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Communities and Local Government Committee Inquiry: The Provision of Public Toilets
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 standard[i]. · 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 difficult[ii]. 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 inadequate[iii]. 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 disabled[iv]. This is a large group with an annual spending power of around £80 billion[v], 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 pence[vi]. · 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 places[vii]. 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, 1 cubicle per 550 females and 1 cubicle or urinal per 1,100 males[viii]. · 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 Richmond[ix]. 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 visit[x]. 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 was[xi]. · 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.
[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 |