Supplementary Memorandum by BRADA
INTRODUCTION
1. Following on from my oral evidence session
on 2 June 2008, I am writing to submit additional written evidence
for consideration by the CLG Select Committee. Comment covers:
— Some of the questions asked of earlier
witnesses on the day.
— The additional CIPFA figures requested
by the committee, with comments.
— Pertinent additional observations
made by colleagues in the Association who have since read the
original written submission made on their behalf.
COMMENT ON
OTHER ORAL
QUESTIONS
2. Provision for the profoundly disabled.
Although I would personally be keen to see additional provision
made in key destinations, I would be concerned about compulsion.
If we experience problems of all types providing standard and
accessible toilets now, what would the impact be of adding to
that burden? In particular, I suspect that the additional equipment
and the large space provided would make such provision a target
for misuse, especially if it were to be provided as a typical
public on-street facility. To my mind, this provision should be
provided but, largely, as part of a public/private sector partnership
within new or refurbished developments. These type of facilities
tend to offer a higher degree of security and supervision and,
in my view, the commercial imperative is more likely to exist
ie if I provide it they and their families, friends and others
are more likely to come and spend in my shopping/leisure facility.
The fact that some of the larger, out of town retail developments
were cited as providing such facility reinforces my view.
3. Perhaps the ethos of going beyond what
has now become standard, accessible provision, needs to be built
into the planning processes and into public/private sector working
practices? Thinking about building such facilities into a Bluewater
is one thing. Getting the same vision to apply to smaller developments
in Cities, Towns and smaller communities across England (UK) will
need some proactive encouragement.
4. Street Fouling. The perceived linkage
between the lack of late night provision and late night fouling
in the streets is plausible but, probably, seriously flawed. Just
because there are toilets made available, does not mean that drunken
males will use them. Female street fouling is by no means unheard
of although, for the time being, at least, is socially less acceptable
among females and, thus, less likely to occur.
5. If there is a lively night time economy,
then public toilets do need to be provided, but there also needs
to be high profile, effective enforcement of any appropriate controls.
The two must go hand in hand if you are to reduce current street
fouling. In my view, it would take a cultural change to eliminate
it entirely, probably involving a reduction in drunkenness and
the development of greater respect, for authority and for the
sensibilities of others. Perhaps these are issues that go way
beyond the scope of this inquiry but they remain issues which
do fall firmly within the remit of Central Government and DCLG
within it.
6. The thought that pubs and clubs should
be encouraged to allow individuals to come off the street at night
simply to use toilet facilities is again plausible. Unfortunately,
it ignores the fact that many establishments have to apply restricted
access control for other valid reasons (including licensing conditions).
The drunk who might otherwise urinate in the street may not be
the type of person that you would particularly wish to invite
into your premises late at night. To do so, simply so they can
use your toilet, seems to be stretching the bounds of probability.
7. Larger cubicles. Comment was made about
the need to enlarge existing and, in particular, new style toilet
cubicles for use by the elderly and other groups. As far as we
are aware, one of the key design principles employed to limit
the abuse of modern toilets is to restrict the size. The principle
is simple, if you cannot swing a cat, then you cannot easily swing
anything else that might cause structural damage. Nor is it easy
to camp out with all your worldly goods in tow, or easy to indulge
in activities of any kind with others in the limited space provided.
One major problem cited with the new, accessible (disabled) on-street
toilets is that they do offer that additional space and are increasingly
open to all users for all or much of the day. Thus, they are now
frequently selected for misuse in preference to the standard cubicle
units. If lack of space is a discouragement for the elderly then
perhaps more elderly customers should be encouraged to make use
of accessible toilets, rather than viewing them as a facility
specifically for the "disabled". Again, perhaps this
is cultural change, but one, perhaps, more easily achieved than
changing public attitudes to alcohol usage?
COST OF
PROVISION
8. I promised to provide some of the additional
financial information that I have recently accessed. In my written
evidence, I made an estimate based on one resort's figures that
a break-even charge of between £4.40 and £5.50 a visit
might be needed. I made the point that it does not really matter
much if it is £3, £4, £5 or even £10. The
reality is that, anything much more than a few tens of pence,
a pound perhaps, is likely to be unacceptable to the public and
change the dynamics of usage to such a degree that the base calculations
would become almost meaningless.
9. The attached CIPFA out turn figure for
2006-07 gives the latest full year costs for public toilet provision
in England. Previous year's figures are broadly in the same order
and can also be accessed via the Local Government Association's
website. The figures give a reasonably clear picture of expenditure,
revenue and typical capital costs. The latter do tend to vary.
