very limited pan-borough service savings to made from introducing
fully automated provision in only one town, albeit the major resort
in a much larger urban and rural district.
19. While much of the new provision is on
a smaller scale than that it replaces, there are many instances
of the total withdrawal of facilities. Typically, the major strategically
placed facilities will be replaced or updated with a lower capacity,
more manageable facility, while many peripheral facilities will
be closed altogether. Often vandalism, drug and sexual misuses
will be cited as reasons for closing smaller, more isolated blocks
and, while there is a logic to it and it is a major factor, other
considerations including cost v the volume of usage are undoubtedly
equally significant. If large, well used facilities can be replaced
by, say, three unisex cubicles at an affordable (?) £120,000
capital cost, then at very best, a much smaller, less well used
facility can be replaced by one cubicle. However, this will be
at a less justifiable pro rata cost of say £40,000 (or again
£120,000 for a fully automated unit). In addition, critical
revenue costs like travel to and from remote sites, opening and
closing them, repairing and servicing, all largely remain in place.
Misuse is a symptom of the difficulties of providing public toilets,
it is exacerbated by reduced supervision in remote sites but it
is not the sole cause in a decline in provision, despite it often
being cited as such.
MISUSE
20. This is not to say that misuse does
not cause major problems or adds to the cost of providing public
toilets. Misuse of new and older facilities ranges from deliberate
vandalism, drug and sexual activity through trading in stolen
goods, to using toilets as dry, relatively warm, cheap and secure
temporary shelter or even accommodation for the night. Traditional
style toilet blocks provide a sheltered, dry area where individuals
or groups cannot easily be observed and where there is a reasonably
legitimate excuse for almost anyone to go. Unless they are permanently
manned by the right quality of staff, they provide an ideal public
environment for abuse, from mindless vandalism to criminal activity.
Even when manned tradition style toilet blocks still offer the
seclusion and sanctuary of the closed cubicle.
21. Modern, unisex, direct off-street access
cubicles are designed to remove some of the problems created by
the "toilet block". However, these modern cubicles themselves
are not immune to abuse of all types. Risking being seen to enter
or leave a cubicle alone or with others might discourage some
individual but by no means all, particularly when in reality the
risk of being seen and then someone doing something about it is
actually very low. Accessible (disabled) loos being particularly
popular as, apparently, the extra space provided allows for larger
gatherings, including their use for small private parties (!)
and other liaisons. The problem of accessible toilets is now greater
because many are no longer accessed using the Radar key system,
but are open to everyone paying the standard fee. Closing old
facilities down and designing as many of the problems out of new
facilities clearly helps reduce misuse but it does not remove
the problem entirely.
WHO PAYS
22. Currently public toilets are paid for
by the local authority and, arguably, largely out of the local
charge payer contributions. There is no specific allowance made
in the Central Government grant in recognition of business rates,
or for the local community or visitors usage. In effect, the local
community pays and that, as alluded to earlier, can cause problems,
particularly in areas with high non-residential visitor numbers.
Often the suggested solution is to charge the public, who use
the facilities. However, charging for these facilities is a complex
matter. There is public resistance to charging, particularly if
the facilities are not then in pristine condition. In older facilities
payment tends to go hand in glove with the provision of attendants,
which serves only to add significantly to the running costs. Most
new fully or semi-automated cubicles are charged for. The typical
charge is now 20p which in no way represents the true pro rata
cost of using old or new facilities. Indeed, in many circumstances,
the cost of collecting, transporting, counting, banking and accounting
for the sum consumes much of the average of 20p. In reality, the
charge is often levied only as a minor discouragement to those
who would wish to misuse the facility. In reality, the level of
charge needed to pay, or at least significantly contribute to
the running and administrative costs, would have to be several
times more (£1/£2 plus?). Many feel that would be pushing
the cost well above what the public would deem acceptable for
a service that many already believe should be free.
23. To illustrate the cost issue, one major
popular resort destination now provides 72 units at 32 locations.
The current annual contract cost is £1.1 million, or £5.5
million since the contract started in 2003. Over the same five
year period approximately 1.25 million visits have been made to
the facilities, each charged at 20p, generating an approximate
gross income of £250,000. Given that this amount has been
gathered over five years, in 20p pieces, from 72 different unit,
at 32 location the income, net of administrative and other charges,
is likely to be significantly less. A gross revenue of £0.25
million against an actual expenditure of £5.5 million puts
the provision of toilets firmly in the bracket of a public service
rather than a commercial activity.
24. Although only an approximation, and
thus a potentially dangerous yardstick, in this particular council's
case each visit has cost around £4.40 and thus, allowing
for net costs, they would probably have needed to charge £5.50,
or more, simply to have broken even. As charges rise the dynamics
of fixed cost and flexible revenues change dramatically. So even
this ridiculously high figure probably illustrates little more
than the fact that you cannot reasonably expect to charge anything
like a true commercial rate, or indeed expect much more than to
recover a token contribution toward it.
25. If local government struggle to fund
public toilet provision and the public are reluctant to pay a
commercial rate then there is only one other obvious course of
action. That is to seek payment from local business on the basis
that it is their customers and, thus, their business that will
directly or indirectly benefit from the service provided. This
is a plausible argument, but totally flawed. How would such a
system work, particularly if it were not compulsory (a new local
tax)? Does the undertaker pay as much as the butcher or the clothing
shop? Is the publican, who already provides facilities for his
own customers, exempt? Moreover, these businesses would argue
that they already pay via business rates, it is not their fault
that Central Government choose not to allocate or ring fence any
of that money returned via the Formula Grant to local government
for the provision of local conveniences.
26. To our mind, the solution lies with
Central Government who should be defining the minimal levels of
provision and allocating local authorities an amount based on
local population, business rate income and, critically, visitor
numbers. If local government then chose not to spend that allocation
on the provision, then they would have to justify that decision
to the local electorate. Where the additional funds would come
from or what other service would have to have its funding allocation
reduced in order to allow it, is not an issue we feel competent
to address. We do, however, believe that the level of provision
is so variable, disjointed and potentially neglected that any
funding would need to be genuinely additional. Simply allocating
an amount for public toilet provision, whilst clawing the funding
back in some other area of local government spending, would not
be an effective solution.
SECURITY
27. There is little doubt that the best
service and provision is provided by well maintained, staffed
toilets, where the staff display a personal pride in the service
provided. Bearing in mind that toilet duties are generally regarded
as a low skill, low paid activity that pride in their work is
not always a given. Staffing and good staffing are not necessarily
the same thing and in a Local Government environment, finding,
training, retaining and maintaining excellence in toilet cleaning
and attendant staff can be difficult. Good staff are highly prized
yet are difficult to adequately reward. Unmanned facilities need
to be visited. Most are opened and closed and are visited for
cleaning purposes on a set rota that reflects location and usage.
The logistics of opening and closing facilities at a stated time
are complex and the cost of mobile cleaning, whether in-house
or contracted out are considerable.
28. In some circumstances the staff who
man toilets do not wish to have the responsibility for collecting
and handling cash, or their employers have reservations. In unmanned
facilities charging can simply encourage theft with the resulting
cost of replacement locks far outweighing the revenue opportunities.
Higher charges to cover true costs would simply increase the temptation
in remote, unmanned locations and may encourage theft from less
remote facilities. Semi automated facilities in public places
are less of a temptation target for vandalism and for theft. Nonetheless,
what some individuals will try and get away with in the dead of
night, or under the influence of drugs or drink, even in a town
centre, at any time of day, are quite remarkable.
29. Fully automated, self opening, self
closing, self cleaning self fault reporting cubicles do have some
revenue cost advantages, however, at typically three times the
initial capital cost per unit they would need to have. Both automated
and fully automated systems are designed to discourage misuse
and vandalism, just as the presence of a good attendant should
do. The difference is that if there is misuse and damage the attendant
can do something more than just report it when it inevitably happens.