The table also usefully allows comparisons with other local government
service costs, for example, it struck me that local authorities
in England would appear to spend roughly 10n times more on library
provision than they did on public toilets in 2006-07. This is
not to suggest those public libraries or public toilets warrant
any more or any less spent on them, it just helps put the current
spending in a wider context.
10. Looking at line 227 column 9, we see
a total expenditure (net of income) of £99.382 million and
at column 6, a total income of £4.617 million. Conveniently,
this allows us to say that the expenditure (less income) is about
£100m and income £4.5 million or that broadly that current
income is a meagre 4.5% of expenditure. This means income across
England would need to be increased 24 fold in order to reach break-even.
11. On that basis, the average 20p payment
would need to be £4.80 nationally, much in the mid range
of my written evidence estimates. Accepting the slightly suspect
mathematics and, rather more importantly, the complex financial
dynamics involved, the figure of £4.80 -(£4.40 to £5.50)
remains a useful indicator of the scale of increase needed to
turn a £100 million a year publicly funded activity into
a self-sustaining service.
12. Doubling or trebling the current 20p
average is not going to make that much difference to the income
stream relative to expenditure, but it would make a considerable
difference to public attitudes, long before the cost started to
truly contribute to the level needed to significantly enhance
the service. We also ignore at our peril the fact that, if the
current service is enhanced (expanded), the associated costs of
providing it are also going to increase, thus, we will never easily
break the cycle of current under investment by tweaking the public
charging regime alone.
ADDITIONAL OBSERVATIONS
FROM COLLEAGUES
13. Most of the improvements made in recent
years have been achieved by providing fewer, but better, facilities,
often at existing sites. This has enhanced the perception that
provision is contracting, because, in terms of units/blocks/cubicles,
providing better has resulted in a smaller number of cubicles/urinals
at each site.
14. New toilet facilities are expensive
to provide and then expensive to run. It's a fallacy to believe
that new equals cheaper on a unit for unit basis. The penalty
paid for making improvements within existing budgets has been
far fewer, very often unisex, facilities. At best, the price of
providing fewer, better facilities will be broadly in line with
previous expenditure, often it may be more. This means that the
public's demand for more, better toilets made available and maintained
24/7 cannot ever reasonably be fulfilled under current funding
arrangements.
15. One colleague in support of our comments
on the additional cost of maintaining new facilities cited a staggering
bill of £10,000 to replace the door unit on a modern on-street
cubicle. Clearly, that is likely to be an extreme case, however,
it neatly illustrates that efforts to design out vandalism and
reduce routine maintenance costs are not necessarily without significant,
alternative cost, elsewhere within the system. Typically a £10,000
bill would still fall outside the cover of a local authority's
insurance excess, as indeed would almost all routine damage done
to old or new public toilet provision. Vandalism of public toilets
falls as a direct cost to the council, it is not an insured "victimless
crime" as many of the perpetrators and some of the public
might assume.
16. Self-cleaning cubicles, although seemingly
the answer to the problem of providing clean facilities 24 hours
a day, are not always the answer. Colleagues stress that they
are not suitable for use in busy locations; the cleaning cycle
is simply too long. The problem of length of the cleaning cycles
is exacerbated by their high unit cost (typically three to four
times higher per unit). Few authorities, if any, can afford to
deploy self cleaning units in the quantity needed to compensate
for slow throughput.
17. Equally, the typical new provision of
a half dozen unisex on-street manually cleaned cubicles is designed
for routine throughput. Bank Holiday peaks, or the arrival of
a coach will generally swamp the provision. Again, unit costs
generally prohibit building in any significant degree of redundancy
to meet these occasional peaks.
18. The BRADA written evidence focused on
urban destinations. This prompted comment from colleagues in rural
destinations. The cost of providing and then servicing even the
most basic provision in popular rural destinations is prohibitive.
For example, the cost of visiting them simply to open and close
them will be significant, before any routine cleaning or maintenance
arrangements are considered. Local staffing and provision by Parish
Councils is an option, but few Parish Councils are willing, or
able, to take on the burden of provision.
19. Attended facilities may well be the
"gold standard" but colleagues feel that the additional
costs can now only really be justified where the throughput is
significant and constant. In effect, the attendant is needed to
constantly clean and maintain the facility and, thus, is providing
the security and monitoring as an ancillary function. That type
of throughput is more likely at major transport nodes, at major
attractions, in large cities or retail centres. Several colleagues
commented that, for them, the best provision would be modern,
self-cleaning toilets provided in sufficient quantity to meet
peak demands. Currently that is unlikely, especially in holiday
resorts and destinations where large peaks and troughs are part
of the daily routine, within an industry that also experiences
significant mid-week/weekend and seasonal fluctuations.