On balance attended services are deemed to be the best solution,
however, there is a significant cost issue, particularly if a
facility is open for more than a standard 37 hour, five day week.
In many cases we are not talking about an attendant but attendants
and a service with administrative support capable of providing
shift, sickness and holiday cover etc.
30. Modern life styles also mean significant
changes. Resorts and rural destination are visited 365 days a
year, pubs and clubs can open 24 hours a day, seven days a week,
shops now keep longer hours and are all open on Sundays. This
has spread the demand and changed the nature of it. As a consequence,
longer opening, or 24-hour services are needed with all the associated
baggage of maintenance, cleaning and security. Arguably, self-maintaining,
fully automated cubicles are the way forward but, for all the
reasons stated earlier, it is not that simple as they are by no
means the sole solution to maintenance and other cost issues.
GENDER BALANCE
31. Traditionally, the gender balance of
public conveniences has been poor relative to gender related use
issues. Male toilets require fewer cubicles and, on the whole,
urinals are quicker to use and, potentially, need less maintenance,
cleaning and few consumables. Modern toilet blocks try to address
the usage issue by providing significantly larger female facilities
with more cubicles, while new off the street unisex cubicle provision
effectively removes the issue entirely. That said, many females
apparently find public unisex toilets less savoury than the single
sex equivalent, an issue made worse by allegedly poor or negligent
use by standing males users.
PRIVATE SECTOR
PROVISION
32. Many businesses provide toilets for
customers, the definition of customer varying from those simply
browsing in, say, a department store, to those paying customers
in a café. Those businesses that provide a toilet have
no issue with their use by paying customers. The issue comes with
non-paying customers and, more particularly, with non-paying customers
who have no intention of doing anything else other than to use
the facilities. Seeking payment in private facilities is generally
deemed even less acceptable than in the public environment, as
many customers will have indirectly paid via the purchase of other
goods or services. A café owner is likely to have more
cause for complaint than the department store owner, if someone
comes in off the street to use the toilet for free; in the latter
case they may at least browse which is part of the marketing ethos
of the department store.
33. Anecdotal evidence suggests that shop
owners are reasonably content for their facilities to be used
to support good local public provision, but far less content where
public provision is poor or, in particular, is getting poorer
or has been withdrawn altogether. Again, most businesses view
public toilet provision as the duty of the local authority. There
is also an issue over who precisely in the private sector bears
the brunt of servicing the demand. Most provision is made by catering
premises and the odd larger departmental stores, but not by other
retailers and/or other general service providers. Why should it
be reasonable to demand to use the customer toilet in a café
but not, say, the (staff) toilets in every high street retailers,
the estate agents or the local solicitor's office? There is a
real issue of fairness and sharing the burden.
34. A number of innovative schemes have
been tried where those who already provide facilities for customers
are compensated by the public authority for allowing genuine public
access. For example, a pub may be given a grant for promoting
and allowing free public access to its toilets. In general it
seems to be a sensible solution to providing provision in certain
circumstances, without the need to provide expensive publicly
funded infrastructure. We believe that the specific circumstances
are more likely to be in smaller towns and remoter areas with
relatively limited measurable demand. We may be wrong. How the
system would be managed and widely employed, say, in a Blackpool
or Bournemouth currently escapes us. We also have some concern
about quality control, liability and other pragmatic issues.
35. Less innovative, but probably of greater
utility is the use of planning gain to ensure that new publicly
accessible facilities are provided and, preferably, run at no
cost to the local authority. In practice it is not necessarily
as simple a process as it sounds. Providing facilities and providing
service in the right place that are easily accessed and which
are managed and well run over time are not necessarily the same
things.
36. Beyond specifically funding private
sector provision there are perhaps only two other ways forward.