20. The demand for toilets is significantly
greater at popular visitor destinations and typical traditional
leisure destinations due to the nature of the customer and the
trade that takes place. For example, Lancaster City Council confirm
that the demand and usage of public facilities in their traditional
resort town of Morecambe is significantly greater than its near
neighbour Lancaster City, despite Lancaster being a popular tourism/retail
centre in its own right. Lancaster Council also has a significant
popular rural tourism area within its boundary and is, thus, exceptionally
well placed to comment on the relative difficulties of providing
a wide range of services in different leisure locations.
CONCLUSION
21. I hope that these additional notes are
of some assistance to the Committee. If you require any clarification
on any of the above, please let me know.
Annex A8
REVENUE OUTTURN CULTURAL, ENVIRONMENTAL AND
PLANNING SERVICES (RO5) 2006-07
| | |
| | |
| | | | £ thousand
|
| Employees | Running expenses
| Total expenditure | Sales, fees & charges
| Other income | Total income
| Net current expenditure | Capital Charges
| Net Total Cost (excluding specific grants)
|
| (1) | (2)
| (3) = (1) + (2) | (4) | (5)
| (6) = (4) + (5) | (7) = (3)-(6)
| (8) | (9) = (7) + (8)
|
| CULTURAL AND RELATED SERVICES |
| | | |
| | | |
|
| | |
| | | |
| | |
| Culture and heritage |
| | | |
| | | |
|
| 111 Archives | 30,989 | 23,387
| 54,376 | 3,809 | 9,265
| 13,074 | 41,302 | 3,098
| 44,400 |
| 112 Arts development and support | 36,966
| 115,163 | 152,129 | 10,672
| 22,977 | 33,649 | 118,479
| 9,793 | 128,273 |
| 113 Heritage | 24,347 | 31,351
| 55,698 | 8,078 | 15,197
| 23,275 | 32,423 | 3,793
| 36,215 |
| 114 Museums and galleries | 109,197
| 141,771 | 250,967 | 34,215
| 32,191 | 66,405 | 184,561
| 21,416 | 205,978 |
| 115 Theatres and public entertainment | 83,723
| 232,865 | 316,588 | 129,395
| 28,382 | 157,777 | 158,811
| 33,394 | 192,205 |
| Recreation and sport |
| | | |
| | | |
|
| 121 Community centres and public halls |
34,307 | 59,398 | 93,705
| 17,432 | 17,440 | 34,873
| 58,831 | 18,693 | 77,524
|
| 122 Foreshore | 7,107 | 15,820
| 22,927 | 11,987 | 3,364
| 15,351 | 7,577 | 2,501
| 10,078 |
| 123 Sports development and community recreation
| 122,917 | 149,091 | 272,006
| 37,887 | 49,974 | 87,861
| 184,146 | 14,743 | 198,888
|
| 128 Sports and recreation facilities, including golf courses
| 345,511 | 574,998 | 920,509
| 353,388 | 52,415 | 405,803
| 514,707 | 155,781 | 670,487
|
| 130 Open spaces | 381,403 |
752,550 | 1,133,953 | 118,351
| 196,702 | 315,053 | 818,902
| 36,999 | 855,901 |
| 140 Tourism | 62,076 | 141,478
| 203,553 | 38,669 | 15,973
| 54,642 | 148,911 | 3,654
| 152,565 |
| 150 Library service | 554,969
| 450,409 | 1,005,377 | 65,013
| 50,983 | 115,996 | 889,382
| 61,688 | 951,070 |
| 190 TOTAL CULTURAL AND RELATED SERVICES
| 1,793,511 | 2,688,279
| 4,481,790 | 828,894 |
494,862 | 1,323,758 | 3,158,031
| 365,552 | 3,523,583
|
| 210 Cemetery, cremation and mortuary services
| 64,088 | 134,861 | 198,949
| 177,219 | 12,638 | 189,857
| 9,092 | 10,177 | 19,270
|
| ENVIRONMENTAL SERVICES |
| | | |