The first is radical and probably unworkable; that is the withdrawal
of most, if not all, public provision. The continental model is
often cited as proving that the private sector can provide much
of the toilet provision. Although plausible it is based largely
on a chicken and egg scenario. The public sector in many European
countries has limited or no tradition of providing the service,
therefore, the private sector, for good commercial reason, has
learnt to do so. Feeling obliged to buy something in order to
use the loo is not a situation we British would necessarily be
comfortable with. The other route is by simple partnership negotiation.
If local business can be convinced that better provision is needed
but in reality local funding cannot support it, then some more
enlightened businesses may be willing to help out by offering
their services. There are several examples of such local schemes
in operation. Unfortunately such agreements are usually hard won
and then tend not to be that enduring.
PUBLIC TOILETS
AND TOURISM
37. As already indicated, the provision
of good quality, well maintained and serviced, safe toilets is
an essential in any town that relies to any degree on visitors
from the locality or further afield. Most visitors will start
their visit and end it with a trip to the loo. If they can not
find one, or the public facility they do find is of poor quality,
then that is what their first and their last memory of the place
will be. Local Government's role in place making has recently
been recognised as key function. To our minds, excellence in public
toilet provision is a critical factor in what makes a place. Nice
places are worth visiting and once visited the quality of the
experience, including public toilets, will influence the decision
to return, whether that is for few hours at the shops, a meal
or night out, or whether it is for a day trip or a longer break
or holiday.
A SOLUTION
38. We believe that the provision of decent
public toilets is such a significant factor in building and maintaining
tourism and the visitor economy that local authorities should
receive funding to assist then raise current standards and then
maintain them. This could be achieved in England (and similarly
elsewhere in the UK) by making specific provision within the Formula
Grant for the provision of public toilets for visitors, rather
than simply making an unspecified provision for them in the Other
Services Block. In order to ensure that any addition grant made
did not simply displace existing spending the allocation would
need to be linked to historic and current spending and be based
on known, robust day and staying visitor numbers. Any grant would
have to be at least matched by existing spending. There would
also probably need to be relative weighting, based on the difference
between the resident population, for whom the authority should
provide something, and visitors from outside for whom this assistance
would be specifically given. If devised correctly a heavily visited
town or rural area with a small resident population would be compensated
relatively better than, say, a comparative destination, with a
large resident population, that was equally well visited.
39. We acknowledge that there are perceived
problems with allocating overnight and, in particular, day visitor
figures down to the local level and that, therefore, more work
(ongoing?) would be needed in order to ensure that the visitor
numbers used were fit for purpose. We also acknowledge that the
theory of producing a fair an equitable formula for allocating
funding is rather different from achieving it in practice. Notwithstanding
these practical difficulties, we do still feel that this is an
area where progress still could and should be made. The Association
and various member authorities would be only too pleased to try
and help DCLG develop this idea further.
40. In pulling this response together we
struggled to access hard and fast figures, some of which are viewed
as being commercially sensitive. Had we realised these difficulties
we may have sought factual comment from our members much earlier.
We are continuing to seek more detailed costing and indicative
figures, ranging from the average cost of providing attendant
cover by the day, week and year, to typical maintenance cost,
by unit, by toilet block and more indicative detail on the cost
of refurbishment and replacement. That information may be available
in the coming few months and could be submitted as supplementary
written evidence, or presented at an oral evidence session, if
the Committee wished to receive it.
CONCLUSION
41. We have tried to give a frank overview
of the complexities of providing public toilets. Seen in relative
isolation it is a fairly simple issue, which warrants fairly simple
solutions. Indeed, if we were starting afresh with a clean slate,
it might well be far simpler. Unfortunately those at the coalface,
are victims of the past, historic provision, the ad hoc local
solutions that have evolved to cope and, in most cases, a protracted
period of under investment, in what is oddly still a non-statutory
function of local government. No solution is going to make radical
change overnight, nor is there much prospect of quickly dragging
extraordinarily different provision, in different places, up to
a uniformly excellent standard across England or the UK as a whole.
Nonetheless, there is still every reason to make major progress
and, in England (and similarly elsewhere in the UK) we believe
the solution lies in making specific provision in the Formula
Grant for day and staying visitors.
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