| | | |
|
| Environmental health |
| | | |
| | | |
|
| 221 Food safety | 68,820 |
52,927 | 121,747 | 7,064
| 3,867 | 10,931 | 110,816
| 361 | 111,178 |
| 227 Public conveniences | 15,611
| 75,590 | 91,201 | 2,144
| 2,473 | 4,617 | 86,584
| 12,798 | 99,382 |
| 228 Other environmental health | 284,355
| 257,395 | 541,750 | 55,092
| 72,563 | 127,655 | 414,095
| 11,568 | 425,662 |
| 229 Licensing | 65,754 | 83,619
| 149,373 | 96,115 | 16,846
| 112,961 | 36,412 | 499
| 36,911 |
| Community Safety | |
| | |
| | | |
|
| 231 Crime reduction | 121,284
| 239,590 | 360,874 | 19,082
| 69,986 | 89,068 | 271,806
| 13,498 | 285,304 |
| 232 Safety services | 85,948
| 87,928 | 173,876 | 7,679
| 27,844 | 35,523 | 138,354
| 1,863 | 140,216 |
| Flood defence, land drainage and coast protection
| | | |
| | | |
| |
| 241 Defences against flooding | 4,146
| 16,400 | 20,546 | 1,047
| 3,937 | 4,984 | 15,562
| 3,558 | 19,120 |
| 243 Internal drainage levy work | 1,070
| 25,832 | 26,902 | 778
| 55 | 833 | 26,069
| 281 | 26,350 |
| 247 Coast protection | 2,947
| 13,437 | 16,384 | 325
| 2,488 | 2,813 | 13,571
| 19,401 | 32,972 |
| 250 Agricultural and fisheries services |
1,413 | 14,736 | 16,149
| 17,134 | 4,967 | 22,101
| -5,952 | 2,377 | -3,575
|
| 260 Trading Standards | 124,842
| 70,980 | 195,822 | 13,288
| 12,028 | 25,316 | 170,506
| 1,470 | 171,976 |
| 270 Street cleansing (not chargeable to Highways)
| 242,988 | 521,611 | 764,599
| 24,554 | 78,962 | 103,516
| 661,083 | 6,009 | 667,092
|
| Waste management | |
| | |
| | | |
|
| 281 Waste collection | 361,741
| 1,192,350 | 1,554,092 | 249,736
| 188,561 | 438,297 | 1,115,795
| 40,017 | 1,155,812 |
| 282 Waste disposal | 60,707 |
1,754,408 | 1,815,115 | 138,013
| 222,744 | 360,757 | 1,454,357
| 9,154 | 1,463,511 |
| 290 TOTAL ENVIRONMENTAL SERVICES |
1,505,715 | 4,541,662
| 6,047,378 | 809,270 |
719,959 | 1,529,229 | 4,518,148
| 133,031 | 4,651,179
|
| PLANNING AND DEVELOPMENT SERVICES |
| | |
| | | |
| |
| 310 Building control | 143,343
| 111,416 | 254,759 | 157,757
| 22,751 | 180,508 | 74,251
| 856 | 75,107 |
| 320 Development control | 320,015
| 323,811 | 643,826 | 254,876
| 40,582 | 295,458 | 348,367
| 5,427 | 353,795 |
| Planning policy | |
| | |
| | | |
|
| 335 Conservation and listed buildings planning policy
| 23,007 | 22,371 | 45,378
| 1,000 | 3,244 | 4,244
| 41,134 | 3,116 | 44,250
|
| 338 Other planning policy | 146,664
| 158,797 | 305,461 | 55,761
| 37,161 | 92,922 | 212,539
| 7,510 | 220,049 |
| 340 Environmental initiatives | 72,628
| 92,395 | 165,023 | 15,864
| 34,614 | 50,478 | 114,545
| 15,351 | 129,896 |
| 350 Economic development | 307,823
| 854,715 | 1,162,537 | 210,861
| 208,862 | 419,723 | 742,816
| 310,448 | 1,053,264 |
| 360 Community development | 168,699
| 363,463 | 532,163 | 13,360
| 79,042 | 92,402 | 439,762
| 9,211 | 448,973 |
| 390 TOTAL PLANNING AND DEVELOPMENT SERVICES
| 1,182,179 | 1,926,968
| 3,109,148 | 709,479 |
426,255 | 1,135,733 | 1,973,414
| 351,920 | 2,325,334
|
| 400 TOTAL CULTURAL, ENVIRONMENTAL & PLANNING SERVICES
| 4,481,405 | 9,156,911
| 13,638,314 | 2,347,644
| 1,641,076 | 3,988,721 |
9,649,593 | 850,503 |
10,500,096 |
|
